1

“IED-IRAM Inspection Programme”

Environmental inspections of industrial installations in accordance with the Industrial

Emissions Directive (IED) – Drawing up of IRAM related inspection programmes

Final report

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Introduction to IMPEL

The European Union Network for the Implementation and Enforcement of Environmental Law (IMPEL) is an

international non-profit association of the environmental authorities of the EU Member States, acceding and

candidate countries of the European Union and EEA countries. The association is registered in Belgium and its

legal seat is in Brussels, Belgium.

IMPEL was set up in 1992 as an informal Network of European regulators and authorities concerned with the

implementation and enforcement of environmental law. The Network’s objective is to create the necessary

impetus in the European Community to make progress on ensuring a more effective application of

environmental legislation. The core of the IMPEL activities concerns awareness raising, capacity building and

exchange of information and experiences on implementation, enforcement and international enforcement

collaboration as well as promoting and supporting the practicability and enforceability of European

environmental legislation.

During the previous years IMPEL has developed into a considerable, widely known organisation, being

mentioned in a number of EU legislative and policy documents, e.g. the 6th Environment Action Programme

and the Recommendation on Minimum Criteria for Environmental Inspections.

The expertise and experience of the participants within IMPEL make the network uniquely qualified to work on

both technical and regulatory aspects of EU environmental legislation.

Information on the IMPEL Network is also available through its website at: www.impel.eu

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Title report:

IED-IRAM Inspection Programme

Environmental inspections of industrial installations in accordance

with the Industrial Emissions Directive (IED) – Drawing up of IRAM

related inspection programmes

Number report:

2013/08

Project manager:

Horst Büther

Report adopted at IMPEL General

Assembly: December 2013 – Vilnius,

Lituania

Authors:

Rob Kramers (InfoMil)

Horst Büther

Number of pages: 31

Report: 13

Annexes: 18

Project team

• Belgium: Jean-Pierre Janssens, Martine Blondeel, Roel Vaneerdeweg

• Cyprus Chrystalla Stylianou

• Czech Republic: Tomáš Augustin, Helena Neklolava

• Germany: Horst Büther, Hartmut Teutsch, Wulf Böckenhaupt

• Italy: Romano Ruggeri, Fabio Carella, Giuseppe Sgorbati

• Netherlands: Rob Kramers, Tony Liebregts

• Portugal Isabel Santana

• Romania: Florin Homorean

• Slovenia Vladimir Kaiser

Executive summary:

The main objective of IED-IRAM Inspection Programme project, executed in 2013, was to develop

applications helping to draw up inspection programs for IED inspections but also for other kinds of

inspection tasks. Based on IRAM data the inspection program shall be an internet tool that can be accessed

from the IMPEL website. The project group developed an overview on how an inspection programme should

look like. Most of these functionalities were realised within a further development of the IRAM internet

application. The remaining functionalities are still only available on an Excel application that was also

developed within the project. It is recommended implementing these functionalities into the IRAM web

application in following IMPEL projects.

Disclaimer:

This report is the result of a project within the IMPEL-Network. The content does not necessarily represent

the view of the national administrations or the Commission.

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Contents

Summary _________________________________________________________________ 5

1. Introduction ___________________________________________________________ 6

2. Inspection programme ___________________________________________________ 7

3. IRAM online tool ________________________________________________________ 8

4. IRAM Excel tool _________________________________________________________ 9

5. Results of the workshop in Malta __________________________________________ 10

6. Recommendations for future IMPEL work ___________________________________ 12

Annex I Functional Design of the IRAM online tool _____________________________ 13

Annex II Full description of the IRAM online tool _______________________________ 14

Annex III Full description of the IRAM Excel tool _______________________________ 15

Annex III Minutes of the meetings ____________________________________________ 16

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Summary

This is the final report of „IED-IRAM Inspection Programme” project.

The main objective of this project, executed in 2013, was to develop applications helping to draw up inspection

programs for IED inspections but also for other kinds of inspection tasks. Based on IRAM data the inspection

program shall be an internet tool that can be accessed from the IMPEL website.

The project group developed an overview on how an inspection programme should look like.

Mandatory issues are:

1. Defined time period of the program

2. Name of installations / identification numbers

3. Risk categories and related frequencies

4. Type of inspections (e.g. integrated etc.)

5. Dates of the last inspections

6. Dates of the next inspections (year, month)

Optional issues are:

7. Results of the last inspections (compliance)

8. Compliance records

9. Alert when dates have passed

10. Names or teams of inspectors or units

11. Inspection categories; inspection efforts

12. Amount of time needed for the inspections

13. Amount of staff needed for the inspections

14. Qualifications and/or skills needed

15. Equipment needed

16. Co-operation with other authorities needed

Most of these functionalities were realised within a further development of the IRAM internet application. The

remaining functionalities are still only available on an Excel application that was also developed within the

project. It is recommended implementing these functionalities into the IRAM web application in following

IMPEL projects.

