Measuring The Effectivenrjess of Ems Phase 1-2

Measuring the effectiveness of
Environmental Management Systems
Phase 1: Desktop Report, June 2009
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www.ni-environment.gov.uk
Measuring the Effectiveness of Environmental Management Systems: Phase 1

Background to the Project
Background to the Project

DoE Environment and Heritage Service (now Northern Ireland Environment
Agency, NIEA) commissioned An Evaluation into the Effectiveness of
Environmental Management Systems as part of the Better Regulation
agenda, which includes assessing aspects of a risk based approach to
regulation, a more integrated approach to enforcement and improving
awareness of obligations and best practice (EHS Tender Brief ).
The main aims of the study are to measure the effectiveness of EMS and
analogous systems implemented by NI businesses in:
1. Having a demonstrable impact on the level of legislative compliance,
2. Improving an organisations environmental performance / reducing its
environmental impacts.
This study has been undertaken on behalf of NIEA by White Young Green
in two distinct phases. The first is the completion of research and a desk
top study into the types of management system, certification process and
uptake from an international, national and local perspective. The desk top
review has also collated research information relating to the effectiveness
of Environmental Management Systems (EMS) undertaken within the last
decade. The second phase is data analysis and interpretation from 1000
Northern Ireland organisations in June 2008 (subject to a separate report).
Background to Environmental Management Systems
Environmental Management Systems are a systematic, planned approach
to the management of environmental issues at an organisation and should
be adopted as part of the overall company management structure. They
are based on a Plan-Do-Check-Act methodology that aspires to continual
improvement. There are a number of differing types of EMS. These can be
summarised as :

EMAS (Eco-Management and Audit Scheme)

BS EN ISO 14001 (International standard)
BS8555 : 2003 & the Acorn Scheme (Phased approach)
Green Dragon (Arena Network) (phased approach)
EMS is a risk management tool and all EMS standards have a similar
framework and can be applied to any public or private sector organisations.
EMAS is often viewed as the most stringent management system, as there is
an explicit requirement for legal compliance and reporting of this status to
the Regulator. All other systems require identification of legislation relevant
to an organisations activities, products and services and a commitment
to assess the level of compliance against the identified legislation. Whilst
blatant non-compliance with legislation will result in a company incurring
penalties with respect to any management systems certification body audit
(e.g. a category 1 noncompliance), refusal or removal of certification is rare.
Generally, companies reporting non-compliances with legislation, within
their EMS, are encouraged to develop a detailed Action Plan to address the
noncompliant issues. Certification bodies provide recognition of the EMS
against the standards noted above (e.g. EMAS, ISO 14001 etc). In addition, all
EMS standards require organisations to commit to continual improvement
Continual improvement
Environmental Policy
Management Review
Planning
Checking
Implementation
and
operation
and evidence of this commitment is usually found in the setting of

environmental objectives, targets, management plans or environmental
performance indicators. Certification bodies are regulated by a strict code
administered by the United Kingdom Accreditation Service (UKAS) in the UK,
BS EN ISO/IEC 17021:2006. This code ensures consistency of the assessment
process. There has been an amount of bad press associated with EMS and
legal compliance in recent years and UKAS and the accreditation bodies
have been working hard to provide some clarification on the issue of the
association between EMS and legal compliance (paper EA 7/04 seeks to add
clarification to the certification bodies as regards auditing legal compliance
as part of ISO 14001:2004).
The Drivers & Uptake
There are a number of drivers for organisations wishing to develop and
implement EMS, above and beyond legislative compliance or performance
improvements. A key driver for organisations operating in England and Wales
are the Opra requirements relating to risk screening of activities and the
relative proportion of effort applied to regulating organisations. In regulating
through Opra Environment Agency (England & Wales) demonstrates
a policy commitment that for those organisations regulated under the
Environmental Permitting Regulations an effective EMS is important in
managing the risks associated with and delivering permit requirements. ISO
14001 is the most favoured type of management system to be implemented
within organisations in the UK, with over 6000 registrations (at the end of
2006).
EMS drivers
Legal compliance
Improved environmental performance
Cost savings
Customer / client pressure
Supply chain management
Enhanced PR
Environmental Risk Management
EMS in Northern Ireland
Northern Ireland business and industry has been served by a range of EMS
support mechanisms over the last 15 years. These have been :
IRTU (now Invest NI) Environmental Audit Support Scheme grant
IRTU Environmental Management Support Scheme grant
Invest NI Building Blocks to a Better Business pilot programme for 11
no. manufacturing companies
The STEM Programme cross border programme involving
implementation of BS8555 for up to 240 businesses and 11 no. district
councils
Easy Access (BS8555 for construction companies)
BiTES - Belfast City Council (Green Dragon through Arena Network) for 9
organisations in the Belfast CC area
Coleraine BC (Green Dragon through Arena Network)
Whilst research and evaluation of the above programmes has been on

an ad-hoc basis, there have been some positive outcomes in relation to
specific projects accumulating environmental improvements and indicating
compliance with environmental legislation. This compares to less than 400
registrations to the EMAS standard within the same period. There is evidence
that levels of ISO 14001 uptake are stabilising in the UK, however significant
growth in uptake in all standards have been seen in Spain and Italy.
To conclude :
Whilst desk top analysis of research would indicate strong evidence that EMS
has a positive outcome in terms of improved environmental performance,
the research is inconclusive in terms of legislative compliance. There is also
not enough evidence to support the measurement of the effectiveness of the
EMS in terms of its type (e.g. EMAS, ISO 14001 etc), particularly in relation to
the collation of data in a local setting.
The findings indicate the need for the detailed study into 1000 Northern
Ireland organisations* and an evaluation of the data for organisations with
accredited EMS, non accredited EMS and no systems in place. Validation of
that data against regulator and certification body records would also be a
valuable exercise.
* This research has been carried out in conjunction with this desk top study.
EMS Research
The last decade has seen a plethora of research studies into EMS with
a number considering their effectiveness in relation to compliance and
improvements. These are summarised below:
Survey
International
Findings
EMAS Ever
Remas
MEPI and follow up study
Northern Irish
Findings
National
Findings
ISO 14001 - a National Study in Austria

SME-enviroment Survey 2007
EMS and company Performance
STEM
BITES
EASS
Building Blocks
Indicative of legal
compliance?
Indicative of improved
Environmental Performance?
Contents

1
Introduction
What is an Environmental Management System
10
2.1
History of EMS
11
2.2
Types of EMS
12
2.3
Accreditation
22
2.4
Certification
26
2.5
Management Systems and Legal Compliance
37
Drivers to Implementation of an EMS
40
Overview of legislation and policy
40
3.1.1
Formulation of Legislation
40
3.1.2
NI Legislation
40
3.1.3
Enforcement in Northern Ireland
40
Procurement Policy and Promotion of EMS
43
3.2.1
Central Procurement Directorate
45
3.2.2
Other Local Procurement Drivers
46
3.2.3
Compliance Drivers in England and Wales
48
3.2.4
Other Drivers for Implementing an EMS
51
3.1
3.2
Uptake of EMS
54
4.1
The International Scene
54
4.2
Europe
55
4.3
UK Wide
57
4.4
Northern Ireland
57
4.4.1
Invest NI
57
4.4.1.1 Support Schemes
57
4.4.1.2 Building Blocks
60
4.4.2
STEM
BITES
68
4.4.4
Easy Access
68
4.4.5
Green Dragon Coleraine Borough Council
69
4.4.6
Arena Network Survey
69
4.4.3
61
Research Studies
71
5.1
SME-nvironment Survey (NetRegs)
71
5.2
Ever Evaluation of EMAS and Eco-label for their revision
73
5.3
EMS and Company Performance
74
5.4
REMAS
75
5.5
MEPI
79
5.6
ISO 14001 Experiences, Effects and Future Challenges:
a National Study in Austria
80
5.7
USA National Database
81
5.8
Urban Government Review in Japan
82

6
7
Conclusion
Recommendations
83
87
References
88
Appendix 1
Chapter 1 Key Targets Northern Ireland Sustainability Strategy
Appendix 2
Chapter 6 Key Targets Northern Ireland Sustainability Strategy
Appendix 3
Implementation of EMAS outside EU List of Figures
Appendix 4
NI PPC Permits
Appendix 5
NIEA Organisational Structure
Figure 1
Key elements of legal compliance in an EMS
Figure 2
Regulatory value of an EMS
Figure 3
ISO14001:2004 EMS
Figure 4
EMAS EMS
Figure 5
BS8555:2003 EMS
Figure 6
Green Dragon EMS
Figure 7
EMAS Registration process
Figure 8
ISO14001:2004 Assessment process
Figure 9
Evolution of EMAS organisations

Introduction
In March 2008, Environment and Heritage Service (now NIEA) published
Better Regulation for a Better Environment. This position statement defines
the principles of streamlining the regulation process for organisations. Many
of the businesses in Northern Ireland are not subject to direct regulation
by EHS [NIEA] but are nonetheless required to comply with environmental
legislation. The differing scales and activities covered by our regulations
demand that we adopt a smarter range of tools and approaches to suit the
nature and risk of an organisation and this falls within the overall aim of
working closely with those we regulate to raise awareness of obligations
and good practice, to simplify compliance and engagement with our
regulatory teams and to reward those organisations who actively identify
and manage their risks to the environment. As part of this strategy, a
commitment is made to assess effectiveness of Environmental Management
Systems (EMS) as a measure of environmental performance and compliance.
WYG successfully tendered to the EHS, now re-branded Northern Ireland
Environment Agency (NIEA), to undertake this study on its behalf. The main
aims of the study are:
1. To evaluate the effectiveness of an EMS in improving an organisations legal
compliance and,
2. To evaluate the effectiveness of an EMS in improving an organisations
environmental performance.
The study is in two distinct phases, the first is desk based and concentrates
on analysis of existing data and studies relating to the implementation of
an Environmental Management System on a world wide scale. The results of
this desk based research are presented in this report. The second element
of the study involves a large scale survey of NI businesses and public sector
organisations to capture evidence of legal compliance and environmental
performance of organisations with, and without, EMSs. Full data analysis and
verification is enclosed within Report 2.
Running in parallel to this study, Scotland & Northern Ireland Forum for
Environmental Research (SNIFFER) are currently conducting report and
survey UKCC19 - entitled Better Regulation Rethinking the Approach for
SMEs.
SNIFFER has looked at how best regulatory bodies should target their
resources in the future, and finds that SMEs are neglected at present, while
resources currently go to firms with the most resources to self regulate.
The findings are also likely to suggest that SMEs would be best suited by a
supportive command and control framework of regulation, since their limited
resources mean they are less able to meet the requirements of regulated selfregulation.
Methodology of firm categorisation enables SMEs and large firms to be
divided into four separate categories related to size, and capacity for, or
efficacy of, self regulation. Since SNIFFER seem to be advocating a trend
towards allowing larger companies to exercise a greater degree of selfregulation, and that a greater proportion of resources to be focused on SMEs,
it could be seen as a logical step that these larger, more environmentally
proactive companies should be encouraged to implement, and have
certified, EMS in place to allow this shift of regulatory resources which has
been witnessed in terms of the encouragement on those firms appraised

by the Environment Agency (England & Wales) under Opra to implement
certified EMS.
Since the Better Regulation programme is actively considering the shift
towards a more risk based system of regulation and were this to be the
case, then it is of great importance to know whether there is empirical
evidence that an EMS can reduce the risk associated with a particular
organisation. It is the aim of this project and report to establish statistically
robust data to be able to support or discount the hypothesis that an EMS
improves an organisations compliance with applicable environmental
legislation, and / or its environmental performance. This is in line with the
Environment Minister Sammy Wilsons vision of a new Agency that will
help business implement improved environmental management systems
(keynote speech 1st July 2008).
In detail, this project has involved:
1) A desktop survey and review of existing data and literature relating to
development and implementation of EMS internationally, regionally and
locally. The aim of this is to develop an understanding of the trends seen by
those companies that have developed formal EMS to the various different
standards including, but not limited to: EMAS; ISO 14001 and BS8555.
2) Survey of 1,000 Northern organisations throughout Northern Ireland,
including public and private, SMEs and large organisations.
3) Data Evaluation, statistical analysis and verification of information
gathered through the survey and questionnaires
4) Preparation of an Interim and Final report and recommendations to
the NIEA regarding the potential role of EMS within the Department of
Environments programme for Better Regulation.
EMS Evaluation
Project Overview
Desk Top
Research
Data Collection
Interim Desk
Top Report
Data Analysis &

Review
Final Report with

Recommendations
2.0 What is an Environmental Management System?

