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Risk based approach to compliance monitoring in Norway

Risk based approach to compliance monitoring in Norway. Anne Marie Mo Ravik Senior adviser Section for International Affairs , Klif. International Conference on Environmental Compliance and Enforcement The Emerging Global Trend Kolkata , West Bengal 19-20 March 2013. 1.

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Risk based approach to compliance monitoring in Norway

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  1. Risk based approach to compliance monitoring in Norway Anne Marie Mo Ravik Senior adviser Section for International Affairs, Klif International Conference onEnvironmentalCompliance and Enforcement The Emerging Global Trend Kolkata, West Bengal 19-20 March 2013 1

  2. About Norway Area (mainland): 323.758 km² Coastline: 2 500 km (fjords not included) Population: 5 million Counties: 19 Capital: Oslo

  3. Environmental authorities in Norway Will form Norwegian Environment Agencyfrom 1. July 2013

  4. The Climate and Pollution Agency,  functions and roles: Foto: Reinertsen 1. Exercise regulatory authority and carry out inspections 2. Monitor and inform about the state of the environment and its development 3. Instruct and guide the County Governors’ environmental departments 4. Provide expert advice and promote key environmental initiatives 5. Participate in international environmental and development cooperation

  5. International work: EU directives and regulations Norway is not a EU-member, obligationsthrough European Economic Area Agreement (EEA) Participate in expertgroups, examples: • IPPC/ Industrial Emissiondirective (IED) • REACH • CLP International conventions and agreements Norway as a downstream country Bilateral cooperationprojects Oceans and air currents

  6. Klif areworking to: reduce greenhouse gas emissions reduce the spread of substances harmful to health and environment increase recycling and reducing pollution from waste to protect and maintain good quality of rivers, lakes marine and coastal environment through an ecosystem-based management reduce harmful effects from air pollution and noise 6

  7. What is our legal basis? • 3 main Acts: • The Pollution Control Act • The Product Control Act • The Greenhouse Gas Emission Trading Act • Regulations connected to the acts • EU directives and regulations • International Conventions and Agreements Side 7

  8. Permitting and inspections in Norway 40 years ago What has been our approach?

  9. Some principles for environmental protection in Norway • Precautionary principle • Polluter pays principle • Substitution principle • Recipient orientated/Critical loads on nature • Environmental management system • More important to preventdamagecaused by • pollutionthan to repair it

  10. The Pollution Control Act • Nobody is allowed to pollute without special permission • Details outlined in discharge permits and regulations foto: Reinertsen

  11. Pollution permits Individually, case by case, for high risk industrial enterprises Integrated Limit values for emission to air and water based on The pollution potential The technology (BAT) Status of ambient air and recipient water International agreements and standards (EU etc.) Limits for noise Requirements for treatment of waste Other requirements, as: Annualreporting Contingencyprepardeness

  12. Risk basedregulation in Norway Industrial plants/sites are divided into four risk categories, which are determined by the hazard their emissions and discharges represent and the quality/sensitivity of the receiving environment

  13. Responsibilityoftheindustry: Industry areresponsible for theenvironmental impactoftheiractivities Internal Control Regulations: Environmental management system (mandatory) • organization and responsibilities, • routines and procedures, • system for self-monitoring , quality assurance and documentation of pollution, • system for corrective actions, • assessment of risk • etc.

  14. How the regulators follow up onpermits Enterprises reports to Klif annually Communication between enterprises and authorities Audits and inspections Sanction possibilities

  15. Inspection frequency • Multi annual inspection plans • Frequency based on i.a: • Risk category : Higher frequency and more time spent on high-risk facilities. • Compliance history : bad compliance record , increased frequency • Areas of high concern: special focus on selected areas/chemicals may increase the frequency

  16. How to utilize your resources more optimally? • Focus on the most important issues (risk based) • Different kinds of inspection approaches used in Norway: • Audits • Inspections (planned and reactive) • Campaigns • Desk control (letter control) Foto: Reinertsen Foto: Reinertsen Foto: Reinertsen

  17. Audits and Inspections Audits: • 2- 5 days on-site • Thouroghinvestigation • Mainlyused for enterprises in thehighest risk categories (1 and 2) Inspections: • Normally 1 dayonsite, • More narrowfocusthanaudits • Planned, oftenunnanounced • Unplanned, reactionto accidents, complaintsetc. Foto: Reinertsen Foto: Reinertsen Foto: Reinertsen

  18. Campaigns • Oftentogetherwiththecountygovernorsenvironmentaloffices • Supervised by Klif • Focusonselectedbranches, topics, chemicals/hazardoussubstancesetc Examples: • Electrical and electronicalwaste (WEEE) • Chemicals (mercury,PCB, etc, link to action plans) • Risk management • Waste handling • Fish farmingindustry

  19. Control of the take back system for EE-waste Regulations: • Retailers/distributors; duty to take back discarded EE- equipment • Take back companies: collects and handles the EE-waste • Producers/importers: needmembership in a take-back company • Inspectioncampaignswithfocusonretailers: • Cooperation withCountygovernors all over the country • Supervied by Klif • Follow-up campaigns • Auditsofthe EE-wastetake back companies • Free-riders (producers/importers lackofmembership )

  20. Resultsarepublicavailable • Norwegian PRTR + inspection reports Facility specific Internet page: www.klif.no/norskeutslipp • Information onwww. klif.no http://www.klif.no/no/english/english/ • Press releases • Reports availablethroughofficial journal • State ofthe Environment: http://www.environment.no/

  21. Summing up:Risk based approach to compliance monitoring in Norway The system in Norway is basedon: • Risk categories (pollution and resipient) • Clear reponsibilities for theenterprices, (mandatory management system) • Multiannualinspection plans, risk based, flexible • Different types ofinspectiontools • Good link between policy/focus areas oftheagency and topics for control A risk basedapproach for prioritizingyourwork, helpsyou to focusonthe most importantenvironmentalissues.

  22. Thank you for your attention ! Foto: Anne Marie Mo Ravik

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