EMAS, the Eco-Management and Audit Scheme was introduced by a European Union council regulation (No.1836/93), requiring implementation in all European Union Member States. Although the scheme itself is mandatory in all EU Countries it is, at present, a voluntary scheme for individual companies who must be within the industrial sector. It is intended to provide recognition for those companies who have established a programme of environmental action designed to protect, and to continuously improve, their environmental performance.

A Summary Description

In 1992, the European Commission published a draft proposal, in the Official Journal of the European Communities, creating an Eco-Audit scheme or what is now referred to as the Eco-Management and Audit Scheme (EMAS). Through voluntary participation and publicly disclosed environmental reviews, EMAS attempts to create a framework for ensuring that organizations undertake measures to implement positive environmental management programs. The scheme is intended to complement other existing management and quality standards of practice.

Registration in the scheme is site-specific, in that a company can not register on behalf of its subsidiaries. In order to register, an organization must carry-out the following steps:

1. Initiate a comprehensive environmental audit of its activities. This could include a review

2. of its use and choice of raw materials, energy sources, transportation, methods of waste disposal and so forth.

3. Establish and document an internal environmental protection system, which, at the very least, should create a corporate environmental policy, program and environmental management system.

4. Issue a public statement in accordance to the requirements outlined in the EMAS document. The statement should include the following:

   • description of the organization's activities at the site with respect to its impact on the environment.

   • summary of quantitative data used for evaluation.

   • a set of policy goals and targets for improvement.

   • assessment of the site's compliance with regulatory requirements, company standards, and site objectives.

   • Reference to when subsequent issues will be discussed, and new audits will be performed.

5. Validate the statement through an accredited environmental auditor or verifier , and then submit it to a competent body . This body judges the submission on the accuracy of its content, validity of its audit practice, and internal procedures for generating its information.

   Once a submission is approved, an organization can register into the EMAS scheme; although only on a company wide basis, and not for specific products or activities. Deregistration can only occur if an organization fails to submit periodically up-dated audits, and not if it fails to meet its environmental targets.

   Even though EMAS is scheduled to become a regulation in the summer of 1995, there still remains a number of issues to be resolved, including:

   • how to determine the qualification of a verifier; and

   • which Government agency, of each Member State, will fall under the purview as a competent body .

Introduction to EMAS

EMAS is generally a site based registration system with due consideration provided to off site activities that may have a bearing upon the products and services of the primary site. Within the UK an extension to the scheme has been agreed for local government operations, who may also register their Environmental Management Systems to the EMAS Regulations.

EMAS requires an Environmental Policy to be in existence within the organisation, fully supported by senior management, and outlining the policies of the company, not only to the staff but to the general public and other stake holders. The policy needs to clarify compliance with Environmental Regulations that may effect the organisation and stress a commitment to continuos improvement. Emphasis has been placed on policy as this provides the direction for the remainder of the Management System.

Those companies who have witnessed ISO9000 Assessments will know that the policy is frequently discussed during the assessment, many staff are asked if they understand or are aware of the policy, and any problems associated with the policy are seldom serious. The Environmental Policy is different, this provides the initial foundation and direction for the Management System and will be more stringently reviewed than a similar ISO9000 policy. The statement must be publicised in non-technical language so that it can be understood by the majority of readers. It should relate to the sites within the organisation encompassed by the Management System, it should provide an overview of the compan's activities on the site and a description of those activities. A clear picture of the company's operations is the basis of the policy formulation.

In addition to a summary of the process, the statement requires quantifiable data on current emissions and environmental effects emanating from the site, waste generated, raw materials utilised, energy and water resources consumed, and any other environmental aspect that may relate to operations on the site.

The preparatory review is part of an EMAS Assessment. This is not the case for BS7750. The Environmental Review must be comprehensive in consideration of input processes and output at the site. This control process is designed to identify all relevant environmental aspects that may arise from existence on the site. These may relate to current operations, they may relate to future, perhaps even unplanned future activities, and they will certainly relate to the activities performed on site in the past (i.e. contamination of land).

The initial or preparatory review will also include a wide-ranging consideration of the legislation which may effect the site, whether it is currently being complied with, and perhaps even whether copies of the legislation are available. Many of the environmental assessments undertaken already have highlighted that companies, and in particular SME's, are often unaware of ALL of the legislation that affects them, and being unaware, are often not meeting the requirements of that legislation.

The company will declare its primary environmental objectives, those that can have most environmental impact. In order to gain most benefit these will become the primary areas of consideration within the improvement process, and the company's environmental programme. The programme will be the plan to achieve specific goals or targets along the route to a specific goal and describe the means to reach those objectives such that they are real and achievable. The Environmental Management System provides further detail on the environmental programme. The EMS establishes procedures, work instructions and controls to ensure that implementation of the policy and achievement of the targets can become a reality. Communication is a vital factor, enabling people in the organisation to be aware of their responsibilities, aware of the objectives of the scheme, and able to contribute to its success.

The environmental audit and review cycle

As with ISO9000 the Environmental Management System requires a planned comprehensive periodic audit of the Environmental Management System to ensure that it is effective in operation, is meeting specified goals, and the system continues to perform in accordance with relevant regulations and standards. The audits are designed to provide additional information in order to exercise effective management of the system, providing information on practices which differ to the current procedures or offer an opportunity for improvement. Under EMAS the bare minimum frequency for an audit is at least once every three years.

Most companies are used to producing an annual report and accounts describing the activities of the organisation over the previous year, and its plans for the future. EMAS generally expects a similar system for the company's environmental performance.

That there should be a periodic statement about performance during the previous period, a set of current performance data, and notice of any particular plans for the future that may have an effect upon the environmental performance of the organisation, whether detrimental or beneficial.

The peculiarity with EMAS is that the policy statement, the programme, the management system and audit cycles are reviewed and validated by an external accredited verifier. The verifier not only provides a registration service but is also required to confirm, and perhaps even sign, the company's periodic environmental statements.