hsse s 022 environmental management

Regulation Class Document Class

Standard Main document

Regulation Title

Environmental Management

Topic Description of the system for identification and effective management of environmental aspects and impacts of OMV Group’s activities, products and services during the entire life-cycle.

Objective To provide a framework for managing the activities through common methods and procedures in order to prevent, reduce or eliminate the environmental impacts, to comply with the relevant legislation, and to demonstrate that environmental risks and liabilities are being managed responsibly, throughout OMV Group.

Target group Line Managers, HSSE Business Partners, HSSE Managers, Environmental Experts

Scope of effectiveness OMV Aktiengesellschaft and all companies which are fully consolidated. In companies not fully consolidated, where OMV Aktiengesellschaft has a controlling interest. All stock corporations are excluded with the result that these regulations have to be separately enforced in these entities.

Responsible for Content: PGSEM-P Alexandra luminita Aurora

Vladu 18.04.2012

Org. Unit First- Last Name

Signature Date

Regulation Approver 1: GTR-V Barbara Oberhauser 19.04.2012 Org. Unit First- Last Name

Signature Date

Regulation Approver 2: GT-R Rod D. Ritchie 19.04.2012 Org. Unit First- Last Name

Signature Date

Regulation Approver 3: G-T Gerald Kappes 02.05.2012 Org. Unit First- Last Name

Signature Date

As approved by the Executive Board of: Not applicable

Date

Effective as of: 08.05.2012

In the interests of simplicity and readability, the language of this statement is gender neutral to the extent possible. Where applicable, the masculine includes the feminine. Print-out is only valid on the date printed. Check for the latest version in the Regulations Platform. In case of conflict, the document in its Master Language must be applied.

HSSE-S-022 Master Language: English Version: 1.0

of 15

Index of content

1. Introduction & Intended Purpose of the Standard ...............................................3 2. Contents of the Standard ........................................................................................3 2.1. EMS Background .....................................................................................................3 2.2. Development and Implementation of EMS...........................................................4 2.2.1. General requirements..............................................................................................4 2.2.1.1. Operational and environmental management boundaries..................................4 A Start preparation of Environmental Management Manual ..................................4 2.2.1.2. Organizational structure and responsibilities .......................................................5 2.2.1.3. Communication........................................................................................................5 2.2.1.4. Training, awareness and competency...................................................................5 2.2.2. Environmental policy...............................................................................................5 2.2.3. Planning....................................................................................................................5 2.2.3.1. Identification environmental aspects & impacts, evaluation of significance.....5 2.2.3.2. Legal and other requirements ................................................................................6 2.2.3.3. Operational control, targets and objectives ..........................................................7 2.2.3.4. Environmental Management Program ..................................................................7 B Consolidation of Environmental Management Manual .......................................8 2.2.4. Implementation and operation...............................................................................8 2.2.4.1. EMS documentation................................................................................................8 2.2.4.2. Document control ....................................................................................................9 2.2.4.3. Operational control..................................................................................................9 2.2.4.4. Emergency preparedness and response ...............................................................9 2.2.5. Checking and improvement actions ......................................................................9 2.2.6. Management review..............................................................................................10 3. Internal Reference Links........................................................................................11 4. External Reference Links .......................................................................................11 5. Obsolete Regulations ............................................................................................11 6. Certification Standards..........................................................................................11 7. Terms & Abbreviations .........................................................................................11 8. Keywords / Search Criteria....................................................................................12 9. Sub Documents / Annexes....................................................................................12 10. Amendments from Previous Versions .................................................................12


of 15

1. Introduction & Intended Purpose of the Standard

The purpose of this Standard is to define all aspects necessary for the preparation and implementation of an Environmental Management System (EMS) within OMV Group

An EMS prescribes methods for developing procedures to protect the environment that addresses the operational activities and every activity, product or service that OMV Group encounters.

An EMS enables to:

Reduce negative operational environmental impacts of the activities, products and services

Proactively increase positive impact of the activities, products and services on the environment

Comply with relevant legislation

Demonstrate that environmental risks and liabilities are being managed responsibly

Minimize harmful discharges to the atmosphere, land and water

Reduce energy consumption and improve energy efficiency

Use natural resources efficiently and avoid waste

All these aspects, in addition to helping to protect and enhance the environment, are leading to financial cost savings.

