Article is from
Electrical & Mechanical Contractor
Sept. 2002, p. 55

Articles & Info

The starting steps

How do you set up an environmental management system? Chris Ottaway explains where to begin.

Before setting off down the road marked ISO 14001, a comprehensive environmental survey of a firm's operations should be undertaken. This is known as the Preparatory Environmental Review. Its aim is to consider all aspects of the organisation and identify strengths, weaknesses, risks and opportunities as a basis for establishing an environmental management system.

The preparatory review should cover four key areas:

• legislative and regulatory requirements;
• identification of significant environmental aspects;
• existing environmental working practices;
• feedback from the investigation of previous incidents and non-compliance with legislation or existing policies and procedures.

In all cases, normal and unusual operation, plus possible emergency conditions should be considered.

A combination of questionnaires, checklists, interviews and other forms of consultation and direct inspection and measurement could be used for a review. Which are used will depend on the nature of the activities and the size of the organisation.

The following areas may be considered in the review:

• where environmental performance can be improved;
• environmental objectives and targets beyond regulations;
• expected changes to regulations and legislation;
• adequacy of resources and environmental information;
• environmental records;
• environmental cost-benefit analysis and accounting methods;
• resource consumption (energy, fuel, materials);
• waste minimisation and recycling initiatives;
• use and disposal of hazardous materials and products;
• transport policy;
• complaints and their recording and follow up;
• visual impact, noise and odours;
• environmental analysis of suppliers;
• environmental hazards and risk assessment of potential emergencies.

Once this valuable exercise has been completed, the firm's Environmental Aspect Analysis can be undertaken.

In evaluating aspects and developing objectives, any codes of practice to which the organisation subscribes should be considered. These codes may commit the firm to achieve certain levels of control over adverse effects and to specify targets for such matters as pollutant load reduction.

The views of interested parties and the frequency and nature of complaints about environmental performance may also help to identify and evaluate aspects. The evaluation should address aspects arising from support functions, such as planning, finance, personnel and administration services. Both direct (waste, fuel use, materials, for example) and indirect (such as misuse and disposal of the organisation's products) aspects should be considered.

The environmental probity of suppliers should also be considered, with regard to their products and activities. In many cases it may not be possible to compile detailed registers of suppliers, but it will often be possible to compare them to alternative firms in respect of their most important environmental aspects.

Known or suspected consequences of past activities, those transferred from other firms, and possible future effects should be considered.

Attention should be paid to all operating conditions, including emergency situations. With the latter, the risks of a situation arising and the severity of its potential environmental aspects need to be considered. This will help to establish objectives, control risks and develop an environmental component-to the emergency plan. The degree of detail that aspects should be evaluated to depends upon such factors as:

• the likely environmental significance;
• any related regulatory requirements;
• the extent of concern of other interested parties;
• existing knowledge of the type of aspect.

Risk assessment and other techniques may be used to compare the aspects identified. A firm may, depending on its environmental policy, accept an evaluation implied by regulatory conditions or it may undertake further assessment if it wishes to consider the aspect in more detail. Evaluating significance will often involve subjective judgements. The system established for evaluation should provide a consistent approach to that process.

The organisation should identify environmental issues relevant to new developments, products, processes, services and other elements of its activities to ensure that these are considered at the earliest stages of planning.

Once the preparatory review and environmental aspect analysis are complete an Initial Environmental Findings Report can be produced for the firm. This should address the nature and extent of problems, and deficiencies, and the priorities to be accorded to rectifying them. It should also outline an improvement programme designed to ensure that the personnel and resources required are identified and made available.

...

Chris Ottaway manages the ECA's free management systems helpline for members (tel 01277 363653). He is md of Ottaway & Associates.