measuring the effectivenrjess of ems phase 1-2

8/15/2019 Measuring the Effectivenrjess of Ems Phase 1-2

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Measuring the effectiveness of

Environmental Management Systems

Phase 1: Desktop Report, June 2009


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Background to the Project

Measuring the Effectiveness of Environmental Management Systems: Phase 1

1

www.ni-environment.gov.uk


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Background to the Project

DoE Environment and Heritage Service (now Northern Ireland Environment

Agency, NIEA) commissioned ‘An Evaluation into the Effectiveness of

Environmental Management Systems’ as part of the ‘Better Regulation’

agenda, which ‘includes assessing aspects of a risk based approach toregulation, a more integrated approach to enforcement and improving

awareness of obligations and best practice’ (EHS Tender Brief ).

The main aims of the study are to measure the effectiveness of EMS and

analogous systems implemented by NI businesses in:

1. Having a demonstrable impact on the level of legislative compliance,

2. Improving an organisations environmental performance / reducing its

environmental impacts.

This study has been undertaken on behalf of NIEA by White Young Green

in two distinct phases. The first is the completion of research and a desk

top study into the types of management system, certification process anduptake from an international, national and local perspective. The desk top

review has also collated research information relating to the effectiveness

of Environmental Management Systems (EMS) undertaken within the last

decade. The second phase is data analysis and interpretation from 1000

Northern Ireland organisations in June 2008 (subject to a separate report).

Background to Environmental Management Systems

Environmental Management Systems are a systematic, planned approach

to the management of environmental issues at an organisation and should

be adopted as part of the overall company management structure. Theyare based on a Plan-Do-Check-Act methodology that aspires to continual

improvement. There are a number of differing types of EMS. These can be

summarised as :

EMAS (Eco-Management and Audit Scheme)•

BS EN ISO 14001 (International standard)•

BS8555 : 2003 & the Acorn Scheme (Phased approach)•

Green Dragon (Arena Network) (phased approach)•

EMS is a risk management tool and all EMS standards have a similar

framework and can be applied to any public or private sector organisations.

EMAS is often viewed as the most stringent management system, as there is

an explicit requirement for legal compliance and reporting of this status to

the Regulator. All other systems require identification of legislation relevant

to an organisations activities, products and services and a commitment

to assess the level of compliance against the identified legislation. Whilst

blatant non-compliance with legislation will result in a company incurring

penalties with respect to any management systems certification body audit

(e.g. a category 1 noncompliance), refusal or removal of certification is rare.

Generally, companies reporting non-compliances with legislation, within

their EMS, are encouraged to develop a detailed Action Plan to address the

noncompliant issues. Certification bodies provide recognition of the EMS

against the standards noted above (e.g. EMAS, ISO 14001 etc). In addition, allEMS standards require organisations to commit to continual improvement

Environmental Policy

Planning

Implementation

and

operation

Management Review

Checking

Continual improvement


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and evidence of this commitment is usually found in the setting of

environmental objectives, targets, management plans or environmental

performance indicators. Certification bodies are regulated by a strict code

administered by the United Kingdom Accreditation Service (UKAS) in the UK,

BS EN ISO/IEC 17021:2006. This code ensures consistency of the assessment

process. There has been an amount of ‘bad press’ associated with EMS andlegal compliance in recent years and UKAS and the accreditation bodies

have been working hard to provide some clarification on the issue of the

association between EMS and legal compliance (paper EA – 7/04 seeks to add

clarification to the certification bodies as regards auditing legal compliance

as part of ISO 14001:2004).

The Drivers & Uptake

There are a number of drivers for organisations wishing to develop and

implement EMS, above and beyond legislative compliance or performance

improvements. A key driver for organisations operating in England and Wales

are the ‘Opra’ requirements relating to risk screening of activities and therelative proportion of effort applied to regulating organisations. In regulating

through ‘Opra’ Environment Agency (England & Wales) demonstrates

a policy commitment that for those organisations regulated under the

“Environmental Permitting” Regulations an effective EMS is important in

managing the risks associated with and delivering permit requirements. ISO

14001 is the most favoured ‘type’ of management system to be implemented

within organisations in the UK, with over 6000 registrations (at the end of

2006).

EMS ‘drivers’

Legal compliance•

Improved environmental performance•

Cost savings•

Customer / client pressure•

Supply chain management•

Enhanced PR•

Environmental Risk Management•

EMS in Northern Ireland

Northern Ireland business and industry has been served by a range of EMS

support mechanisms over the last 15 years. These have been :

IRTU (now Invest NI) Environmental Audit Support Scheme grant•

IRTU Environmental Management Support Scheme grant•

Invest NI Building Blocks to a Better Business – pilot programme for 11•

no. manufacturing companies

The STEM Programme – cross border programme involving•

implementation of BS8555 for up to 240 businesses and 11 no. district

councils

Easy Access (BS8555 for construction companies)•

BiTES - Belfast City Council (Green Dragon through Arena Network) for 9•

organisations in the Belfast CC area

Coleraine BC (Green Dragon through Arena Network)•


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Whilst research and evaluation of the above programmes has been on

an ad-hoc basis, there have been some positive outcomes in relation to

specific projects accumulating environmental improvements and indicating

compliance with environmental legislation. This compares to less than 400

registrations to the EMAS standard within the same period. There is evidence

that levels of ISO 14001 uptake are stabilising in the UK, however significantgrowth in uptake in all standards have been seen in Spain and Italy.

To conclude :

Whilst desk top analysis of research would indicate strong evidence that EMS

has a positive outcome in terms of improved environmental performance,

the research is inconclusive in terms of legislative compliance. There is also

not enough evidence to support the measurement of the effectiveness of the

EMS in terms of its’ type (e.g. EMAS, ISO 14001 etc), particularly in relation to

the collation of data in a local setting.

The findings indicate the need for the detailed study into 1000 Northern

Ireland organisations* and an evaluation of the data for organisations withaccredited EMS, non accredited EMS and no systems in place. Validation of

that data against regulator and certification body records would also be a

valuable exercise.

* This research has been carried out in conjunction with this desk top study.

EMS Research

The last decade has seen a plethora of research studies into EMS with

a number considering their effectiveness in relation to compliance and

improvements. These are summarised below:

Survey Indicative of legal

compliance?

Indicative of improved

Environmental Performance?