The British Standards Institute have defined an EMS as part of the overall
management system that includes organisational structure, planning
activities, responsibilities, practices, procedures, processes and resources
for developing, implementing, achieving, reviewing and maintaining the
environmental policy (BS8555; 2003). It can be seen as a risk management
tool also since the standards to which organisations are assessed are not
prescriptive, they provide the framework within which an organisation must
identify its own potential impacts upon the environment, and seek to control
these as well as to identify opportunities to reduce the associated risks. An
EMS can be considered to follow the Deming cycle of Plan Do Check
Act
Plan
The role of an EMS is in delivering the commitments within an environmental
policy. The policy should commit an organisation to legal compliance and
continual improvement (BS8555 phase 1, Stage 3; ISO 14001:2004 clause
4.2). The organisation should then identify all applicable environmental
aspects that may create an environmental impact and also all relevant
environmental legislation. Compliance with legislation must also be
demonstrated in order to meet the requirements of BS8555 Phase 2
Stage 1-5; ISO 14001;2004 clause 4.3.2 and 4.5.2. While in relation to
Environmental performance, the organisation will have made a commitment
to continually improve, and should set out Objectives and Targets and a
programme to achieve these (BS8555 Phase 3 Stage 3-7; ISO 14001:2004
clause 4.3.3). The objectives and targets provide the organisation with
an improvement plan specifically tailored to ensure improvements in
environmental performance related to its environmental aspects (BS8555
Phase 3 Stage 1; ISO 14001:2004 - 4.3.1) associated with the range of activities
it carries out, the product(s) manufactured or the service(s) provided.
Do
Control measures and procedures are intrinsic to the successful
implementation and maintenance of an EMS, whether this is related to
Training (BS8555 Phase 1 Stage 6 and Phase 4 Stage 2; ISO 14001:2004
4.4.2), Operational Control (BS8555 Phase 3 Stage 6; ISO 14001:2004 4.4.6),
or Emergency Preparedness and response (BS8555 Phase 4 Stage 5; ISO
14001:2004 4.4.7). Most organisations will have a clearly defined, written set
of procedures that will outline what needs to be done to ensure compliance
with the EMS.
Check
The success of implementation should be reviewed within the management
system through a programme of Internal Audits (BS8555 Phase 5 Stage
1; ISO 14001:2004 4.5.5) and identification of corrective and preventive
actions to deal with identified non-conformances (BS8555 Phase 5 Stage
2: ISO 14001:2004 4.5.3). Conformance of an organisation against the
procedures will be evaluated during the audit process. Compliance with
legislation will also be checked during auditing as a number of Operational
10
Procedures are drafted to ensure legal compliance of the activity as a

minimum.
Act
The results of the checking stage of the process should be used to inform
Management of areas of progress, or problems within the system as part of
Management Review (BS8555 Phase 5 Stage 3: ISO 14001:2004 4.6). This
management review process should, in turn, then be used to re-address the
issues of Environmental Policy, the organisations environmental aspects
& impacts, legal compliance and objectives and targets. The continually
improving organisation will then be able to adjust to any changes that may
have occurred and set objectives and targets for forthcoming years.
According to a study conducted by Business in the Community
(Environmental Index Report 2006) an EMS helps an organisation to improve
its environmental performance. Common requirements of an EMS (such
as a policy, objectives, targets, training and reporting) demonstrate a
commitment to incorporating environmental issues into key practices with
the resultant benefits of:

improved risk management

reduced liability costs
increased competitive advantage
more employee involvement and
improved public image (www.bitc.org.uk)
These benefits are further support by findings from a NetRegs survey

conducted in 2007 of small and medium sized enterprises (SMEs) across the
UK (including Northern Ireland) to reveal their attitudes and behaviours.
In relation to benefits in addressing environmental issues, the three main
business benefits of addressing environmental issues were:

Reduced risk of prosecution (81% strongly agree / agree);

Creates good relations with customers (67% strongly agree / agree); and
Reduces operating costs (66% strongly agree / agree)
2.1 History of Environmental Management Systems

The Worlds first formal EMS developed by the British Standards Institute (BSI)
was BS7750, first published in March 1992. The standard was based on a two
year pilot implementation programme with 230 implementing organisations
and was then modified on the basis of feedback, with the publication of
this modified standard in January 1994 (Starkey, 1998). At the same time as
the development of BS7750, the European Commission was setting out its
proposal for an eco-audit scheme, after some initial proposals and changes
the Commission published what has become known as the Eco-Management
and Audit Scheme (EMAS), this was adopted by the Council of Ministers on
June 29th 1993, and became open to company participation in April 1995
(Starkey, 1998).
The development of ISO14001 came about because of the need for improved
environmental performance expressed at the United Nations Conference
11
on Environment and Development (UNCED) in Rio de Janeiro in 1992. The

International Organisation for Standardization (ISO) was charged with
creating an internationally recognised environmental management system
(Bansal and Bogner, 2002). ISO14001 was developed in under three years,
much quicker than it usually takes to develop an international standard
mainly because it relied heavily on the content of BS7750 as a framework
(Schaltegger et al., 2003). The Comit Europ de Normalisation (CEN) realised
that some companies would prefer to meet the EMS requirements of an
equivalent standard to EMAS meaning that it had to adopt ISO14001 as a
European standard, which meant that equivalent national standards had
to be withdrawn, and as a result BS7750, that had influenced ISO14001 so
much, was withdrawn by March 1997 (Starkey, 1998).
This led to two EMS standards being available to organisations in European
countries, the international standard ISO14001 and the European EMAS
scheme. The EMAS regulation was revised in April 2001 and based on ISO
14001, one of the principle benefits of this meant it made it easier for ISO
14001 certified organisations to progress to what is considered the more
rigorous EMAS regulation (LRQA, 2004).
BS8555 was launched after an initial pilot programme called Project Acorn.
Through Project Acorn, the Acorn Method for implementation of an EMS
was run between October 2001 and March 2003, supported by British
Standards Institution and White Young Green Consultants (Sheldon, 2003)
Funded in the main by the UK Department of Trade and Industry (DTI), and
supported by the UK Department of Environment, Food and Rural Affairs
(DEFRA). On the completion of Project Acorn the Acorn Method was
withdrawn and the new British Standard BS8555, the phased approach to the
implementation of an Environmental Management System, was published in
April 2003 (The Acorn Trust, 2003).
2.2 Types of Environmental Management Systems

There are now five main recognised standards in relation to environmental
management. The five main standards are:

ISO 14001:2004 International Standard for Environmental Management.

Eco-Management and Audit Scheme (EMAS).
IEMA - Acorn Scheme
BS8555:2003 Environmental Management Systems.
Green Dragon (Arena Network).
The first four can be subject to UKAS accredited certification and Green
Dragon can be subject to UKAS accredited inspection.
ISO 14001:2004 International Standard for Environmental Management
ISO, the International Standards Organisation, has developed a series
of voluntary standards and guidelines in the field of environmental
management which collectively are known as the EN ISO 14000 series.
Developed under ISO Technical Committee 207, the 14000 series of standards
addresses many aspects of environmental management including the
following:
12
Environmental Management Systems requirements with guidance for

use (ISO 14001 : 2004)
Environmental Management Systems General Guidelines on principles,
systems and support techniques (ISO 14004: 2004)
Environmental Management Systems Draft Guidelines for a staged
implementation of an environmental management system, including
the use of environmental performance evaluation (ISO 14005) due for
publication in September 2010.
Environmental Performance Evaluation (ISO 14031:1999)
Within this series, EN ISO 14001 environmental management systems

specifications with guidance for use is the only certifiable standard, the
remainder being supportive guidelines. The aims of EN ISO 14001 are to
promote environmental protection in light of socio-economic concerns.
Clause No
Clause Title
Clause No
Clause Title
4.1
General Requirements
4.4
4.4.1
4.4.2
4.4.3
4.4.4
4.4.5
4.4.6
4.4.7
Implementation &
Operation
Resources, roles,
responsibility & authority
Competence, training &
awareness
Communication
Documentation
Control of Documents
Operational Controls
Emergency Preparedness &
Response
4.2
4.5
4.5.1
4.5.2
4.5.3
4.5.4
4.5.5
Checking
Monitoring and
measurement
Evaluation of Compliance
Nonconformity, corrective
action and preventive
action
Control of Records
Internal Audit
4.3
4.3.1
4.3.2
4.3.3
Planning
Environmental Aspects
Legal & Other
Requirements
Objectives, Targets &
Programmes
4.6
Management Review
13
An effective environmental management system based on ISO14001

provides an organisation with a defined structure to allow them to more
confidently and effectively manage environmental issues by:

Establishing a policy and awareness that good environmental

performance is a strategic objective of the organisation.
Focusing on the prevention of waste and pollution and on continual
improvement of environmental performance.
Systematic analysis, planning, control and monitoring of all activities that
may affect environmental performance.
Assisting companies to more effectively meet legislative and regulatory
requirements.
Demonstrating to regulators, stakeholders and other interested third
parties that a formal environmental management system is operational
and effective (www.nsai.ie).
The main rationale for the creation of ISO14001 was that its world wide
acceptance should facilitate international trade by harmonising otherwise
diffuse environmental management standards and by providing an
internationally accepted blueprint for sustainable development, pollution
prevention and compliance assurance (Delmas Magali A., 2002).
Continual improvement
Management Review
Planning
Checking
Figure 3 ISO14001:2004
14
Implementation
and
operation
ISO 14001 is very similar to EMAS but at the time of registration,

Environmental regulators are consulted to make sure that they are satisfied
that organisations have identified and know the implications [to the
organisation] of all environmental legislation and that their system is capable
of meeting these on an ongoing basis. , it can take a more prescriptive
approach to environmental management issues. The ISO 14000 standards,
by contrast, rely on voluntary acceptance by all interested parties, and
therefore must maintain a balance between the needs and expectations of
each of these parties. (www.europa.eu).
Eco-Management and Audit Scheme (EMAS)
The EU Eco-Management and Audit Scheme, known as EMAS, is a voluntary
market based instrument designed to encourage better environmental
performance from all types of organisation. EMAS is completely compatible
with the international standard for environmental management systems, ISO
14001, but goes further in its requirements for performance improvement,
employee involvement, legal compliance and communication with
stakeholders. Uniquely EMAS requires organisations to produce an
independently verified report about their performance (www.emas.org.uk).
EMAS is a direct response to some of the key principles in the European
Unions Environmental Action Programmes and the challenge of sustainable
development. Behind EMAS stands the concept of broadening the range
of policy instruments and promoting an approach of shared responsibility
in environmental protection. EMAS was first adopted by the European
Environment Council on 29th June 1993 and became open to industrial
participation from April 1995 onwards. EMAS was revised in 2001, and
eligibility widened to include all sectors of public and private economic
activity (DEFRA).
The EMAS Regulation applies to all 27 EU Member States, and the 3
European Economic Area States (Iceland, Norway and Liechtenstein) all
candidate countries (e.g. Turkey, Croatia and the Former Yugoslav Republic
of Macedonia) are obliged to implement the scheme in preparation for their
accession to the EU.
Some international companies operating sites outside of the EU / EEA, have
opted to pursue EMAS registration. However, since these countries are not
members of the EU / EEA, their registrations do not hold the same legal
status; in this instance they are referred to as quasi-registrations currently
these quasi-registrations exist in countries such as Brazil, Switzerland, China
and the USA.
15
Figure 4 EMAS
Source of Diagram : EMAS: A Practical Guide, ISBN : 0-946655-81-2
Institute of Environmental Management and Assessment (IEMA) Acorn
Scheme
Acorn is the name of a project with a main objective to help British SMEs
improve their environmental performance through a five-level approach to
the implementation of an environmental management system (EMS) in line
with ISO 14001, and a sixth level that facilitated external certification to ISO
14001 and / or registration to EMAS.
Once the project was completed a not for profit organisation, the Acorn
Trust, was founded in order to develop a standard based on the projects
methodology (www.europa.eu).
The IEMA Acorn Scheme, an officially recognised EMS standard, offers
accredited recognition for organisations evaluating and improving their
environmental performance through the phased implementation of an
environmental management system (EMS). Acorn focuses on environmental
improvements that are linked to business competitiveness and is flexible
so that all types of organisation, whatever their size, can participate. Acorn
offers a unique feature whereby organisations can engage environmental
performance indicator (EPI) reporting within the procurement process in
accordance with ISO 14031. This compliments the one size fits all aspects
of ISO14001 & EMAS and provides the opportunity to set environmental
requirements in supplier contracts and monitor operational/product
performance a strength acknowledged by the Government in a recent
EMS position statement published by DEFRA. A system of independent
inspection is central to providing recognition that an organisation has
met the achievement criteria of a particular Acorn phase and continues to
improve its environmental performance (www.iema.org).
16
BS 8555:2003 Environmental Management Systems

