1. Introduction
2. The Structure and Content of the Management System
3. Designing and Implementing a Management System
4. Auditing
5. What will the Verifiers be looking for?
References
Glossary of Terms
1.1 Many UK local authorities who have completed the first three stages of EMAS have felt that the annual Environmental Programme is sufficient to maintain and improve their environmental performance. At first sight the Management System and Audit can appear to be much bureaucratic effort for little reward. But local authorities who have gone some way towards implementing these stages unanimously agree that they are vital for achieving a high standard of environmental performance. To quote two EMAS coordinators:
"Without the Management System and Audit, there is no point having an Environmental Policy, Review and Programme."
"Procedures represent the arrival of environmental matters in normal practice and are the mechanism which stops things falling back to the way they were."
1.2 What are the benefits? These are summarised in the boxes below. Of course the main drawback to the Management System and Audit stages is the effort required to establish and maintain them. We hope that this guide will make that process easier, and convince most local authorities that the benefits are well worth the effort.
A Management System ensures
that:
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An Audit ensures that:
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1.3 The purpose of the Management System is to ensure that all stages of EMAS are properly implemented and continue to operate, and that all significant environmental effects are managed. The Management System has four levels:
i) The Corporate Overview and Coordination System
For managing EMAS corporately
ii) A Management System for the Operational Unit
For managing EMAS within the Operational Unit
iii) A System for managing each service activity with significant environmental effects
iv) A System for managing each significant direct environmental effect
Each level comprises a set of procedures. Examples of procedures for all the four levels are given in this guidance.
1.4 An Audit is a systematic evaluation of how well the first four stages of EMAS are operating. The Audit may be undertaken by internal local authority officers or external staff. However, the auditors must be independent of the section which they are auditing, for example from a different section. Section 4 describes how to undertake an Audit in your authority.
1.5 This guide contains numerous real examples from the three UK local authorities which have reached the stage of EMAS verification, i.e. Hereford City Council, Stratford on Avon District Council and the London Borough of Sutton. (Referred to simply as Hereford, Stratford on Avon and Sutton in the text). Hereford and Stratford on Avon have implemented EMAS across the whole authority, i.e. they have treated the entire authority as one operational unit. Sutton has opted for the alternative of introducing EMAS a few sections at a time. In their case each section of the Council is a separate operational unit. The examples are reproduced in boxes with thick black borders. The examples which have been included do not always exactly reflect the advice contained in this guide. This is because experience of the Management System and Audit stages of local authority EMAS is still very new, and we are all still learning.
1.6 EMAS is about an organisation managing its significant effects, i.e. its most important effects on the environment. There have been concerns that the Management System might encourage local authorities to lose sight of their really significant environmental impacts and become preoccupied with managing relatively minor effects, because the latter may be easier to control. For example, detailed procedures might be established for ensuring that relatively rare oil spills in car parks do not enter drains, while the council vehicle fleet continues to belch out noxious fumes across the district. Service effects are thought particularly at risk because generally it is more difficult to create procedures which manage these.
1.7 In fact, if EMAS is properly implemented, it should be impossible to lose sight of the Council’s most significant environmental impacts. The purpose of the Management System is to manage the Council’s significant effects, and any Council which is not doing so will not meet the requirements of either the Auditors or the Verifiers. The key is to:
i) Make sure that you have a consistent methodology for identifying the Council’s significant effects during the Environmental Review. List these in the Register of Significant Effects.
ii) Make a clear link from each significant effect to how it is being managed in the Environmental Programme and Management System.
iii) If necessary, resist pressure from the Verifier to shift your emphasis to effects which the Council considers are less significant. Ultimately, as long as you can justify your decision, the Verifier must accept the Council’s view of what is significant. (See section 5.)
1.8 All local authorities will have a financial management system with at least some documented procedures and a system of internal audits. There may also be Performance Review procedures. Many local authority sections and direct labour organisations are also introducing quality management schemes such as ISO 9000. These also require procedures, auditing and independent verification.
1.9 Trying to operate several parallel systems can be time consuming, confusing, and contradictory. If more than one procedure is set down for each activity, staff may well respond by ignoring them all. Also, environmental, quality and financial objectives may conflict, for example in purchasing. The answer is to integrate management systems. This brings any conflict into the open, and a decision must be made on the priority given to the different objectives. For example, there might be a procedure for the purchase of new IT equipment which:
The actions set out in this procedure may have been derived from financial, quality and environmental management systems, but ultimately the purchasers of IT equipment should only need to follow one procedure.
1.10 EMAS was designed to control significant environmental effects. It is perfectly possible to use the EMAS process to address wider sustainability objectives, such as impact on equity or quality of life, by broadening the definition of significance at the Review stage to include additional issues. For example, if, as part of the Local Agenda 21 process you have consulted local communities on which issues are most important to their quality of life, (perhaps encapsulated in a set of local sustainability indicators), then these will provide a natural addition to those issues which must be covered by EMAS. However, these aspects of the system may not considered by the Verifier when assessing you for EMAS registration, and may need to be treated as part of a separate but integrated management system, just like financial, or quality management.
1.11 But the expansion of EMAS should be treated with caution. Remember, once an activity is determined as significant, then the same standards of recording and auditing will be needed as for all other significant effects, and each activity will have to be managed through the Programme and Management System, just as with traditional EMAS. Trying to cover all sustainability issues at your first attempt could be extremely demanding. We would recommend that you get the official version of EMAS fully operational first, then think about widening the coverage once it is running. If you try to cover all aspects of sustainability the first time round you may never get past the Review stage.
1.12 If the Council has prepared a Local Agenda 21 Strategy then this will include a programme of action covering both the Council and its partners. The actions to which the Council is committed should be incorporated into either the EMAS Environmental Programme, or into programmes for other appropriate council strategies, e.g. Economic Development.
Back to 'Contents'
2.1 This section describes what must be included in the Management System, factors which contribute to a workable and lasting Management System, and how to document the System. The next section discusses how to go about designing your Management System.
2.2 The Management System is defined as ‘that part of the overall management system which includes the organisational structure, responsibilities, practices, procedures, processes and resources for determining and implementing the Environmental Policy.’ There are four levels to the Management System:
i) The Corporate Overview and Coordination System
ii) The Operational Unit
iii) Service activities with significant environmental effects
iv) Significant direct environmental effects
Each level comprises a set of Procedures.
2.3 The key to a successful Management System is:
2.4 A procedure always describes:
Who will take the action - Responsibility
What action will be taken - Action
How and where the action will be recorded - Recording
Recording is necessary so that Auditors, Verifiers, or any one else who is interested, can check that the procedure is being followed. Below is an example of a simple direct effects procedure designed to manage water consumption in public conveniences. Procedures like this, which control the environmental impact of significant activities, are known as an operational control procedures. As you will see, the example includes the essential components of all procedures:
Responsibility - the cleaning operatives and Building Cleaning Supervisor (BCS)
Action - what they are going to do
Recording - recording of faults and repairs
| Equipment
Checks and Repair of Public Conveniences 1. All cleaning operatives will, on appointment, be trained to check operation of equipment and report any repairs which are necessary. 2. The following will be checked by operatives: Personnel sensors are operational Percussion taps are working correctly That there are no water leaks or dripping taps 3. The operatives will report any equipment which is in need of repair immediately to the Building Cleaning supervisor (BCS). 4. The BCS supervisor will arrange for repair of equipment within 24 hours of receiving a report. 5. The BCS will keep a record with time and date of all faults reported and when repairs were completed. The records will be held on the public convenience maintenance file held by the BCS. EMAS Water 4, Version 3, Aug 96, 1/1 |
2.5 A recent guide to quality management lists:
Four Principles of Effective Procedures
1. Understandable
2. Actionable
3. Auditable
4. Mandatory
(From: Achieving BS EN ISO 9000 by P.Jackson and D. Ashton)
2.6 If procedures are to be of any value then they must be both possible (actionable), and relatively easy to follow (understandable), otherwise they will almost certainly be ignored. Procedures are not discretionary, they must always be followed (mandatory). However, discretionary decisions may be included within a procedure. For example, an IT purchasing procedure may require an officer to weigh the savings on the purchase price of a less energy efficient model against the long term cost of energy saved when running a more efficient model. Finally, there must always be some sort of record to demonstrate that the procedure has been followed (auditable).
2.7 Staff faced with a plethora of documented procedures can soon feel disempowered and uninterested in their work. EMAS should not aim to document every action an individual takes. It should focus only on those activities which are really environmentally significant, and where not following the procedure could have a serious environmental impact. Staff motivation should also be maintained by:
2.8 As far as possible procedures should be designed so that the people who have to implement them have no more to do than is absolutely necessary. One important pit-fall to avoid is the creation of additional paper-work. It is not necessary to create, say, a new form which demonstrates that the Environmental Programme has been considered by all the relevant Working Groups and Committees. The minutes of these Committees are quite enough. The Auditor or Verifier just needs to be able to check the records of the appropriate meetings. Similarly, if a procedure is developed for incorporating environmental standards in Council leases as they come up for renewal, then the implementation of this procedure should be evidenced by a new clause in all the latest leases. Always try to avoid the creation of new forms or records, and where possible integrate existing systems into EMAS.