EMAS Ever

Remas

MEPI and follow up study

ISO 14001 - a National Study in Austria

SME-enviroment Survey 2007

EMS and company Performance

STEM

BITES

EASS

Building Blocks

I n t e r n a t i o n a l

F i n d i n g s

N a t i o n a l

F i n d i n g s

N o r t h e r n I r i s h

F i n d i n g s


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1 Introduction 8

2 What is an Environmental Management System 10

2.1 History of EMS 11

2.2 Types of EMS 12

2.3 Accreditation 22

2.4 Certification 26

2.5 Management Systems and Legal Compliance 37

3 Drivers to Implementation of an EMS 40

3.1 Overview of legislation and policy 40

3.1.1 Formulation of Legislation 40

3.1.2 NI Legislation 40

3.1.3 Enforcement in Northern Ireland 40

3.2 Procurement Policy and Promotion of EMS 43

3.2.1 Central Procurement Directorate 45

3.2.2 Other Local Procurement Drivers 46

3.2.3 Compliance Drivers in England and Wales 48

3.2.4 ‘Other’ Drivers for Implementing an EMS 51

4 Uptake of EMS 54

4.1 The International Scene 54

4.2 Europe 55

4.3 UK Wide 57

4.4 Northern Ireland 57

4.4.1 Invest NI 57

4.4.1.1 Support Schemes 57

4.4.1.2 Building Blocks 60

4.4.2 STEM 61

4.4.3 BITES 68

4.4.4 Easy Access 68

4.4.5 Green Dragon – Coleraine Borough Council 69

4.4.6 Arena Network Survey 69

Contents


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5 Research Studies 71

5.1 SME-nvironment Survey (NetRegs) 71

5.2 Ever – Evaluation of EMAS and Eco-label for their revision 73

5.3 EMS and Company Performance 74

5.4 REMAS 75

5.5 MEPI 79

5.6 ISO 14001 – Experiences, Effects and Future Challenges:

a National Study in Austria 80

5.7 USA National Database 81

5.8 Urban Government Review in Japan 82

6 Conclusion 83

7 Recommendations 87

References 88

Appendix 1 Chapter 1 Key Targets Northern Ireland Sustainability Strategy

Appendix 2 Chapter 6 Key Targets Northern Ireland Sustainability Strategy

Appendix 3 Implementation of EMAS outside EU List of Figures

Appendix 4 NI PPC Permits

Appendix 5 NIEA Organisational Structure

Figure 1 Key elements of legal compliance in an EMS

Figure 2 Regulatory value of an EMS

Figure 3 ISO14001:2004 EMS

Figure 4 EMAS EMS

Figure 5 BS8555:2003 EMS

Figure 6 Green Dragon EMS

Figure 7 EMAS Registration process

Figure 8 ISO14001:2004 Assessment process

Figure 9 Evolution of EMAS organisations


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8


Introduction

In March 2008, Environment and Heritage Service (now NIEA) published

“Better Regulation for a Better Environment”. This position statement defines

the principles of streamlining the regulation process for organisations. “Many

of the businesses in Northern Ireland are not subject to direct regulationby EHS [NIEA] but are nonetheless required to comply with environmental

legislation. The differing scales and activities covered by our regulations

demand that we adopt a smarter range of tools and approaches to suit the

nature and risk of an organisation” and this falls within the overall aim of

working “closely with those we regulate to raise awareness of obligations

and good practice, to simplify compliance and engagement with our

regulatory teams and to reward those organisations who actively identify

and manage their risks to the environment”. As part of this strategy, a

commitment is made to “assess effectiveness of Environmental Management

Systems (EMS) as a measure of environmental performance and compliance”.

WYG successfully tendered to the EHS, now re-branded Northern Ireland

Environment Agency (NIEA), to undertake this study on its behalf. The mainaims of the study are:

1. To evaluate the effectiveness of an EMS in improving an organisations legal

compliance and,

2. To evaluate the effectiveness of an EMS in improving an organisations

environmental performance.

The study is in two distinct phases, the first is ‘desk based’ and concentrates

on analysis of existing data and studies relating to the implementation of

an Environmental Management System on a world wide scale. The results of

this ‘desk based’ research are presented in this report. The second element

of the study involves a large scale survey of NI businesses and public sector

organisations to capture evidence of legal compliance and environmentalperformance of organisations with, and without, EMS’s. Full data analysis and

verification is enclosed within “Report 2”.

Running in parallel to this study, Scotland & Northern Ireland Forum for

Environmental Research (SNIFFER) are currently conducting report and

survey UKCC19 - entitled “Better Regulation – Rethinking the Approach for

SMEs.

SNIFFER has looked at how best regulatory bodies should target their

resources in the future, and finds that SMEs are neglected at present, while

“resources currently go to firms with the most resources to self regulate”.

The findings are also likely to suggest that SMEs would be best suited by a

supportive command and control framework of regulation, since their limited

resources mean they are less able to meet the requirements of regulated self-

regulation.

Methodology of firm categorisation enables SMEs and large firms to be

divided into four separate categories related to size, and capacity for, or

efficacy of, self regulation. Since SNIFFER seem to be advocating a trend

towards allowing larger companies to exercise a greater degree of self-

regulation, and that a greater proportion of resources to be focused on SMEs,

it could be seen as a logical step that these larger, more environmentally

proactive companies should be encouraged to implement, and havecertified, EMS in place to allow this shift of regulatory resources – which has


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been witnessed in terms of the encouragement on those firms appraised

by the Environment Agency (England & Wales) under Opra to implement

certified EMS.

Since the “Better Regulation” programme is actively considering the shift

towards a more risk based system of regulation – and were this to be thecase, then it is of great importance to know whether there is empirical

evidence that an EMS can reduce the risk associated with a particular

organisation. It is the aim of this project and report to establish statistically

robust data to be able to support or discount the hypothesis that an EMS

improves an organisations compliance with applicable environmental

legislation, and / or its’ environmental performance. This is in line with the

Environment Minister Sammy Wilson’s vision of a new Agency that will

“help business implement improved environmental management systems”

(keynote speech 1st July 2008).

In detail, this project has involved:

1) A desktop survey and review of existing data and literature relating to

development and implementation of EMS internationally, regionally and

locally. The aim of this is to develop an understanding of the trends seen by

those companies that have developed formal EMS to the various different

standards including, but not limited to: EMAS; ISO 14001 and BS8555.

2) Survey of 1,000 Northern organisations throughout Northern Ireland,

including public and private, SMEs and large organisations.

3) Data Evaluation, statistical analysis and verification of information

gathered through the survey and questionnaires

4) Preparation of an Interim and Final report and recommendations to

the NIEA regarding the potential role of EMS within the Department of

Environments programme for Better Regulation.

