Introduction

Worldwide political pressure and public concern over environmental issues, is forcing many governments to react and introduce legislation to try and improve the legacy this generation leaves behind for the next. The momentum is gathering and these issues will not evaporate with time, they are here to stay. Global warming, ozone depletion, groundwater pollution and rapid depletion of the Earth’s natural resources are all high on the global political agenda. . Industry will have to insulate against the growing tide of opinion, and make itself less vulnerable to the predatory politicians.

ISO 14001 is an internationally recognized standard through which an organization can demonstrate an advanced level of competence in managing the environmental impacts of its activities and processes. Company’s aspiring to achieve certification to the standard, must fulfil the demanding criteria of its six elements.

A browse through the ISO 14001 standard will undoubtedly leave one with a sense of déjà vu, indeed, this is entirely intentional, as the standard was designed to fully compliment ISO 9002, its quality cousin. Although there are familiar rings to the technology and disciplines of a quality system, implementation of an environmental management system is appreciably different in approach.

I can now share the experiences of designing and implementing an EMS, from the very beginning, right through to successful accreditation to ISO 14001, a process taking slightly more than eighteen months to complete.

Where To Start

If you do decide that this is just what your organization needs, start at the beginning and plan your way to success, spending time now will pay dividends as you move forward. Look at how your company is structured and appreciate any areas of weakness; where are you most likely to encounter difficulties when planning organizational changes? The end result will only be successful if it is complimentary to existing business practices; to contemplate major changes will almost certainly lead to failure. So work at integrating your EMS into the current set-up, and create the least amount of inconvenience to people, it does work, trust me!

Produce a strategic implementation plan outlining what resources are required to develop the EMS, this would almost certainly involve a gap analysis, and should clearly indicate how the system will be supported in terms of human, financial and technical resources. At this stage it is worth exploding one myth at least, and that is that companies should not be put off simply because they believe that they would be disadvantaged, perhaps due to the hazardous nature of their particular business. A company does not have to solve all its environmental problems in order to get certification to ISO 14001. Recognition of its major problems, and the introduction of management controls to reduce the significance of their environmental impacts, is what an accreditation body is looking for initially, followed by a progressive plan of further improvements to reasonable and practicable levels.

The Planning Process

Although not an assessable element of the standard, a thorough, preparatory site review is essential in order to establish precisely where your company currently stands. Take plenty of time with the review, Assessors will be impressed with a thorough investigation and a sound platform from which your EMS has been developed.

Your review should broadly cover the following key areas: -

Site history and geographical setting

Hydrology and hydrogeology

Use of raw materials and substances

Energy and water usage

Detailed evaluation of all direct and indirect site activities

Analysis of waste

Evaluation of any emissions to air or discharges to water

Complaints from local authorities, neighbors or employees,

Drainage maps

Site plans and perhaps an analysis of the sub-soil if there is any possibility that your site’s activities have lead to contamination of the land.

Your review should also include a thorough examination of all the environmental legislation that could affect, either directly or indirectly, your company’s activities. There are several excellent sources from which this kind of information can found, such as the Environmental Technology Best Practice Program, The Environment Agency, The Scottish Environmental Protection Agency and various Trade Associations. One important thing worth remembering is that compliance with all relevant legislation is a pre-requisite to achieving accreditation to ISO 14001, as a minimum your company must operate within the law.

The investigation does not have to have a scientific bias, nor does it have to contain a high degree of detail. It should however, contain enough information to provide prospective readers with an accurate and balanced account of the interaction between the site’s activities and processes, and the environmental issues you are endeavoring to address.

Once you have completed the process of gathering relevant information, you need then to consider how to summarize it, and consolidate your facts and figures into a report. In my experience, the most effective way has been to evaluate the company by department or function, against the same criteria. This option provides an alternative perhaps, to looking at the company as a whole, and trying to determine varying degrees of significance for emissions to atmosphere, discharges to foul or surface drains and waste disposal etc. The reasons for this approach will become more apparent later, but the result will allow a smoother interface when you consider setting objectives and targets.

I think it is probably appropriate that we clarify a couple of things here, and that is the difference between environmental “aspects” and “impacts”. An aspect is any activity, operation or service provided or performed at your company, which does or has the potential to, affect the environment in either a positive or a negative way. An impact is the way in which the activity, operation or service affects the environment. For example the transport of a 20 ton load of wooden pallets from Manchester to London, may be described as an environmental aspect of one particular company’s operation. The impact of this aspect could be evaluated in the following way: – 20 tons of wood contributes to the depletion of the earth’s finite, natural resources (albeit in a small way), the burning of vehicle fuel involving emissions of CO2, CO, NO, SO, smoke, dust and particulates and noise pollution. There would almost certainly be a legislative issue to consider with respect to the vehicles condition and exhaust emissions.