Work on Project Acorn led to recognition by the British Standards Institute
(BSI) of the phased approach to development of an EMS and the benefits
for small to medium sized enterprises (SMEs). As with Acorn, the standard,
BS8555:2003, sets out a six phase implementation programme, to work
towards a formal EMS that can be certified to BS EN ISO 14001 or the EU EcoManagement and Audit Scheme (EMAS) at Phase 6. Each phase is broken
into a number of specific stages, with guidance and process planning
spreadsheet available to organisations to assist their development. Progress
can be acknowledged against the standard, with certification at any of the
six phases, allowing SMEs greater control and freedom over the project plan.
After full certification to ISO 14001, at phase 6, the second most popular
certification for SMEs is at Phase 3. This allows for actual cost, compliance and
environmental benefits to be realised before detailed written procedures are
required. Although principally aimed at SMEs, the guidance can be used by
any organisation, regardless of size, the nature of their business undertaken
or their location (Environmental Management Systems Fact Sheet No. 4).
The Six Phases of BS8555:
1. Commitment & establishing the baseline
2. Identifying & ensuring compliance with legal and other requirements
3. Developing objectives, targets & programmes
4. Implementation and operation of the EMS
5. Checking, audit & management review
6. Certification to either ISO 14001 or EMAS
The International Standards Organisation (ISO) is currently reviewing the
incorporation of BS8555:2003 into the international family of standards.
ISO 14005 Guidelines for the staged implementation of an environmental
management system, including the use of environmental performance
evaluation is currently in development with a proposed publication date of
September 2010.
17
Figure 5 BS8555:2003 - Overview of the phased implementation of an environmental management system.
18
Green Dragon
Green Dragon was developed by ARENA Network and Groundwork Wales
with support from the Welsh Assembly Government, Environment Agency
Wales, Welsh Local Authorities and the European Regional Development
Fund. Funding for the project was provided from a mix of Welsh Assembly,
private companies and also several high profile multinationals funded the
pilot scheme. There are 971 organisations from a variety of sectors and
across a broad range of size that have already made the commitment to the
implementation of Green Dragon to date.
The Green Dragon Standard offers an environmental management system
relevant to the specific needs of any organisation, large or small in the UK or
Republic of Ireland. Green Dragon is a stepped approach aimed at simplifying
the approach to implementation of environmental management systems
(www.greendragonems.com).
The standard is made up of five steps each incorporating the key elements
of Planning, Taking Action, Checking Progress and Reviewing Achievements
to realise continual environmental improvement. Some organisations may
progress through each of the steps until they reach level 5. However, an
organisation can enter the process at a suitable level and can remain at
whichever level is most appropriate.
Organisations achieving Green Dragon feature on a register of certified
companies. The register is a resource similar to that maintained by IEMA of
organisations registered under EMAS and the Acorn scheme which enables
quick validation of an organisations claim to hold valid certification
The Five Steps

1Commitment to
Environmental
Management
2Understanding
Managing
Environmental
Impacts
Environmental
Responsibilities
4Environmental
Management
Programme
Continual
Environmental
Improvement
Figure 6 Green Dragon

In-Brief
There are five main recognised standards or schemes in relation to
environmental management.

ISO 14001 International Standard for Environmental Management.
Eco-Management and Audit Scheme (EMAS).
IEMA Acorn Scheme
BS8555:2003 Environmental Management Systems (developed as direct

result of Project Acorn and adopted as a British Standard).
Green Dragon (Arena Network).
19
20
Planning
Environmental Review
Environmental Programme
Roles, resources, responsibility and

authority
Competence, training and awareness
Communication
Documentation
Control of documents
Operational Control
Emergency preparedness and
response
Implementation and operation
Environmental aspects
Legal & other requirements
Objectives targets and programmes
ISO14001
EMAS
Register of environmental aspects

Evaluation & control of environmental
aspects
Pollution prevention plan
Objectives and targets
Monitoring environmental
performance
Carbon data collection
Environmental statement
External communication
Step 3 Managing environmental

impacts
Register of legal & other requirements

Managing legal requirements
emergency preparedness
Communication and competence
Environmental records
Stage 1 Identify Legal Requirements

Stage 2 Identify other requirements
Stage 3 Checking compliance
Stage 4 Ongoing compliance
Stage 5 Developing compliance
indicators
Audit
Phase 3 Developing objectives,
targets and programmes
Stage 1 Evaluation of environmental
aspects and impacts
Stage 2 Finalizing the environmental
policy
Stage 3 Developing objectives and
targets
Stage 4 Establishing indicators
for environmental performance
evaluation
Stage 5 Developing the environmental
management programme
Stage 6 Developing operational
control procedures
Stage 7 Launch environmental policy;
objectives; targets and indicators
Audit
Step 2 Understanding environmental

responsibilities
Responsibility
Environmental Review
Environmental Monitoring
Improvement Plan
Step 1 Commitment to
environmental management
Green Dragon
Phase 2 Identifying and ensuring

legal and other requirements
Phase 1 Commitment and

Establishing the baseline
Stage 1 Gaining Top Mgt Commitment
Stage 2 Baseline Assessment
Stage 3 Developing draft
environmental policy
Stage 4 Developing environmental
indicators
Stage 5 Developing draft
environmental management system
implementation plan
Audit
BS8555 : 2003 / IEMA Acorn Scheme
Summary Table: Comparative Analysis of the main standards For the purposes of this analysis BS8555 and Acorn are taken together

Validation (independent
validation of the environmental
statement, and therefore of
environmental performance)
Environmental Statement
Environmental Audit Cycle
Environmental Management
System
EMAS
Preparing for EMAS Registration or

Preparing for ISO14001 Assessment
Phase 6 Environmental management

system acknowledgement:
Stage 1 Establishing audit

programmes
Stage 2 Correcting non conformances
and taking preventive action
Stage 3 Management review
Stage 4 Improving environmental
performance
Stage 5 Improving the environmental
management system
Audit
Monitoring and measurement

Evaluation of compliance
Nonconformity; corrective action and
preventive action
Control of records
Internal audit
Management review
Phase 5 Checking, audit and review
Stage 1 Finalise management

structure and responsibilities
Stage 2 Training, awareness and
competence, plans and records
Stage 3 Establishing and maintaining
formal communication
Stage 4 Documentation and record
keeping
Stage 5 Reviewing and testing
emergency preparedness and
response
Stage 6 Developing indicators of the
environmental management system
Audit
Phase 4 Implementation and

operation of the environmental
management system
BS8555 : 2003 / IEMA Acorn
Checking
ISO14001
improvement
Internal audit programme
Management review
Addressing sustainability
Supply chain
Reducing greenhouse gas emissions
Environmental report
Step 5 Continual environmental
Training
Environmental manual
Control of documents
System procedures
System monitoring
Carbon data collection
Step 4 Environmental management

Programme
Green Dragon
21
2.3 Accreditation
The UK Picture
In the UK, the United Kingdom Accreditation Service (UKAS) performs
the accreditation function for ISO 14001:2004 certification bodies, EMAS
verifiers and IEMA Acorn inspection bodies. Accreditation criteria and
guidance is developed at an international level by organisations such as the
International Accreditation Forum (IAF) and accreditation bodies are required
to comply with BS EN ISO/IEC 17011:2004 Conformity assessment General
requirements for accreditation bodies accrediting conformity assessment
bodies. Certification assessments are carried out according to international
standards and guidelines, such as EA 7/02 (IAF, 2003). It is of particular note
within the context of Northern Ireland that the Irish National Accreditation
Board operates as the UKAS equivalent in the Republic of Ireland: they, along
with UKAS co-operate with one another and European wide accreditation
bodies ensuring that a multilateral agreement applies to the recognition of
accredited certificates.
The Accreditation Process:
United Kingdom
Accreditation
Service (UKAS)
Accreditation Body
BS EN ISO/IEC 17011: 2004
CERTIFICATION BODIES(CAB)
BS EN ISO/IEC 17021:2006
Certification Body
Auditors
22
Certification Body
Auditors
Certification Body
Auditors
Certification Body
Auditors
While in order to accredit conformity assessment bodies (CABs), the

Accreditation body e.g. UKAS, must meet the requisite standards (detailed
above) the CABs (or Certification Bodies {CBs}) must in turn comply with an
international standard - BS EN ISO/IEC 17021:2006 Conformity assessment
- Requirements for bodies providing audit and certification of management
systems. To apply for accreditations to certify organisations, the CAB must
seek approval from UKAS (in the UK) to conduct the certification to the
defined scope. Individual auditors working on behalf of the CAB must also
have the competence to carry out this certification and they will also be
subject to individual approvals by UKAS.
UKAS accreditation underpins the validity of testing, inspection, calibration
and certification activities including those relating to: air, soil and water
quality, the development of renewable energy sources, environmental
management systems and energy efficiency. UKAS is the sole national
accreditation body recognised by UK Government to assess, against
internationally agreed standards.
Accreditation on an International Scale
In most developed economies there are bodies similar to the United
Kingdom Accreditation Service. Were these to operate only national
accreditation systems, barriers to trade would be accentuated. Instead,
however, they have set up international accreditation infrastructures to
facilitate the acceptance of goods for import and export across international
borders. In order that these can work, the national accreditation bodies
agree the elements of mutually acceptable international accreditation
systems, develop the necessary technical detail for these to have integrity,
and operate peer evaluation so as to confirm the basis for acceptance of
accredited results worldwide (www.ukas.com).
UKAS is a member of three international accreditation organisations:

International Laboratory Accreditation Cooperation (ILAC)

International Accreditation Forum (IAF)
European cooperation for Accreditation (EA)
UKAS represents the UK Government in these international organisations

and, generally through these, negotiates mutual recognition arrangements
with other overseas accreditation bodies. The international functions are
undertaken on behalf of Government and are supported by the Department
of Trade and Industry. The international recognition of UKAS as a signatory
to multilateral agreements enables government to use accredited bodies to
meet its obligations under world trading agreements such as those deriving
from EU Directives and the World Trade Organisations Agreement on
Technical Barriers to Trade.
EA-7/04: Legal Compliance as a part of Accredited ISO 14001: 2004
certification.
The European Co-operation for Accreditation (EA) is the European Network
of nationally recognised accreditation bodies operating within the European
region. Including organisations such as UKAS and INAB - all members must
be able to demonstrate compliance with the applicable standards, and are
23
subject to peer review.