EMS is a comprehensive management system that can be integrated with other management systems of the industry (e.g. ISO 9001, OHSAS 18001). The implementation of EMS has as scope to:

Develop good environmental management practices that continuously improve to protect humans ecology and property

Receive international recognition for maintaining and consistent application of effective environmental practices that should also ease conducting the activities in various parts of the world

Develop environmental management programs that are common sense and business driven

This Standard follows the requirements set down by ISO 14001 and the EU Eco Management and Audit Scheme (EMAS). However, the scope and extent of an EMS shall be scaled to the requirements of the specific business activities and the scope of effectiveness to which it relates.

By following the steps and applying the structure of EMS set down in this Standard, operations will be able to either fulfill the requirements for certification against ISO 14001 or/and EMAS , wherever this is necessary, or to conduct the activities in a unique structured way and in accordance with ISO 14001/EMAS recommendations throughout the Group.

2. Contents of the Standard

2.1. EMS Background

EMS follow the typical PLAN – DO – CHECK – ACT cycle (see also HSSE Management System Directive) to ensure continuous improvement.


of 15

An EMS helps to ensure that the Group’s overall environmental objectives, as set out in the HSSE Policy, are implemented throughout OMV Group and that employees, contractors and suppliers know their roles and responsibilities in helping OMV Group to achieve them.

Regular measurements, monitoring and auditing of the Group’s environmental performance and of the system put in place to improve it, provide management with a basis for evaluating the effectiveness of the EMS and making changes as appropriate. A core principle of an EMS is that of continual improvement, thereby leading to better environmental performance on a sustained basis.

Developing an EMS includes the development of various components as:

General requirements Environmental Policy which is included in the HSSE Policy Planning Implementation and operation Checking and Improvement Actions Management review

2.2. Development and Implementation of EMS

This section follows the EMS process flowchart as shown in Annex A of this Standard.

2.2.1. General requirements

2.2.1.1. Operational and environmental management boundaries

Before the system’s design and implementation are undertaken, the scope has to be clearly defined. The whole life-cycle of an activity/operation, a product or of services shall be considered, including the planning/design phase as well as the abandonment (decommissioning, dismantling, remediation), and shall cover also activities performed by external partners on behalf of OMV Group.

EMS specific implementation at organizational level is decided by each Business segment. Business segments also decide which organizational units or activities are to be certified according to ISO 14001.

A Start preparation of Environmental Management Manual

After having decided on the implementation boundaries and EMS specific application, the Environmental Management Manual (EMM) is to be prepared.

The EMM is the document to be prepared for the organization, activity, operation, project (or a group of activities / operations / projects that have the same purpose) that has an EMS. It is constituted to summarize information and describe the key elements of the EMS. EMM includes statements of objectives and targets, descriptions of programs, responsibilities and procedures for carrying out processes that relate to its identified significant environmental aspects. This manual has as correspondent in project management the Environmental Management Plan or HSSE Plan, depending on the project manager decision.

EMM represents an overview of the EMS and provides direction to related documentation.

The components of an EMM depend on the location, the set up of the activity and the associated risks. The responsible for preparing the EMM is operational HSSE.


of 15

2.2.1.2. Organizational structure and responsibilities

To have an effective system, line management, advised by the operational HSSE, assigns a formalized structure with clear responsibilities and authorities for development and maintenance of the EMS. This includes the establishment of, trainings, communication, documentation, monitoring, audits and reviews.

2.2.1.3. Communication

Internal and external communication with regard to environmental objectives, programs and performance is required.

2.2.1.4. Training, awareness and competency

Training needs are to be identified according to the Group’s environmental aspects.

Training shall be provided to make sure that people are given the knowledge and skills to fulfill their roles in the EMS and to be able to achieve the environmental targets and objectives they have been assigned for.

Awareness building can be done through signs, posters, newsletters or internal communication campaigns.