EMS Evaluation

Project Overview

Desk Top

Research

Data Collection

Interim ‘Desk

Top’ Report

Data Analysis &

Review

Final Report with

Recommendations


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2.0 What is an Environmental Management System?

The British Standards Institute have defined an EMS as “part of the overall

management system that includes organisational structure, planning

activities, responsibilities, practices, procedures, processes and resources

for developing, implementing, achieving, reviewing and maintaining theenvironmental policy” (BS8555; 2003). It can be seen as a risk management

tool also – since the standards to which organisations are assessed are not

prescriptive, they provide the framework within which an organisation must

identify it’s own potential impacts upon the environment, and seek to control

these as well as to identify opportunities to reduce the associated risks. An

EMS can be considered to follow the Deming cycle of “Plan – Do – Check –

Act”

Plan

The role of an EMS is in delivering the commitments within an environmental

policy. The policy should commit an organisation to legal compliance andcontinual improvement (BS8555 – phase 1, Stage 3; ISO 14001:2004 – clause

4.2). The organisation should then identify all applicable environmental

aspects that may create an environmental impact and also all relevant

environmental legislation. Compliance with legislation must also be

demonstrated in order to meet the requirements of BS8555 – Phase 2

Stage 1-5; ISO 14001;2004 – clause 4.3.2 and 4.5.2. While in relation to

Environmental performance, the organisation will have made a commitment

to continually improve, and should set out Objectives and Targets and a

programme to achieve these (BS8555 – Phase 3 Stage 3-7; ISO 14001:2004

– clause 4.3.3). The objectives and targets provide the organisation with

an improvement plan specifically tailored to ensure improvements in

environmental performance related to it’s environmental aspects (BS8555 –Phase 3 Stage 1; ISO 14001:2004 - 4.3.1) associated with the range of activities

it carries out, the product(s) manufactured or the service(s) provided.

Do

Control measures and procedures are intrinsic to the successful

implementation and maintenance of an EMS, whether this is related to

Training (BS8555 – Phase 1 Stage 6 and Phase 4 Stage 2; ISO 14001:2004 –

4.4.2), Operational Control (BS8555 – Phase 3 Stage 6; ISO 14001:2004 – 4.4.6),

or Emergency Preparedness and response (BS8555 – Phase 4 Stage 5; ISO

14001:2004 – 4.4.7). Most organisations will have a clearly defined, written set

of procedures that will outline what needs to be done to ensure compliance

with the EMS.

Check

The success of implementation should be reviewed within the management

system through a programme of Internal Audits (BS8555 – Phase 5 Stage

1; ISO 14001:2004 – 4.5.5) and identification of corrective and preventive

actions to deal with identified non-conformances (BS8555 – Phase 5 Stage

2: ISO 14001:2004 – 4.5.3). Conformance of an organisation against the

procedures will be evaluated during the audit process. Compliance with

legislation will also be checked during auditing as a number of Operational


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Procedures are drafted to ensure legal compliance of the activity as a

minimum.

Act

The results of the “checking” stage of the process should be used to informManagement of areas of progress, or problems within the system as part of

Management Review (BS8555 – Phase 5 Stage 3: ISO 14001:2004 – 4.6). This

management review process should, in turn, then be used to re-address the

issues of Environmental Policy, the organisations environmental aspects

& impacts, legal compliance and objectives and targets. The continually

improving organisation will then be able to adjust to any changes that may

have occurred and set objectives and targets for forthcoming years.

According to a study conducted by Business in the Community

(Environmental Index Report 2006) an EMS helps an organisation to improve

its environmental performance. Common requirements of an EMS (such

as a policy, objectives, targets, training and reporting) demonstrate acommitment to incorporating environmental issues into key practices with

the resultant benefits of:

improved risk management•

reduced liability costs•

increased competitive advantage•

more employee involvement and•

improved public image (www.bitc.org.uk)•

These benefits are further support by findings from a NetRegs survey

conducted in 2007 of small and medium sized enterprises (SMEs) across the

UK (including Northern Ireland) to reveal their attitudes and behaviours.In relation to benefits in addressing environmental issues, the three main

business benefits of addressing environmental issues were:

Reduced risk of prosecution (81% strongly agree / agree);•

Creates good relations with customers (67% strongly agree / agree); and•

Reduces operating costs (66% strongly agree / agree)•

2.1 History of Environmental Management Systems

The World’s first formal EMS developed by the British Standards Institute (BSI)

was BS7750, first published in March 1992. The standard was based on a two

year pilot implementation programme with 230 implementing organisations

and was then modified on the basis of feedback, with the publication of

this modified standard in January 1994 (Starkey, 1998). At the same time as

the development of BS7750, the European Commission was setting out it’s

proposal for an eco-audit scheme, after some initial proposals and changes

the Commission published what has become known as the Eco-Management

and Audit Scheme (EMAS), this was adopted by the Council of Ministers on

June 29th 1993, and became open to company participation in April 1995

(Starkey, 1998).

The development of ISO14001 came about because of the need for improvedenvironmental performance expressed at the United Nations Conference


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Environmental Management Systems – requirements with guidance for•

use (ISO 14001 : 2004)

Environmental Management Systems – General Guidelines on principles,•

systems and support techniques (ISO 14004: 2004)

Environmental Management Systems – Draft Guidelines for a staged•

implementation of an environmental management system, includingthe use of environmental performance evaluation (ISO 14005) – due for

publication in September 2010.

Environmental Performance Evaluation (ISO 14031:1999)•

Within this series, “EN ISO 14001 environmental management systems —

specifications with guidance for use” is the only certifiable standard, the

remainder being supportive guidelines. The aims of EN ISO 14001 are to

promote environmental protection in light of socio-economic concerns.

Clause No Clause Title Clause No Clause Title

4.1 General Requirements 4.44.4.1

4.4.2

4.4.3

4.4.4

4.4.5

4.4.6

4.4.7

Implementation &Operation

Resources, roles,

responsibility & authority

Competence, training &

awareness

Communication

Documentation

Control of Documents

Operational Controls

Emergency Preparedness &

Response

4.2 Environmental Policy 4.5

4.5.1

4.5.2

4.5.3

4.5.4

4.5.5

Checking

Monitoring and

measurement

Evaluation of Compliance

Nonconformity, corrective

action and preventive

action

Control of Records

Internal Audit

4.3

4.3.1

4.3.2

4.3.3

Planning

Environmental Aspects

Legal & Other

Requirements

Objectives, Targets &

Programmes

4.6 Management Review


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An effective environmental management system based on ISO14001

provides an organisation with a defined structure to allow them to more

confidently and effectively manage environmental issues by:

Establishing a policy and awareness that good environmental•

performance is a strategic objective of the organisation.Focusing on the prevention of waste and pollution and on continual•

improvement of environmental performance.