EA-7/04 was produced by a working group within the EA with the purpose
to provide useful information on the relationship between an organisations
accredited Environmental Management System (EMS) certification according
to ISO 14001:2004 and that organisations degree of compliance with
applicable environmental requirements (EA, 2007). The document provides
a summary of the areas within the system and of the auditing process
(internal and external) which should serve to ensure and demonstrate
compliance with applicable environmental legislation.
The main purpose of EA-7/04 is to provide clarification over the issue
of whether the implementation and maintenance of an EMS enhances
environmental performance, and therefore can lead to a relaxation in
regulatory oversight, by focusing on the issue of legal compliance. As such, it
has become the benchmark tool regarding legal compliance for certification
bodies which via accreditation through UKAS, fall under its remit.
EA-7/04 defines legal compliance as full implementation of applicable
environmental legislation. Compliance occurs when requirements are met
and desired changes are achieved (IMPEL, 1992); and goes on to state that
legal compliance with respect to the interface between the organisation
and the environmental regulators can be understood as the situation
when no reactive enforcement actions are made or can be expected by the
organisation (EA, 2007).
The issue remains, however, as to what extent certification of an EMS can
and does demonstrate legal compliance, and the European Co-operation
for Accreditation assert that while certification of an EMS against the
requirements of ISO 14001:2004 is not a guarantee of compliance they add
that neither is any other means of control, includinglegal compliance
inspections, {but} it is a proven and efficient tool to achieve and maintain
such legal compliance (EA, 2007)).
EA-7/04 specifically states that any organization failing to demonstrate their
initial or ongoing commitment to legal complianceshall not be certified or
continued to be certified [and] deliberate or consistent non-compliance
shall be considered a serious failure to support the policy commitment to
achieving legal compliance and should preclude certification or cause an
existing ISO 14001 certificate to be suspended or withdrawn (EA, 2007)
The issue regarding whether the system ensures compliance is further
complicated by the assertion that it is not the role of certification body
auditors to make a direct evaluation of legal compliance, but it is the role
of the organisation, and a function of the EMS to be able to demonstrate
compliance status.
Within the section on Compliance Criteria for the Certification decision,
there are three important clauses:
1) The organisation should be able to demonstrate that it has achieved
compliance with environmental legal requirements through its own
evaluation of compliance prior to the certification body granting
certification
24
2) Where the organisation may not be in legal compliance, they should

be able to demonstrate a documented agreement with the environmental
regulator on a plan to achieve full compliance. The successful
implementation of this plan should be considered as a priority within the
management system
3) Exceptionally the certification body may still grant certification but shall
seek objective evidence to confirm that the EMS is capable of achieving
the required compliance once the above documented agreement is fully
implemented
In summary, this document has become the benchmark assessment tool
with respect to legal compliance for both certification bodies as well as
for the Accreditation body (e.g. UKAS). The document stresses throughout
that assessors are not inspectors of the environmental regulator, and should
not provide statements or declarations of legal compliance, but that they
verify the evaluation of legal compliance and that whilst ISO 14001 cannot be
an absolute and continuous guarantee of legal compliance, neither can any
legal scheme. The EMS provides a framework whereby compliance can be
assessed and achieved consistently, and provides the support for continual
improvement of the organisations environmental performance.
Confidence in Accreditation
UKAS sought to bolster confidence in UKAS-accredited EMS via a review
of the EMS accreditation processes. The assessment process is conducted
in a more robust and challenging manner, scrutinising the assessment
methodologies of EMS certification bodies in greater detail. The transition
from the current accreditation standard ISO / IEC Guide 66:1999(E) to a new
International Standard ISO / IEC 17021:2006 (see pgs. 36-37) in tandem with
EA-7/04 places greater emphasis on the impartiality of the certification
process and the competence of all certification body personnel, managers,
administrators and auditors. Certification bodies face significant work to
demonstrate to UKAS that their processes meet the requirements of the
standard by the transition deadline of 15 September 2008. UKAS has
recognised that the ability to provide feedback plays an important role in
maintaining confidence in the integrity of EMS. Consequently, each UKASaccredited certification body is required to have a complaints procedure and
make this information available to its clients. Additionally, EMS certification
holders can make customer feedback to UKAS directly and these matters
are managed with strict confidentiality. The International Standard ISO
14001:2004 and the EMAS Regulation (EC No 761 / 2001) are also under
revision, which presents an ideal opportunity to direct the purpose of the
standards. UKAS has a clear voice in the revision process through its roles
on the relevant British Standards Institution Committee and the Forum
of Accreditation Bodies established by the European Commission. Other
avenues for UKAS to influence the development of accreditation guidance
include involvement in the European Cooperation for Accreditation and
the International Accreditation Forum. The UKAS EMSAC (Environmental
Management Systems Advisory Committee) provides one of the main
opportunities for engagement in EMS accreditation. UKAS also continues to
work closely with IEMA, Defra and the regulators, such as the Environment
Agency and the Scottish Environment Protection Agency, to enhance the
value of accreditation at a government level.
25
2.4 Certification of EMSs

Defra believes that a robust and effective EMS should be externally audited
to a recognised international or national standard by a Certification Body
accredited by the United Kingdom Accreditation Service (UKAS) (Defra
Positioning Statement April 2008), with the view that accredited third
party certification is important to realise many of the benefits of an EMS.
Companies with an accredited certified EMS are given greater recognition
by the Environment Agency under Integrated Pollution and Prevention
Control (IPPC) and some other regulatory regimes. Accredited certification
means that organisations can demonstrate to shareholders, regulators
and the public that their system has been audited, in the same way as are
their financial accounts, by those with appropriate professional skills, and
knowledge. The information provided by a certified system is often seen as
being more credible and reliable.
The Scottish Environmental Protection Agency in their position statement
has stated support for EMS and believes that they can benefit the
company and the environment and assist companies in understanding how
environmental law applies to their site, products and operations. However,
at the time of publication (prior to remas) they were unconvinced that
EMS had a sufficiently positive impact upon: permit compliance, frequency
of incidents, and numbers of public complaints. They stated that if, as a
regulator, they were to consider provision of financial incentives (such as
available via the Environment Agencys Opra scheme) they would have to be
provided with a clear case to the contrary (SEPA, 2004)
Certification is the process by which an organisations system (e.g. its EMS)
is assessed for its conformity to the requirements of a standard (e.g. ISO
14001:2004). Certification Bodies (CBs) may be accredited to perform such
assessments where they meet the criteria in ISO/IEC Guide 66 (ISO, 2003) or
ISO/IEC 17021:2006 (from September 2008).
Accreditation bodies check on a regular basis via surveillance at the CBs
offices, witnessed assessments at their clients sites and other activities that
certification bodies are capable of providing accredited certification. Similar
processes are operated to accredit environmental verifiers to carry out
verification under EMAS, including the validation of EMAS environmental
statements, and IEMA Acorn inspection bodies.
Accredited CBs are bound by the requirements under which they operate
to maintain confidentiality. They must have arrangements to safeguard
the confidentiality of the information they obtain in the course of their
certification activities, including on-site audits. CBs cannot disclose
information to a third-party about the organisation that has been certified
without the written consent of that organisation. If there are circumstances
where the law requires information to be disclosed, then the CB must inform
the organisation beforehand of the information that they have been required
to provide.
26
There are different types of audits that are required within an EMS and that
usually make up an organisations audit programme. These are a combination
of:
1st Party - An audit performed within an organisation by the
organisations own auditing resource. Also referred to as an internal
audit.
2nd Party - Audits of contractors/suppliers undertaken by or on behalf
of a purchasing organisation. This may include the assessment of
companies or divisions supplying goods or services to others within the
same group.
3rd Party - Audits of organisations undertaken by an independent
certification body or registrar or similar third party organisation.
Purpose of certification
Third-party certification assessment provides an independent appraisal of
a management system. The assessment is designed to determine whether
or not an organisation satisfies the requirements of the relevant clauses of
the standard. It will involve preparation, a review of documentation, on-site
audit and a consideration of audit reports. It also includes other activities
such as a site tour and staff interviews at all levels within an organisation.
On completion of an assessment, a CB should have sufficient information
to enable a decision on the grant of certification to be made. An important
element of the certification and verification process is that, in addition to
evaluating whether the system elements have been implemented, the
assessor will determine whether the organisation is capable of running the
system and improving it in the future. As such, the award of an accredited
ISO 14001:2004 certificate or EMAS registration indicates an organisations
ongoing commitment to legal compliance and gives some indication of its
capability to comply in the future. The certification and verification process
will also determine the extent to which the organisation has set objectives
and targets, instigated improvement programmes, and how well they
are linked to its legal compliance and performance improvement policy
commitments. The IEMA Acorn Scheme uses accredited inspection, rather
than accredited certification, for determining whether an organisation has
met the schemes requirements. The reason for this is that the certification
standards used by accreditation bodies can only be used for assessing
organisations that have a fully implemented and functioning system;
organisations using the IEMA Acorn Scheme will not have all the system
elements implemented in the earlier phases, hence the use of inspection
standards.
EMAS Registration
(www.iema.net)
The route to EMAS begins with a document review normally conducted
on site to meet accreditation requirements for ISO 14001, and an on-site
verification audit and validation of the environmental statement. The
process is illustrated in Figure 7. As a first step, the verifier ensures that an
EMS has been implemented according to the requirements of Annex 1 of
the EMAS Regulation. The process of verification of the EMAS management
system is essentially similar to that for ISO 14001:2004 as described above
except for the additional environmental statement, although there is also
additional emphasis on legal compliance and environmental performance
27
improvement (www.iema.net).
Statement validation: when the requirements of the EMAS Regulation have
been adequately addressed by the organisation, the verifier checks the
accuracy and adequacy of the statement and, once satisfied, confirms (or
validates) it by signing and dating each page and counter-signing the final
page of the statement. The statement is then forwarded to the verification
body along with the report. Importantly, the verifier shall not validate the
environmental statement if during the verification process he/she finds
through spot-checks that the organisation is not in legal compliance.
Statement amended by verifier: when the requirements in the EMAS
Regulation have not been fully addressed by the organisation, the verifier
issues corrective actions or nonconformities and the organisation then
amends the environmental statement as necessary. The verifier agrees a
timescale for the revised statement to be forwarded for validation once the
changes have been made.
Statement reviewed: the statement will be reviewed by the verification
body and the original signed statement is returned to the organisation.
The organisation can then apply for EMAS registration with the appropriate
competent body by completing the application form and enclosing
the appropriate fee. The competent body in the U.K. is the Institute of
Environmental Management and Assessment. The organisation should also
forward a copy of the final printed version of the environmental statement to
the verification body.
Verification frequency: following EMAS registration, the verifier ensures that
all elements required to maintain EMAS registration are verified in a period
not exceeding 36 months. This is usually through a surveillance programme
of a visit every 12 months in the 36 month period. In addition, any updated
information on the environmental statement is validated at intervals not
exceeding 12 months. In smaller organisations, the verification may take
place in one visit, at a frequency to be agreed between the verifier and the
organisation. Even so, the whole system must be verified at least every 36
months. Deviations from the frequency with which updates are performed
can be made in certain circumstances.
Figure 7 EMAS registration process

Source: IEMA Vol 6 Legal Compliance
28
ISO14001 Certification
(www.iema.net)
Certification assessment is conducted in two stages (in accordance with ISO /
IEC 17021:2006):
Stage 1 audit: the purpose is to check that the requirements of the standard
are adequately addressed by the organisations EMS. Stage 1 also assesses
the extent to which the EMS has been implemented and applied in order to
determine a suitable time frame for the organisation to move towards the
stage 2 audit. The assessment programme for the stage 2 audit is also agreed
at this stage. With reference to legal compliance, the stage 1 audit should
ensure that the:

EMS is designed to meet the environmental policy the policy should

include a commitment to comply with applicable legal requirements and
other requirements relating to its environmental aspects;
organisation has appropriate environmental permits in place, e.g.
discharge consents and process licences, relevant to its activities,
products and services;
organisation has identified all applicable legal requirements relevant
to its activities, products and services within the scope of its EMS and
determined how the legal requirements apply to its environmental
aspects; and
an overview has been carried out of applicable regulations (including
licences and permits) and any agreements with regulators, (such as the
Environment Agency or the local authority), that the organisation may
have.
The assessor also informs the organisation of any additional information that
will be required for inspection at the stage 2 audit, such as:

licence and permit requirements; and

records, including records of incidents, breaches of regulation or
legislation and relevant correspondence with regulators and relevant
authorities and any other information on which the organisation based
its assessment of compliance with regulatory requirements.
Stage 2 audit: the objective of the stage 2 audit is to ensure that the
requirements of the standard are being met in practice. This stage of the
assessment focuses on many issues. Key issues are control, monitoring and
improvement to ensure compliance with legal and other requirements. An
assessor examines matters relating to legal compliance in detail, including
ensuring that the organisation has established, implemented and is
maintaining a procedure for periodically evaluating its compliance with
legislation. The assessor will inspect the results of the periodic evaluation of
legal compliance. The Stage 2 assessment has a standard format consisting
of:

an opening meeting at which the assessor confirms the scope of the

registration and the audit programme this will relate to the scope of the
EMS which the organisation is required to define and document under
clause 4.1;
the assessment itself including a tour of the premises, interviews with
29
staff at all levels, examination of documentary evidence and observation

of tasks being carried out it is at this stage that any deviation from
procedures or the requirements of the standard is noted by the assessor
these non conformances are discussed with the organisation which is
given an opportunity to challenge or agree to them; and
a closing meeting, during which the assessor presents a report on the
assessment and summarises the agreed non-conformities. Depending
upon the nature of the non-conformities, the assessor recommends
either certification or non-certification.
Certification: the assessors report is forwarded to the CB with a

recommendation regarding certification. The report will be reviewed and if
approved a certificate will be issued.
Regular surveillance: an EMS is, or should be, dynamic and regular
surveillance visits are undertaken to ensure continued conformance with
the standard and to confirm continual improvement in the performance
generated by the EMS. With respect to legal compliance, the surveillance
audit ensures the functioning of procedures for the periodic evaluation and
review of compliance with applicable legal requirements. CBs carry out a reassessment of the entire EMS over a three-year period, ensuring that all the
elements of the system are audited.
Enquiry
Application
Stage 1 audit
Stage 2 audit
Certification not
recommended
Reassessment
Certification
recommended
Surveillance
Figure 8 ISO14001 Assessment Process
Source: IEMA Vol 6 Legal Compliance
30
BS8555 Certification
The BS8555 implementation process has been designed as a series of
iterative cycles or phases. There are six phases in all with a number of stepby-step actions or stages within each phase. The first five phases relate to
implementation of an environmental management system. At the end of
each phase and prior to embarking on the next, organisations can consider
an internal audit to satisfy themselves that the stages are complete, and
that the associated guidance has been considered and, where appropriate,
implemented. A sixth phase is included for those organisations that wish
to achieve accredited certification to BS EN ISO 14001 and/or that decide
to pursue external reporting on their environmental performance and/or
registration under the EMAS scheme.
Green Dragon Certification (Arena Network)
The standard made up of five steps incorporates the key elements of
Planning, Taking Action, Checking Progress and Reviewing Achievements to
realise continual environmental improvement.
Some organisations progress through each of the steps until they reach
Step 5, a certificate is issued at each of the 5 steps and upon achieving all 5
steps. Organisations are re-audited annually to ensure the standard is being
maintained and those achieving Step 5 may also be successful in achieving
ISO 14001 or EMAS.
Role of Assessors and auditors
An assessor conducts a visit as part of the initial certification process.
Subsequent periodic surveillance and re-assessment visits are made to verify
the continuing conformity of the organisations EMS to the standard and that
the EMS has been properly implemented and maintained and that continual
improvement is evident. An assessor checks that the requirements of the
ISO 14001:2004 or EMAS standard have been met. The assessment focuses
on the resources committed to satisfying these requirements to ensure that
they are being applied in a manner which benefits the environment, the
organisation and the local community in which the organisation operates.
This is accomplished through close examination of the factors that give
rise to ongoing environmental performance improvement. It assists the
organisation in meeting regulatory requirements and delivering reductions
in its environmental impacts, thus improving environmental performance
as a whole. Assessors play a key role in ensuring that certified EMSs are
delivering meaningful results. This requires them to meet comprehensive
competence criteria.
Competence of assessors and auditors
The competence requirements for assessors are laid down in the
accreditation criteria of CBs offering certification of EMSs. In addition,
minimum criteria are prescribed in ISO 19011 (ISO, 2002). The qualification
criteria for EMS auditors cover:

personal attributes;
the ability to apply knowledge and skills;
audit principles, procedures and techniques;
31
management systems knowledge;

organisational situations such as organisational size and structure;
applicable laws, regulations and other such requirements;
environmental management methods and techniques;
environmental science and technology; and
technical and environmental aspects of operations.
An assessor should have knowledge of environmental management systems,

environmental terminology, pollution abatement and control techniques
and the type of organisation being audited this includes knowledge of
the sector and issues such as the size and complexity of the organisation.
In addition, an assessor should have a sufficiently detailed knowledge of
environmental laws and regulations to know whether an organisation
has correctly identified all its applicable legal requirements related to its
environmental aspects. Inspectors involved in the IEMA Acorn Scheme
require the same competencies as those already outlined, but with additional
training given in order ensure consistency of interpretation when judging
degrees of EMS development against the guidance in BS 8555.
Auditors may gain certification to the International Register of Certified
Auditors (IRCA) or other recognised national schemes such as the IEMA
Register of Auditors. These registers provide programmes of Continuing
Professional Development and recognition for the competence of auditors
across environment, quality and health and safety auditing roles.
In-Brief

Certification is the process by which an organisations system (e.g. its

EMS) is assessed for its conformity to the requirement of a standard (e.g.
ISO 14001:2004).
Certification to any environmental standard will require :
- A detailed understanding of legal requirements and a commitment
to comply
- Evidence of continual improvement in environmental issues
Certification Bodies (CBs) may be accredited to perform such
assessments where they meet the criteria in ISO/IEC Guide 66 (ISO, 2003)
or ISO / IEC 17021:2006 (from September 2006) .
1st, 2nd and 3rd party audits will make up an organisations audit
programme.
Third-party certification assessment provides an independent appraisal
of a management system.
An assessor conducts a visit as part of the initial certification process.
Subsequent periodic surveillance and re-assessment visits are made
to verify the continuing conformity of the organisations EMS to the
standard and that the EMS has been properly implemented and
maintained. Continual improvement must be evident.
Validation for EMAS can only take place when there is evidence of full
legal compliance.
The competence requirements for assessors are laid down in the
accreditation criteria of CBs offering certification of EMSs and auditors
may be placed on international (IRCA) or national (IEMA) registers.
32
EMS Certification: the ENDS Survey 2003 & 2006

In December 2003, the ENDS Report published the results of an opinion
survey conducted jointly with the Institute of Environmental Management
and Assessment. It revealed widespread concern regarding the perceived
integrity of certified EMS, with almost half of respondents believing that
certification bodies are not sufficiently competent (ENDS, 2003), and
67% believing that EMSs provide the basis for achieving significant
environmental performance improvement that otherwise would not have
been achieved. Following this survey, and speaking at the EMS national
Forum later that month, the UKAS external affairs Director, Roger Brockway,
stated we have let things slide and I think certification bodies have let things
slide, and we have to take some responsibility for that (ENDS, 2003).
Subsequently UKAS began a review to the system of accreditation in order
to reassert the integrity of the certification process. In 2006, ENDS, along
with IEMA, UKAS and the Environment Agency engaged in another survey
to ascertain the opinions of professionals once again with around 600
respondents, participation was almost twice that of 2003.
Interestingly, respondents views regarding the role of an EMS in enhancing
environmental performance had changed relatively little, with 70% citing
EMS as the basis for driving performance improvements a 3% gain on
2003, which while perhaps lower than one might expect, the report does
suggest that few if any other voluntary tools could provide such assurance.
With regards the question of legal compliance: over 90% believed that the
implementation of an EMS leads to better identification of legislative noncompliance.
Key findings are demonstrated below, and they demonstrate a belief among
respondents that confidence in UKAS and certification bodies was growing,
though it should be noted that organisations would be principally operating
under the revised standard of ISO 14001:2004 at this point, and that to some
extent this may have driven the confidence in the certification process also.
The findings are outlined on the next page:
33
Over 95% of respondents were of the belief that an EMS can/

will reduce risk 64% stating that performance between
different organisations is variable.
85% of prospective purchasers said a suppliers EMS would

have some influence on their decision to buy but they would
want additional evidence or product-specific criteria to be
met.
Over 70% feel that verifiers and certifiers spend an

appropriate amount of time on-site.
34
Greater than 80% believe certifiers and verifiers check

at least for documentary evidence that a full internal
evaluation of compliance has been carried out.
One-fifth felt that individual assessors within certifying/

verifying bodies do not provide consistent or comparable
conclusions.
Three-quarters of respondents feel certifiers/verifiers spend

an appropriate amount of time on assessments.
A small majority said their confidence in UKAS has not

grown in the last 12 months
Source: Ends, 2006

Half of respondents feel that the credibility of accredited
certified/verified EMSs has improved.
35
Since these surveys UKAS has undertaken an extensive review of its

own accreditation processes based on stakeholder consultation. Greater
attention was given to the assessment of auditor competence, the reporting
of environmental performance and legal compliance and the role of the
advisory committee within certification bodies. UKAS also increased
its awareness campaign, promoting the benefits of UKAS-accredited
certification to businesses across all industries. The most important
acknowledgement of the benefits of accredited certification has been
given through the work of the remas project. This three-year pan-European
project provides evidence directly linking EMS with improved environmental
performance, which in turn leads to improved regulatory performance. These
findings effectively restored confidence in the integrity of UKAS-accredited
EMS certification (see section 5.4 remas).
In Brief

An Accredited Certification Body is an organisation accredited by an

authorising body such as UKAS (the United Kingdom Accreditation
Service) to undertake third party assessment of management systems
such as ISO14001 and to award and withdraw Certificates of registration
to these standards.
Accredited certification means that organisations can demonstrate
to shareholders, regulators and the public that their system has been
audited, in the same way as are their financial accounts, by those with
appropriate professional skills, and knowledge.
The British Government in its position statement believes accredited
third party certification is important to realise many of the benefits of an
EMS.
In most developed economies there is a body similar to the United
Kingdom Accreditation Service.
In October 2006 a professional opinion survey involving more than
600 environmental professionals revealed how effective they think
environmental management systems (EMSs) really are. The survey was
carried out jointly by ENDS, the Institute of Environmental Management
and Assessment, the Environment Agency and UK Accreditation
Service and concluded that whilst confidence in UKAS had not
grown significantly in the 3 no. years since the previous survey, many
respondents had increased confidence in the credibility of certification
bodies and 97% believed that an EMS will reduce environmental risk.
36
2.5 Management Systems and Legal Compliance

Continual management of environmental impacts requires a structured
approach and EMSs provide a way for an organisation to do this. Legal
compliance (BS8555 Phase 2 Stage 1-5; ISO 14001;2004 4.3.2 and 4.5.2)
and good environmental performance are fundamental requirements of an
EMS. A robust EMS should lead to improved environmental performance,
including better and more consistent legal compliance. Regulators are
supportive of accredited certification to ISO 14001:2004 as the basis for a
systematic approach to managing environmental legal compliance
(www.iema.net).
Environmental impact
assessment
(identify legal requirements)
Risk assessment
(assess legal compliance)
of
of
Activities, products and

services
Environmental impacts
Control measures to mitigate environmental impacts

(achieve legal compliance)
System and procedures - to operate and maintain control measures

(manage legal compliance)
Figure 1 Key Elements of legal compliance in an EMS

Source: IEMA Practioner Vol 6, 2005
37
Regulators may also support EMAS (which incorporates conformance to ISO

14001) as a way for organisations to demonstrate their green credentials
beyond ISO 14001:2004 accredited certification. A company registered to
EMAS must comply with legislation, and assurance must be sought from
the environmental regulator. EMAS also places additional emphases on
environmental performance and public environmental reporting. The
regulatory approach at any site will always be informed by the observed
standards of environmental protection and management, including permit
breaches, incidents and complaints from the public. When regulators carry
out assessments of compliance, information from an EMS may be used
to demonstrate (i.e. give assurance) that an organisation is or has been in
compliance. EMS records provide an objective means for the regulator to
make such appraisals and may provide evidence for an audit trail.
Figure 2 Regulatory value of an EMS

Source: IEMA Practioner Vol 6, 2005
38
Source: IEMA Practioner Vol 6, 2005.