2.2.2. Environmental policy

Central to an EMS is the Environmental Policy. The Environmental Policy is a commitment and its declaration of an organization’s overall aims and principles with respect to environmental protection. It must include a commitment to pollution prevention, sustainable use of natural resources and energy, the continual improvement of environmental performance of the organization and a commitment to compliance with environmental, legal and other requirements. It will be also used to communicate aims and objectives to employees and other interested stakeholders. The Environmental Policy shall be based on the evaluation of the organization’s environmental aspects and impacts, and it has to be updated regularly. Where deemed necessary, more specific policies for certain environmental aspects, like Water Policy, Carbon Policy, or Energy Policy might be derived from the Environmental Policy.

OMV Group has adopted an HSSE Management System which incorporates environmental management. The Group’s commitment to environmental protection is clearly stated in its HSSE Policy and its Group HSSE strategy as well as in its Vision and Mission statements.

2.2.3. Planning

Based on the HSSE Policy approved by the top management, planning for the development and implementation of the EMS is required, having as major components:

Identification of environmental aspects and impacts as well as evaluation of the significance

Legal and other requirements Operational control, targets and objectives Management program

2.2.3.1. Identification environmental aspects & impacts, evaluation of significance

A key element of an EMS is the identification and evaluation of impacts on the environment through the activities that cause them (i.e. environmental aspects). The process of identification/revision of environmental aspects and impacts has as main driver, the environmental review/assessment. This shall begin with the map out of the


of 15

boundaries of the EMS and highlight potential areas of concern in relation with the environment.

The environmental review shall apply a systematic process to:

Determine all the activities, products and services and identify their significant environmental aspects according to a defined method

Determine the impacts each activity, product or service has on the environment Identify which activities, products and services cause significant impacts Identify which activities, products and services are covered by applicable

environmental legislation and regulations Determine the extent to which significant environmental aspects are being controlled

and whether effective controls are already in place Identify objectives and targets for environmental improvement and implement

additional operational controls as necessary. The outcome of the environmental review is documented in the Environmental Aspect and Impact Register.

The EMS shall address direct and indirect environmental aspects, considered in normal and abnormal (i.e. periods of maintenance and shutdown) operating conditions or which can occur during emergencies. Historical existing and potential environmental impacts, associated with the current and planned operations shall be identified during the process.

Environmental aspects will vary for each activity, product and service and may include the following (non-exhaustive list):

Atmospheric emissions (including greenhouse gas, venting, flaring and ozone depleting substances)

Wastewater / effluent discharges Water use and management Use of resources, consumption of utilities Energy use and energy-efficiency Waste management Storage, handling and transport of hazardous substances Chemicals management Noise and vibration Biodiversity impacts Terrestrial and marine impacts and project footprint Incidents with environmental impact (e.g. from transportation of hazardous goods,

blow-outs, flaring, leakages etc) Spills/discharge of oil and other hazardous substances

Significant environmental aspects are determined based on:

Size, nature, frequency, likelihood and duration of the environmental impact; Sensitivity of the receiving environment and the extent to which the impact is

reversible; Laws and regulations, as well as contractual requirements; Concerns of the stakeholders, e.g. employees, neighbors, regulators, NGOs; Media interest and company reputation, especially in case of emergencies.

2.2.3.2. Legal and other requirements

The planning phase requires that all legal, regulatory and contractual requirements are considered in the development of the EMS.


of 15

While an EMS cannot guarantee legal compliance, it supports the organization to know its compliance status so that corrective and preventative actions can quickly be implemented. In the event of noncompliance, corrective measures must be taken to redress the situation.

The Legal Compliance Register shall be the documented record that makes the management and control of the legal aspects and their consequences more systematic.

An example for a register that will be used or modified to suit the specific operational needs is provided in Annex B, Table 2: Legal Compliance Register.

The results of the environmental impact evaluation shall be recorded in an Environmental Aspects and Impacts Register making the management and control of these aspects and impacts more systematic. It must include all inputs and outputs to the processes and activities that create environmental impacts under normal and abnormal operation as well as potential emergency situation.

2.2.3.3. Operational control, targets and objectives

Based on the environmental aspects and impacts established in the first phase of the planning, associated operational controls shall be identified.