2.9 Make sure that a procedure describes what you really intend to do. Remember, Auditors and Verifiers will be checking that you are following a procedure, so do not commit yourself to more than you can manage, and be sure that the procedure accurately describes what you intend to do.
| Stratford on Avon found that verifiers followed procedures to the letter. So getting the wording of procedures exactly right is crucial. For example, Stratford on Avon established a procedure for assessing the environmental performance of companies tendering for Council contracts. The verifier asked why they were not following this procedure for every contract let for small repairs in the Council offices. Stratford on Avon have now amended the procedure to state that it only applies to ‘main service contracts’. Similarly a procedure for control of energy and water consumption in public conveniences stated that ‘inspection details will be recorded by the BMO including the date of inspection, any defects noted and corrective action taken.’ The verifiers asked to see the records, but only records of defects had been recorded. To follow the procedure as written would have resulted in extra work and was not what was intended. The procedure was amended to say that `any defects found will be recorded by the BMO, including the date of inspection and corrective action taken.’ |
2.10 As a minimum, UK LA-EMAS Guidance suggests the following topics must be covered in the Corporate and Operational Unit (Operational Unit) Management Systems:
Corporate Overview and Coordination System
1. Overall responsibility for EMAS in the Council naming lead Committee and officer and their responsibilities in regard to EMAS
2. Development and periodic review of the Environmental Policy
3. Inter-departmental coordination of environmental issues including membership and responsibilities of Environment Committees, Working Groups, Coordinators
4. Environmental overview of budgets
5. Storing and disseminating environmental information (including legislation).
Overall Management System for the Operational Unit
6. Environmental review of all new activities and incorporation of new activities onto the Register of Significant Effects where appropriate (Environmental assessment.)
7. Developing, budgeting for and monitoring the Environmental Programme
8. Holding Regular Environmental Audits
9. Periodically reviewing and revising the Management System
10. Preparation of and distribution of the Public Statement
11. Provision of information to the public and consultation on environmental issues
12. Dealing with complaints about environmental performance usually part of general Council complaints procedure
13. Staff / Elected Member information and training related to environmental impact and EMAS including training for new Elected Members and staff about their specific responsibilities under EMAS
14. Ensuring that contractors apply environmental standards equivalent to the local authority’s own
15. Dealing with non-compliance with, or deficiencies in, the Policy, Programme or Management System
2.11 It is not essential for each of these topics to have its own separate procedure. Procedures 1 and 2, for example, might naturally combine into one procedure.
2.12 If the whole Council is intending to implement EMAS, then the two Management Systems may be combined into one Corporate Management System.
| London
Borough of Sutton Corporate Overview and Coordination Procedures 1. Training needs analysis (amended) 2. Contract Development (all CCT and contracts above £75,000) 3. Environmental assessment of policy proposals 4. Environmental assessment of budget proposals (both capital and revenue) including assessing the environmental impact of cuts exercises 5. Environmental assessment of minor proposals such as TPPs, and bids for resources such as SRB and European funds 6. Environmental assessment of Committee reports 7. Procedure for reporting progress on EMAS implementation and performance of system 8. Possible corporate impact on direct effects re energy, water and waste |
| Stratford-on-Avon
District Council Procedure COCS 5 Inter-departmental Co-ordination 1. Inter-departmental co-ordination on environmental issues will be undertaken by two inter-departmental working groups - the Environmental Steering Group and Grassroots. 2. The Environmental Steering Group will carry out the inter-departmental co-ordination tasks identified in the Terms of Reference of that group appended to this procedure and agreed by ESG on 2 February. 3. The group will be under the Chairmanship of the Director of Environmental Health. 4. Grassroots will carry out the Inter-Departmental responsibilities identified in the Terms of Reference of that group agreed by ESG on 2 February and held by the Chairman of Grassroots. 5. The chairman of Grassroots will be a member of the Environmental Steering Group. 6. Evidence of decisions and actions taken with regard to Inter-Departmental Co-ordination will appear in the minutes of Environmental Steering Group meetings (to be held by the Environmental Co-ordinator) and Grassroots meetings (also held by the Environmental Co-ordinator). V1/COCS5/OCT95 |
| Stratford-on-Avon
District Council Corporate Overview and Co-ordination System Procedures 1 : Development and Review of the Corporate Environmental Policy 2 : Environmental Review of all New Activities 3 : Developing and Monitoring Corporate Environmental Programmes 4 : Auditing EMAS 5 : Inter-Departmental Co-ordination 6 : Environmental Overview of Budgets 7 : Storage and Dissemination of Environmental Legislation and Information 8 : Public Information and Consultation 9 : Dealing with Complaints 10: Information Dissemination and Training for Council Staff and Members 11: Ensuring that Contractors Apply Environmental Standards Equivalent to our own 12: Non-Compliance with or Deficiency in the Policy, Programme or Management System 13: Reviewing and Revising the EMA Management System 14: Overall Responsibility for the Implementation of EMA Corporately and by Department 15: Compliance with and enforcement of environmental legislation 16: Controlling documentation relating to EMAS |
2.13 Direct Effects are the effects which the Council has on the environment which are directly under its control. Service effects describe environmental impacts which the Council may have through its influence on the behaviour of its residents, businesses, or visitors. The terms control and influence are increasingly replacing the terms direct and service effects.
2.14 While local authorities need to demonstrate that they are managing all of their significant effects, this does not mean that a local authority must have a written procedure in place for every significant effect before it can complete verification.
2.15 Documented work instructions are only necessary where absence of such instructions could result in infringement of the environmental policy.’ So if you think that some significant activities will automatically meet the Council’s environmental standards, or that well established procedures exist even if not documented, and that you can convince the Auditor and Verifier that this is the case, then there is no need to prepare written procedures. However, there must be some way of demonstrating (records or some other form of evidence) to the Auditor or Verifier that the unwritten procedure is being followed, i.e. an Audit trail.
| Hereford found that where a robust procedure is obviously in place, even if not written down, then Verifiers are prepared to accept this. An example was the control of development applications. |
2.16 Secondly, it is satisfactory at the time of verification to demonstrate that:
| Stratford on Avon found that although verifiers did not rigidly look at every significant effect to check that each had procedures, those effects that they did look at had to be properly managed. |
2.17 It is not acceptable to say that a significant effect has not been included in the Management System because it is out of the control of the local authority. If a local authority has no potential to directly control or cannot be expected to have reasonable influence over an environmental impact, the effect is not ‘significant’ in EMAS terms and should not have been included at Review stage.
2.18 It is best to prepare a limited number of procedures initially. Otherwise you may never get the Management System in place. It will be much easier to expand the system over time.
2.19 Where you have decided to prepare an Effect procedure, start by asking:
The procedure(s) should cover:
1. Operational control
2. Monitoring and reporting of trends in the effect
3. Accidents and abnormal operating conditions. Only for situations where accidents/abnormal operating conditions are likely to lead to significant environmental damage.
4. Research and information collection and dissemination of good environmental practice in relation to the specific effect
5. Staff training in the implementation of the relevant sections of the Programme and procedures for the effect
2.20 Frequently these can all be covered in one procedure. Thus, the example of water consumption in public conveniences (para 2.4) already covers training of the cleaning operatives. It might also have stated that the BCS will: monitor water consumption in public conveniences and report consumption annually to the Environmental Health Committee (monitoring and reporting); and regularly check trade journals and ask suppliers about new water efficient equipment (research and information collection).
2.21 There is a debate over what constitutes an ‘effect’. Hereford have defined these very broadly, eg. waste or air quality. Stratford on Avon have defined them more narrowly, e.g. waste from offices, impact of the land use plan on air quality. There is no right answer, but obviously if broad headings are used then a number of procedures will be needed for each, whereas only one procedure may be necessary for the narrower headings.
2.22 There should be one named manager for managing each (authority or Operational Unit wide) significant direct effect, e.g. for Energy and Water Consumption in Council buildings, Staff Transport, Council Vehicles, and Office Waste. (In a small Operational Unit this might all be the same person.) There may be several procedures grouped under each direct effect. For example, if EMAS is being implemented across the whole authority, which has a central unit with responsibility for water consumption in public conveniences, in office buildings and in leisure centres, then procedures for all of these might be included under the authority wide management system for water consumption. But, if EMAS is only being implemented in, say, the Vehicle Maintenance section, then there might only be a procedure for managing the use of water when washing vehicles.
2.23 It is often easiest to cover all of the significant effects of a service activity in one procedure. So, if the Economic Development Unit’s advice to businesses on property availability is seen as having a potentially significant impact on transport use and demand for water resources, then a procedure which covers both of these issues could be developed.