Practitioners from 9 IMPEL member countries participated in the project team meetings and a workshop. The

objectives were delivered through the products described in this report. The recommendations for future

IMPEL work (chapter 6) and follow up activities are to be considered by Cluster I.

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1. Introduction

On 6 January 2011 the Industrial Emissions Directive entered into force, and its provisions listed in Article 80(1)

have to be transposed into national law within two years. The IED sets new requirements on the inspection of

industrial installations as described in Article 23 of the Directive. The obligations on routine environmental

inspections constitute a new challenge for the EU member states. IMPEL already has written a guidance book

within the IMPEL project IED Inspections.

After the obligations of the IED have been clarified and a guidance book has been written during the IED

Inspections project there is a further need to develop guidance on the development of inspection programmes

and to give advice on a possible IT tool for inspection programmes. The further aim of this project is to prepare

the storage and processing of risk assessment data to build up inspection programmes (schedules) as a follow

up of the easyTools project. The main objective of the latter, executed in 2010 and 2011, was to develop an

easy and flexible risk assessment tool as part of the planning of environmental inspections linked to European

environmental law (IED and SEVESO) and the RMCEI. Experts from 11 IMPEL Member countries formed the

project team, led by Germany. After collecting information on the risk assessments that are used across

Europe, a new rule based methodology was developed and tested, called Integrated Risk Assessment Method

(IRAM).

The risk assessment method IRAM is based on results of an evaluation of risk assessment tools currently used

in IMPEL member countries. The risk score of each impact criterion is directly related to the final risk category

and therefore to the inspection frequency. This guarantees that all environmental aspects with a high score get

the necessary attention. The risk itself is defined by impact criteria and operator performance criteria. They

represent the effect and the probability of the risk. Besides the methodology the project also developed a new

web based tool (IRAM tool) that is accessible from the IMPEL website (www.impel.eu).

The easyTools project team recommended to start a new project by IMPEL that could develop a tool for

drawing inspection schedules using an internet data base that will help the inspecting authorities in this

inspection planning phase. With this tool it will be easier for inspection authorities to decide on the setting of

IRAM steering parameters because the delivered effects can be seen directly on all assessed installations.

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2. Inspection programme

Article 23(4) of the IED requires that

competent authorities shall regularly

draw up an inspection programme

for routine environmental

inspections including the frequency

of site visits for different types of

installations. This inspection

programme should be based on the

inspection plan. Preparing an

inspection plan and inspection

programme is part of step 1D

(Planning and Review) in the

Environmental Inspection Cycle.

As can be seen in the figure the

information that is assessed and

developed in step 1a, 1b and 1c will

find its place within the inspection

plan. Please note that the inspection plan is not only for internal use, it also available for public and therefore

gives justification of what and how the inspecting authority is dealing with its responsibilities.

The inspection programme can be part of the inspection plan. The inspection plan however is publicly available.

Therefore the inspecting authority might want to decide to include the programme as an annex or separate

document. This way the programme can stay confidential.

The chapters of an Inspection plan could look this:

1. Scope of this inspection plan

2. The environment, activities and installations

3. Last years performance <optional>

4. This years planned performance

5. Overview of inspection activities for the coming year

For more information of what should be understood under the different chapter we direct you to the guidance

book for IED inspections.

During the project the participants discussed again the content of the Inspection programme (or schedule). The

team came with the following information:

• Defined time period of programme

• Name of installations / identification number

• Risk category and related frequency

• Type of inspection (e.g. integrated, waste etc)

• Time period of next inspection (date, month, year)

• Date of last inspection

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Next to this “mandatory” information above, the team also came with a list of items that could be seen as

optional for the inspection programme.

• Name or team of inspector(s) or unit

• Inspection category

• Amount of time and staff needed for the inspection

• Qualification / Skills needed

• Equipment needed

• Co-operation with other authorities needed

• Compliance history

• Address and contact data

• Inspection profile

Things to consider.

The outcome of a risk assessment (box 1b

Setting priorities) as it’s done in IRAM will

deliver a list with inspection objects and

their accompanying risk category and

inspection frequency. This information

could be imported directly into the

inspection programme.

Although the project team believes that this

action could be done for the low risk

inspection objects it stresses that for

inspection objects with a high risk step 1c should first be taken. This means that inspection targets and

inspection strategies will be defined for these inspection objects before developing an inspection programme.

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3. IRAM online Tool

Under the name ‘easyTools’ an IMPEL project collected information on the risk assessments that are used

across Europe. Based on this information a new rule based methodology was developed and tested,

called Integrated Risk Assessment Method (IRAM). Besides the methodology the project also developed a

new web based tool (IRAM tool) that can be accessed by the IMPEL website (www.impel.eu). As the method

works with flexible risk criteria and steering mechanisms it can be used for all kinds of inspections tasks

including IED, Seveso, TFS, and water as well as nature inspections.