Systematic analysis, planning, control and monitoring of all activities that•

may affect environmental performance.

Assisting companies to more effectively meet legislative and regulatory•

requirements.

Demonstrating to regulators, stakeholders and other interested third•

parties that a formal environmental management system is operational

and effective (www.nsai.ie).

The main rationale for the creation of ISO14001 was that its world wide

acceptance should facilitate international trade by harmonising otherwisediffuse environmental management standards and by providing an

internationally accepted blueprint for sustainable development, pollution

prevention and compliance assurance (Delmas Magali A., 2002).

Environmental Policy

Planning

Implementation

and

operation

Management Review

Checking

Continual improvement

Figure 3 ISO14001:2004


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ISO 14001 is very similar to EMAS but at the time of registration,

Environmental regulators are consulted to make sure that they are satisfied

that organisations have “identified and know the implications [to the

organisation] of all environmental legislation and that their system is capable

of meeting these on an ongoing basis”. , it can take a more prescriptive

approach to environmental management issues. The ISO 14000 standards,by contrast, rely on voluntary acceptance by all interested parties, and

therefore must maintain a balance between the needs and expectations of

each of these parties. (www.europa.eu).

Eco-Management and Audit Scheme (EMAS)

The EU Eco-Management and Audit Scheme, known as EMAS, is a voluntary

market based instrument designed to encourage better environmental

performance from all types of organisation. EMAS is completely compatible

with the international standard for environmental management systems, ISO

14001, but goes further in its requirements for performance improvement,

employee involvement, legal compliance and communication withstakeholders. Uniquely EMAS requires organisations to produce an

independently verified report about their performance (www.emas.org.uk).

EMAS is a direct response to some of the key principles in the European

Union’s Environmental Action Programmes and the challenge of sustainable

development. Behind EMAS stands the concept of broadening the range

of policy instruments and promoting an approach of shared responsibility

in environmental protection. EMAS was first adopted by the European

Environment Council on 29th June 1993 and became open to industrial

participation from April 1995 onwards. EMAS was revised in 2001, and

eligibility widened to include all sectors of public and private economic

activity (DEFRA).

The EMAS Regulation applies to all 27 EU Member States, and the 3

European Economic Area States (Iceland, Norway and Liechtenstein) – all

candidate countries (e.g. Turkey, Croatia and the Former Yugoslav Republic

of Macedonia) are obliged to implement the scheme in preparation for their

accession to the EU.

Some international companies operating sites outside of the EU / EEA, have

opted to pursue EMAS registration. However, since these countries are not

members of the EU / EEA, their registrations do not hold the same legal

status; in this instance they are referred to as “quasi-registrations” – currently

these “quasi-registrations” exist in countries such as Brazil, Switzerland, China

and the USA.


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Figure 4 EMAS

Source of Diagram : ‘EMAS: A Practical Guide’, ISBN : 0-946655-81-2

Institute of Environmental Management and Assessment (IEMA) Acorn

Scheme

“Acorn” is the name of a project with a main objective to help British SMEs

improve their environmental performance through a five-level approach tothe implementation of an environmental management system (EMS) in line

with ISO 14001, and a sixth level that facilitated external certification to ISO

14001 and / or registration to EMAS.

Once the project was completed a “not for profit” organisation, the Acorn

Trust, was founded in order to develop a standard based on the project’s

methodology (www.europa.eu).

The IEMA Acorn Scheme, an officially recognised EMS standard, offers

accredited recognition for organisations evaluating and improving their

environmental performance through the phased implementation of an

environmental management system (EMS). Acorn focuses on environmental

improvements that are linked to business competitiveness and is flexible

so that all types of organisation, whatever their size, can participate. Acorn

offers a unique feature whereby organisations can engage environmental

performance indicator (EPI) reporting within the procurement process in

accordance with ISO 14031. This compliments the ‘one size fits all’ aspects

of ISO14001 & EMAS and provides the opportunity to set environmental

requirements in supplier contracts and monitor operational/product

performance – a strength acknowledged by the Government in a recent

EMS position statement published by DEFRA. A system of independent

inspection is central to providing recognition that an organisation has

met the achievement criteria of a particular Acorn phase and continues toimprove its environmental performance (www.iema.org).


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BS 8555:2003 Environmental Management Systems

Work on Project Acorn led to recognition by the British Standards Institute

(BSI) of the phased approach to development of an EMS and the benefits

for small to medium sized enterprises (SMEs). As with Acorn, the standard,

BS8555:2003, sets out a six phase implementation programme, to worktowards a formal EMS that can be certified to BS EN ISO 14001 or the EU Eco-

Management and Audit Scheme (EMAS) at Phase 6. Each phase is broken

into a number of specific stages, with guidance and process planning

spreadsheet available to organisations to assist their development. Progress

can be acknowledged against the standard, with certification at any of the

six phases, allowing SMEs greater control and freedom over the project plan.

After full certification to ISO 14001, at phase 6, the second most popular

certification for SMEs is at Phase 3. This allows for actual cost, compliance and

environmental benefits to be realised before detailed written procedures are

required. Although principally aimed at SMEs, the guidance can be used by

any organisation, regardless of size, the nature of their business undertaken

or their location (Environmental Management Systems Fact Sheet No. 4).

The Six Phases of BS8555:

1. Commitment & establishing the baseline

2. Identifying & ensuring compliance with legal and other requirements

3. Developing objectives, targets & programmes

4. Implementation and operation of the EMS

5. Checking, audit & management review

6. Certification to either ISO 14001 or EMAS

The International Standards Organisation (ISO) is currently reviewing the

incorporation of BS8555:2003 into the international ‘family’ of standards.ISO 14005 “Guidelines for the staged implementation of an environmental

management system, including the use of environmental performance

evaluation” is currently in development with a proposed publication date of

September 2010.


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Figure 5 BS8555:2003 - Overview of the phased implementation of an environmental management system.


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Green Dragon

Green Dragon was developed by ARENA Network and Groundwork Wales

with support from the Welsh Assembly Government, Environment Agency

Wales, Welsh Local Authorities and the European Regional Development

Fund. Funding for the project was provided from a mix of Welsh Assembly,private companies and also several high profile multinationals funded the

pilot scheme. There are 971 organisations from a variety of sectors and

across a broad range of size that have already made the commitment to the

implementation of Green Dragon to date.