| Hereford
City Council Environmental Management System Lorry Wash Operating Instructions During Day 1. Lorries - Trailers. Drivers clean out inside of vehicles with broom and fork, first throwing solid waste in a pile in the bottom of the wash bay. A token is then purchased from the metre and used for 20 minutes wash. 2. Once the vehicle is washed out any remaining time is used to wash outside of the vehicle. 3. Several times during the day a Council employee pushes the waste towards the back of the wash with the tractor (when available) and swills down wash bays with a spare pipe to prevent build up of soil and waste. 4. At the end of the day all the waste lying at the bottom of the wash is pushed to one end and placed on the raised back of the wash where it is left to rot. The bays and bottom of the wash are then washed down. 5. Stored waste on the back of the wash is used by allotments and gardens around Hereford. If there are no orders it is disposed of with market waste. 6. The waste is generally cleared away every six weeks and a new pile is started. 7. Waste water and sediment flows along drains at the bottom of the wash to a small settling pit where most of the sediment is caught, however, floating waste and straw flows into a larger settling tank where it is drawn out by sludge disposal lorry twice a week on Tuesdays and Thursdays. Surplus water on busy days flows out of second tank into main sewer. ISSUE NO.2 DATED: NOVEMBER 1995 ISSUED BY R.A. FORD AUTHORISED BY This is a Controlled Document in the Environmental Management System and can only be issued by R.A. Ford. If there are any changes please inform the issuer at once. |
| Hereford
City Council Procedure for ecological comment on planning applications affecting Sites of Importance to Nature Conservation (SINCs). Issue No.2, 3 June 1996 The following procedures are adopted to ensure that suitable ecological advice is made available on planning applications affecting Sites of Importance to Nature Conservation (SINCs): 1. SINCs are shown on the Hereford Local Plan: Deposit Draft Proposals Map dated April1994, as proposed to be modified (Proposed Modifications, June 1996). 2. Planning applications which are within a SINC are identified by David Dugdale and Phil Butts on registration. This is noted on the computer file and case file. Applications which are outside but likely to affect SINCs are also identified by these officers and noted. In cases of doubt, for instance where an application is some distance from a SINC but could have an effect through such factors as water pollution, land drainage, alteration to the water table, or increased activity and disturbance in the locality, the precautionary principle is applied and the application identified as of relevance. 3. All planning applications identified as of relevance are sent by Development Control to the Environmental Promotion Unit (EPU) and to the Herefordshire Nature Trust (HNT) for comment with a clear indication of the timetable for response. Paperwork sent should include a copy of the application, any supporting material, and a set of submitted plans. 4. The aim should be to provide advice on the impact of the planning application on the scientific importance, nature conservation value (including impact on the City’s green network of sites and corridors), and value to the local community of SINCs. In the case of the applications sent to EPU, after initial vetting by Trish Marsh these are passed to Shawn Fleet (Local Plans) for formulation of comment on behalf of EPU. This work is timelord coded to Development Control. Comment written by Shawn Fleet is then verified by Trish Marsh before a response is made by EPU to Development Control. 5. Where Nature conservation matters arise which impinge on areas for which other consultees within the City Council have responsibility, the EPU as advised by Shawn Fleet should on identifying these matters liaise direct with the relevant consultee to agree a common position. Examples of such areas are drainage (foul and surface) and landscaping. Where agreement cannot be reached, separate position statements should be submitted to Development Control which allow the areas of disagreement on matters pertaining to nature conservation to be identified. 6. Cases will arise where the EPU and/or HNT on assessment of an application consider that further information or expert advice/assessment is required in order to provide a proper response. In these cases and after consultation with the case officer this information will be sought by Development Control as follows: (a) from local specialist groups, or (b) from the developer in accordance with Local Policy Plan NC6 7. Where Sites of Special Scientific Interest are concerned there are additional consultation arrangements with English Nature. The River Wyre is a SSSI and a SINC and the Lugg Meadows and River Luggs SSSIs lie outside but about the City boundary. The General Development Order requires local planning authorities to consult English Nature before granting permission for development in an SSSI. There is also a requirement to consult in respect of development within notified consultation areas. No consultation area has yet been notified to the City Council by English Nature and in these situations the consultation requirement refers to development which in the opinion of the local planning authorities is likely to affect the SSSI. English Nature have issued interim advice to local planning authorities setting out general criteria for such consultations over development in the vicinity of SSSIs (by letter dated 8.2.94 held by Phil Butts) and have indicated that they are ready to advise informally of the need for any formal consultation. The responsibility for ensuring that these conditions are carried out lies with Development Control. 8. Protected species. Where development proposals are made for sites thought to form a protected species habitat, the EPU, HNT and English Nature (Protected Species Officer) are consulted by Development Control. 9. A standard form is used for the submission of EPU policy comments to Development Control. This form provides the basis of a database which is used to assess changes to SINCs due to development. The results of this assessment are reported annually to the City Council’s Environmental Management Group by David Nicholson, Planning Directorate Environmental Representative. Contact the Planning Directorate’s Environmental Representative, David Nicholson, if you wish to amend this. |
| London
Borough of Sutton - Waste Management Team Procedure 1 : Transport Use as a Direct Effect EMAS PROCEDURE NOTES Waster Management Team Reference EMAS/Proc 1/995 EMAS Procedure notes Procedure number 1 Transport use as a Direct Effect Objective : To reduce the Environmental damage caused by the use of transport in contract management. Target : 10% reduction in car mileage by 1/1/96 : 20% reduction in car mileage by 1/1/97 : 30% reduction in car mileage by 1/1/98 Procedure Note 1. Before commencing use of motor vehicle in connection with undertaking Council duties, the team member should consider the following points in order to minimise the environmental effects:
2. Car allowance daily log sheets (as shown in Appendix EMAS/proc 1b) shall be completed daily by team members following completion of their days work. 3. Monthly car mileage sheets (as shown in the Appendix EMAS/Proc 1a) shall be handed to Malcolm Kendall (or such a person as nominated by Malcolm in his absence) on the last Monday of each calendar month. 4. Details from the submitted monthly car allowance sheets shall be entered onto Excel spreadsheet CARALLOW, currently stored on personal computer on Malcolm Kendall’s desk. 5. Details to be recorded shall include the following:
6. As the details are entered, the spreadsheet will display the accumulative total for the current fiscal year for each team member. 7. Details of the accumulative car mileage for the Waste Management team is displayed within the spreadsheet on page headed Accumulative total, together with the previous fiscal year mileage for comparison and monitoring purposes. 8. Corrective action shall be introduced by Malcolm Kendall should the levels of car usage by the Waste Management team exceed the yearly target. 9. Following details of individual team members claims being recorded, each monthly car mileage sheet shall be signed and authorised by Malcolm Kendall (or such person as nominated by Malcolm in his absence). 10. Once signed and authorised the sheets shall be forwarded to Anne Jennings (or such person as nominated by Anne in her absence), who shall undertake a numerical check of all the claims. 11. Following completion of the numerical checks, Anne shall forward these forms to payroll section, based at Sutton Gate. Waste Management Team Sutton Sheet 1 of 1 Document Number DES4 (Waste Management) Procedure and Guidance Checked by Date: 6/10/95 Notes Doc. No EW2006 |
| Stratford-on-Avon
District Council Procedure DESA EandW2 Operational Control of Energy and Water Consumption in Council Offices Schedule of Equipment 1. The Engineering and Building Services Manager (EBSM) will keep a schedule of all machinery, equipment and appliances in council offices which may affect consumption of energy or water in a significant manner, with the exception of IT equipment (i.e.computers, printers and photocopiers). The schedule will identify the buildings in which the items are located. Inspection and Repairs 2. The custodian will inspect every month : all boilers all light fittings all radiators all sanitary fittings all other machinery, equipment or appliances which are listed on the schedule referred to in point 1 in the following buildings : Elizabeth House, Stratford-upon-Avon The Grange, Southam 11, Telegraph Street, Shipston-on-Stour Grove House, Alcester and will record the date of the visit with a note regarding any action required 3. Boilers will be inspected to check that: they are operating correctly and efficiently. 4. Light fittings will be inspected to check that: the lights are working and that there is no flickering: timers are working correctly: light fittings are clean 5. Radiators will be inspected to check that: thermostats on radiators are operational: there are no air locks in radiators: there are no leaks 6. Sanitary fittings will be inspected to check that: there are no leaks from taps or pipes: percussion taps are operating correctly: sensors on urinals are operating correctly: cisterns fill to required level (occasional check) 7. All other machinery and appliances will be checked to ensure that they are operating efficiently and safely. 8. Monthly inspection details will be recorded by the custodian, including the date of the inspection and any defects noted. 9. On completion of the inspection the custodian will immediately notify the EBSM of any serious defects and the EBSM will arrange for any corrective action taken. Minor defects will be dealt with on site by the custodian. 10. The custodian will record the consumption of water, gas and electricity by meter readings on at least a monthly basis. 11. The custodian will record any unexpected deviations (more than 10% in a single month as compared to the same month in the previous year, or more than 5% over a complete year) from normal consumption, and will inform the EBSM who will take action to identify the cause of the deviations. The custodian will immediately notify the EBSM of any defects and the EBSM will arrange for the corrective action to be taken. 12. The EBSM will arrange for all new custodians, or for custodians transferred to different buildings, to receive training in what to look for during an inspection, and what machinery, equipment and appliances should be inspected. Servicing of Equipment 13. The EBSM will maintain a service contract for all main items of machinery (boilers, lifts, automatic doors and solar energy panels) which will ensure that items are serviced in accordance with the manufacturer’s recommend service frequency Records 14. Records relating to this procedure will be kept in the appropriate property file held by EBSM, including :
V1/DESAEandW2/FEB96 |
| Stratford-on-Avon
District Council Procedure DESA PL1 Monitoring and Reporting Procedure on Implementation of the Local Plan (Covering the following strategies : Land Use, Transport, Housing, Employment, Recreation,Tourism, and Conservation) 1. The Assistant Director of Planning (Policy and Office Management) will have overall responsibility for monitoring the implementation of the Local Plan 2. The Assistant Director of Planning (Policy and Office Management) will identify the appropriate officer for monitoring progress on the various elements within each of the 7 strategy areas in the Local Plan that have been identified as having a significant effect. 3. The identified officer will collect and collate the following information (where possible) for each element :
4. The material gathered for each strategy area will be analysed by the Policy Group in the Planning Department and will be made available for inspection/purchase on a selective basis 5. Based on the annual monitoring exercise, the Director of Planning will submit an annual report to the June or September meeting of the Planning Committee 6. An annual monitoring report will be published and will be available for public inspection at the Planning Department reception as well as at District Council Sub-Offices, local libraries, etc. It will also be circulated to Parish/Town Councils and other appropriate organisations. 7. Records relating to this procedure will be kept in : a) monitoring files held by the Policy Team in the Planning Department b) records of the Planning Committee held by the Committee Administrators V1/DESAPL1/FEB96 |
2.24 EMAS requires participating organisations to comply with ‘all relevant regulatory requirements.’ This condition is included because it would be unacceptable for a firm or local authority to be registered under EMAS while also breaking environmental regulations. You must therefore be prepared to demonstrate to auditors or verifiers that you are complying with all relevant regulations. However, this does not mean that all local authority activities which are subject to environmental regulation must be defined as significant effects and managed within EMAS. Support Material on Environmental Effects Evaluation ...(weblink)... gives advice on how to determine which are your significant environmental effects, i.e. those effects which have the greatest impact on the environment. You may feel that, of your activities which are subject to environmental regulation, only some contribute to the local authority’s most significant environmental impacts. If you do not classify regulated activities as significant effects, then they do not have to be included in the Management System.
| Hereford listed which officer is in charge of complying with each piece of legislation. The Verifiers could then talk to that officer. Written procedures were not essential, but if the lead officer appeared not to understand the legislation or did not have adequate resources or systems to manage compliance, then this would be a non conformity, i.e. failure to meet the EMAS Regulation. |
2.25 Since all Councils which are implementing EMAS must as a minimum cover the topics listed for the Corporate and Operational Unit Management System (para. 2.10), there will undoubtedly be a lot of similarity between these procedures in different Councils. It would certainly be helpful to look at what another Council has done before drafting your own procedures. But remember, if you are opting for Council-wide EMAS then look at a Council that is doing the same, and likewise if you are opting for a few Operational Units at a time.