Background

Since the beginning of its existence the IMPEL network is working on the improvement of inspection activities

of its member countries. Milestones of these activities were the publications of “Minimum criteria for

inspections” (1997-1999), “IMPEL Reference Book for Environmental Inspection” (1999) and “Step by step

guidance book for planning of environmental inspection” (2007). The work on the former publications resulted

in the European Union issue of the “Recommendation on minimum criteria for environmental inspections”

(RMCEI) in 2001 which on the other hand laid out the ground for the IMPEL guidance book. A key issue of the

RMCEI and the guidance book is the prioritisation of environmental inspections. An essential part of this

prioritisation is the assessment of the probability of environmental disruptions caused by industrial or

comparable activities. Such kind of risk assessment also plays a key role in inspection planning according to the

Industrial Emissions Directive (IED) and the Seveso III Directive.

Content in Brief

The availability of basic data for quantifying risk criteria differs largely between the member countries. This

implies that already existing risk assessment tools which require a specific fixed set of data do not fulfil the

needs of most member countries. As a consequence, nearly every competent inspection authority needs its

own specific set of risk assessment tools for different inspection tasks. Based on these conclusions the project

developed a new method and a flexible and user friendly application for environmental risk assessments. Each

inspection authority from every IMPEL member country can chose from a compilation or develop own risk

criteria to use them within the method for their own specific inspection tasks. To make it an easy tool the risk

assessment can be performed with an advanced interactive IT tool from the internet.

Key Points

Most risk assessment methods that are used across Europe use the average value of scored risk criteria. This

brings the disadvantage that high risks of some criteria are levelled out by low risks of other. To avoid this, a

new rule based methodology called Integrated Risk Assessment Method (IRAM) was developed that only takes

the highest risks of the scored criteria into consideration. The methodology is based on the following principles:

1. The inspection frequency is determined by the highest scores (and not by an average value)

2. The inspection frequency is reduced by one step, if the set minimum number of highest scores (called

“the Rule”) is not met

3. The inspection frequency can be changed by one step up or down depending on operator performance

4. The sum of criteria scores is related to the effort needed for an on-site inspection

The risk score of each impact criterion is directly related to the final risk category and therefore to the

inspection frequency. This approach guarantees that all environmental aspects with a high score will get the

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necessary attention. The risk itself is defined by impact criteria and operator performance criteria; they

represent effect and probability.

The new IRAM inspection programme

As a result of the project discussions the IRAM tool was upgraded as described in Annex I: Functional design of

the IRAM tool. The main new features are that there is now a data base on the internet where all risk

assessment data are stored. These data can be used again for recalculations without the need of an upload

from an external data base. Also the inspection frequencies and inspection dates of all inspection objects under

consideration can now be displayed in one table. All steering parameters changed by the responsible

inspection coordinator now have a direct effect on all open risk assessments carried out under this

coordination. Concerning data protection on the internet the names of the inspection objects are no longer

obligatory but optional. The identification of the objects is guaranteed by identification numbers. The internet

application and the data base are hosted by the German IT Agency of North-Rhine Westphalia with all

necessary measures of data safety and protection.

A detailed description of the internet application can be found in Annex II.

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4. IRAM Excel Tool

As in the easyTools project the first draft of the application for drawing an inspection programme was

developed on Excel basis. For budget reasons the internet application is still not equipped with all

functionalities of the Excel tool. These functionalities are:

• The numbers of non-compliance detected during the last inspection

• The different levels of non-compliance: minor, relevant and important

• The date of an additional inspection in the case of an important case of non-compliance

• The date of the next inspection resulting from risk ranking taking into account risk assessment and

development of objectives and targets during the phase of inspection planning

• Name or team of inspector(s) or unit

• Amount of time and staff needed for the inspection

• Qualification / Skills needed

• Equipment needed

• Co-operation with other authorities needed

• Compliance history

For this reason the project team still recommends to use the Excel tool beside the internet application for

drawing up inspection programmes but also to further develop the internet application to these needs.

A detailed description of the Excel application can be found on the help sheet of the attached application and

in Annex III.

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5. Results of the workshop in Malta

The IED/IRAM Inspection Program workshop was held back to back with the Implementation Conference of

IMPEL and the EU Commission on 1 October in Malta. The workshop was attended by 18 inspectors from 11

IMPEL member countries. After an introduction into the environmental inspection cycle and the new features

of the developed tools a practical demonstration of the internet application and the Excel tool was given.

During the practical presentation some minor errors of the application were detected that have to be fixed by

the application developer Proximity. In total the objects described in the functional design were achieved as

was demonstrated in the workshop.

