Here’s an interesting article on Environmental Management Systems (EMS) by guest blogger Eric Monson.
Increasing public awareness of environmental issues and responsibilities is fueling the need for the wider business community to demonstrate their green credentials and manage their business activities in an environmentally friendly and cost efficient manner, without adversely affecting profitability.
Finding the starting point and establishing how a business actually goes about implementing an EMS can often be a daunting prospect. This article is intended to provide a little practical guidance and advice to business managers who may have been given the task of implementing an EMS.
Implementing an EMS
In our modern society, there is a general acceptance that there is a need to protect the environment and preserve our natural resources. Taking practical steps towards reducing our environmental impact is another matter entirely.
Minimising our environmental impact is primarily driven by the legislative framework which has resulted in a plethora of education and intervention programmes and regulatory enforcement. While this approach has had a significant impact across the public sector and amongst larger private sector organisations it is now beginning to cascade down to the wider, smaller business community.
General enquiries regarding environmental legislation and how this may impact on a small business are, more often than not, met with silence or a blank stare. This is a perfectly understandable response in the current economic climate as smaller businesses focus on keeping their business afloat. Many depend solely on suppliers and/or contractors to keep abreast of emerging legislation and new regulations which may impact on their business sector, as a result, they rarely ever have a full appreciation of their environmental responsibilities.
A primary driver for environmental improvement is effective supply chain management. Larger public and private organisations, in seeking to improve their own environmental performance, are now implementing vendor compliance systems. This requires that their suppliers meet strict quality and performance standards before being accepted onto an approved/registered supplier list.
As is the case with Health and Safety management, Environmental Management will ultimately, by necessity, become an established business management process. This will not however, occur overnight.
In the meantime, a proven and sustainable method of improving business performance and minimising environmental risk, is through the introduction of an environmental management system (EMS). Ethical responsibilities notwithstanding, there is a sound business case to be made for implementing an EMS;
it is a basis for managing compliance with environmental regulations
it helps to improve process efficiency, reducing resource costs
it helps retain existing business and acts as a platform for attracting new business
Developing an EMS implementation plan and identifying the project team
The size of the business will very often determine who is assigned the role of developing, implementing and managing an EMS. Whoever is selected, will become the environmental manager and the green representative for the business. Normally, they should set aside one day per week working on the development, implementation and management of the EMS.
This time is required to for effective administration, training, research (legislation / regulatory updates), monitoring and reviewing project targets and developing policies, procedures and work instructions. The time commitment will increase during the EMS implementation phase.
As with any project, it is advisable to form a project team to manage the development and implementation phase and a peer group should oversee the process (normally a review board of senior managers who meet the environmental manager at predefined stages in the project).
The environmental manager and the project team(s) should have a basic understanding of the environmental issues affecting the business and a working knowledge of the on-site processes and operational activities, these must be well defined from the project outset.
EMS – the benefits
Besides demonstrating a commitment to minimising the environmental impact of the business, there are a good many other potential benefits associated with an EMS;
It raises awareness of environmental regulations which impact on your business and helps to ensure compliance
It can significantly reduce resource use, improve process efficiency and reduce operating costs (raw materials, energy and waste)
It encourages staff ownership and skills development
It improves customer satisfaction ratings and is a highly effective marketing tool
It can help to lower insurance premiums and increases the prospect of securing financial capital for business development
It provides an opportunity for integration with other quality and/or health and safety systems
All businesses are facing unprecedented challenges in the current economic climate and while it can often be difficult to convince a business to see the merit in allocating precious / limited resources to develop and implement an EMS, there is no shortage of examples and case studies which provide reassurance, if that is needed, that initial ‘no cost’/low cost’ savings are achievable and that the EMS can be quickly and easily implemented. The real benefit, more often than not, is the capacity for sustainable business growth through environmental compliance, quality assurance and good reputation.
Environmental Review
An environmental review is the basis for developing and implementing an EMS. It provides an overview of the environmental aspects and impacts of the business and identifies the environmental legislation and regulations that apply to the business processes and activities.
It is vital that every business process and activity (on-site and off-site) is examined closely at this stage. All emissions to air, discharges or releases to water and land, energy and resource consumption (raw and ancillary materials / products), process and/or activity waste(s) and issues that may be of concern to the local community should be identified and recorded.
The primary objective, is to collect sufficient information about the business activity and processes and the site in order to gain an accurate picture of any potential environmental impact. This is a critical means of identifying any environmental ‘source and receptor’ pathway issues. This will normally involve desktop analysis, to review documents and records, followed up by a site survey to observe business activities and processes. Accurate records that should be collected and analysed and may include;
Business site plans and historical / development background to the locale
Previous survey reports
Site drainage plans
Planning constraints
Process information
Maintenance plans and records
Material usage data
Material safety data sheets
Copies of any permitted process authorisations (PPC, CARS,WML, consents and licences)
Waste management data
Water, air, or noise monitoring results
Utility (energy, gas and water) accounts
Business processes and production data
Risk management and environmental procedures
Records of any environmental incidents or complaints
A checklist is helpful reminder and will assist in ensuring that you obtain a complete record relating to;
the condition of the business site, buildings, storage facilities and pollution control measures
visible evidence of land or water contamination
environmentally hazardous materials
business process controls
site waste management
environmental risks
Ensure that design and development activities are included at this stage. The potential environmental impact of a business process can often be mitigated through minor changes to production methods and/or processes.