2.26 However, it will never be possible to copy exactly what another Council has done. All Councils have their own way of doing things. One Council might, for example, decide that all Environmental Programmes should be considered by Policy and Resources Committee, while another might think that relevant service Committees are sufficient. One Council might feel that the Chief Officers’ Group must have a chance to comment on the Environmental Programme, whereas another would want the Green Team to be able to give their views. Inevitably, then, even corporate and Operational Unit procedures will have to be adapted to your particular circumstances.
2.27 There is likely to be much greater variation in the Management System for Effects, for two reasons:
For example, a Council such as Bristol, with large land ownership in the City, might decide that Council leases are a significant service activity, whereas a large rural authority might attach more importance to the impact of travel to Council facilities. Secondly, the way a Council is organised is likely to vary considerably between authorities. In one all purchasing of IT equipment may be by the IT department, in another by departmental IT advisors.
2.28 Once again, it will undoubtedly be useful to look at what other councils have done, but keep in mind that such procedures may have to be radically altered, and should never be unnecessarily imposed on what is already satisfactory current practice by your own sections. For effects procedures it is therefore generally better to start by looking at current practices, and adapting these as necessary.
2.29 The decision to declare the whole authority as the operational unit, or to define different Council sections as operational units will affect the Management System in several respects:
i) As explained above, operational unit and corporate procedures may be merged if the whole council is the operational unit
ii) The process of devising and agreeing procedures is likely to require less corporate working if the LA is split into operational units for EMAS.
iii) Preparing corporate overview and coordination procedures may be more problematic for an individual Operational Unit because the unit will not have the authority to change corporate procedures.
iv) Some direct effects are naturally best dealt with corporately, e.g. purchasing of office equipment, waste disposal from offices, even if separate Operational Units are applying for registration. Where possible the Operational Unit should try to persuade the Council to manage these direct effects corporately. If the effect is being managed corporately, then the Operational Unit will not need to have a separate management system for the effect.
2.30 Councils often have written procedures which meet EMAS requirements, e.g.Complaints procedures. In this case the list of EMAS procedures included in the Environmental Management Manual (see below) can simply refer to the name and number of the relevant procedure.
2.31 Procedures which are too specific can get out of date very quickly, and you may find that you are having to update and distribute new procedures every 6 months. Try to design procedures to avoid this problem. Referring to other documents which may be updated independently is a useful device. For example, instead of listing what species must be protected in the grounds maintenance contract, say that all species listed in the local Wildlife Trust’s Priority Species List, or your local equivalent, must be protected.
2.32 EMAS requires the local authority to establish documentation with a view to:
(a) present in a comprehensive way the environmental policy, objectives and programme;
b) document the key roles and responsibilities
c) describe the interaction of system elements
Usually this information is combined into an Environmental Management Manual.
2.33 You should keep a list of all the authority’s procedures in the Manual, along with the date and number of the latest version and a distribution list for each procedure. It is not essential to keep a copy of all procedures in the Manual, although most local authorities have found it useful to do so.
2.34 It will also be useful to include in the Manual (especially for Auditors and Verifiers):
| London
Borough of Sutton Corporate Overview and Coordination Procedures Extract from EMAS Overview Document 5. Documents 5.1 Arrangements and numbering. The numbering of the documents relates to the Department in which the Operational Unit is situated, the stage of the Management System to which the document relates and the specific aspect of the programme or Management System. The documents are organised as follows. (i) Overview document is numbered OV1-100 Supporting documents in Annex Volume are numbered as main document with suffix S. (ii) All remaining documentation is by operational units numbered as follows.
For example Point 7 of the Management System for the Purchasing Unit in the Environmental Services Department will be numbered DES1/MS7. 5.2 Where can information be found. (i) Overview document is attached to each unit based management system and hence available to every unit. (ii) Unit specific documentation is held in that particular unit. 5.3 Management of Records Records related to Baseline Information and Research and use of procedures and guidance are to be retained within the specific unit for a period of five years from the date of publication of the Environmental Statement for that year. This will allow for the effective monitoring and auditing of the management of environmental effects. |
2.35 Most of the examples of procedures included in this guidance are written as numbered paragraphs. Sometimes procedures may be easier to follow if they are presented as flow charts or checklists.
2.36 However they are written down, procedures must include:
It may also be useful to include:
This may seem like bureaucratic overload at the moment. But when you have revised the procedure 4 times, and suddenly discover that the Area Housing Office, or your equivalent, is still following version 2 from 3 years ago, you will begin to realise the benefits. Furthermore, the Auditors and Verifiers will be checking that all relevant staff are using the latest procedure.
2.37 Procedures can often be kept shorter by cross referencing to other procedures as appropriate. For example, the procedure for Environmental Review of all new activities might note that, where a new activity which is subject to tender is considered environmentally significant, then procedure no.x (for ensuring that contractors apply environmental standards equivalent to the local authority’s own) will be invoked.
| Hereford
City Council Environmental Management Manual Contents Page Section Index (BS 7750 clause numbers in brackets) 0. Document Control (4.7.2) 1. Environmental Effects Evaluation and Register (4.4.2) 2. Register of Register, Regulatory and other policy requirements. (4.4.3) (includes signposts to sources of legal information) 3. Environmental Policy (4.2) 4. Organisation and Personnel - Responsibility, Authority and Resources (4.3.1 and 3.3) 5. Environmental Objectives and Targets plus (4.5) Directorate management programmes for targets (4.6) 6. Operational Control Measures (4.8.2) plus Directorate management programmes for them 7. Verification (4.8.2 and 3) 8. Non-Compliance and Corrective Action (4.8.4) 9. Audit (4.10.2 and 3) 10. Training (4.3.4) 11. Contractors (4.3.5) 12. Communications (4.4.1) 13. Emergency and Abnormal Operation (4.7.1) 14. Records (4.9) 15. Review Plan (4.11) Date: 16/5/95 Authorised by: PPM Review by April 96 Issue number 2 index doc |
| London
Borough of Sutton DES1/MS10.1 Environmental Statement Implications |
2.38 EMAS requires local authorities to ensure that contractors apply environmental standards equivalent to the local authority’s own. This may be dealt with as follows:
i) Undertake an Environmental Review of all Contracts, and identify which are environmentally significant and in what ways they are significant.
ii) Establish a corporate procedure to ensure that (over time) all contracts which are environmentally significant meet the objectives set out in the environmental policy. This, for example may require that, as each contract comes up for renewal, the contract manager will introduce procedures for improving the environmental impact of the contract by introducing procedures to cover the items in point (iv) and (v).
iii) The Environmental Programme may also list which contracts are to be renewed over the duration of that Programme. In some case officers may feel that there might be an opportunity to improve the environmental standards before the contract is renewed. As one-off opportunities, these should be included in the Programme rather than the Management System.
iv) As a contract comes up for review, procedures specific to that contract should be established which, for example, set out:
v) Environmental standards should also be built into the contract specification.
2.39 It is generally preferable to develop environmental standards based on contract outcomes rather than inputs. This allows you to define what you are trying to achieve environmentally, not how it is going to be done. It also gives the contractor more flexibility to find the best way of meeting the standard which has been set. For example, a contract to run the Council’s swimming pools might specify a minimum level of water pollution resulting from the disposal of pool water, rather than specifying what chemicals and disposal methods the contractor should use. Similarly a cleansing contract might specify that the contractor will reduce the amount of waste arising from households by 10% over the duration of the contract, but leave it to the contractor to experiment with the most successful way of achieving this.
2.40 It is very likely that the Council will already have procedures for assessing the quality of potential contractors, for tender evaluation, and for monitoring performance. Environmental features should be incorporated into these existing procedures.
| Stratford on Avon has found that the issue of anti-competitiveness has been raised by contractors when the council has asked for confidential information such as water and energy consumption in leisure centres. However, they have found that contractors have been prepared to assist even where the information that they have asked for goes beyond the requirements of the contract, although in one case the Council have had to agree that the information will not be made public. This means that they can not include the information in their public Statement, but it does allow Stratford on Avon to trigger responsive action where the information |
2.42 Any local authority will have some management procedures in place, although not necessarily written down. Typical examples are guidance or procedures for letting contracts and for developing training plans. These procedures can usually be relatively easily adapted to take account of EMAS.