After the presentation the participants tested the internet application first as inspectors and than as

coordinators. During this exercise some minor changes of the application were proposed that can be realized

within the project budget.

The additional functionalities described in chapter 4: IRAM Excel tool, were identified as helpful for drawing up

of inspection programmes, and it was recommended to implement them also into the internet application. For

budget reasons this will be only possible within the framework of a future IMPEL project.

The conclusion of the workshop was that the new features of the internet application and the Excel tool are

very helpful for the inspection practise of in competent authorities and that the internet application shall be

developed further.

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6. Recommendations for future IMPEL work

During the last years IMPEL developed a lot of supporting tools to help IMPEL member countries to achieve a

level playing field concerning the implementation of European environmental law. Especially in the field of

environmental inspections the developed methodologies and tools serve as guidance materials during peer

reviews (IRIs) of member country inspection authorities. As an example these are:

• DTRT Inspection cycle

• EasyTools integrated risk assessment

• Inspection targets and performance monitoring

• IED Inspections

• Internet and Excel applications for drawing up of inspection programs

To prepare for an IRI these methodologies should be implemented into the inspection authorities’ routine

procedures. This is not often an easy task as can be seen by the still lacking IRIs and the results of already

performed IRIs.

To achieve a better implementation of the inspection obligations of the EU environmental laws IMPEL should

launch an implementation initiative. This shall be done by assisting individual inspection authorities of the

member countries in implementing IMPEL methodologies.

Especially for the risk assessment and the drawing up of inspection programs the IED/IRAM Inspection Program

project developed an IT tool that is accessible from the IMPEL homepage. During the above mentioned

workshop some further features especially for the use of the tool to draw up inspection programs were

collected. These features shall make the tool more comprehensive and user friendly. The project group

therefore recommends implementing these features into the internet tool.

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Annex I – Functional Design IRAM online Tool

1. Introduction

During the February and May meeting of the IED-IRAM project team in Cologne and Milan, the meeting

discussed the advantages and disadvantages of the current IRAM tool and the possibility to use the output of

this tool to set inspection targets and develop an inspection program (inspection schedule). The meeting

decided that the user friendliness of the tool needs to be improved by making use of the already present

database to store all inspection objects and the related assessment data. Storing this information in a database

would also benefit to generate a ranking list.

This document describes the overall functions of a risk assessment tool (a modified IRAM-tool).

The project decided that the new / modified tool should meet the following conditions:

- Data will be stored online on a secure basis;

- It will be possible to store companies anonymously;

- The application can provide an overview of the stored installations;

- From this overview an installation can be selected and changes can be made;

- Changes to the steering data will directly influence risk assessment data of all installations in that

group;

- The coordinator can change the inspectors that are linked to the installation;

- The stored data can easily be presented (downloaded or printed) so inspection targets can be set and

an inspection program can be developed;

2. Functionality

IRAM-tool

The existing IRAM-tool has the functionality to perform risk assessments. This function works well but has the

disadvantage that data of inspection objects have to be uploaded and downloaded per assessment. The tool

generates separate files that need to be stored locally. Fine-tuning with steering mechanism is therefore

consuming time and to generate an inspection plan is more complex.

New situation: the disadvantage of uploading and downloading inspection objects can be taken away by storing

the data online. Inspection objects (installations) and related assessment data will be stored in a database that

can only be accessed by the owner of this information.

By storing all the data online it will be easier to fine tune the risk assessment and the tool can export the results

of all selected inspection objects in one file. Using the data to define inspection targets and strategies and

develop an inspection programme will be less complex.

The owner of the information in IRAM is the Inspecting Authorities (this is a new entity). Coordinators and

Inspector might change position within an organisation. It should therefore be possible to replace a coordinator

or inspector without loosing the information.

The following entities should be available within IRAM

- Inspection Authorities (new level of hierarchy)

- Coordinators

- Inspectors

- Inspection objects

- Inspection task

- Impact and Operator performance criteria

- Steering mechanism

- Assessment / Scoring

- Output risk assessment

- Assignment of time periods to risk categories (optional)

- Assignment of inspection efforts (e.g. hours) to inspection categories (optional)

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An Inspection authority is competent for the inspection activities in its geographic area. The relation between

industry and the authority is not likely to chance. An Inspection authority is therefore the highest entity. An

Inspection object is always related to an inspection authority.

One of the coordinators should be the main contact person of the Inspection Authority for the administrator of

IRAM.

Coordinators that work for a certain inspection authority are responsible for the coordination of inspectors and

predefining the impact and operator performance criteria and steering mechanisms within IRAM. A

coordinator is related to an inspection authority, to inspectors and to inspection tasks. It should be possible for

a coordinator to change the inspectors that are linked to an inspection object.

Inspectors that work under a coordinator are responsible for inspection work within that geographic area and

for performing the risk assessment within IRAM for certain inspection objects. An inspector is related to a

coordinator and to the assessment within an inspection task.