Evaluation of Environmental Impacts

At this point, you should have a fairly detailed description of the environmental aspects of your organization, conveniently evaluated by department. The job now is to convert the data into an objective appraisal, and this can be done with numbers. The benefit of taking a slightly longer route initially, and assessing all environmental aspects by department, should now pay off.

For every aspect identified at your company, you must consider the environmental impacts, and this is best achieved using a pre-determined set of criteria, including emissions to atmosphere, discharges to sewer or controlled waters, contamination of the land, associated issues of waste production and disposal, types and volumes of substances used in your process, storage and handling requirements, fuel and energy consumption, types and volumes of raw materials used, transport and shipping, current controls. It is also essential that you consider all relevant, environmental legislation relating to all your company’ activities, and to include this in your assessment of the impacts.

Devise a scoring system that can be applied uniformly, then look at the environmental impacts, awarding collective scores for each department. Use a hierarchy of criteria to base your scores, for example any activity that is covered by legislation would score highly, due to the potential consequences of failing to comply with the law; consider the actual or potential level of environmental damage e.g. toxicity, greenhouse gas emissions, ozone depletion; what would be the reaction of interested parties such as local residents, neighboring companies, employees, shareholders, environmental interest groups and enforcement agencies; what quantities are used and what is the frequency of use/discharge etc.

Use three categories to classify the severity of the actual or potential impact; Only slight or temporary environmental impact or deterioration in environmental quality; Some deterioration and/or public concern in environmental quality, such as noise, smoke, odors and emissions; High risk to environmental quality and/or public safety, potential/actual breach of legislation.

Use three similar categories to determine the likelihood of occurrence; Activity or aspect is well controlled by documented procedures, monitors are in place which result in the likelihood of an incident occurring is relatively low; Activity is under general control although documented procedures are not in place, there is some history of incidents occurring on a regular basis, and these are not always brought under control quickly resulting in noticeable environmental damage; Activity has no formal controls in place, resulting in a frequently volatile process with the potential to cause serious and possibly irreversible environmental damage.

Finally, and again with the use of three categories, determine the likelihood of failure associated with each impact; Controls in place will almost certainly detect a failure almost immediately, and in time to prevent any serious or lasting environmental damage; Controls may detect a failure, but are unlikely to prevent some environmental damage on each occasion of failure; Controls have little or no chance of detecting failure and would virtually never prevent releases to the environment, resulting in serious and lasting environmental damage.

Each impact would have to be evaluated against these criteria, under two, separate sets of circumstances; normal operating conditions, and abnormal operating condition. The eventual scores awarded under each set of operating conditions would be aggregated to give a total environmental impact rating, which would then determine the degree of significance for each of your identified environmental impacts. Develop a threshold for your points scoring system, and any impacts awarded scores greater than the threshold, would qualify for improvement project status, and be automatically included in the Management Improvement Program.

Based on the scores you award, and your company’s resources and ability to take corrective actions, produce a register of your significant environmental impacts. The results of this exercise, and your subsequent appraisal of those impacts, is entirely dependent upon the activities of your organisation, and the controls in place to reduce their significance. However, you should, at this stage, be able to produce an objective evaluation of how your company’s activities impact on the environment.

The Improvement Process

This is a good time to start thinking about developing an environmental policy statement, which must be appropriate and scaled according to the size and complexity of the business. It should be endorsed by a senior member of the management team, preferably the Managing Director, and include certain commitments to eliminating and/or reducing environmental pollution. Your policy must also make unambiguous references to continuous improvement and outline your objectives and targets, be available to the public, and subject to regular reviews.

The next step is to consider the development of a series of objectives and targets, based on your evaluation of significant environmental impacts. Providing that you have maintained the theme of evaluating all your significant impacts by department, your Register of significant Environmental Impacts, should be a descending list rating each department on its overall potential to cause environmental damage.

This provides a logical and progressive platform for developing a series of improvement projects built around the departments with the highest overall impact rating. Your scoring system, and points awarded, can be compared against the threshold you have set, with those departments awarded the highest scores developed into projects, with targets set for improvement. Ownership of the improvement projects goes directly to the management team of that particular department, and there are no conflicts of interest. Project progress is reviewed on a quarterly basis, with each department head, and significance scores re-assigned according to what actions have been taken.

A management system provides the framework in which tangible and practical improvements can be made. Keep the whole thing simple, implementing only those procedures that are necessary to maintain the integrity of the EMS. Thoroughly develop the training and communication aspects of your system, and support this with a comprehensive set of procedures. You can have a technically sound environmental management system, but if little is known about it, or people are not trained in its disciplines, your time is wasted

Articles, Knowledge engineering
Environmental Impacts, environmental issues, Environmental Management System, hydrogeology, Hydrology, Worldwide political pressure