2.43 There are also formal standards such as the quality standard ISO 9000 which requires documented procedures. You will probably find that, whatever standard you start with, the first effort at establishing and documenting a structured management system will be the hardest. After that it should usually be possible to add to and build on existing procedures to meet the objectives of other management systems. Always avoid having more than one procedure for a particular activity, instead incorporate the requirements for the different standards into one procedure.
| London Borough of Sutton Training Programme for 1995 onwards 7.2. Training Programme for 1995 onwards (i) Environmental issues to be included in every corporate and department induction. (ii) Pre-training for Operational Units embarking on EMAS as a half day course (see attached document (OV2.2.7.1.S). (iii) Continuation of a two day course for units embarking on EMAS. Training programme, needs and achievements. |
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3.1 The previous section discussed what you need to include in a Management System. This section considers how to go about devising a Management System which is tailored to your needs.
3.2 The key to designing a useful and workable management system is to make sure that:
i) You have only defined as significant those effects which are really important (Otherwise you will be trying to manage too much and be swamped by procedures)
ii) The people who will have to implement the procedures are involved in their design (Otherwise the procedures are likely to prove unworkable for both technical reasons and because they will meet staff resistance.)
3.3 Procedures should not be seen just as a burden - even a necessary one. If staff are persuaded of the importance of their own work to the Council’s environmental performance, designing procedures can be a rewarding and creative process. It may also give formal recognition to existing good practice.
3.4 There is no right way to prepare procedures. Different Councils have used different methods. In a small Operational Unit one officer may be able to draft all of the procedures. For a Council wide system a substantial number of officers will probably have to be involved. This section gives some suggestions as to how to go about it.
3.5 Unless the Council or Operational Unit has already embarked on quality management, documented procedures are likely to seem very unfamiliar to Council staff. It is advisable to begin the process with a practical training session about procedures for those staff who will have the task of drafting them.
3.6 The list (above) of what topics need to be covered by corporate and Operational Unit procedures should make preparing these not too difficult. Often it will be a case of writing down what already happens, e.g. for the inter-departmental coordination of environmental issues. For others, e.g. Environmental Auditing, new procedures will have to be created.
3.7 The officer responsible for leading the implementation of EMAS, who may be a senior manager in the Operational Unit, should coordinate the design and writing of Corporate and Operational Unit procedures. There are two possibilities. He or she might do a first draft of procedures and circulate these for comments, or hold meetings to discuss the drafts with all the managers who will have the task of implementing the procedures. Alternatively the managers could hold a brain-storming session to write the first draft of the procedures, and then allocate the task of tidying up these first drafts among themselves or to the EMAS lead officer. Council Committees have a role in corporate procedures, and some Councils may choose to involve elected members in the design of procedures which will affect them.
| In Stratford on Avon the Environmental Steering Group (ESG), which is comprised of senior officers of the Council, spent half a day brainstorming all of the corporate procedures, and then each took a couple of procedures to finalise. |
3.8 Designing Effects procedures will need a different approach, and is likely to require more effort. For a start, there will be more of them. Secondly, they will encompass a very diverse set of activities, from housing maintenance to enterprise support. It is best to start from the Register of Significant Effects. It should be fairly obvious which officer has responsibility for each significant direct effect and service activity. In a small Operational Unit the manager of the Unit might be responsible for all of these.
3.9 Section 2 discussed which significant effects need to be covered by procedures. It is up to the responsible officer to decide (usually in consultation with the EMAS coordinator or an Environment working group) if:
i) The effect needs to be covered by documented procedures
ii) There already exists a documented procedure which (with adaptations) meets EMAS. If yes then all that is needed is to supply the name and number of the existing (adapted) procedure for inclusion in the EMAS Manual.
iii) The significant effect is already being managed, in which case what they are doing just needs to be written down, possibly with improvements added.
iv) The significant effect is not being managed, in which case they should:
3.10 Councils always have corporate procedures, but few councils currently meet the corporate and overall Operational Unit management structures required by EMAS. It is likely that many of the corporate procedures will have to be created from scratch, but they should be relatively simple to devise.
3.11 Almost certainly, some effects procedures will already be in place. Where an activity is regulated, for example waste disposal or use of hazardous chemicals, it is highly likely that there will already be a procedure and that it may even be written down. For many other activities, such as what to do with used oil and batteries from vehicles, or how to respond to a planning application on contaminated land, there will probably already exist standard practices which can be converted into procedures. However, it is also probable that many new effects procedures will have to be created. This is especially true of service effects where the environmental impact is much less likely to be subject to regulation.
| Stratford on Avon found that nearly all of their corporate procedures and 40% of their effects procedures were completely new. Sutton had started out with the principle that they would only need to add one or two lines to existing procedures, but found that very few procedures already existed. |
3.12 Devising and documenting the management system is one of the most time consuming stages of EMAS. But once the Management System is in place it should only need incremental adjustment over time. It is impossible to say how much time this stage is likely to take. It will depend on:
The effort involved will also depend on the number and complexity of environmental effects. The Council’s most significant environmental effects are likely to concentrate in a few departments, such as Technical Services, Planning or Transportation.
3.13 Copies of procedures should be kept where they have to be implemented. The staff who have to apply the procedures need to have ready access to the latest versions. Some procedures may only have to be implemented by one member of staff, who can keep their own copy. Others may have to be implemented by all members of staff, e.g.waste disposal from offices, and copies should be circulated in the same way that other advice is distributed. Procedures might, for example, be included in staff manuals or induction packs or simply placed on notice boards. Procedures which involve elected members should similarly be distributed to members of appropriate committees.
3.14 It is not necessary to keep copies of all procedures in the Environment Management Manual. A list of procedures and their location is sufficient. However, some local authorities have found it useful to hold at least one copy of all procedures in a central location for ease of reference. The Manual should be held by the EMAS lead officer. For a small Operational Unit it is probably only necessary to have one copy of the Manual. Where EMAS is being implemented across an authority, it may be appropriate for a copy of the Manual to be held by the administrative section or an environmental representative in each department.
| A list of procedures across
the Authority are held centrally in Hereford. Lists of procedures for each Directorate are
held by the Directorate’s Environmental Representative. This list documents the issue
date, the responsible officer and also the checking regime. In Stratford on Avon the EMAS
lead officer holds a central copy of all the EMAS documentation. Each department also has
a copy of the Manual held by the Chief Officer’s Secretary. In addition certain key
sections within departments hold their own copies of relevant procedures, e.g. Public
Cleansing, Energy Management, Environmental Protection. A copy of all procedures is kept with Sutton’s EMAS coordinator. The coordinator keeps an overview over all the units being taken through EMAS. An overview document, describing the entire Council wide system and procedures of relevance to all units (such as contract management) are distributed to the heads of all operational units. Beyond that each Operational Unit keeps their own procedures. |
3.15 Document control is the task of ensuring that, when procedures are updated, copies of the revised procedure are circulated to all relevant staff and that all out of date versions are taken out of action. To date this task has tended to fall to the EMAS coordinator. However, this is essentially an administrative task, and once the Management System is up and running, it may be more appropriate to hand this on to an administrative section.
3.16 Devising and documenting procedures is only half the job. The other half is to make sure that staff and elected members understand and follow procedures. This is especially important when:
When Management Systems are first established it is essential to make staff aware of EMAS and its purpose before introducing procedures. Where a section is to be subject to new procedures, they deserve an explanation of why their activity is considered environmentally significant, and wherever possible should be involved in thinking through procedures for improving their environmental impact. Of course, some procedures will apply to a large number of staff and not everyone can be involved in procedure design. However, all staff and elected members should understand the environmental benefits of following procedures. They should also be reassured that if the procedure proves unworkable, or not the best solution, then it can be changed. Procedures, especially new procedures, are not set in stone, and staff and elected members should be invited to come up with suggested improvements.
| Stratford
on Avon District Council Procedure COCS 16 Procedure for Controlling Documentation Relating to EMAS 1. The Environmental Co-ordinator will be responsible for controlling documentation relating to EMAS. 2. Each Department will nominate at least one officer to hold all EMAS documentation and to keep that documentation up to date. Departments may nominate additional officers as required. 3. Each Chief Officer will inform the Environmental Co-ordinator of the name(s) of the nominated officer(s), and will notify the Environmental Co-ordinator of any changes to the nominations. 4. The Environmental Co-ordinator will issue each nominated officer with a green EMAS folder which shall contain :
5. Each Chief Officer will circulate the documentation to all relevant staff, along with a sign off slip - which should be signed by staff to confirm that they have read and understood the contents. 6. Any alterations or updates to the documentation approved under one of the other COCS procedures, will be made on the "master copies" held by the Environmental Co-ordinator, who will issue each nominated officer with updated versions, along with clear instructions about which page(s) should be replaced. 7. Each nominated officer will follow the instructions provided for keeping documentation up to date. 8. The Environmental Co-ordinator will inform members of staff of changes to the procedures which relate directly to their areas of responsibility. 9. Records relating to this procedures will be kept on the EMAS files held by the Environmental Co-ordinator. V1/COCS16/Aug96 |
3.17 Incremental changes in staff and procedures should be relatively easy to deal with. The main thing is to ensure that awareness of procedures is not lost as staff and elected members leave. Procedure 13 for the Overall Management of the Operational Unit (see para 2.10 above) should set out how this will happen. For example, section heads might be given responsibility for explaining procedures to all new appointments, while Committee clerks might be given the task of explaining to committees their responsibilities under EMAS at the beginning of each Council year.