Inspection objects are the facilities that fall under the supervision of an inspection authority. The inspection

objects will be stored in the database of IRAM. They can be made anonymous by working only with ID's and

hiding the names (ID is mandatory and name is optional). It should be possible to enter the data of the

inspection object one by one or import the data from a foreign database. The coordinator and the inspector

should be able to add inspection objects. An inspection object is related to an inspection authority and an

inspection task.

An inspection task is the collection of Impact and Operator Performance criteria and steering mechanisms. An

inspection task is related to one or more inspection objects. The coordinator defines the inspection tasks and

links the tasks to inspection objects. It should be possible for the coordinator to give the right to link inspection

tasks to inspection objects also to an inspector.

Impact and operator Performance Criteria are the description of a set of criteria that are used to perform a risk

assessment. The description includes the values of the scoring system.

The coordinator has the right to change existing criteria and add new criteria.

The steering mechanisms within IRAM are the whole of weight factors and terms and highest and lowest score.

The coordinator has the right to change the steering parameters (related to a certain inspection task). By

changing one of the steering parameters that is related to a certain inspection task all the inspection objects

that are linked to that inspection task should be re-calculated. Optional it shall be possible to assign time

periods to risk categories and inspection efforts (e.g. hours or descriptions like “full integrated inspection”) to

inspection categories.

The assessment itself is the activity in which the inspector enters the scores for the Impact and Performance

criteria. An inspection object can have more then 1 inspection task and therefore also more then 1 assessment.

The inspector and the coordinator have the right to fill in the scores.

IRAM should be able to keep track of historical information (e.g. an archive with former risk assessments and

inspection results).

An inspection authority can have 1 or more inspection objects

Security issues

The tool and the database will be stored on a server in Germany (Information Technology Agency of North-

Rhine Westphalia (IT NRW)).

It should be possible to annonomize the data by storing inspection objects with only an ID. This way only

the owner of the information can trace the data back to actual facilities and installations. Therefore the field

“Inspection object” shall be changed from obligatory to optional.

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An inspection authority can have 1 or more coordinators

A coordinator can have 1 or more inspectors

A coordinator can have 1 or more inspection tasks

An inspection object can have 1 or more inspection tasks

An inspection task has only one set of steering mechanism

An inspector can have 1 or more assessments (with scoring data)

Relation between entities could look something like

3. Ownership and rights

The inspection authorities are the owners of their information in IRAM.

The coordinators have the right to:

- Add and delete inspectors

- Connect inspectors to inspection objects

- Add and change inspection tasks (this includes the steering mechanisms and criteria)

- Mark the inspection task as non-active (in stead of deleting it)1

- Add or change inspection objects

- Mark the inspection object as non-active (in stead of deleting it)2

- Execute a risk assessment or change an already executed risk assessment.

Inspectors have the right to:

- Execute a risk assessment (giving scores) for which they are responsible;

- Add and change inspection objects

Wish: is it possible to let the coordinator decide (by check boxes) about the rights of the inspector.

4. User-interface

This section describes in general steps what the users (Admin, Coordinator or Inspector) see and how to

navigate through IRAM.

1. After logging in an overview of all the inspection objects of the inspection authority will be presented:

ID inspection object; (name inspection object); inspection task; risk category; (inspection frequency);

1 and 2: Marking an inspection object or inspection task as non-active will prevent data to get lost (or float)

Inspection

Authority

Coordinators

Inspectors

Inspection

Objects

Steering

mechanism

Impact and OP

criteria

Assessment Output:

Ranking list

Inspection Task

Inspection targets,

strategies and

program

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inspection category; (inspection effort); highest and lowest score; name coordinator; name inspector

(that performed last inspection), and last inspection date;

2. The overview can be filtered by ID inspection object, name coordinator (representing an inspection

unit), an inspection task or the inspector;

3. From this (filtered) overview the user can:

a. select an inspection object (Inspectors can select only the inspection objects for which they

have the right to make changes. Coordinators have the right to select any of the inspection

objects);

b. print this (filtered) overview of the inspection objects or export this overview to an XML or

CSV file;

4. Quick search options will be available to select the right inspection object;

5. After a selection has been made the form of an inspection object will be presented (this is the form as

we know it from the present version);

6. In this form the coordinator can add or change the name of the inspector; this option is not available

for the inspector;

7. In this form the inspector and coordinator can make changes in the risk assessment

8. In this form the inspector and coordinator can make a print of the total form (in pdf) or a download as

already realized

9. Leaving the form will bring the user back to the overview.

5. Reporting and output

IRAM should be able to generate a report or an XML or CSV file that can be used to define inspection targets

and strategies and further develop an inspection program:

This file should contain at least the following information:

1. the selected inspection objects (ID; Name object)

2. the names of the inspectors (Name inspector that performed last inspection)

3. the inspection task

4. the risk categories of the inspection objects

5. the inspection categories

6. dates of the last inspection

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Annex II - Description of the IRAM online Tool

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Annex III - Description of the IRAM Excel Tool

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Annex IV – Minutes of the meetings

Minutes of the meeting

21-22 February in Cologne

Participants: Horst Büther, Florin Homorean, Helena Neklolava, Romano Ruggeri, Giuseppe Sgorbati, Hartmut

Teutsch, Wulf Böckenhaupt, Rob Kramers

Day 1 (21 February)

1. Welcome

Horst welcomes the participants.