The Green Dragon Standard offers an environmental management system

relevant to the specific needs of any organisation, large or small in the UK or

Republic of Ireland. Green Dragon is a stepped approach aimed at simplifying

the approach to implementation of environmental management systems

(www.greendragonems.com).

The standard is made up of five steps each incorporating the key elementsof Planning, Taking Action, Checking Progress and Reviewing Achievements

to realise continual environmental improvement. Some organisations may

progress through each of the steps until they reach level 5. However, an

organisation can enter the process at a suitable level and can remain at

whichever level is most appropriate.

Organisations achieving Green Dragon feature on a register of certified

companies. The register is a resource – similar to that maintained by IEMA of

organisations registered under EMAS and the Acorn scheme – which enables

quick validation of an organisations claim to hold valid certification

In-Brief

There are five main recognised standards or schemes in relation to

environmental management.

ISO 14001 International Standard for Environmental Management.•

Eco-Management and Audit Scheme (EMAS).•

IEMA Acorn Scheme•

BS8555:2003 Environmental Management Systems (developed as direct•

result of Project Acorn and adopted as a British Standard).

Green Dragon (Arena Network).•

Figure 6 Green Dragon

The Five Steps

1 2 3 4 5Commitment to

Environmental

Management

Understanding

Environmental

Responsibilities

Managing

Environmental

Impacts

Environmental

Management

Programme

Continual

Environmental

Improvement


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E M

A S

I S

O 1 4 0 0 1

B S 8 5 5 5 : 2 0 0 3 / I E M A A c o r n S c

h e m e

G r e e n D r a g o n

E n

v i r o n m e n t a l P o l i c y

E n v i r o n m e n t a l P o l i c y

P h a s e 1 C o m m i t m e n t a n d

E s t a b l i s h i n g t h e b a s e l i n e

S t a g e 1 G a i n i n g T o p M g t C o m m i t m e n t

S t a g e 2 B a s e l i n e A s s e s s m e n t

S t a g e 3 D e v e l o p i n g d r a f t

e n v i r o n m e n t a l p o l i c y

S t a g e 4 D e v e l o p i n g e n v i r o n m e n t a l

i n d i c a t o r s

S t a g e 5 D e v e l o p i n g d r a f t

e n v i r o n m e n t a l m a n a g e m e n t s

y s t e m

i m p l e m e n t a t i o n p l a n

A u d i t

S t e p 1 C o m m i t m e n t t o

e n v i r o n m e n t a l m a n a g e

m e n t

R e s p o n s i b i l i t y

E n v i r o n m e n t a l R e v i e w

E n v i r o n m e n t a l P o l i c y

E n v i r o n m e n t a l M o n i t o r i n g

I m p r o v e m e n t P l a n

E n

v i r o n m e n t a l R e v i e w

P l a n n i n g

E n v i r o n m e n t a l a s p e c t s

L e

g a l & o t h e r r e q u i r e m e n t s

O b j e c t i v e s t a r g e t s a n d p r o g r a m m e s

P h a s e 2 I d e n t i f y i n g a n d e n s u r i n g

l e g a l a n d o t h e r r e q u i r e m e n t s

S t a g e 1 I d e n t i f y L e g a l R e q u i r e m e n t s

S t a g e 2 I d e n t i f y ‘ o t h e r ’ r e q u i r e m e n t s

S t a g e 3 C h e c k i n g c o m p l i a n c e

S t a g e 4 O n g o i n g c o m p l i a n c e

S t a g e 5 D e v e l o p i n g c o m p l i a n c e

i n d i c a t o r s

A u d i t

S t e p 2 U n d e r s t a n d i n g e n v i r o n m e n t a l

r e s p o n s i b i l i t i e s

R e g i s t e r o f l e g a l & ‘ o t h e r ’ r e q u i r e m e n t s

M a n a g i n g l e g a l r e q u i r e m e n t s –

e m e r g e n c y p r e p a r e d n e s s

C o m m u n i c a t i o n a n d c o m p e t e n c e

E n v i r o n m e n t a l r e c o r d s

E n

v i r o n m e n t a l P r o g r a m m e

I m

p l e m e n t a t i o n a n d o p e r a t i o n

R o l e s , r e s o u r c e s , r e s p o n s i b i l i t y a n d

a u

t h o r i t y

C o m p e t e n c e , t r a i n i n g a n d a w a r e n e s

s

C o m m u n i c a t i o n

D o c u m e n t a t i o n

C o n t r o l o f d o c u m e n t s

O p e r a t i o n a l C o n t r o l

E m e r g e n c y p r e p a r e d n e s s a n d

r e

s p o n s e

P h a s e 3 D e v e l o p i n g o b j e c t i v e s ,

t a r g e t s a n d p r o g r a m m e s

S t a g e 1 E v a l u a t i o n o f e n v i r o n m

e n t a l

a s p e c t s a n d i m p a c t s

S t a g e 2 F i n a l i z i n g t h e e n v i r o n m e n t a l

p o l i c y

S t a g e 3 D e v e l o p i n g o b j e c t i v e s

a n d

t a r g e t s

S t a g e 4 E s t a b l i s h i n g i n d i c a t o r s

f o r e n v i r o n m e n t a l p e r f o r m a n c

e

e v a l u a t i o n

S t a g e 5 D e v e l o p i n g t h e e n v i r o

n m e n t a l

m a n a g e m e n t p r o g r a m m e

S t a g e 6 D e v e l o p i n g o p e r a t i o n a l

c o n t r o l p r o c e d u r e s

S t a g e 7 L a u n c h e n v i r o n m e n t a l p o l i c y ;

o b j e c t i v e s ; t a r g e t s a n d i n d i c a t o r s

A u d i t

S t e p 3 M a n a g i n g e n v i r o n m e n t a l

i m p a c t s

R e g i s t e r o f e n v i r o n m e n t a l a s p e c t s

E v a l u a t i o n & c o n t r o l o f e n v i r o n m e n t a l

a s p e c t s

P o l l u t i o n p r e v e n t i o n p l a

n

O b j e c t i v e s a n d t a r g e t s

M o n i t o r i n g e n v i r o n m e n

t a l

p e r f o r m a n c e

C a r b o n d a t a c o l l e c t i o n

E n v i r o n m e n t a l s t a t e m e n t

E x t e r n a l c o m m u n i c a t i o n

S u m m a r y T a b l e : C o m p a r a t i v e A n a l y s i s o f t h e m a i n s t a n d a r d s