3.18 The biggest task is obviously when the Management System is first implemented. At that stage the EMAS coordinator or coordinating group will need to put together a thorough package of training and awareness raising which will probably combine:
i) briefings to all staff, e.g. via management or specially called section meetings, to explain EMAS, and their responsibilities within the system
ii) circulating ‘universal’ procedures, i.e. procedures which apply to all staff, e.g. by posters, e-mail or memos
iii) ensuring that relevant staff and elected members are made aware of the procedures which apply to them, e.g. through briefings or training organised by section heads or Operational Unit managers.
| In Stratford on Avon nearly all Council staff (about 350) received a one hour training session on EMAS which included information on the procedures. The training took two forms. One was a basic introduction and summary of general responsibilities for all staff. The other was aimed at staff who have specific responsibilities within EMAS. This latter training session involved a workshop where the staff worked through the procedures and wrote down all the procedures which related to them on a pre-prepared form. In this way they developed a kind of personal action plan. In addition copies of relevant procedures have been circulated round each department, and staff have been asked to sign off that they have read and understood the documents. |
| In Sutton each Operational Unit makes available to all staff (or all staff having a task to fulfil within the system) a summary of procedures and checklists which help staff remember at what stage they need to act. This may be diagrammatic with a summary sheet of no more than one page which staff can pin up on the wall. |
3.19 Procedure 9 for the Overall Management of the Operational Unit (Periodically reviewing and revising the Management System) should set out how the Council plans to keep the Management System up to date. There will be several reasons why updating is necessary:
i) New procedures are necessary for new Council activities which are judged to be environmentally significant
ii) New or amended procedures as a result of improvement activities in the Environmental Programme (Such as results of research or monitoring available, new equipment installed, higher insulation standards established.)
iii) New or amended procedures as a result of new information about environmental impact (e.g. impact of diesel on air pollution) or new technologies (e.g. water based paints)
iv) Amended procedures because earlier versions were found to be unworkable or inefficient
v) Regular reviews of the Management System, probably following each Audit
3.20 Updating as a result of (i) to (iv) should be the responsibility of officers in the relevant sections. However, they must report any new or revised procedures to the person responsible for document control, who must revise the list of procedures, circulate the new procedure to all relevant sections, and ensure that any old procedure is taken out of action. Some authorities or Operational Units may also wish that any revisions to procedures are confirmed by the EMAS coordinator or an environment working group. Periodically, the EMAS coordinator or environment working group should initiate a general review of procedures to check if any need revising or if new procedures are necessary.
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4.1 Once you have got a Management System in place, the next thing to do is to think about how it should be audited. This section discusses how to conduct an Audit, who should do it, and how often.
4.2 EMAS audits should normally consider:
i) Does the Environmental Policy of the local authority or Operational Unit address all of the issues listed in Annex 1C of Department of Environment Circular 2/95?
ii) Does the Environment Programme and Management System meet the commitments made in the Environmental Policy?
iii) Does the Environment Programme and Management System manage the significant environmental effects?
iv) Are all statistics or results reported as part of the monitoring programme accurate and based on auditable records, i.e. can the accuracy be checked?
v) Is the Management System being followed?
vi) Is the local authority or Operational Unit complying with all relevant environmental legislation and regulations?
4.3 Quality and financial audits usually focus on items (iv) and (v). However, EMAS is a more demanding standard which requires the local authority to: have an Environmental Policy which commits it to managing environmental issues; continuously improve its environmental performance; and comply with environmental legislation. Consequently the EMAS auditor has a wider remit.
4.4 Some audits, e.g. by the UK Audit Commission, consider:
vii) How does the Council’s performance measure up against best practice or externally set standards?
This is not an essential component of an EMAS audit, and (apart from a few simple quantifiable comparisons, e.g. against the Energy Efficiency Office’s energy consumption guide for offices), would be a difficult task for an auditor. It is unlikely that auditors will have the breadth of experience to advise on good practice from transport policy to catering. The task of assessing performance against best practice is best left to environment staff or specialist staff in each section, and this should be part of their responsibilities within the Management System. However, it is the responsibility of auditors to check that staff are keeping up to date with good environmental practice in their area of work, e.g. by scanning professional journals and considering how the section’s own practice might be improved. Auditors might, for example, look at records of such activities in minutes of team meetings or internal reports.
4.5 It is not the role of the Audit to produce monitoring reports on the implementation of the Environmental Programme, or on trends in the environmental impact of the Council. This kind of monitoring should be incorporated into the Management System, and procedures should specify what information will be collected, who will collect it, and when and where the results will be reported. The purpose of the Audit is to check that such records are being kept, and that the statistics reported are accurate.
4.6 If the first audit takes place soon after the Management System has been established, there will obviously be very few records available to check, and it will be difficult to assess the achievements of the Environmental Programme which may have been running for less than a year. Items (iii) and (iv) in para. 4.2 will therefore be of low priority in the first Audit, whereas item (v) tends to dominate the first Audit. In future years, when the Management System is well established, the importance attached to the various Audit objectives will probably change.
4.7 The auditor is often seen as the person who has arrived to ‘catch you out.’ They depart grimacing and issue ‘non-conformity reports’ which list everything the section is not doing correctly. This approach to auditing is no fun for those who are being audited or for the auditors. It can be demoralising for staff who have done their best to get EMAS operating, and adds very little to the EMAS process. The key to a good Audit is to make it as positive an experience as possible which:
i) motivates staff
ii) makes positive suggestions as to how the Programme and Management System might be improved
4.8 The Audit should be about ‘catching people doing things right’. The Audit should record what is working well and recognise the efforts of the staff involved, while also pointing out where some improvements may still be necessary. The auditors should also take the opportunity, in consultation with relevant staff, to make suggestions as to how the Policy, Programme and Management System might be improved. It will of course be up to appropriate staff, working groups and Committees, to decide whether to act on these recommendations.
4.9 The quality of the Audit very much depends on the quality of the auditors. The EMAS Regulation does not specify who should undertake the Audit apart from stating that:
Auditors can be internal staff from other sections, staff from other Councils (e.g.through twinning arrangements), or external specialists. In practice, most Councils have used their own Internal Auditors. The advantage of Internal Audit are seen as:
i) they understand the process and techniques of auditing
ii) they are viewed as independent by authority staff
iii) environmental issues are given the same status as financial issues
iv) they are cheaper than external auditors
v) once they have acquired an environmental perspective they can spread this into other parts of the authority which are not implementing EMAS
4.10 The main drawback to using Internal Audit (IA) is that they are rarely trained in either EMAS or environmental issues, and this has proved a problem for all the Councils which have used IA. The former is easier to remedy than the latter. There are two solutions to improving IA’s understanding of EMAS:
4.11 An understanding of EMAS does not necessarily bring an understanding of environmental issues. A good way to strengthen this aspect of the Audit is to have a mixed audit team which includes members from an environment background or from an Environment Working Group. (This mirrors EMAS verification teams which usually consist of an environmental expert and a management systems assessor.) A mixed team may be less necessary for future Audits when internal auditors have become more familiar with environmental issues. We would not recommend that environment staff lead the Audit because:
4.12 The corporate or Operational Unit Management System should include a procedure which sets out how the Audit will be conducted. It should cover:
i) Who will initiate the Audit, e.g. an Environment Working Group or the Internal Auditor
ii) How often Audits will be held, minimum frequency and situations where more frequent audits will be organised
iii) Who will be involved in the Audit ‘scoping’
iv) Who will pay for the Audit, e.g. the Operational Unit or the Environment Committee
v) What will be included in the Audit report, and where it will be reported
vi) How the findings of the report will be followed up
Most of these items are discussed in more detail below.
| Stratford-on-Avon
District Council Procedure COCS4 : Auditing EMAS 1. The Internal Audit Manager will be responsible for auditing EMAS 2. The EMAS audit will cover the following : a) The extent to which the Environmental Policy is being implemented through the programme and procedures b) The supporting evidence for effects which are considered significant c) Checks that all the environmentally significant activities of the Council are included in the register of significant effects d) The extent to which commitments in the Environmental Programme and Environmental Management System reflect the environmental policy e) The extent to which the Council is achieving commitment made for improving environmental performance in the Environmental Policy f) Checks that all identified significant effects are properly managed through the EMS procedures g) Staff awareness of their responsibilities as set down in the procedures and programme h) The extent to which commitments made in the programme are being achieved on time i) An assessment of the success of any corrective actions taken arising from procedure COCS12 3. EMAS will be audited on a rolling programme starting with a two year cycle in December 1996 as follows : December 1996 to May 1997 Document Review and co-ordination of EMAS: random and/or targeted Assessments of the EMAS documentation, supported by random and/or targeted assessments to look at the following (3 Person days) :
June 1997 to Nov 1997 Detailed Assessment : An assessment of the review, programme achievements and EMAS procedures for the following impact headings (3.5 person days for each six month block): i) Waste - Direct Effects ii) Energy - Direct Effects iii) Transport - Direct Effects iv) Planning - Service Effects v) Economic Development and Tourism - Service Effects Dec 1997 to May 1998 i) Contracts - Direct Effects ii) Technical and Amenity Services - Service Effects iii) Corporate Services - Direct and Service Effects iv) Purchasing - Direct Effects v) Environmental Health - Service Effects From June 1998 to May 2001 and thereafter every three years, this cycle will be repeated 4. At least every six months, the Internal Audit Manager, in consultation with the Environmental Co-ordinator will be responsible for preparing a detailed audit programme for the following six months. This programme shall include the following:
The programme will reflect the nature, scale and complexity of the activities to be audited in the number of audit days allocated to each activity. Each six monthly programme will detail which members of staff will be involved in carrying out the audit. 5. Where the audit shows particular problems arising within any particular part of the scheme, the Internal Audit Manager may add to or amend the audit programme to increase the frequency of auditing within that particular part. The Internal Audit Manager will allow 2.5 person days contingency for each audit cycle for this. 6. Within one month after the end of each six month period, the Internal Audit Manager will be responsible for submitting a report to the Environmental Co-ordinator of the findings from the audit. At Internal Audit Manager’s discretion, this may include recommendations on how improvements may be made. The Environmental Co-ordinator will discuss the findings and conclusions of the audit with the Environmental Steering Group to assess appropriate action. 7. The Internal Audit Manager will be responsible for ensuring that there is a sufficient number of adequately trained staff for carrying out the audit programme effectively including where necessary technical assistance from outside the Internal Audit division. 8 The report of the Internal Audit Manager will be considered by ESG. ESG will take whatever action it considers necessary arising from the Audit report within its terms of reference and will make additional recommendations as necessary to COMT. 9. Each year, the Chief Executive will be responsible for reporting a summary of the findings of the audit to the June/July Policy and Resources Committee. 10. In accordance with procedures COCS 1, COCS 2, COCS 3, COCS 12, COCS 13 and COCS 14, ESG or COMT, Departmental Directors shall report appropriate recommendations arising from the audit to appropriate Committees 11. Details of the audit programme will be kept on file held by the Internal Audit Manager 12. Details of action arising from the findings of the audit will be recorded in the minutes of ESG and COMT. |
4.13 The Audit can take place in stages. Different sections of the Operational Unit or the Council may be audited at different times. Similarly, not all of the objectives listed in paragraph 4.2 have to be considered at the same time. Indeed, given the likely work loads of those who will be responsible for the Audit, it will probably be preferable to phase the Audit cycle over 2 or 3 years. However, with the exception of the very first Public Statement, a full Audit cycle must be completed before the next Public Statement is issued.