Horst goes through the agenda and logistic arrangements.

2. Tour de table

Horst (Project leader): The IRAM tool is now direct accessible through the home page of the IMPEL website.

The inspection plan and the first Inspection report has been published on the website of the Bezirksregierung

Köln. The IED is not yet transposed in Germany

Wulf: member of the staff of Horst (Inspector). We need a program that can evaluate our work. Monitoring !

Rob: InfoMil moved to an other agency (from NL Agency to RWS). Supported IMPEL projects for the last 6

years.

Ulricke: Supports this project, is an inspector and works in Achen.

Giuseppe: works in an agency in Milan that supports local administration and execute monitoring activities. He

is interested because they need to choose a program to develop inspection programs.

Hartmut: Works as an inspector in Bremen, inspections are not integrated,

Florin (Inspector in Roma: Works as an inspector at a regional authority in Romania, they perform inspections

on Seveso and IED installations (amongst others). Is interested in this project because they have to chance

software for risk assessment and inspection programs.

Romano: Inspector for IED installations from Sardinia. They need a methodology to develop a plan, they have a

low number of resources and need to allocate their inspectors the best they can.

Helena: is from the regional inspectorate in Czech Republic. Beginning this year the IPPC department no longer

exist. Inspections are now no longer integrated.

3. Objectives of the project (Horst)

1. Development of an IED Inspection Program

2. Planning of an IT tool for drawing up the inspection programme using IRAM data

3. Beginning with the development of the tool

4. Workshop back to back at the IMPEL conference

Not all project members could join the meeting , some for financial reasons

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1. Development of procedures for inspection programmes taking into account

• Routine inspections

• Non-routine inspections

• Different types of inspections

• Different inspection authorities

• IT support (link to easyTools)

2. Preparation and execution of a back to back workshop at the IMPEL conference in Malta concerning best

practices for the implementation of article 23 of the IED taking into account the findings of the IED Inspections

project, the Doing the Right Things Methodology (DTRT) and the IMPEL Integrated Risk Assessment Method

(IRAM):

• Inspection plan

• Criteria for the risk appraisal

• How to use the IMPEL IRAM web application in this context

• Inspection programme

• Linking routine with non routine inspections and with other inspections

• Preparation and publication of inspection reports

Should that not be possible, preparation and execution of a workshop with the same content. If there are

financial restrictions in 2013 it shall be planned for 2014.

3. Development of good solutions for an IT supported inspection programme using IRAM risk assessment xml

files

• Choose a data base solution for the storage of IRAM data that can be used for inspection planning by

every IMPEL member country without problems

• Define the interface between the xml output of IRAM data, the input of the chosen data base and

other data bases used by IMPEL member countries

• Develop the requirements of the inspection programme IT tool

• Make a proposal for the development of such a tool and the steps needed to achieve this

• Start with the development of the IT tool if financial support is available in 2013

Further objectives in a 2014 follow up project if approved by the GA:

• Development of an IT tool with data base that fulfils these requirements and that works with IRAM

data

• Placing the tool for drawing up inspection programmes on the IMPEL website

Making sure that the inspection programme and/or the tool itself can be downloaded

4. Results of the easyTools project (Horst)

Horst presents the history of the easyTools project and explains the methodology of IRAM

Web Tool: the programme distinguishes between coordinator (decides on the tasks, criteria and steering terms

and factors) and inspector (does the risk assessment)

No data storage on internet

Data to be downloaded as XML or CSV files and can be imported into national databases (access and excel)

There are now different language versions of easyTools

The address of the easytool program can be changed with a re-direct.

Outcome of the workshop: methodology was accepted; participants confirms the added value of IRAM,

procedure arrangements need to be made, user friendliness need to be improved.

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5. Results of the IED project (Rob)

Content of an inspection programme

1. Defined time period

2. Name and/or type of facilities / installations

3. Name or team of inspectors

4. Amount of time and staff needed

5. Frequency / Date, Month, period

6. Type of inspection

7. Equipment needed

8. Cooperation with other authorities

Not all issues are mandatory

3 categories: what is in IRAM (forms the structure of the program); what is mandatory by IED; and what is

optional and good to know for the inspector.

