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Enhancing Environmental Management Systems: Meeting Stakeholder Expectations in Compliance

This presentation by Chris Howes, Policy Manager at the Environment Agency, delves into the critical role of Environmental Management Systems (EMS) in compliance and performance. Highlighting key issues, it examines stakeholder expectations versus the actual delivery of EMS. While operators benefit, external stakeholders often feel underserved. To bolster credibility, consistency, and transparency, this session emphasizes the necessity for stronger accreditation and clearer communication pathways. The presentation includes insights from various studies across Europe, the USA, and the UK, addressing the effectiveness and perceived challenges of certified EMS.

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Enhancing Environmental Management Systems: Meeting Stakeholder Expectations in Compliance

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Presentation Transcript

  1. EMS: Expectations, Experience and Solutions Chris Howes Policy Manager - Compliance Assessment & Enforcement

  2. 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 • We need to do more on: robustness, consistency, credibility and transparency

  3. EMS 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

  4. 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

  5. Expectations - 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

  6. ENDS Report February 2003 ENDS Report March 2003 ENDS Report April 03 Experience?

  7. Experience: 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)

  8. Experience: 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

  9. Experience: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

  10. EMS and Operator Performance

  11. Enforcement Action (IPC)

  12. EMS and Performance (Landfills) (High score is associated with worse performance)

  13. Decision time • Does a certified EMS imply a baseline of compliance? • Or is it just an indicator of intent? • No rewards for good intentions though!

  14. Improving the value of certification • Clarify roles of accreditation and certification bodies - and regulators • Stronger accreditation/certification requirements • Better communication (including complaints handling)

  15. Improving 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

  16. Improving 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

  17. Improving the value of certification • Communications: • dealing with complaints • dialogue on non-compliance • ongoing dialogue UKAS/CBs/ with Regulators and Industry

  18. REMAS A pan European project that examines the value of environmental management systems in the context of regulation

  19. Who is involved? • The Environment Agency • Scottish Environmental Protection Agency • Irish Environmental Protection Agency • Institute of Environmental Management & Assessment

  20. remas 1 Pan-European multi-sector benchmarking study remas 2 Site based improvement over time based on emissions data remas 3 Assessment of regulatory duplication/facilitation remas 4 Gathering of other evidence remas linking environmental management and performance Methods www.remas.info

  21. Process & timescales BY END OF MAR 03 JAN - MAY 2003 JULY - SEPT 2004 JUNE 03 -JULY 04 SEPT 04 -SEPT 05 DEVELOP & PILOT Company recruitment & training Establish REMAS Criteria Data collection & analysis Demonstrate mechanisms DISCUSSION, DISSEMINATION & CONSENSUS BUILDING

  22. Links and contacts • Chris.howes@environment-agency.gov.uk • REMAS: martyn.cheesbrough@ environment-agency.gov.uk • www.remas.info • enquires@remas.info • REMAS project, Environment Agency, Block 1 Government Buildings, Burghill Road, Westbury-on-Trym, BS10 6BF • +44 (0) 7768 276947

  23. 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 • We need to do more on: robustness, consistency, credibility and transparency

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