4.14 The European Commission has recently advised on the frequency of the full Audit Cycle. Their view is that this should be subject to two broad influences:
The Commission have therefore recommended an Audit Cycle frequency as follows:
| Experience | Complexity of the Activities |
||
| Low | Medium | High | |
| Less than 2 years | 2 years | 1 year | 1 year |
| Less than 4 years | 3 years | 2 years | 1 year |
| More than 4 years | 3 years | 3 years | 3 years |
4.15 Some aspects of the system may need to be audited very infrequently, i.e. only once every cycle, but other activities may need more frequent auditing. New procedures will probably need to be checked more frequently until they are well established. The Circular specifies that the frequency of auditing should depend on:
a) nature, scale and complexity of the activities
b) nature and scale of emissions, waste, raw material and energy consumption and, in general, of interaction with the environment
c) importance and urgency of the problems detected, following the initial environmental review of the previous audit
d) history of environmental problems
4.16 There must, therefore, be some agreed mechanism for deciding how frequently audits should take place for each activity. This mechanism should be described in the Audit procedure. It should describe who will make the decision on audit frequency and how they will decide. It should not specify audit frequencies for different activities, as this is likely to change over time. For example, when EMAS is first introduced a lot of sections may take some time to get the system operating properly, and there may be a need for, say, 6 monthly checks. Once the system is fully implemented, 2 or 3 yearly audits may be sufficient.
4.17 A local authority may complete verification and registration before starting its first Audit. However, there are two good reasons for at least beginning an Audit before moving to verification.
i) To make sure that the system (especially procedures) are operating before calling in verifiers
ii) To reduce the cost of verification.
4.18 Several local authorities have described how, no matter how many briefings on EMAS had been organised, the Management System did not really start happening until someone arrived and asked to see how a procedure is being implemented. It may therefore well be worth conducting a sample or mini audit, particularly focusing on the implementation of the Environmental Programme and Management System, before inviting in verifiers.
4.19 Generally, the more comprehensive the Audit, the less needs to be checked by verifiers, and therefore the lower the cost of verification. However, at the time of the first Audit the authority is unlikely to have a clear grasp of what the verifiers will be looking for, and may not pick up exactly the same things as the verifiers are interested in. The first verification is therefore likely to take some time.
| Stratford on Avon describe
how staff, although aware of the procedures, seemed to be waiting for a starting gun’
before putting them into practice. Most procedures did not start happening until Stratford
ran a mini audit. Hereford have done a number of mini (sample) audits, and feel that they are well worth having as a regular feature throughout the audit period. The Council’s verifiers suggested that sample audits should be done and then if problems were encountered that these should be followed up by a more widespread audit. |
4.20 Each individual Audit must begin with an Audit Scoping. The EMAS Regulation specifies that the Audit scope should specify:
1. subject areas covered, e.g. which of the 7 items listed in para 4.2
2. activities to be audited, e.g. a broad effect such as energy management, or the significant activities of one section
3. environmental standards to be considered
4. period covered by the audit
The Audit Scoping will probably only require a brief meeting between relevant officers. The Audit procedure should specify who will be responsible for the scoping, e.g. the Internal Auditor, Environmental Coordinator and head of the section or Operational Unit. The Audit scope must be recorded in the Audit report.
| London
Borough of Sutton Audit Brief - EMAS Compliance - Unit..... Objective and Scope To establish compliance of the unit with the requirements of EMAS registration and that the Council Environmental Policy. Scope This audit will cover the (unit) and will examine matters relating to the adequacy, operation and effectiveness of the EMAS system of that unit. Control Objectives
Audit Information
Brief Issued Audit Manager Date Brief Approved Chief Internal Auditor Date |
4.21 Audit techniques are much the same for any kind of Audit and will be very familiar to Internal Audit staff. They generally comprise a combination of:
| In Sutton, where separate Operational Units have registered under EMAS, the internal auditor begins the Audit by writing to the head of the Operational Unit, usually a week in advance, to explain that an Audit is due, and notifying the start and finish dates and the target date for reporting on the Audit. The auditor then makes an appointment for an initial meeting with the Operational Unit manager. This is followed by looking at the minutes of team meetings, copies of the EMAS documentation, and relevant records. |
4.22 Auditors should submit a written Audit Report to the top local authority management. The latter might comprise the head of the appropriate Operational Unit or section audited, the appropriate Chief Officer, the EMAS coordinator and / or an Environment Working Group or Committee. The recipients of the Audit Report should be specified in the Audit Procedure.
4.23 The report should describe the scope of the Audit, report on the successes and failures identified in the Audit, and make recommendations for improvements. As emphasised above, the Report should aim to record what is working correctly and recognise the efforts of the staff concerned, while also pointing out where some improvements may still be necessary. It is recommended that the draft report should be discussed with relevant staff before the report is finalised.
4.24 Appropriate officers (probably the auditors and those who received a copy of the report) should, if necessary, prepare a plan to implement the recommendations in the Audit Report. Again, this should be agreed with relevant staff before it is finalised. At this stage it may be agreed that the auditors will return after a specified period to check on the implementation of the plan.
4.25 As with the Management System, it is impossible to predict how many person-days a full Audit Cycle is likely to take. Nor has any local authority been auditing for long enough to have a well established procedure in place. However, the time needed will depend on:
| Sutton have allowed from 14 to 48 hours for the Audit of each Operational Unit, depending on the size and complexity of the Unit. Stratford on Avon have set aside 12 days for auditing the whole authority over a 3 year cycle. 12 days was selected because this was the time taken by the verifiers to check the system. |
4.26 It will also be necessary to decide who should pay for the Audit. When separate Operational Units are registering, it may be most appropriate for the Operational Unit to pay for the Audit. Where there is an authority wide EMAS, then it may be more suitable to pay for the Audit out of a corporate budget.
| In Sutton EMAS has been added to the discretionary part of the annual audit cycle. Directors can therefore allocate some of their existing budget for auditing to EMAS audits. |
Can we do the EMAS Audit as part of a general audit?
4.27 All local authorities are familiar with regular financial audits. Some local authority sections may also be undertaking quality audits. Obviously, to save time and disruption there may be benefits in combining these audits into one process. However, the EMAS does require the Environment Audit to be reported separately. EMAS Audits also consider wider issues than compliance with procedures (see para 4.2), and there is a danger that these might be neglected if the different audits are combined.
4.28 Combined audits are more likely to be successful when the aim of the EMAS Audit is limited to objectives (iv) and (v) in para 4.2. Even then, remember that the Circular requires that the auditors should have an understanding of EMAS, and that financial or quality auditors who have not received additional training in EMAS would be inappropriate. An integrated Audit has to be carefully designed and usually requires multi-discipline teams.
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5.1 The verifiers will be looking very closely at the EMAS Management System and Audit when they come to inspect your scheme. This section discusses what they will be looking for.
5.2 The purpose of verification is to make an independent assessment of the Unit’s EMAS system and to check two aspects in particular:
5.3 Compliance with all the requirements of the scheme includes implementation of the Environmental Policy, Review and the Programme as well as the functioning of the Environmental Management System. The latter will include the corporate overview and co-ordination system, the Environmental Audit process and the Environmental Statements.
5.4 Verification therefore works like an external quality check on the application of EMAS in a Council. Although verification has only a limited influence or remit to comment on the level of environmental improvements, or the starting point for any improvements, the verifier will need to get involved in making judgements, for example on whether the Council has concentrated on significant rather than marginal issues. A typical example would be where a significant environmental issue has been omitted. In such a case the verifier is bound to question the reasons and whether they are justifiable.
5.5 By inviting a third party to examine your system you are already accepting the need for transparency. Only by having clear documentation and precise information gathering and handling systems, which allow a third party to lay audit trails, can you hope to demonstrate to the verifier the validity of your systems and your data. The verification lends credibility to the Council’s environmental efforts, a matter of increasing importance in a time where unverified green claims are made by so many organisations.