Issues that are in the program of Horst: Frequency IRAM; Compliance Frequency; Last inspection, Compliance;

Next inspection; Finished; Next after next; Archive (Inspection date; compliance; )

Inspection program could have the inspection profile in as annex (not all agree)

6. Content Inspection program

See presentation

7. Functional specifications

Online IRAM program

Advantage: one application for risk assessment and inspection program. We can use the data from RA for the

inspection program. One program that is the same for all users, also when there is an update

Disadvantage: costs; database is needed when you use more then 1 installation

IRAM Excel file

Advantage: costs, easy user interface

Disadvantage: Not so robust, not professional

Conditions:

• Online tool

• User friendly

• Data should not be stored on internet.

• The entries should be in one overview to easily check and make changes..

Conclusion

Inspection program will be made in Excel. Budget will be used by making the IRAM online tool more user

friendly. This means that more then 1 installation will be up and downloaded and fine tune the risk assessment

should be very easy. It should be optional to leave your data on internet or not.

IRAM should provide an overview to make data entry

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9. IT solutions

Discussion with Proximity

Database to store online all the installations.

It will not be possible to upload all the data so data has to be stored.

Security: stored at Horst and we could use only ID and not the name of the facility. The option to work file by

file will also be possible.

1step: build database – possible to show all the installation, from an overview you can select the installation

and make changes

As a coordinator you can change the steering data that will have effect on all installations.

Coordinator can decide if he wants to select an other inspector for the inspection program

Extra data fields could be entered for the inspection plan. They should also be optional.

Day 2 (22 February)

10. Results of day 1

1. Develop an Excel file that can produce an inspection program

2. Further develop the Online IRAM tool for more then 1 installation in a session

11. Program development costs

No issues

12. Project organisation

Basecamp: new project with names from presentation (Rob)

Flyer: needs to be updated to IRAM-tool

Project organisation: next team meeting / 21and 22 May in Milan: Offer, functional design, layout inspection

program

Florin will do the organisation of the workshop (a.s.a.p.)

Horst will prepare the inspection program (1st

May)

Horst, Wulf and Ulricke will update the flyer (24st of May)

Rob will prepare the functional design (1st

of May)

13. Time table and mile stones

Aim: Introduction and training

20 participants

1 Oct Description Name

09:00 Welcome Horst

09:10 Introduction of the project Horst

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09:30 Environmental Inspection Cycle

Focus on inspection plan and inspection program

Rob

10:00 IRAM: methodology and criteria Wulf

11:00 IRAM: Online tool / Demonstration Horst

12:30 Lunch

14:00 Exercise

16:00 Discussion / questions

17:00

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Minutes of the meeting

21 – 22 May Milan

Participants: Horst Büther, Isabel Santana, Florin Homorean, Helena Neklolava, Chrystalla Stylianou, Romano

Ruggeri, Giuseppe Sgorbati, Fabio Carella, Hartmut Teutsch, Vladimir Kaiser, Jean-Pierre Jansens, Tony

Liebregts, Martine Blondeel, Roel Vaneerdeweg, Rob Kramers

1. Welcome

Giuseppe and Horst welcomes the participants and goes through the agenda and logistic arrangements.

2. Tour de table

Horst: There are new language versions are available in IRAM. Finland is also using IRAM. Representatives of

the IED project team have presented the IED guidance book to the EU Commission. It was well received. The

guidance book is reviewed by the Commission and there comments have been received.

Isabel: Portugal has got a Risk assessment tool already in place for IPPC. Last year IRAM was implemented for

REACH. The aim now is to adapt other tasks as well to this tool.

Florin: Romania is not yet using the methodology of IRAM. As there is no strict procedures about developing

inspection plans every region is doing it in their way.

Chrystalla: Cyprus is looking for a program to develop an inspection program. They have been looking for

products from IMPEL. The program should be easy to use, reliable and should fulfil the obligations from the

COM.

Helena: Czech Republic has transposed the IED and is now working on the implementation

Romano: Sardinia has developed an inspection plan that follows the doing the right things methodology. The

interest for this inspection plan is strong.

Giuseppe / Fabio: IRAM is an important tool to prioritise all the installations in Lombardia and manage the work

of ARPA. IRAM has been tested for 6 months and it is believed to be a good tool. There is a lot of industry and

not and not enough resources, setting priorities is therefore important. IRAM will also be implemented in the

Komo region as from the beginning of 2014.

Hartmut: the IRAM methodology is being used by Hartmut’s organisation for prioritising inspection work.

Vladimir: Slovenia is using the IRAM tool to plan inspections for IED installations.

Tony: The Dutch Inspectorate is also using the methodology from the guidance book. They are however using a

different program for risk assessment. Further Tony is working on a an IMPEL project “ Cross cutting” that

connects all the good work of IMPEL to the Environmental Inspection Cycle. It’s important to show what we

have done in IMPEL and where the blank spots are.

