EMAS

1. Introduction
2. Overview
3. Global adoption
4. Benefits
5. Auditing
6. Choosing a registrar
7. Route to registration
8. Costs
9. Contributing editor

EMAS (Eco Management and Audit Scheme) is a voluntary initiative designed to improve an organization’s environmental performance. It was initially established by European Regulation 1836/93, which has since been updated twice with Regulation (EC) No 1221/2009 coming into force in January 2010. It is a voluntary scheme and in this respect is similar to ISO 14001:2004.

Its aim is to recognize and reward those organizations that go beyond minimum environmental legal compliance and continuously improve their environmental performance and again in this respect is similar to ISO 14001:2004. Commentators have stated that EMAS is ISO 14001:2004 with an additional requirement for participating organizations to regularly produce a public environmental statement. This statement reports on the organizations environmental performance in a given period almost invariably one year. It is the voluntary publication of environmental information, whose accuracy and reliability that needs to be independently checked by an environmental verifier, which gives EMAS enhanced credibility and recognition.

EMAS is strongly backed by Government, the EU and environmental regulators – organizations who participate are recognized as making a strong commitment to the environment and to improving economic competitiveness.

Each EU member state has a competent body for EMAS and in the UK that body is IEMA.

In order for an organisation to be EMAS registered the organisation must comply with certain requirements:

• Policy statement; adopt, for an organisation, a policy that provides for compliance with all relevant regulatory requirements and commit the organisation to reasonable and continuous improvement of its environmental performance.
• Review; conduct a review to identify environmental issues related to activities that are significant and to provide a performance baseline to allow evaluation of future improvements.
• Programme; introduce a programme that focuses on significant issues identified during the review and which translates the policy into objectives for the improvement of environmental performance.
• EMS; introduce an EMS applicable to all activities at the site to implement the programme and achieve its objectives within deadlines – this is based on ISO 14001:2004 and must include environmental audit (internal). See auditing.
• Statement; the organisation must prepare a statement for approval by the verifier and subsequent submission to the Competent Body.  The statement must be disseminated as appropriate to the public; be prepared following the completion of a full audit cycle and initial review (for the first statement).

Is EMAS relevant to your organisation?

Yes it is applicable to all organisations large or small and in the UK has a particular applicability to Local Government and public bodies.

Prior to EMAS 111 the scheme was limited to Europe. ‘Global’ EMAS is aimed at encouraging global uptake of the scheme by making EMAS certification possible for organizations and sites located outside the EU.

• EMAS has a European appeal and there is a specific logo
• Is closely linked to Corporate Social Responsibility reporting
• Encourages and recognises resource efficiency
• Creates a framework for legal compliance, continual improvement and pollution prevention

Internal Audits

Organisations must establish an internal audit programme and conduct an audit based on:

• Importance/urgency of the problems
• Scale/complexity of activities
• Volume of emissions
• History of environmental problems

The agreed frequency for auditing a particular operation needs to be discussed with the relevant management who will make a decision on the overall impact of the operations.

External Verification

The process of external verification includes a review of an organisation’s policy, environmental review, programme, EMS and Statement. All must be verified and the statement validated by an accredited environmental verifier. A significant part of verification is a review of the draft environmental statement, which should be written for the public in a concise, non-technical form and which should contain the following information:

1. A clear and unambiguous description of the organisation registering under EMAS and a summary of its activities, products and services and its relationship to any parent organizations as appropriate;
2. The environmental policy (objectives) and a brief description of the environmental management system of the organization;
3. A description of all the significant direct and indirect environmental aspects which result in significant environmental impacts of the organization and an explanation of the nature of the impacts as related to these aspects;
4. A description of the environmental objectives and targets in relation to the significant environmental aspects and impacts;
5. A summary of the data available on the performance of the organization against its environmental objectives and targets with respect to its significant environmental impacts. Reporting shall be on the core indicators and on other relevant existing environmental performance indicators as set out in the EMAS III Regulation (Section C);
6. Other factors regarding environmental performance including performance against legal provisions with respect to their significant environmental impacts;
7. A reference to the applicable legal requirements relating to the environment; and
8. The name and accreditation or license number of the environmental verifier and the date of validation.