Existing operational controls/barriers (engineering and managerial, preventive and reactive) shall be identified in the Environmental Aspects and Impacts Register. All significant environmental aspects require operational controls to ensure that activities are carried out as planned. Some of them require additional or more adequate controls/barriers, which lead to preventive and reactive measures, to be included in the programs established in EMS implementation. Objectives and targets address the environmental significant aspects in order to achieve continual improvement in correspondence with the HSSE Policy.

The regulatory requirements should be used as a guide for setting the targets.

The Environmental Aspects and Impacts Register is also used for the identification and development of the key performance indicators (KPIs), environmental objectives and targets as a result of the assessment of environmental aspects and impacts, based on a methodology chosen.

An example for a register should be used or modified to suit the specific operational needs is presented in Annex B, Table 1: Environmental Aspects and Impacts Register.

In order to achieve the objectives and targets, the organization/activity/operation/project shall follow a process: For each policy commitment, identify an objective that corresponds to that commitment, establish the program to achieve each objective and target, and identify specific KPIs and actions to implement the program.

2.2.3.4. Environmental Management Program

Identified objectives and targets shall be agreed and approved by Line Management and their progress/achievement/adequacy will need to be reported back to Senior Management as part of the Management Review process.

The Environmental Management Program represents the SMART (Specific, Measurable, Achievable, Realistic, Time) list of actions that is developed under the planning phase for achieving the environmental objectives and targets, focusing mainly on risk reduction.

It will have as base of information the assessment results of the environmental aspects and impacts, prioritized in accordance with their significance and under the consideration of regulatory requirements. The Environmental Management Program shall be reviewed, updated and approved by the Management at least once per year. Every significant change resulted from different new strategies, assessments, projects, actions, nonconformities etc.,


of 15

shall be taken into consideration as an update of the program every time when this is necessary. The Environmental Management Program can be part of the EMM.

B Consolidation of Environmental Management Manual

The EMM has to be completed with the information previously specified in this Standard. The EMM is an ever-changing document that will be updated once per year or whenever the conditions of the location require this.

An EMM should be organized into chapters and shall include at least the sections specified in Annex C to this Standard.

The EMM shall be approved by the Line Management and shall be considered as main document for the set up of the Environmental Management System.

2.2.4. Implementation and operation

The implementation starts with the development of the organizational structure and responsibility (2.2.1.2), continues with the communication and training processes (2.2.1.3., 2.2.1.4), which are developed permanently, and it is supported by the:

EMS documentation; Document control; Operational control; Emergency preparedness and control.

Internal and external communication strategies and programs with regard to OMV Group’s environmental policy incorporated in the HSSE Policy, its environmental objectives, programs and performance shall be organized.

Training needs are to be identified according to the Group’s environmental aspects and programs for awareness, knowledge, skills improvement and EMS requirements appliance shall be implemented.

2.2.4.1. EMS documentation

The organization shall develop and maintain documented information to:

Describe the core elements of the EMS and their direction; Provide direction to related documentation.

The EMS documentation shall include:

Environmental policy, objectives and targets; Description of the scope of the EMS; Description of the main elements of the EMS and their interaction, as well as

reference to related documents: information of participation in trainings, results of operational controls etc;

Documents, including records, required by ISO 14001 and other relevant norms like ISO 50001: nonconformities, corrective and preventive actions, results of EMS audits etc.;

Documents, including records, determined by OMV Group to be necessary to ensure the effective planning, operation and control of processes that relate to its significant environmental aspects: environmental attributes of activities, products and services, evidences of fulfillment of objectives and targets etc.

Documents, including records, on compliance with environmental legal requirements: permits, licenses, other legal authorizations, results of authorities’ inspections etc.


of 15

The following list of key documents, although not exhaustive, provides examples of the documents that are relevant:

Site/installation environmental history file: Environmental baseline assessment of new/acquired sites, environmental complaints and external requests etc;

Environmental Aspects and Impacts Register; Environmental monitoring and reporting procedures: Emissions and discharges,

environmental Incidents; Environmental emergency response plans; Waste management plans; Water management plans; Discharge management plans; Energy management plans; Environmental restoration and remediation plans; Performance against objectives and targets/analyses, improvement plans; Status and validity of environmental permits and/or conformity programs.