Martine/ Roel: Flanders started implementing IRAM after the easyTools project. They have used different

criteria. Inspection plans are now based on IRAM. This year the inspectors in the provinces are now informed

how this methodology.

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3. Results of the first meeting

The minutes of the Cologne meeting are adopted without comments.

4. Extended Excel application

Horst and Roel present the IRAM Excel application.

Password for coordination: “steuerung”

Password for the other tables: “tabellenblatt”

Discussions, comments and remarks:

At the moment we run separate risk assessments for different inspection tasks, for example for IED and for

Seveso. If we would like to reduce the burden for industry by combining inspection tasks, this also has to be

possible in IRAM. At the moment this is not possible.

It should be possible to store the date of the last inspection in IRAM. Horst will add a new column with the

actual planned period. This field will not be mandatory to fill in.

Title follow-up inspection will be changed in “next inspection”. How to deal with the classification of the non-

compliance is defined in the guidance book. At the moment the classification in the guidance is not the same as

in the excel sheet.

It’s difficult to assess compliance. For example should this be based on one inspection or should this be based

on a longer period. We need to say something about how to deal with this issue.

Should there be a new column for follow-up inspections (to inspect the non-compliance)

We have to make sure that we will not forget to include the inspection targets with this dynamic inspection

tool. Could this be solved with an annual inspection schedule?

The project team was impressed by how elaborate this tool is. For example it prescribes that a new inspection

has to be conducted, 6 months after a serious compliance has been identified. The extended excel tool is more

then a planning instrument. It’s also manages the process of an organisation.

Rob presents the Environmental Inspection Cycle and shows how the developments that have been presented

are no longer in line with the principles of this methodology. There is direct link between a risk assessment

(setting priorities) and developing an inspection programme. For an organisation that knows exactly what to

do, what their inspection targets and their intervention strategies are, these developments are ok. For the

majority of inspecting authority there is a risk that inspections will be performed on output and no longer on

outcome (quality of the environment).

Horst: explains that there is not enough budget in the project to build a tool within IRAM that will generate an

inspection schedule based on the risk assessment data. This means that the outcome of IRAM tool will be an

XML file and not an inspection program. This XML file can be imported in an Excel file.

5. Functional specifications of the web application

See annex 1 for presentation.

The document describes the functionality, ownership and rights, the user interface and reporting and output.

The document was discussed and comments were made. A new version of the documents was made shortly

after the meeting and is attached in annex 2.

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6. Further trainings

Training sessions on IRAM should be developed for the coordinators.

Discussion if these sessions should be broadened and also take aboard inspection targets and inspection

program. These training sessions will take at least 2 days. Training materials has to be developed as well.

Instead of joint training sessions (with more then one country) an option is that one trainer will visit the

interested countries and give assistance. Interested for this option to participate are Horst and Vlado. During

the training sessions an introduction of the EIC will also be made. A small working group will help to develop a

training package. Also an online tool could be part of this package.

The workshop in Malta will be used to decide what the best option is. Based on this a ToR will be made for the

GA.

7. Preparation of the workshop

For the workshop the new IRAM tool will be ready and presented to the participants.

Preliminary agenda (20 participants)

1 Oct Agenda item Speaker

09:00 Welcome Horst

09:10 Introduction of the project Horst

09:30 Environmental Inspection Cycle

Focus on inspection plan and inspection program

Rob

10:00 IRAM: methodology and criteria Wulf

11:00 Demonstration

Risk assessment: Online IRAM tool

Planning tool: Excel

Horst

12:30 Lunch

14:00 Exercise: participants can practise with the new tools on their own laptop,

running a case study. (Note: Wifi connection is needed)

16:00 Discussion / questions

17:00 End of workshop

8. IED/IRAM guidance book

There was not enough time to discuss the comments of the EU Commission on the IED guidance book. The

comments will be discussed during the workshop in Lisbon on Inspection targets and performance monitoring.

9. Project organisation: next steps, follow-up project 2014, project

communication

Next step: Training sessions as mentioned under section 6.

In case the budget for IRAM this year is not enough to make the necessary changes, it’s foreseen to do this in

2014.

Project communication: A Factsheets will be written on the new IRAM tool. The Cross-cutting project could also

play a role in this. We also need to explain how IRAM is used in practice: for this we could use the good

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practices from Flanders and Italy and place on the website. The IRAM methodology could also be included in

the IRI questionnaire.

12. Time table and milestones; who does what and when? nr Action Who When

1 New version of functional design Rob 25-5 (done)

2 Prepare a case study Rob 1-9

3 Offer from Proximity Horst a.s.a.p

4 Communication issues

Good practices

Horst

Roel and Romano

a.s.a.p

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Annex 1 Presentation Functional design

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