The updated environmental statement shall contain at least these elements and shall meet the minimum requirements as set out in points 5 through 8.

Each member state has a register of verifiers who are registered with a competent body in that state, for example in the UK it is IEMA.

You should consider the following items when choosing a verifier:

• Ensure that the verifier is accredited by the member state competent body. (Every Member State has designated a Competent Body which is responsible for registering organizations and for maintaining the list of registered organizations in their country).
• Receive quotations from several verification bodies or individual verifiers.
• Ensure that the verifier is recognised by your customers and has some relevant experience.

There are various steps to registration:

1. Pre-audit Assessment
   • Check documentation with the verifier
     A verifier will review your documentation to ensure that all documented procedures cover the requirements of EMAS and in particular legal compliance.
   • Determine date of assessment
     With your verifier you will determine a suitable timetable and agree on dates for the initial assessments. Many organizations benefit from the pre-assessment "dry run" of the formal assessment. You may choose to divide your assessment into two phases.
2. Initial assessment conducted (1st Stage optional)
   A 1st stage initial assessment will be conducted by verifier. This will cover the basic documentation and your prepared state for the 2nd stage audit. You will be informed of the recommendation at the closing meeting.
3. Initial assessment conducted (2nd Stage)
   The 2nd stage initial audit cannot be conducted immediately after the 1st stage audit in the aerospace scheme but areas covered in the 1st stage can be accounted for in the 2nd stage audit. The combination of the 1st and 2nd stage audits will result in a recommendation from the verifier at the end of the audit.
4. Registration confirmation
   Following the recommendation, your registration will be confirmed by the technical reviewers. At about the same time you will need to register with IEMA.
5. Certificate issue and EMAS logo
   Your certificate of registration will arrive soon after your registration has been confirmed. The EMAS logo set out in Annex V of EMAS III may be used by registered organizations as long as their registration is valid and the logo bears their registration number.

Internal Costs

For organisations that have only recently started in business, the new requirement for documentation is that the external auditor will need to see a minimum of 12 months of records before recommending the certificate be issued.

External Consultancy

The complexity of EMAS means that there are a number of pitfalls for the do-it-yourself organisation.  The consultant, with years of experience in both auditing and installing EMAS for organisations, knows what is required and the organisation will not need to 're-invent the wheel’.  In addition, it is more cost effective for the consultant to advise on progress rather than spend time actually doing the work for you.

Certification Costs

Third party costs are dependent on the size of your organization and the complexity of your environmental emissions. Verification charges are based on a certain rate per day to be on-site. This day rate will vary depending on your country but the typical day rate in the United Kingdom will vary between £600 and £800 per auditor day, depending on the registrar. Small companies with less than 20 staff could expect one auditor on site for the initial audit for 2-3 days; large companies with 126-175 staff can expect several auditors on site for approximately 10 days, depending on the complexity of the processes being carried out.

Other fees include application fees, certificate fees or annual licence fees.

To maintain your registration the verifier must return periodically (annually). These costs will be similar than the original visit, since the time spent will be shorter.

Julian Ringer

Julian Ringer is the Managing Director of Safety, Environment and Quality Management (SEQM) Ltd.  He has been involved in environmental consultancy since March 1989 specialising in environmental management, auditing and impact assessment.  He is an environmental certifier for a number of certification bodies and is a registered EMAS verifier for industry and local government.

Julian is an approved EMAS verifier in the UK, Denmark and Italy and has completed 25 verification exercises for organisations in the chemical, automotive, printing, paper and public administration sectors including Sutton, Camden, Leicester and Kirklees Councils. He coordinated the national UK launch of EMAS in Middlesbrough in 1994.