Regulators have been previously concerned at the lack of consistency
in approach between certification bodies during assessments with not
enough attention paid to compliance with legislation. IEMA also states that
regulators have expectations of accredited certification these are detailed
below:
Assurance that legal compliance is being effectively managed,

regulators expect:
certification assessments to provide assurance that organisations
are conforming to the standards key requirements concerning
legal compliance (ISO 14001 : 2004, clauses 4.3.2, Legal and Other
Requirements and 4.5.2, Evaluation of Compliance);
a greater emphasis on identifying and correcting legal non-compliances,
as well as detecting and correcting non-conformances with the standard;
better communication and information exchange, particularly with
regard to the identification and notification (to regulators) of noncompliances found or reported during a certification assessment;
greater transparency in the circumstances and process for suspension or
withdrawal of certification, including dealing with complaints from third
parties; and
that organisations that have regular legal non-compliances (due to
management failures) would not retain their ISO 14001 certificates, or
EMAS registrations,
Competencies and training of certification assessors: regulators expect:
assessors and assessment teams to be selected according to relevant
environmental and legal competencies and experience related to the
organisation being assessed; and
all UKAS accredited certification bodies to have access to and use
the same criteria for selecting assessors. It should be stressed that
accredited certification bodies are required to use auditors who meet the
requirements of ISO 19011 (ISO, 2002).
39
3.0 Drivers to the Implementation of an EMS

3.1 Overview of Legislation & Policy
3.1.1 Formulation of Legislation
Environmental legislation is changing all the time. Much of it originating from
the European Union, but there is a great deal of national regulation as well.
Most legal requirements fall into one of the following categories:

EU Regulations - Binding on all Member States in their entirety and

directly applicable in law. Normally used for detailed and specific issues.
EU Directives - These must be transferred into the national law of each
Member State.
EU Decisions - Binding in their entirety, they may be addressed to a
government, a private enterprise or an individual.
Acts of Parliament - Laws generated by the UK. They will include laws
derived from EC Directives.
Regulations - Enabled by Acts of Parliament and made by Ministers.
These are made by government ministers under rights, powers and
duties which stem from Acts.
Orders - Give the force of law to enabling actions of Ministers.
3.1.2 Northern Ireland Legislation

Within Northern Ireland, the Planning and Environmental Policy Group
(PEPG) is the key department within the Department of the Environment
(DoE), responsible for policy and legislation relating to environmental issues.
It has set out a number of objectives which among others, include:

Develop Integrated and effective environmental policies and legislation

Ensure the timely and effective transposition of EU Environmental
Legislation
Promote sustainable development within Northern Ireland
Working alongside devolved institutions in Wales and Scotland as well as

other Northern Irish Agencies particularly the NI Environment Agency, DoE
PEPG has responsibilities covering issues as diverse as Waste, Climate Change,
Biodiversity, Contaminated land and protection of Water Bodies.
3.1.3 Enforcement of Legislation in Northern Ireland

(see Appendix 5)
The main authority responsible for enforcing environmental legislation
in Northern Ireland is the Northern Ireland Environment Agency. NIEA
incorporates four directorates, three of which administer and enforce diverse
sub-sectors of legislation. The four directorates are as follows:
Environmental Protection:
Water Management Unit
Land and Resource Management Unit
Industrial Pollution and Radiochemical Inspectorate
Drinking Water Inspectorate
Strategy Unit
40
Built Heritage:

Protecting Historic Buildings

Protecting Historic Monuments
Recording Built Heritage
Corporate Services:

Learning and Development

Finance
Co-ordination Unit
Information Technology
Corporate Communication
Freedom of Information
Natural Heritage:

Conservation Science
Conservation Designations and Protection
Countryside and Coast
Regional Operations
Biodiversity
Three of the key units responsible for regulation of NI organisations are as

follows:
The Water Management Unit has responsibility for the protection of the
aquatic environment. It carries out a variety of activities including:
1) Monitoring water quality
2) Controlling effluent discharges
3) Taking action to combat or minimise the effects of pollution.
The Land and Resource Management Unit is responsible for the
implementation of waste management policy. Towards Resource
Management (NIs current waste management strategy) reinforces the
proposed activity as enshrined within the Framework for waste prevention
in Northern Ireland to encourage the implementation of Environmental
Management Systems, stating that EMSs provide a systematic way of
managing the environmental concerns of a business addressing immediate
and long term impacts of all practices within an organisation. The remit of
LRM includes among others:
1) Waste Management Licensing
2) Control and Management of Hazardous Waste
3) Development of guidance for contaminated land
4) Management of land quality database
The Industrial Pollution and Radiochemical Inspectorate is the unit
responsible for the regulation of operators in Northern Ireland which fall
under Part A and Part B of the Integrated Pollution Prevention and Control
Regulations and with responsibility relating to the controlled keeping, use
and disposal of radioactive waste. Those operators which would fall under
41
only Part C of these regulations are regulated by the local District Council.
The system of Integrated Pollution Prevention and Control (IPPC) applies an
integrated environmental approach to the regulation of certain industrial
activities. This means that emissions to air, water (including discharges
to sewer) and land, plus a range of other environmental effects, must
be considered together. It also means that the enforcing authority must
set permit conditions so as to achieve a high level of protection for the
environment as a whole. These conditions are based on the use of the Best
Available Techniques (BAT), which balances the costs to the operator against
the benefits to the environment. IPPC aims to prevent emissions and waste
production and where that is not practicable, reduce them to acceptable
levels. IPPC also takes the integrated approach beyond the initial task of
permitting, through to the restoration of sites when industrial activities
cease.
In order to ensure a high level of environmental protection, effective
management systems are considered useful tools. Under IPPC, some
operators will apply environmental management systems at their
installations, certified to standards such as EMAS, ISO 14001:2004, BS8555
and Green Dragon, while a number of permitted organisations have informal
(un-certified) management systems in place.
Across Northern Ireland, 82 Permits have already been determined for Part A
and B processes, with a further 209 Permits pending. A full list of these can
be seen in Appendix 4.
Along with the responsibilities of District Councils in regulating the impacts
on the environment, NI Water Ltd holds some responsibility, particularly in
the area of Trade Effluent Discharges. Since the 1st April 2007, NI Water took
over from the Department of Regional Developments Water Service. While
still 100% Government owned, NI Water Ltd has now lost Crown Immunity.
This has been important in ensuring the NI Water increases the quality of
its own effluent discharges, whilst increasing the importance placed on the
quality and quantity of effluent it will receive from domestic and commercial
/ industrial premises.
To date there is no reliable NI specific information on the level of compliance
with legislation of companies with or without Environmental Management
Systems. The next phase of this project for NIEA will provide data surrounding
this compliance evaluation issue.
42
3.2 Procurement Policy in Northern Ireland

Northern Ireland Sustainable Development Strategy First Steps
towards Sustainability
(www.ofmdfmni.gov.uk)
First Steps is the first ever sustainable development strategy for Northern
Ireland, published in May 2006 the strategy presents the opportunity to
achieve a better balance between social, environmental and economic
progress.
One of the visions of the strategy is a vision of Northern Ireland as a one
planet economy. (reference Northern Limits) The priority is to reduce
dramatically the amount of resources consumed and, just as important,
the amount wasted and to get much more from the resources used in
production. Three strategic objectives on sustainable consumption and
production have been chosen for the strategy.
To become more resource efficient;

To make the Northern Ireland public sector a UK regional leader in
sustainable procurement
To minimise the unsustainable impacts of consumption
The government will meet the objectives by:

Communicating and promoting the one-planet living concept and

regularly updating the ecological footprint for Northern Ireland to
illustrate impact and to measure progress.
Promoting the wider use of Environmental Management Systems (EMS)

and the uptake of environmental reporting such as the annual survey of
the largest Northern Ireland companies.
Significantly reducing leakage of mains water and developing campaigns

to encourage reductions in the demand for consumption of potable
water.
Pursuing sustainable development objectives through purchasing and

expenditure decisions and make Northern Ireland a regional leader in
sustainable public procurement.
Developing a database to monitor the implementation of existing
guidance on integrating environmental, social and economic
considerations into procurement decisions.
Working with the Food Standards Agency and other partners to promote
healthy eating.
Introducing across the Northern Ireland Civil Service a wide-ranging

programme known as Workplace 2010 which aims to make better use of
space and reduce energy consumption.
Implementing a rolling plan to require public sector office
43
accommodation to achieve a BREEAM rating of at least very good.

Environmental Management Systems (EMS) will reinforce the progress
made.

Promoting the Travelwise initiative to achieve a modal shift in terms of

how staff travel to and from work.
3.2.1 Central Procurement Directorate

(www.cpdni.gov.uk)
Governance can be defined as the process of decision making and
implementation. Central Government is one key component of good
governance. Sustainable development has profound implications for
governance. A society committed to sustainable development will be
characterised by a system of governance that focuses on mainstreaming and
balancing social, economic and environmental progress.
There are two strategic objectives on governance in the Northern Ireland
sustainability strategy:

To mainstream sustainable development across Government;
To strengthen the network of accountability for governance for

sustainable development
The key targets and important steps from Chapter 6 of the sustainability
strategy are outlined in appendix 2
The public procurement policy for Northern Ireland was agreed in 2002
by the Northern Ireland assembly outlining key governing principles and
the implication of those principles. One implication is that the Executives
economic, social and environmental strategies and initiatives should be more
closely integrated into procurement policy.
Construction can affect communities and businesses and can make heavy
demands on limited natural resources. When planned successfully it can
also lead to positive outcomes. The Government recognises this and is
committed to addressing these issues in order to achieve the delivery of
sustainable development in Northern Ireland. The CPD Policy Framework
for the Procurement of Public Sector Construction Projects (June 2005) is
testament to this commitment with a 5 point plan outlining procurement
strategy. Point 2 embraces Excellence with the OGC Achieving Excellence
Procurement Guide 11: Sustainability identified as the mechanism for
delivering sustainable development. The suite of guides set out the processes
by which public sector clients can procure and deliver construction projects
that best promote sustainable development while still achieving optimum
whole life value for money.
Whilst Procurement Guide 11: Sustainability covers in some detail the
sustainable development issues that should be considered at each key
decision making stage from preparing the initial business case, to operating
and decommissioning the completed facility, it does not fully reference the
benefits of the implementation of an Environmental Management System
and the reader could therefore deem that sustainability and EMS were
44
entirely separate entities.

Point 5 of the CPD Policy Framework outlines the implementation plan for
construction sustainability Sustainability Action Plan with a deadline date
of March 2006. The requirement for all public sector construction projects
to have a BREEAM (or equivalent) rating of excellent for new build and
very good for refurbishment projects, is a commitment by March 2006 and
evidence of this has been seen in public sector tenders since this date. EMS as
a requirement, is again not mentioned in the Sustainability Action Plan.
A large proportion of construction and construction supply companies in
Northern Ireland do however have a fully certified EMS. Recent QPA figures
cite that 49 no. quarrying (and associated road contractor) companies are
accredited to ISO 14001. This could be due largely to the stringent quality
and health and safety systems requirements imposed by DRD Roads Service
for tendering contractors. The Highways Agency National Sector Schemes
has a minimum need for an accredited ISO 9001 (Quality Management
System). Many contractors have used this as an opportunity to integrate
systems with ISO 14001 and the health and safety specification OHSAS
18001, or Northern Ireland specific Safe-T-Cert standard (administered by
Construction Employers Federation). In addition, the Aggregates Levy Credit
Scheme requires all quarry operators to undergo a detailed Environmental
Audit process to enable them to pay a significantly reduced aggregate tax.
The DoE and HMCE have stipulated that this audit must be carried out by
an IEMA accredited Environmental Auditor to a strict protocol covering
104 environmental issues, with a section on Environmental Management
Systems. There is however, no specific requirement for quarry operators to
implement EMS and in the second round of Audits (in 2008) Improvement
Notices issued by DoE under the scheme have yet to stipulate any
conditions relating to the implementation or accreditation of Environmental
Management Systems.
At present the government procurement regime focus appears to be on
sustainability rather than on EMS. The evidence based credits of BREEAM
and its civil engineering equivalent (CEEQUAL) lend themselves well to
organisations with formal or informal environmental management systems
yet, these do not seem to have been recognised by procurement bodies in a
strategic manner. The DRD Roads Service pre-qualification questionnaire for
Term Contract for Road Markings 2009 Question C2.4 Has your organisation
a third party certified Environmental Management System? If yes, provide
a copy of the certificate and a third party audit report of your system. If no,
provide a concise overview of any internal management system that your
organisation has is typical of recent invitations. This one environmental
question however will be judged amongst 21 no. very specific health and
safety questions.
Sustainable Operations on the Government Estate
Action plans have already been produced by a number of government
agencies in order to support the Governments Sustainable Development
Strategy. These aim to intertwine the CPD policy as detailed above along
with sustainably managing the Governments estate in order to encourage
each body the department sponsors, to among other aspects, lead by
example in publicly demonstrating commitment to sustainable development
45
in the way they run their estates.