2.2.4.2. Document control

Documents, such as records, have to be kept up to date and controlled so that only the most recent versions are available for use. Links with other key documents shall also be identified in the EMS.

The effective control of the records is essential for the successful implementation of the EMS. Environmental document control shall be done through: identification, collection, indexing, filing, storage, maintenance, etc.

2.2.4.3. Operational control

Procedures have to be established and communicated to both, employees and contractors, in order to ensure that activities are carried out and properly managed. Although in some cases long narrative procedures may be required, a flow diagram might be equally effective in ensuring that a task is carried out properly.

2.2.4.4. Emergency preparedness and response

Emergency response procedures shall be developed, including the specific spill prevention, control and response procedures. They have to be trained, implemented and regularly tested for all facilities.

2.2.5. Checking and improvement actions

Information on the Group’s environmental performance is essential to track progress against the HSSE Policy, objectives and targets and for continuous improvement. This is possible through a systematic monitoring of the EMS performance and of the required implementation of the preventive and corrective actions.

It is important to be up to date with new and changing legislation, applicable corporate and other requirements that will have the potential to impact upon current and planned operations.

Monitoring shall also be done through periodic evaluation to ensure compliance with the relevant legislation and internal regulations (directives, standards, procedures, work instructions, technological plans etc).

Internal and external monitoring, audits, site visits, inspections from the authorities or certifier, claims or different other types of verifications may identify deviations/nonconformities from the requirements set in the legislation and/or internal regulations.


of 15

The management of nonconformities shall be established by each Business Segment through specific procedures. This ensures that adequate corrective and preventive measures are implemented to prevent reoccurrence. In addition to the specific requirements for external auditing of certified EMS, different aspects of the implementation of the system shall be audited internally each year. Each Business Segment has to agree and implement an audit program. The objectives/aspects and frequencies of audits are to be determined by the type of environmental risks and frequency of activities. Auditing helps to determine whether the planned elements of the EMS have been implemented as intended and whether the EMS is functioning as planned. It also provides information to management on the overall performance of the system since the audit findings help to improve the EMS through new action plans.

Full audits (against the requirements of this Standard) of the EMS shall be completed every three years.

2.2.6. Management review

Annual reviews by Senior Management shall be conducted to ensure that the EMS is achieving the desired outcomes and that the environmental objectives laid down in the HSSE Policy have been implemented. This provides means for the Line Management to review the organization’s environmental performance trends to ensure that performance is improving and to initiate improvements to the system as necessary.

Inputs used for the Management Review, including but not limited to:

Findings from EMS audit List of nonconformities registered since the date of the previous review Results from incidents analysis/investigations Views of internal and external inspections and audits (e.g. authority inspections’

outcomes, claims of stakeholders) Legal conformity assessment (legal compliance register) Revised and/or updated aspects and impacts register Previous management review Environmental performance related to the previous year’s situation Environmental aspects resulted from major changes within the organization:

technological flow, new activities, new legal requirements etc.

Actions defined and decisions taken shall be documented. Audit and Review results will be used as input for policy updates and planning reviews.

OMV Group's Think:Ahead CARE reporting system shall be used to support the management review by considering findings from audits, nonconformities from previous reviews, results from incidents analysis/investigations etc..


of 15

3. Internal Reference Links

Directive HSSE Management System Directive Environmental Management Corporate HSSE Recommendation Environmental Practices in Projects

4. External Reference Links

ISO 14001 - Environmental Management Systems – Specifications with guidance for use

ISO 14004 - Environmental Management Systems –General guidelines on principles, systems and supporting techniques –

ISO 50001 – Energy management system – Requirements with guidance for use ISO 19011 - Guidelines for Quality and Environmental Management Systems Auditing

5. Obsolete Regulations

OMV E&P Guideline – Environmental Management Systems HSEQ-HQ-06-15-00 OMV E&P Standard – Environmental Standard HSEQ-HQ-06-06-02

6. Certification Standards

ISO 14001 - Environmental Management Systems – Specifications with guidance for use

ISO 50001 – Energy management system – Requirements with guidance for use EMAS - EU Eco Management and Audit Scheme

7. Terms & Abbreviations

Environment The surroundings in which an organization operates including air, water, land, natural resources, flora, fauna, humans and their interrelation. EN ISO 14001:2004

Environmental Aspect

An element of an organization’s activities, products or services that can interact with the environment.