F o r t h e p u r p o s e s o f t h i s a n a l y s i s B S

8 5 5 5 a n d A c o r n a r e t a k e n t o g e t h e r


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21


E M

A S

I S O 1 4 0 0 1

B S 8 5 5 5 : 2 0 0 3 / I E M A A c o r n

G r e e n D r a g o n

E n v i r o n m e n t a l M a n a g e m e n t

S y s t e m

P h a s e 4 I m p l e m e n t a t i o n a n d

o p e r a t i o n o f t h e e n v i r o n m e n t a l

m a n a g e m e n t s y s t e m

S t a g e 1 F i n a l i s e m a n a g e m e n t

s t r u c t u r e a n d r e s p o n s i b i l i t i e s

S t a g e 2 T r a i n i n g , a w a r e n e s s a n

d

c o m p e t e n c e , p l a n s a n d r e c o r d s

S t a g e 3 E s t a b l i s h i n g a n d m a i n t a i n i n g

f o r m a l c o m m u n i c a t i o n

S t a g e 4 D o c u m e n t a t i o n a n d r e

c o r d

k e e p i n g

S t a g e 5 R e v i e w i n g a n d t e s t i n g

e m e r g e n c y p r e p a r e d n e s s a n d

r e s p o n s e

S t a g e 6 D e v e l o p i n g i n d i c a t o r s

o f t h e

e n v i r o n m e n t a l m a n a g e m e n t s y s t e m

A u d i t

S t e p 4 E n v i r o n m e n t a l m

a n a g e m e n t

P r o g r a m m e

T r a i n i n g

E n v i r o n m e n t a l m a n u a l

C o n t r o l o f d o c u m e n t s

S y s t e m p r o c e d u r e s

S y s t e m m o n i t o r i n g

C a r b o n d a t a c o l l e c t i o n

E n v i r o n m e n t a l A u d i t C y c l e

C h

e c k i n g

M o n i t o r i n g a n d m e a s u r e m e n t

E v

a l u a t i o n o f c o m p l i a n c e

N o n c o n f o r m i t y ; c o r r e c t i v e a c t i o n a n d

p r

e v e n t i v e a c t i o n

C o

n t r o l o f r e c o r d s

I n t e r n a l a u d i t

P h a s e 5 C h e c k i n g ,

a u d i t a n d r

e v i e w

S t a g e 1 E s t a b l i s h i n g a u d i t

p r o g r a m m e s

S t a g e 2 C o r r e c t i n g n o n c o n f o r m a n c e s

a n d t a k i n g p r e v e n t i v e a c t i o n

S t a g e 3 M a n a g e m e n t r e v i e w

S t a g e 4 I m p r o v i n g e n v i r o n m e n

t a l

p e r f o r m a n c e

S t a g e 5 I m p r o v i n g t h e e n v i r o n

m e n t a l

m a n a g e m e n t s y s t e m

A u d i t

S t e p 5 C o n t i n u a l e n v i r o

n m e n t a l

i m p r o v e m e n t

I n t e r n a l a u d i t p r o g r a m m

e

M a n a g e m e n t r e v i e w

A d d r e s s i n g s u s t a i n a b i l i t y

S u p p l y c h a i n

R e d u c i n g g r e e n h o u s e g a s e m i s s i o n s

E n v i r o n m e n t a l r e p o r t

E n v i r o n m e n t a l S t a t e m e n t

M a n a g e m e n t r e v i e w

P h a s e 6 E n v i r o n m e n t a l m a n a g e m e n t

s y s t e m

a c k n o w l e d g e m e n t :

P r e p a r i n g f o r E M A S R e g i s t r a t i o

n o r

P r e p a r i n g f o r I S O 1 4 0 0 1 A s s e s s m e n t

V a l i d a t i o n ( i n d e p e n d e n t

v a l i d a t i o n o f t h e e n v i r o n m e n t a l

s t a

t e m e n t , a n d t h e r e f o r e o f

e n v i r o n m e n t a l p e r f o r m a n c e )


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2.3 Accreditation

The UK Picture

In the UK, the United Kingdom Accreditation Service (UKAS) performs

the accreditation function for ISO 14001:2004 certification bodies, EMASverifiers and IEMA Acorn inspection bodies. Accreditation criteria and

guidance is developed at an international level by organisations such as the

International Accreditation Forum (IAF) and accreditation bodies are required

to comply with BS EN ISO/IEC 17011:2004 “Conformity assessment – General

requirements for accreditation bodies accrediting conformity assessment

bodies”. Certification assessments are carried out according to international

standards and guidelines, such as EA 7/02 (IAF, 2003). It is of particular note

within the context of Northern Ireland that the Irish National Accreditation

Board operates as the UKAS equivalent in the Republic of Ireland: they, along

with UKAS co-operate with one another and European wide accreditation

bodies ensuring that a multilateral agreement applies to the recognition of

accredited certificates.

The Accreditation Process:

Accreditation BodyBS EN ISO/IEC 17011: 2004

United KingdomAccreditation

Service (UKAS)

CERTIFICATION BODIES(CAB)BS EN ISO/IEC 17021:2006

Certification BodyAuditors





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While in order to accredit conformity assessment bodies (CABs), the

Accreditation body e.g. UKAS, must meet the requisite standards (detailed

above) – the CABs (or Certification Bodies {CBs}) must in turn comply with an

international standard - BS EN ISO/IEC 17021:2006 “Conformity assessment

- Requirements for bodies providing audit and certification of management

systems”. To apply for accreditations to certify organisations, the CAB mustseek approval from UKAS (in the UK) to conduct the certification to the

defined ‘scope’. Individual auditors working on behalf of the CAB must also

have the competence to carry out this certification and they will also be

subject to individual approvals by UKAS.

UKAS accreditation underpins the validity of testing, inspection, calibration

and certification activities including those relating to: air, soil and water

quality, the development of renewable energy sources, environmental

management systems and energy efficiency. UKAS is the sole national

accreditation body recognised by UK Government to assess, against

internationally agreed standards.

Accreditation on an International Scale

In most developed economies there are bodies similar to the United

Kingdom Accreditation Service. Were these to operate only national

accreditation systems, barriers to trade would be accentuated. Instead,

however, they have set up international accreditation infrastructures to

facilitate the acceptance of goods for import and export across international

borders. In order that these can work, the national accreditation bodies

agree the elements of mutually acceptable international accreditation

systems, develop the necessary technical detail for these to have integrity,

and operate peer evaluation so as to confirm the basis for acceptance of

accredited results worldwide (www.ukas.com).