5.6 You have invited the verifier to check your system for compliance and reliability. You know your system inside out - the verifier has probably never even heard about your organisation before and has absolutely no idea about your environmental problems, issues or how you are going about tackling them. There is an enormous communication gap which you have to bridge if the verification is to be meaningful and is to be completed on time. What will the verifiers be looking for and how can you prepare for it?
5.7 Document Control: In your preparation for EMAS you will have produced a large amount of documentation, progress reports to Committees, management team agendas, instructions to various units across the Council etc. You will also have a policy, your Review documentation, papers which document how you have decided on significance etc., your Environmental Programme and of course your Management System which ultimately is the engine of implementation. You will need to be sure that you have not lost track of any of your significant effects and that you can account for all of them through the entire process up to and including the Environmental Statement. This calls for systematic documentation - where you can read across from the Review to the Environmental Statement possibly in spreadsheet format for each of the significant effects you have identified.
5.8 It also helps if you know what version of the document you have in front of you - dating of each document is therefore a must. Moreover you need an appreciation of the totality of documents involved in your EMAS work, where they are held and how they fit together. Ideally each document (not just procedures) has a unique number and date. This will avoid confusion and will give the verifier a reasonable chance to appreciate all the good work you have done. It is like the packaging of a product - the final 10% of effort can make 90% of the impact.
5.9 Overview Document: There is no requirement for such a document, but it may help you to bring together in one volume your timetable for EMAS implementation, if you are going unit by unit, your internal audit programme, progress in each unit, the training programme and history so far. This may also be the place where you record past achievements, awards given to your Council and other matters of relevance to the Council’s environmental performance. The overview document will allow you to quickly summarise your own progress, identify matters which need to be followed up and of course explain in as systematic or comprehensive a way as necessary your overall position on EMAS to any third party including the verifier. You can even send such a document to the verifier in advance of the visit to the Council’s offices.
5.10 Council Commitment: You are presenting evidence of the Council’s achievements to the verifier. It is up to you whether your visitors will appreciate the work you have done, the environmental commitment of your organisation, the innovations you have put in place and your commitment to training. This all provides useful background to the verifier as to your environmental performance and track record. Most Councils opting for an environmental management system will do so after many years of work in the environmental field. It is up to you to demonstrate that continuity and your understanding of the Council’s significant impacts.
| Hereford City Council | ||||||
| Extract from Environmental Management Manual | Section 6/2 Issue 3 Issue date: July 96 | |||||
| Operation Control Procedures | ||||||
| Operational control EMS X Ref | If no procedure why not? | Responsible Officer | Current Issue Date | File Ref | Issued to and | Comments |
| LEISURE AND ENVIRONMENTAL SERVICES | ||||||
| Safe use of pesticides | COSHH sheets held at \nursery (pesticides cannot be drawn without reference to sheets) | |||||
| Boiler maintenance (by Corporate Plant engineer) | Tony Lindsey Jones | Being developed | Vince Clayton | |||
| Integrating nature conservation info into grounds maint. contracts | No | Geoff Dimblylow to liaise with Trish Marsh | ||||
| Air Monitoring - NOx | Yes | Dave Simmonds | 10 May 95 | ED01 | John Crippen Tech Assts | |
| Air monitoring -particulates | Yes | Dave Simmonds | 10 Nov 95 | ED02 | John Crippen Tech Assts | |
| Safe issue, purchase an disposal of chemicals from L/Centre, L/Pool and Museum stores | Yes, insofar as letter sent reminding staff to follow COSHH guidelines and to report irregularities | Dave Simmonds | 16 May 94 | ED50 | Director Management Team | |
| Tree planting prog | Yes | Dave Simmonds | 10 May 95 | ED09 | Parks Officer | |
| Annual tree survey | Yes | Dave Simmonds | 10 May 95 | ED08 | Parks Officer | |
| London Borough of Sutton Overview Document - Contents | ||
| VOL 1 | PAGE | |
| 1. | Location of Sutton Borough, area intended to be covered by scheme | OV2 |
| 2. | Organisation | |
| 2.1 | Committees and Departments | OV3 |
| 2.2 | Corporate Overview System | OV12 |
| 2.3 | Operational Units scheduled for registration for 1995 and 1996 | OV13 |
| 3. | Environmental Effects | |
| 3.1 | Definition | OV14 |
| 3.2 | Environmental Effects by Units | OV16 |
| 3.3 | Direct Effects | OV17 |
| 4. | Environmental policies in operation | |
| 4.1 | Chart showing how operational units are affected by policies | OV18 |
| 5. | Documents | |
| 5.1 | Arrangements and numbering | OV19 |
| 6. | Environmental Programmes | |
| 6.1 | Summary and breakdown by operational unit | OV20 |
| 7. | Training Achievements and programmes | OV21 |
| 8. | Environmental Performance to date | OV23 |
| 9. | Resources allocated to Environmental Programmes | OV25 |
| 10. | Conventions Adopted | OV26 |
| 11. | Timetable for implementation of EMAS | OV27 |
| 11.2 | Rationale for Programme | |
| 12. | Internal Audit Programme 1996/7 | OV28 |
| VOL 2 | ||
| Supporting Documents: Available from EMAS Co-ordinator | ||
| Overview Document Document Number OV | ||
| OV1 Checked by Date 15/11/95 | ||
5.11 Data Trails: You are presenting the verifier with a host of data, statements, claims and assertions. The verifier will need to be satisfied that your statements are correct and he or she will do this through random checks initially. If the random checks reveal consistent problems a more thorough examination of your systems is likely to result. It is your responsibility to be able to document Committee decisions, commitments, statements etc. A fairly simple task if you are systematic and use say an overview document. As to data shown in the Environmental Statement you will need to be clear about its source and you may have to give the verifier access to the original data. Likewise, if you make statements which seek to quantify environmental impacts in any way, even if you use words rather than figures, you need to be able to demonstrate the validity of your comments. It may help, once you have drafted the Environmental Statement, to have an index of all the data you have used and where it comes from. In fact this could be the embryo of your environmental information system if you have not got one already.
5.12 Policy: The Euro-LA EMAS Support Material on developing an environmental policy ...(weblink)... gives ample indication of what needs to be covered in a policy. You will have covered yourself by including commitments to meet all regulatory requirements and to achieve EMAS for the entire Council by a specified date, if your Council has chosen to implement EMAS in stages. On examining your policy the verifier might find that you have omitted some important aspect where the Council actually is doing environmental work but which is not covered in the policy.
5.13 Timetable (for implementation of EMAS across the whole authority): You may need to give an account for the reasons behind implementing EMAS in the way you are doing. Why the units chosen, how significant are their environmental effects? You will need to be prepared to explain your decisions and the basis on which these were made.
5.14 Review - level of significance: The verifier will have to be convinced that the authority is focusing in on its significant environmental impacts and not just marginal ones. Again you need to be able to justify the basis for your selection of significance, why you have chosen the cut off you have done etc. You can expect some discussions here especially where you are weighing service against direct effects. This is one area where a healthy debate with the verifier is in order, to ensure that the verifier totally understands your decisions.
5.15 Environmental Management System: The verifier will need to be convinced that the system has been set up and that it is operating. If you are going for verification prior to Audit, you will have to help the verifier to understand the operation of your system and demonstrate that it is actually delivering. Verifying an unaudited system puts additional pressure on the verifier and it is in your interest that your documentation is clear and your systems transparent. It does help here to demonstrate the impact of your systems, e.g. Committee decisions arising from it, investment decisions made, changes in policy, improvements delivered, files documenting changes which have taken place, ticksheets completed, etc.
5.16 Audit: Where you have chosen to progress to verification immediately following the Review/Programme stage, the verifier will need to be able to judge whether you have taken all the steps necessary for the Audit to take place, its frequency, organisation, commitment by the Council to it and how it will be funded, etc. It is up to you to demonstrate that the necessary systems are in place and that the Audit will actually happen. Again some organisational detail and a reference to the procedures you will follow could be inserted in the Overview document.
5.17 Environmental Statement: Each word in the Environmental Statement has a meaning. The verifier will need to judge the accuracy of data, qualitative and quantitative comments, presentation of data, etc. You need to be able to demonstrate the accuracy of the data, the basis of your value judgements etc. You can expect comments on relevance of data as well as accuracy. A systematic approach to drafting the Environmental Statement will overcome most problems.
5.18 As the verifiers study your system you could get a completely clean bill of health, a number of non-compliances or one or several major non-compliances. A major non-compliance indicates a systems fault or some other major problem which might require you to go back to the drawing board. Minor non-compliances indicate that your overall system, approach, etc. are reasonable but that you need to correct your system or procedures.
5.19 After you have signed off (i.e. agreed with the verifiers) the list of non-compliances, it is up to you to put them right and to demonstrate to the verifiers that you have done so. Once that has taken place, say some 2-3 weeks after the verifiers’ final visit to your offices, you will get a statement from the verifier that signifies your compliance with the EMAS regulations. This is the point where you submit your application for registration with your country's competent body, i.e. in the UK, the Department of the Environment.
5.20 Verification gives the external seal of approval to your environmental management efforts. It checks your competencies, forces you to be transparent in terms of thinking and organisation and more than likely therefore adds value to your system, as well as improving your capacity to communicate a very complex issue.
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1. A Guide to the Management System and Audit Stages of EMAS for UK Local Government. LGMB. 1996. UK.
| Audit Cycle | The period of time in which all the activities in a given operational unit are audited |
| Audit Trail | Evidence or records that the auditor can follow back to source to check the accuracy of any information included in the Public Statement |
| ISO14001 | The international environmental management scheme for industry. |
| Operational Control | Systems for managing operations so that they meet agreed standards |
| Operational Unit | Any department, division, section or other organisational unit of a local authority, or the authority as a whole |
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