Environmental Impact

Any change in the environment resulting from the organization’s environmental aspects, both positive and negative.

Environmental Management System (EMS)

A structured framework for managing an organization's environmental aspects (activities) and implementing its environmental policy.

Corrective Action Sustainable measures to eliminate the cause of a known/recognized/detected failure/deviation/nonconformity to prevent reoccurrence.

Preventive Action Sustainable measures to eliminate the cause of potential failure/deviation.

ISO 14001

A structured framework for identifying, evaluating, managing and improving an organization’s environmental performance.

ISO 50001 An International Standard specifying energy management system (EnMS) requirements, upon which an organization can develop and implement an energy policy and establish objectives, targets, and action plans which take into account legal requirements.

EMAS EU Eco Management and Audit Scheme


of 15

Organization

A company, corporation, firm, enterprise, authority or institution, or part or combination thereof, whether incorporated or not, public or private, that has its own functions and administration.

HSSE Health, Safety, Security, Environment

8. Keywords / Search Criteria

EMS, Environmental Aspects and Impacts, Management Program, EMM

9. Sub Documents / Annexes

Annex A: EMS Process Flowchart Annex B: Table 1: Example for Environmental Aspects and Impacts Register

Table 2: Example for Legal Compliance Register Annex C: Content of Environmental Management Manual

10. Amendments from Previous Versions

Date of effectiveness:

Regulation code: Changes to previous versions:

08.05.2012 HSSE-S-022 New Version


of 15

Annex A: EMS Process Flowchart


of 15

Annex B:

Table 1: Example for Environmental Aspects and Impacts Register

ACTIVITY / SITE/PLANT/PROCESS :

Environmental Aspects (Cause)

Condition (threat)

Environmental Impacts (Effect)

Existing Control Measures

Control Measures Status

Normal Abnormal Accidental

Applicable legislation

Impact Evaluation Criteria

Significance Actions

Table 2: Example for Legal Compliance Register

Crt. No.

Law/ Decision/ Permit/ Contract

Specific requirement of compliance

Activity Environmental Aspect

Actions necessary for implementation (preventive and corrective)

Deadline Responsible Resources Evaluation of conformity

1 2 3 4 5 6 7 8 9 10


of 15

Annex C: Content of Environmental Management Manual This is a non-exhaustive list; there might be additional chapters depending on the characteristics of the concerned business activity

SECTION CONTENT

1. Introduction

Identify the organization HSSE / Environmental Policy “Stop of work” Policy The purpose and scope of the EMP Legislation in force Description of environmental objectives

2. Description of work

Location Description of technological process Work methodology Working period and during of major operations

3. Description of receiving environment

Elements of geology, hydrogeology and climate Elements of Ecology Proximity to protected areas Socio-economic environment Cultural environment

4. Environmental issues and the assessment of environmental impact and risk

Identification of the frequency, severity and duration of effects and their consequences caused by potential disturbances, discharges and emissions

Identifying direct and indirect effects and risks associated

Physical aspects Biological aspects Social issues Operational issues Emergency, e.g. discharge of petroleum products Specific considerations regarding the location

5. Environmental performance, objectives and standards

Setting goals and standards against which to measure environmental effects and risks

Establishing measurable criteria to assess performance against standards and targets

6. Management and risk reduction procedures

Waste management Management of chemicals and hazardous Wastewater management Preventing oil spills Gaseous emissions, including greenhouse gases and

dust Managing noise and vibration Management of physical disturbance, biological or

social Rehabilitation Program

7. Roles and responsibilities

Establishing a chain of command, emphasizing the roles and responsibilities of personnel in the implementation, management and review


of 15