ems: expectations, experience and solutions
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EMS: Expectations, Experience and Solutions. Chris Howes Policy Manager - Compliance Assessment & Enforcement. Key Issues. Stakeholders expect EMS to deliver on compliance and performance The experience is that they: deliver for the operator don’t deliver for external stakeholders - PowerPoint PPT PresentationTRANSCRIPT
EMS: Expectations, EMS: Expectations, Experience and SolutionsExperience and Solutions
Chris Howes
Policy Manager - Compliance Assessment & Enforcement
Key IssuesKey Issues
• Stakeholders expect EMS to deliver on compliance and performance
• The experience is that they:
– deliver for the operator
– don’t deliver for external stakeholders
• We need to do more on: robustness, consistency, credibility and transparency
EMS and the Environment AgencyEMS and the Environment Agency
• Government Guidance
• Key part of modern, risk based regulation
• Recognised through risk assessment (OPRA) led inspection and charging schemes
• An EMS required under PPC (but not necessarily certified)
• Agency certified to ISO 14001
• EMAS - Article 6 and Article 10
Expectations?Expectations?
• EMSs should improve performance - environmental outcomes
• EMSs should reduce risk of legal non-compliance
• Sites with an EMS should be easier to regulate and lower risk
• Non-regulated aspect should also improve
Expectations - Accredited CertificationExpectations - Accredited Certification
• Accredited certified systems should:
– be more effective
– be challenged/tested/stretched
– take less regulation
– be more consistent
– have a base line of legal compliance
• Accreditation and certification bodies should take account of stakeholders
ENDS Report February 2003
ENDS Report March 2003
ENDS Report April 03
Experience?
Experience: Europe - MEPI StudyExperience: Europe - MEPI Study
• 270 firms, 430 sites analysed across Europe
• No positive relationship between certified EMS and improved performance
• Fossil fuel based electricity producers showed negative correlation
• source: www.environmental-performance.org.uk University of Sussex (SPRU)
Experience: USA - MSWG and UNCExperience: USA - MSWG and UNC
• 83 Facilities in 17 US States
• “ These results do not provide support for the proposition that an externally audited, ISO-certified EMS is associated with greater improvements in performance than uncertified facilities”
• No statistically significant change in compliance
National Database on EMS - University of North Carolina 2003
Experience:UK EA/Policy Studies InstituteExperience:UK EA/Policy Studies Institute
• Survey of 843 process industry sites and 2,200 waste sites
• Summary:
– Link between certified EMS & good procedures;
– Enforcement action just as likely at EMS sites;
– Waste sites with EMS perform worse than non-EMS waste sites
EMS and Operator Performance EMS and Operator Performance
Individual OPA attribute mean scores by type of EMS
22.5
33.5
44.5
5no EMS
ISO14001
EMAS/ISO
Enforcement Action (IPC)Enforcement Action (IPC)
Comparative EMS uptake
0%
20%
40%
60%
80%
no EMS ISO14001 ISO/EMAS
Sites subject toenforcement
All sites
EMS and Performance (Landfills)EMS and Performance (Landfills)
4.1
3.2
0.8
0
1
2
3
4
5
ISO 14001 / EMAS EMS no EMS
(High score is associated with worse performance)
Decision timeDecision time
• Does a certified EMS imply a baseline of compliance?
• Or is it just an indicator of intent?
• No rewards for good intentions though!
Improving the value of certificationImproving the value of certification
• Clarify roles of accreditation and certification bodies - and regulators
• Stronger accreditation/certification requirements
• Better communication (including complaints handling)
Improving the value of certificationImproving the value of certification
• Clarify roles a responsibilities on assessing legal compliance:
– guidance on assessment
– what stakeholders expect
– grading non-compliance with legislation
– communication on non-compliance
Improving the value of certificationImproving the value of certification
• Stronger requirements and interpretation
– understanding legal requirements
– periodic evaluation of legal compliance
– legal compliance as a minimum standard
– increase focus on outcomes
Improving the value of certificationImproving the value of certification
• Communications:
– dealing with complaints
– dialogue on non-compliance
– ongoing dialogue UKAS/CBs/ with Regulators and Industry
REMASREMAS
A pan European project that examines the value of environmental management systems
in the context of regulation
Who is involved?Who is involved?
• The Environment Agency
• Scottish Environmental Protection
Agency
• Irish Environmental Protection Agency
• Institute of Environmental Management
& Assessment
remaslinking environmentalmanagement andperformance
www.remas.info
MethodsMethods
Gathering of other evidenceremas 4
Assessment of regulatory duplication/facilitation
remas 3
Site based improvement over time based on emissions data
remas 2
Pan-European multi-sector benchmarking study
remas 1
Process & timescalesProcess & timescales
BY END OF MAR 03
JAN - MAY 2003
JUNE 03 -JULY 04
DEVELOP &
PILOT
Company
recruitment & training
Data collection & analysis
DISCUSSION, DISSEMINATION & CONSENSUS BUILDING
Establish
REMAS
Criteria
Demonstrate
mechanisms
SEPT 04 -SEPT 05
JULY - SEPT 2004
Links and contactsLinks and contacts
• REMAS: martyn.cheesbrough@ environment-agency.gov.uk
• www.remas.info
• REMAS project, Environment Agency, Block 1 Government Buildings, Burghill Road, Westbury-on-Trym, BS10 6BF
• +44 (0) 7768 276947
Key IssuesKey Issues
• Stakeholders expect EMS to deliver on compliance and performance
• The experience is that they:
– deliver for the operator
– don’t deliver for external stakeholders
• We need to do more on: robustness, consistency, credibility and transparency