UKAS is a member of three international accreditation organisations:

International Laboratory Accreditation Cooperation (ILAC)•

International Accreditation Forum (IAF)•

European cooperation for Accreditation (EA)•

UKAS represents the UK Government in these international organisations

and, generally through these, negotiates mutual recognition arrangements

with other overseas accreditation bodies. The international functions are

undertaken on behalf of Government and are supported by the Department

of Trade and Industry. The international recognition of UKAS as a signatory

to multilateral agreements enables government to use accredited bodies to

meet its obligations under world trading agreements such as those deriving

from EU Directives and the World Trade Organisation’s Agreement on

Technical Barriers to Trade.

EA-7/04: Legal Compliance as a part of Accredited ISO 14001: 2004

certification.

The European Co-operation for Accreditation (EA) is the European Network

of nationally recognised accreditation bodies operating within the European

region. Including organisations such as UKAS and INAB - all members mustbe able to demonstrate compliance with the applicable standards, and are


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subject to peer review.

EA-7/04 was produced by a working group within the EA with the purpose

to “provide useful information on the relationship between an organisation’s

accredited Environmental Management System (EMS) certification according

to ISO 14001:2004 and that organisation’s degree of compliance withapplicable environmental requirements” (EA, 2007). The document provides

a summary of the areas within the system and of the auditing process

(internal and external) which should serve to ensure and demonstrate

compliance with applicable environmental legislation.

The main purpose of EA-7/04 is to provide clarification over the issue

of whether the implementation and maintenance of an EMS enhances

environmental performance, and therefore can lead to a relaxation in

regulatory oversight, by focusing on the issue of legal compliance. As such, it

has become the benchmark tool regarding legal compliance for certification

bodies which via accreditation through UKAS, fall under its remit.

EA-7/04 defines legal compliance as “full implementation of applicable

environmental legislation. Compliance occurs when requirements are met

and desired changes are achieved” (IMPEL, 1992); and goes on to state that

legal compliance “with respect to the interface between the organisation

and the environmental regulators can be understood as the situation

when no reactive enforcement actions are made or can be expected by the

organisation” (EA, 2007).

The issue remains, however, as to what extent certification of an EMS can

and does demonstrate legal compliance, and the European Co-operation

for Accreditation assert that while “certification of an EMS against the

requirements of ISO 14001:2004 is not a guarantee of compliance” they addthat “neither is any other means of control, including…legal compliance

inspections, {but} it is a proven and efficient tool to achieve and maintain

such legal compliance” (EA, 2007)).

EA-7/04 specifically states that “any organization failing to demonstrate their

initial or ongoing commitment to legal compliance…shall not be certified or

continued to be certified… [and] deliberate or consistent non-compliance

shall be considered a serious failure to support the policy commitment to

achieving legal compliance and should preclude certification or cause an

existing ISO 14001 certificate to be suspended or withdrawn” (EA, 2007)

The issue regarding whether the system ensures compliance is further

complicated by the assertion that it is not the role of certification body

auditors to make a direct evaluation of legal compliance, but it is the role

of the organisation, and a function of the EMS to be able to demonstrate

compliance status.

Within the section on “Compliance Criteria for the Certification decision”,

there are three important clauses:

1) “The organisation should be able to demonstrate that it has achieved

compliance with environmental legal requirements through it ’s own

evaluation of compliance prior to the certification body grantingcertification”


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2) “Where the organisation may not be in legal compliance, they should

be able to demonstrate a documented agreement with the environmental

regulator on a plan to achieve full compliance. The successful

implementation of this plan should be considered as a priority within the

management system”

3) “Exceptionally the certification body may still grant certification but shallseek objective evidence to confirm that the EMS is capable of achieving

the required compliance once the above documented agreement is fully

implemented”

In summary, this document has become the benchmark assessment tool

with respect to legal compliance for both certification bodies as well as

for the Accreditation body (e.g. UKAS). The document stresses throughout

that assessors are not inspectors of the environmental regulator, and should

not provide statements or declarations of legal compliance, but that they

verify the evaluation of legal compliance and that whilst ISO 14001 cannot be

an absolute and continuous guarantee of legal compliance, neither can any

legal scheme. The EMS provides a framework whereby compliance can beassessed and achieved consistently, and provides the support for continual

improvement of the organisations environmental performance.

Confidence in Accreditation

UKAS sought to bolster confidence in UKAS-accredited EMS via a review

of the EMS accreditation processes. The assessment process is conducted

in a more robust and challenging manner, scrutinising the assessment

methodologies of EMS certification bodies in greater detail. The transition

from the current accreditation standard ISO / IEC Guide 66:1999(E) to a new

International Standard ISO / IEC 17021:2006 (see pgs. 36-37) in tandem with

EA-7/04 places greater emphasis on the impartiality of the certificationprocess and the competence of all certification body personnel, managers,

administrators and auditors. Certification bodies face significant work to

demonstrate to UKAS that their processes meet the requirements of the

standard by the transition deadline of 15 September 2008. UKAS has

recognised that the ability to provide feedback plays an important role in

maintaining confidence in the integrity of EMS. Consequently, each UKAS-

accredited certification body is required to have a complaints procedure and

make this information available to its clients. Additionally, EMS certification

holders can make customer feedback to UKAS directly and these matters

are managed with strict confidentiality. The International Standard ISO

14001:2004 and the EMAS Regulation (EC No 761 / 2001) are also under

revision, which presents an ideal opportunity to direct the purpose of the

standards. UKAS has a clear voice in the revision process through its roles

on the relevant British Standards Institution Committee and the Forum

of Accreditation Bodies established by the European Commission. Other

avenues for UKAS to influence the development of accreditation guidance

include involvement in the European Cooperation for Accreditation and

the International Accreditation Forum. The UKAS EMSAC (Environmental

Management Systems Advisory Committee) provides one of the main

opportunities for engagement in EMS accreditation. UKAS also continues to

work closely with IEMA, Defra and the regulators, such as the Environment

Agency and the Scottish Environment Protection Agency, to enhance the

value of accreditation at a government level.


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2.4 Certification of EMS’s

“Defra believes that a robust and effective EMS should be externally audited

to a recognised international or national standard by a Certification Body

accredited by the United Kingdom Accreditation Service (UKAS)” (Defra

Positioning Statement April 2008), with the view that accredited thirdparty certification is important to realise many of the benefits of an EMS.