A knowledge and understanding of environmental regulations and emerging legislation underpins an effective environmental review. Reviewing regulatory compliance and applicable legislation is the basis for targeting specific aspects which need to be prioritized.
Managing compliance
Compiling and maintaining a register of environmental legislation is a vital component of the EMS and is a basis for ensuring that your business is kept abreast of emerging legislation and regulatory compliance requirements.
Regulatory compliance is essential for all reputable and responsible businesses. The EMS is a fundamental means of providing evidence of your commitment to comply with legal requirements, accordingly, it must be monitored and evaluated on an ongoing basis.
Organisations such as Business Gateway (Environment and Efficiency) offer a free environmental guidance service that can help your businesses comply with environmental legislation and can be a useful source for updating your EMS register. The use of such sites cannot in itself be seen as a means of mitigating responsibility. The need to be aware of legislation applicable to your business remains your responsibility and you must continuously review emerging legislation to identify what practical action may be required to ensure that your business remains compliant.
Environmental legislation is enforced by bodies such as the Environment Agency and/or local authorities. The penalties for non-compliance can be extensive and extremely damaging to a business, not only from the immediate financial and reputational impact of fines or criminal charges, but from the impact of a temporary or permanent cessation of business operations.
It is therefore essential that a comprehensive legal compliance audit is undertaken as a first step in the development phase of the EMS to ensure that standard policies, systems and procedures are in place to monitor future legal compliance.
Auditing the EMS once it is established, requires objectivity and understanding of all the legal issues. This is the principle reason why many organisations elect to have their EMS impartially audited through a consultant.
Aspects and Impacts – cause and effect
Environmental aspects are businesses activities and/or processes (sources) that could have an environmental impact, ie, harmful emissions and/or discharges to the natural environment (air, water, and land), resource use, energy consumption, waste generation and noise.
Environmental impacts represent the effect of the aspects on the natural environment and the potential damage they may cause to receptors such as air, water and land. Impacts may include toxicity, natural depletion (mining of raw materials and energy use) and disruption to sensitive habitats due to pollution and/or noise.
Once the environmental review has been completed you should begin to understand the aspects of the business that may have an environmental impact. This will provide a basis for assessing their significance and managing and prioritising the response.
Risk assessment is well established health and safety practice. The same methods are used quantify the significance of the aspects of the business and their environmental impact. Business aspects that record the highest risk rating scores should be prioritized and remedial actions identified and implemented to mitigate their environmental impact.
Any aspects of the business that are affected by legal regulatory compliance requirements should receive a high priority status, regardless of the risk assessment rating.
Raising awareness and encouraging ownership
An effective communication and training plan is essential for successful implementation of the EMS and will help to ensure that all staff embrace the EMS and become familiar with their roles and responsibilities. Staff awareness and ownership is the catalyst for ensuring that priority and remedial actions are implemented.
Staff briefings and the use of notice boards, e-mails, newsletters, etc…are effective communication mediums that can be used to convey the benefits of environmental management and will help to ensure that staff are involved and take ownership of the EMS.
Staff should receive training to ensure that they are familiar with their EMS roles and responsibilities. It is essential that practical procedures are built into the respective aspects of the business to ensure that the environmental impact is minimised and staff understand how to respond, for example, emergency procedures for site spillages.
Business processes should be examined carefully to determine if there are alternative production methods or if different materials can be used (ideally from recycled sources). The environmental manager must be aware of the management side of the EMS and have comprehensive knowledge of environmental impacts arising from the various aspects of the business. Staff should also be aware of resource and energy efficiency and waste minimization to allow them to identify opportunities for environmental improvement and process cost reduction. Senior managers should have a clear understanding of the costs and benefits of environmental management.
Staff who are selected as internal environmental auditors will need to be trained in the EMS audit process. Alternatively, if resources are limited, you may elect to secure the services of a consultant to undertake and independent and impartial systems audit.
Some basic guidance
All good management systems are underpinned by documented standard operating procedures (SOP). With regard to developing EMS protocols, development of the SOP must be preceded by a measured consideration of the aforementioned business aspects and their environmental impact. All environmental risks and hazards must be reflected in the SOP and control measures which mitigate any potential environmental impact or legal non-compliance set out clearly, for example, this might include constructing a bunded area around an on-site fuel tank and identifying land drainage and surrounding water courses within the locale which may be impacted by a spillage. Training staff in emergency response measures would be considered as a critical action.
Other control measures which add value to the process and, in all likelihood will reduce costs, include a detailed examination of the processes and activities linked to the significant aspects of the business.
For example, if resource use and energy consumption are the most significant aspect for a business, then examining the use of raw materials and investigating alternative sources (including recycled feedstock) may involve an initial injection of capital investment which generates payback in the medium to long term. Examining energy consumption and how a business can be more energy efficient by setting out an energy policy and management plan can reduce a business’s carbon footprint and realise significant cost savings in the short term.
It is important to view the implementation of an EMS as an evolutionary process and not a simple, quick fix. The EMS is a catalyst for positive and fundamental organisational change and environmental improvement. It is a platform for best practice and continuous improvement, promoting a positive public image and improving efficiency.
Finally, many larger businesses often integrate their quality assurance and health and safety management systems. It is certainly worth considering integrating the EMS with these systems as this can reduce the administrative burden and will help to ensure that there is a consistent management approach across the business. Integration does however, require careful planning and you should be clear about the respective system requirements and standards before adopting this approach.
Eric Monson BSc
My aim is to assist businesses in the development of environmental quality management systems, providing a platform for regulatory compliance, sustainable business growth and increased profitability.