Companies with an accredited certified EMS are given greater recognition

by the Environment Agency under Integrated Pollution and Prevention

Control (IPPC) and some other regulatory regimes. Accredited certification

means that organisations can demonstrate to shareholders, regulators

and the public that their system has been audited, in the same way as are

their financial accounts, by those with appropriate professional skills, and

knowledge. The information provided by a certified system is often seen as

being more credible and reliable.

The Scottish Environmental Protection Agency in their position statement

has stated support for EMS and believes that they can “benefit thecompany and the environment and assist companies in understanding how

environmental law applies to their site, products and operations”. However,

at the time of publication (prior to remas) they were unconvinced that

EMS had a sufficiently positive impact upon: permit compliance, frequency

of incidents, and numbers of public complaints. They stated that if, as a

regulator, they were to consider provision of financial incentives (such as

available via the Environment Agency’s Opra scheme) they would have to be

provided with “a clear case to the contrary” (SEPA, 2004)

Certification is the process by which an organisation’s system (e.g. its EMS)

is assessed for its conformity to the requirements of a standard (e.g. ISO

14001:2004). Certification Bodies (CBs) may be accredited to perform suchassessments where they meet the criteria in ISO/IEC Guide 66 (ISO, 2003) or

ISO/IEC 17021:2006 (from September 2008).

Accreditation bodies check on a regular basis via surveillance at the CB’s

offices, witnessed assessments at their client’s sites and other activities that

certification bodies are capable of providing accredited certification. Similar

processes are operated to accredit environmental verifiers to carry out

verification under EMAS, including the validation of EMAS environmental

statements, and IEMA Acorn inspection bodies.

Accredited CBs are bound by the requirements under which they operate

to maintain confidentiality. They must have arrangements to safeguard

the confidentiality of the information they obtain in the course of their

certification activities, including on-site audits. CBs cannot disclose

information to a third-party about the organisation that has been certified

without the written consent of that organisation. If there are circumstances

where the law requires information to be disclosed, then the CB must inform

the organisation beforehand of the information that they have been required

to provide.


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There are different types of audits that are required within an EMS and that

usually make up an organisations audit programme. These are a combination

of:

1st Party - An audit performed within an organisation by the•

organisation’s own auditing resource. Also referred to as an internal

audit.2nd Party - Audits of contractors/suppliers undertaken by or on behalf•

of a purchasing organisation. This may include the assessment of

companies or divisions supplying goods or services to others within the

same group.

3rd Party - Audits of organisations undertaken by an independent•

certification body or registrar or similar third party organisation.

Purpose of certification

Third-party certification assessment provides an independent appraisal of

a management system. The assessment is designed to determine whether

or not an organisation satisfies the requirements of the relevant clauses ofthe standard. It will involve preparation, a review of documentation, on-site

audit and a consideration of audit reports. It also includes other activities

such as a site tour and staff interviews at all levels within an organisation.

On completion of an assessment, a CB should have sufficient information

to enable a decision on the grant of certification to be made. An important

element of the certification and verification process is that, in addition to

evaluating whether the system elements have been implemented, the

assessor will determine whether the organisation is capable of running the

system and improving it in the future. As such, the award of an accredited

ISO 14001:2004 certificate or EMAS registration indicates an organisation’s

ongoing commitment to legal compliance and gives some indication of its

capability to comply in the future. The certification and verification processwill also determine the extent to which the organisation has set objectives

and targets, instigated improvement programmes, and how well they

are linked to its legal compliance and performance improvement policy

commitments. The IEMA Acorn Scheme uses accredited inspection, rather

than accredited certification, for determining whether an organisation has

met the scheme’s requirements. The reason for this is that the certification

standards used by accreditation bodies can only be used for assessing

organisations that have a fully implemented and functioning system;

organisations using the IEMA Acorn Scheme will not have all the system

elements implemented in the earlier phases, hence the use of inspection

standards.

EMAS Registration

(www.iema.net)

The route to EMAS begins with a document review normally conducted

on site to meet accreditation requirements for ISO 14001, and an on-site

verification audit and validation of the environmental statement. The

process is illustrated in Figure 7. As a first step, the verifier ensures that an

EMS has been implemented according to the requirements of Annex 1 of

the EMAS Regulation. The process of verification of the EMAS management

system is essentially similar to that for ISO 14001:2004 as described above

except for the additional environmental statement, although there is alsoadditional emphasis on legal compliance and environmental performance


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improvement (www.iema.net).

Statement validation: when the requirements of the EMAS Regulation have

been adequately addressed by the organisation, the verifier checks the

accuracy and adequacy of the statement and, once satisfied, confirms (or

‘validates’) it by signing and dating each page and counter-signing the finalpage of the statement. The statement is then forwarded to the verification

body along with the report. Importantly, the verifier shall not validate the

environmental statement if during the verification process he/she finds

through spot-checks that the organisation is not in legal compliance.

Statement amended by verifier: when the requirements in the EMAS

Regulation have not been fully addressed by the organisation, the verifier

issues corrective actions or nonconformities and the organisation then

amends the environmental statement as necessary. The verifier agrees a

timescale for the revised statement to be forwarded for validation once the

changes have been made.

Statement reviewed: the statement will be reviewed by the verification

body and the original signed statement is returned to the organisation.

The organisation can then apply for EMAS registration with the appropriate

competent body by completing the application form and enclosing

the appropriate fee. The competent body in the U.K. is the Institute of

Environmental Management and Assessment. The organisation should also

forward a copy of the final printed version of the environmental statement to

the verification body.

Verification frequency: following EMAS registration, the verifier ensures that

all elements required to maintain EMAS registration are verified in a period

not exceeding 36 months. This is usually through a surveillance programmeof a visit every 12 months in the 36 month period. In addition, any updated

information on the environmental statement is validated at intervals not

exceeding 12 months. In smaller organisations, the verification may take

place in one visit, at a frequency to be agreed between the verifier and the

organisation. Even so, the whole system must be verified at least every 36

months. Deviations from the frequency with which updates are performed

can be made in certain circumstances.

Figure 7 EMAS registration processSource: IEMA Vol 6 Legal Compliance


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staff at all levels, examination of documentary evidence and observation

of tasks being carried out – it is at this stage that any deviation from

procedures or the requirements of the standard is noted by the assessor

– these ‘non conformances’ are discussed with the organisation which is

given an opportunity to challeng