Objectives and targets are set in relation to waste; water; energy; estate;
travel; and procurement. There is also a commitment within the Estate
section of some of the departments plans, to identify and commence a pilot
Environmental Management System (ISO 14001) on minimum of one site by
October 2006. This demonstrates the increased importance placed upon
EMS in not only managing the impact of government Departments, but also
of the need to display that the greening Government agenda is actually in
process.
The Northern Ireland Environment Agency was the first agency of
the Department of the Environment to receive certification for their
environmental management system to ISO 14001. Speaking after
certification in June 2005, the then Chief Executive of the EHS, Richard Rogers
commented that the system would give staff an effective way to control and
minimise their impact on the environment, and continued on to express his
delight that the agency is taking a lead in attaining systems and standards
that will not only help the environment, but also save public money.
3.2.2 Other local (NI) procurement drivers

Despite the sustainability focus from CPD outlined above, other public
sector procurement initiatives give examples of EMS at the heart of the
procurement process.
One of the leaders in this field is Belfast City Council
Belfast City Council has implemented management systems by Department
over the last 5 years. Individual heads of Department have made
independent decisions relating to management systems development.
The procurement unit led the way with an integrated management system
that included ISO 14001 and ISO 9001. This has subsequently been a
significant driver for companies (particularly in the greater Belfast area)
that are providing goods and services to Belfast City Council, to prove their
environmental credentials. All tenders issued by Belfast City Council now
include an Environmental Management Questionnaire with a list of eight
questions. These are as follows:
1) Does your organisation have a named officer responsible for
Environmental Management?
If yes, please state the name, position and qualifications of that person:
2) Does your organisation have an Environmental Policy?
If yes, please enclose a copy
3) Does your organisation have in place an Environmental Management
System?
If yes, do you have any objection to this being inspected?
4) Does your organisation hold either of the following accreditations?
EMAS
ISO14001
5) Has your organisation compiled a register of Environmental Regulations
and Legislation relating to your business operations?
46

6) Has your organisation compiled an Environmental Effects Register?
7) Do you have an Environmental Action Plan in place to reduce your adverse
impact on the Environment?
8) Please identify (on a separate sheet) the environmental impact in the
provision of your supply/service.
Belfast City Council Events Unit and Fleet Management Unit have also
implemented integrated management systems that meet the requirements
of ISO 14001, ISO 9001 (quality) and OHSAS 18001(health and safety) and
Project Management Unit has embarked upon development of procedures in
readiness of certification.
Constructionline
Constructionline is the UKs register of local and national construction and
construction-related suppliers pre-qualified to work for public and private
sector buyers. It is owned for the department for Business, Enterprise
and Regulatory Reform (formerly the DTI) and supported by the Office of
Government Commerce and the Department of Communities and Local
Government. Its aim is to provide efficiency savings to public and private
sector procurers and the construction industry as a whole by streamlining
procedures (Constructionline Registration Criteria, 2008).
It follows current Public Procurement criteria, and aims to reduce the
administrative burden on buyers and suppliers alike since the relevant
information is submitted and then revised annually; thus reducing time
spent preparing tender submissions. It is of note that there is a specific set
of criteria encompassed within an environmental questionnaire which was
developed alongside Constructing Excellence. Answers must be provided,
and where relevant, supporting documentation should be submitted.
This also demonstrates the growing role of environmental issues within the
public procurement process. It is becoming clear that the Public Sector is
quickly beginning to understand the importance of environmental issues,
and the role they can play in championing value for money throughout the
whole life of the project, however, the role of EMS specifically within the
procurement process is still unclear.
47
3.2.3 Compliance Drivers EA approach to Opra in

England and Wales
Environmental Permitting Regulations Operational Risk
Appraisal (Opra for EPR) (England and Wales)
(www.environment-agency.gov.uk)
The Environment Agency has sought to streamline the Regulation process
for organisations in England and Wales culminating in the absorption of
the Pollution Prevention and Control Regulations within the Environmental
Permitting Regulations. An important tool within this approach has been
the Opra methodology which has been amended and revised frequently
since its inception. The latest revision occurred in line with the
The Opra scheme is a risk screening methodology that builds on the
principles developed by the Environment Agencys EP Opra scheme, which
it supersedes. Its role is to provide a common tool with which to undertake
risk assessments of organisations and to target appropriate regulatory
resources. Operator Performance and Risk Assessment (Opra) in turn evolved
from schemes developed separately for Integrated Pollution Control (Opra
for IPC) and Waste Management Licensing (Opra for Waste). The new scheme
assesses both the environmental hazards of an operation and the operators
performance using information from operators, checked by the Environment
Agency.
Opra is a risk-screening tool used to regulate operators under the
Environmental Permitting (England and Wales) Regulations 2007 (EPR). It
allows the EA to identify and score the following elements of an activity:

what the activity is;

where it is being carried out;
how competent the operator of the activity is;
how well the operator complies with the conditions in the permit; in
order to risk evaluate the activity being conducted by that operator at
that location.
EA use the resulting risk profile to decide how much effort they need in order
to regulate a facility, based on a range of factors related to their risk, such as
where theyre located and what their performance has been like in the past.
This information is then used to decide the charges each operator needs to
pay.
Opra is one step towards the EAs goal of developing a common approach to
regulation across a range of regulatory regimes. EA want to:

make regulation more effective and efficient

make the process easier for both industry and regulators
target their resources at activities that pose the greatest risks to the
environment.
Each attribute is scored to produce a band value (A to E) where A equates to

low risk and good performance and E high risk and poor performance. The
scores for each attribute are added to generate the overall Opra risk profile (A
to E). The information from each Opra assessment is used in two ways:
48
in planning compliance assessments; and

in determining application and annual subsistence charges using the
principle that lower risk requires less Agency regulatory effort and hence
lower fees are charged to the operator.
Opra attributes
The risk assessment is based on the five attributes set out below.
complexity: the complexity of the activities and processes operated and

regulated;
emissions: permitted to all environmental media air, water and land;
location: proximity to and sensitivity of environmental receptors;
operator performance: the extent and effectiveness of the operators
environmental management system covering compliance history,
operation and maintenance, competence and training, emergency
planning, performance evaluation and external reporting; and
compliance rating: compliance with permit conditions, driven by
the number and significance of permit breaches, classified using
the Compliance Classification Scheme (CCS). The principle of which
is to evaluate non-compliance in accordance with the potential
environmental effect and rate the non-compliance accordingly (EA).
They are rated from CCS Category 1 (potentially major environmental
effect) through to CCS Category 4 (no potential environmental effect).
Operator performance (management systems) attribute

Operator performance consists of an assessment of the operators ability,
preparedness and commitment to meet permit conditions and other
regulatory requirements. This takes into account the management systems in
place. EA call this OP1. It also considers previous formal enforcement action
taken by regulatory bodies at the site. EA call this OP2. While OP3 is the
Compliance rating attribute and is based upon any non-compliances noted
and scored using CCS.
EAs position statement outlines the policy that effective management
systems are important to managing the risk associated with an activity and to
delivering permit requirements. Operators are responsible for managing their
facilitys impacts and for ensuring compliance with permit conditions. EA
also believe that the absence of an effective and documented environmental
management system (EMS) indicates a need for an increased level of
regulatory oversight. The management systems in place and the regulatory
enforcement history determine the operator performance (management
systems) attribute.
49
This attribute takes into account the following factors:

Presence or absence of management systems or recognised procedures

covering areas such as:
- Operations and maintenance

- Competence and training
- Emergency planning
- Auditing, monitoring, reporting and evaluation.

Enforcement history at the regulated facility.
Management systems
EAs position statement (Version 2 January 2005) says:
The Agency strongly encourages the implementation and use of robust
EMSs. A robust EMS should lead to improved environmental performance,
including better and more consistent legal compliance. We fully support
EMAS (which incorporates ISO 14001) and recognise its additional emphases
on legal compliance, environmental performance and public environmental
reporting.
The detailed requirements for a management system are proportional to
the risks the system seeks to manage. The presence of accredited certified
management systems will be taken into account when determining risk
profiles. Greater weight will be given to certified systems such as EMAS and
ISO 14001, but other robust and auditable environmental management
systems (EMS) will be taken into account. These systems provide EA with
insight into commitment to comply with the permit whether EA are present
or not.
The amount of credit given by the Environment Agency reflects the reduced
effort in determining permit applications due to information generated by
the EMS, and the potential for reduced compliance assessment effort. Of
the points available within the Operator Performance Section of Opra,
the percentages achievable directly through certification to different EMS
standards are as follows:
- 40% for EMAS certification
- 30% for ISO 14001:2004 certification
- 24% for certification to a published standard subject to external verification
(e.g. BS8555 or Green Dragon)
- Up to 24% for an extensive uncertified EMS which produces a public
statement
While these are directly achievable due to the EMS in place, the remaining
60% of credits are likely to be more achievable if an EMS is in place since they
are predominantly related to procedures: for instance
- Operations and Maintenance
- Competence and training
- Emergency Planning
50
The final section of the Operator Performance section can apply a weighting
of up to negative 40% based on the organisations enforcement history.which considers aspects such as enforcement actions, prohibitions and
convictions brought not just by the Environment Agency, but also by the
Health and Safety Executive (HSE) if relevant to the COMAH Regulations, and
Local Authorities.
3.2.4 Other Compliance Drivers

Supply Chain Management:
The importance of market forces in the implementation of Environmental
Management Systems should not be underestimated. The implementation
of an EMS can be driven down the supply chain by operators with high
public visibility; i.e. a company with a large supplier base may decide that
that the next logical step for their own continued improvement is to ensure
that its suppliers conform to an environmental management standard,
thereby re-enforcing the companys claims to be strong environmental
stewards. The Ford Motor Company in October 1999 detailed a requirement
that all suppliers with manufacturing facilities were to certify at least one
manufacturing facility to ISO 14001 by the end of 2001 and all facilities by the
1st July 2003. At the time, Ford was operating 140 Manufacturing facilities in
26 countries around the world. Therefore those companies supplying parts
were under pressure to certify Environmental Management Systems or lose
high profile, high value, business.
Customer Perception:
Often it is felt that improvements in environmental performance can prove
a useful marketing tool. Sir Stuart Rose, the Chief Executive of Marks and
Spencer has said that in the longer-term, a successful business also has to
be an environmentally and socially sustainable business too (Marks and
Spencer, 2008). Marks and Spencer introduced their Plan A eco plan in
January 2007, and fifteen months into its implementation, energy and waste
costs had been reduced, but also industry surveys such as the Chatsworth
FTSE 100 Green Survey and the Covalence Ethical Ranking show how Plan A
is having a positive effect on how people regard Marks & Spencer retaining
the loyalty of existing customers and winning us new business (Marks and
Spencer, 2008).
Therefore, the development of certified EMSs by NI companies could lead to
improved corporate image among customers and the public, as well as the
regulators.
Improved Environmental Performance
Examples of improved environmental performance through the
implementation of EMS can be seen in case studies published by Envirowise
(a government funded organisation aimed at assisting business with resource
efficiency and waste minimisation). These case studies include:
1) Dairy Produce Packers Ltd. located in Coleraine, Northern Ireland, decided
to undertake a waste audit in the run-up to the certification of their EMS,
with the intention of producing a waste minimisation strategy. The results
51
of the implementation of the strategy greatly improved the environmental

performance of the company for instance: waste disposed to landfill
reduced by 140 tonnes per annum; water use fell by 14,000 m3 per annum;
and greatly improved the ratio of materials such as wooden pallets that
were re-used and cardboard recycled. As well as this reduction in terms
of environmental impact, the company made cost savings of an estimated
46,000 per annum. Alan McMinn, the Factory General Manager summed up
the improvements made the company, in promoting a culture of reduce,
re-use and recycle, has attained its waste minimisation goals and reaped the
financial rewards.
2) Based in Beith in Ayrshire, McKechnie Plastic Components appointed
an environmental co-ordinator, in response to customer requirements, to
develop a certified EMS. The cost savings that could be achieved through
simple environmental improvements and reducing waste surprised the
company and more than paid for the co-ordinators salary. Cost savings have
been estimated at over 93,000 per annum, while environmental benefits
include 40 less tonnes of waste to landfill per year, and reductions in new
packaging and the generation of scrap.
Other local companies noted for successfully implementing and running
certified EMS include:
3) Michelin which chose to implement ISO 14001:2004 in order to improve
the impact of site activity on the environmentThe requirements imposed
by this standard are incorporated into the EMS with the following two
objectives:

- to lessen the impact of the Groups activities on the environment

- reduce the environmental risks linked to this activity
Specific targets have been set in relation to reducing energy consumption,
reducing in-process waste, controlling liquid waste and to limit gaseous
emissions, particularly of Volatile Organic Compounds (VOCs). In relation to
VOCs, Michelin announce that they have achieved a 54% reduction in solvent
use and therefore in VOC emissions based upon the 1992 reference level and
have since targeted reductions of 75%.
4) LaFarge Cement, based in Cookstown operates an EMS certified to EMAS.
Objectives have been set for emissions, which are subsequently monitored
and publicly reported. One of the key emissions monitored and targeted is
Carbon dioxide (kgs) per tonne of cement (PCE). In 1999, for every tonne of
cement produced, the Cookstown works was emitting 1014 kgs of CO2. By
2005, this had been reduced to 833kgs per tonne PCE a reduction of over
17%. LaFarge continues to monitor and target these emissions as well as to
produce Biodiversity action plans, and has targeted reductions in the annual
tonnage of waste disposed of to landfill.
5) GPS Colour Graphics, Belfast the first Carbon Neutral printing company
in Northern Ireland. The company was awarded Irish Environmental Printer
of the Year status in 2005 and again in 2006 for initiatives including the
implementation of their ISO 14001 certified EMS. Whilst reducing their
carbon footprint, GPS Colour Graphics also benefited from reducing waste by
14%, improved efficiency the introduction of a CtP Platemaker has reduced
chemical usage at the site by 50% within the first year. The management
team also expound the virtues of the system for encouraging positive
52
engagement with their 57 no. staff. Business has not suffered at GPS since
the implementation of the EMS and Carbon Neutral status. Derek Bell, MD
states We have worked hard and fortunately successfully at maintaining our
high standards whilst our business experienced significant growth over the
last few years. In 2005 GPS increased in size in terms of sheets printed to 54
million compared with 32.8 million in 2003.
(source Irish Printer, February 2007)
In-Brief

There are a number of drivers for an organisation implementing an EMS

- Legal compliance
- Procurement (particularly government procurement strategy
- Supply Chain Pressures
- Enhanced public image and PR
- Improved environmental efficiencies and cost savings
Government procurement strategy relates to EMS in an ad hoc manner

on a tender by tender basis. As yet, procurement strategy does not
provide structured guidance for the public sector bodies on how to
assess or evaluate organisations with a management system against
those that do not.
First Steps is the first ever sustainable development strategy for Northern
Ireland, the strategy presents the opportunity to achieve a better balance
between social, environmental and economic progress. It also makes the
commitment to promote the wider use of EMS as well as the uptake in
the Arena Survey (see section 4.4.6)
The Opra scheme is a risk screening methodology which builds on the

principles developed by the Environment Agencys EP Opra scheme,
which it supersedes. With points available for the implementation of
certified EMS in particular EMAS and ISO 14001:2004, in the knowledge
that the methodology is linked to fees and charges levied on IPPCregulated sites so having an EMS can result in lower costs (Defra Position
statement on EMS, 2008)
53
4.0 Uptake of EMS

4.1 The International Scene
Up to the end of December 2006, at least 129,199 ISO 14001:2004 certificates
had been issued in 140 countries and economies. The 2006 total represents
an increase of 18, 037 (+16 %) over 2005, when the total was 111, 162 in 138
countries and economies.
Service providers accounted for 27 % of all ISO 14001:2004 certificates issued
up to the end of 2006.
From The ISO Survey of Certifications
54
4.2 Europe
ISO14001
EMAS
There are currently 6,205 sites in 4,138 EMAS registered organisations
55
High uptake rates in Spain and Italy can be explained as over the last years,
legislation has been put in place in Italy with allowances for

a higher score for EMAS registered organisations concerning permits for

use of water;
an EMAS registration replaces application for renewal for permits for
waste management activities;
longer life of permits 8 years instead of the usual 5 years;
Reductions in some regions taxes for EMAS registered organisations;
Reductions in fees for inspection;
and in Spain exemptions from inspections for EMAS registered
companies;
Regional governments give financial support to new EMAS registered
companies every year.
Ref: The firm, Environmental Management and Environmental Measures:

lessons from a Survey of European Manufacturing Firms. N. Johnstone, P.
Scapecchi, B. Ytterhus and R. Wolf in Journal of Environmental Planning and
Management; vol. 47, N 5. 685-707, September 2004.
Source: Europa: http://ec.europa.eu/environment/emas/about/participate/
sites_en.htm
Figure 9 Evolution of organisations and sites
Quarterly Data 13/3/2008
EMAS STATISTICS
EVOLUTION OF ORGANISATIONS AND SITES
Quarterly Data
13/3/2008
7000
Organisations in the
EU and EEA
6000
Organisations
(before the
correction)
Sites
5000
4000
3000
2000
2775
5435
5223
5066
4800
4655
4628
3762
3417 3576
3244
3063
2876
2686
2531
2316
2140
1269
1000
1.
2.
3.
4.
5.
3910 3912
5914
5671
5956
5743
4093
4137
3935
3908
4253
3901 4050
3770
3855 3797
3755 3718 3652
4178
3532
3498 3930
3966
3325
3796
3842
3067 3093 3195
3055
3605
3416
3259
3148
3110 3041 3072 3116
To facilitate comparisons, the previously reported figures are kept on the graph.
The Commission started to collect the number of sites in addition to number of organisations in
March 2004 to provide a more accurate picture of EMAS development.
Germany reported a significant number of corrections in March 2004.
Germany and Spain reported corrections in June 2005.
The UK corrected their number of sites in December 2005.
31/12/97
31/03/99
30/09/99
31/03/00
30/09/00
31/03/01
30/09/01
31/03/02
30/09/02
31/03/03
30/09/03
31/03/04
30/09/04
31/03/05
30/09/05
31/03/06
30/09/06
31/03/07
29/02/08
31.09.2007
(Europa. www.europa.eu)
56
Corrections were undertaken in order to accurately ascertain the numbers

of organisations which had implemented EMAS, and how many sites were
incorporated within the organisations system. Interesting to note is the
slow down which occurred during this period of corrections, but that
subsequently, while the number of organisations implementing EMAS has
developed at a relatively steady rate, the number of sites has grown much
more rapidly. This could suggest that for those organisations which have
implemented EMAS clear benefits have been seen in the sites covered, and
this has been extended to other sites within the groups.
4.3 UK Wide
ISO14001
UK organisations have made rapid progress in implementing EMSs over the
last few years. Globally, the UK is now ranked 6th amongst countries with the
highest number of ISO 14001 certificates (as of the end of 2007 there were
over 6,000 UKAS accredited certifications to ISO 14001 in the UK)
UKAS have details of 52 certification bodies which are accredited to certify
EMS to ISO 14001, however, only 40 of these are recorded as having
issued UKAS accredited certificates to organisations operating in the
United Kingdom. It should also be noted that certification bodies must be
approved under the various European Co-operation for Accreditation Scope
References, and even then it may be full or limited accreditation.
In 2006, over 100 ISO 14001:2004 certificates were withdrawn from
organisations within the UK (around 1.5%). The figures though are provided
as a rough indicator (ISO, 2007) as not all certification bodies provide
information relating to withdrawn certificates. Unfortunately no explanation
is provided for why these were withdrawn whether through noncompliances or company withdrawal from the system etc.
4.4 The Situation in Northern Ireland

4.4.1 Invest NI Support
The Technical and Sustainable Development Unit at Invest NI is aimed at
helping business to solve technical energy and environmental problems.
This remit is served through the support of organisations such as Carbon
Trust, NISP (National Industrial Symbiosis Programme) and Envirowise but
also through the development of training packages, grant aid and loans for
delivery by the Invest NI Sustainable Development team. A number of the
initiatives detailed below will have been delivered by IRTU (pre-Invest NI).
4.4.1.1 Support Scheme Grants

The Environmental Audit Support Scheme (EASS) provided financial
assistance to businesses conducting environmental audits. The scheme
offered 66.67% grant towards the cost of up to 15 consultancy days and
reasonable expenses, subject to a maximum grant of 5,000. It had the
overall aim of assisting industry in taking its first step towards improving
environmental performance, with the objective of encouraging industrial
and commercial enterprisesto commission environmental auditswith a
57
view to formulating and implementing environmental policy.

Within the audit, detailed on-site examinations were carried out of
environmental activities by an independent consultant selected by the
business: a wide range of potential impacts were covered: with the aim of
helping businesses create a baseline of environmental performance and
highlight areas of weakness.
First launched in November 1993, circa 560 businesses were assisted; with an
approx. Invest NI spend of 420,000, 95% of which went towards consultancy
costs - circa 80 audits per annum. A follow up evaluation with 49 businesses
which received support revealed the following information.
Factors Influencing an Audit:
The 49 respondents were surveyed on which of the following factors
influenced their decision to undertake the audit:
Influencing Factor
Number of responses
% of respondents
Compliance with legislation
30
61%
Customer influence/demand
16%
Availability of grant
16%
Previous Environmental Concern
18%
Reduce Operating Costs
6%
PR Opportunity
10
20%
Other
14%
Total
74
*Does not add to 100% as some respondents gave more than one response

The vast majority undertook the audit to determine compliance with
legislation (61%), while the other section is stated by Invest NI to represent
those wishing to achieve ISO accreditation. One fifth of respondents felt
it was a valuable PR tool, and a further 16% undertook it due to customer
influence / demand.
Respondents were then asked to identify the potential environmental
impacts that their business was seeking to address through the audit.
Of these, four impacts (waste management 65%, EMS 29%, Energy Efficiency
26%, and Elimination of waste, recycling and recovery 24%) show a trend
towards the areas of legal compliance and cost reduction. Perhaps surprising
is that only 8% of respondents cited pollution abatement as an impact
requiring addressed, but this may suggest that companies that are more
proactive regarding environmental audits and management systems pose
less of a risk to the environment due to an already heightened awareness of
environmental issues.
58
Implementation of Recommendations:
Respondents were asked to outline the key recommendations, and to what
extent they had implemented them:
Of the 47 that were implementing, or had implemented, the suggestions,
98% felt their business environmental performance had improved, and they
were subsequently asked to comment on the benefits. At the time of survey:
Two businesses had achieved ISO 14001 following completion of the
programme;
One business achieved ISO 9000 accreditation;
A number of businesses confirmed that it gave them a greater
understanding of environmental recycling issues; and
A number of businesses confirmed that their costs and waste had
reduced
Summary
Throughout this survey, there are two prevalent themes: firstly, compliance
with legislation; and secondly, cost reduction through improved efficiency.
There is no doubt that the availability of EASS meant that many businesses
went through the formal audit process that otherwise may not (85%
claim financial support was a key factor in their decision to undertake an
Audit) but that virtually all felt this had led to an improvement in their
environmental performance (98% of those implementing recommendations).
A third of whom went on to make further investments, and almost half of
all respondents were now setting quantifiable targets for environmental
improvement.
Invest NI had also sponsored the Environmental Management System
Support Scheme (EMSS). This scheme operated for a shorter duration than
the Environmental Audit Support Scheme and provided up to 75% grant on
consultancy and certification fees for businesses seeking to implement an
EMS to a recognised standard. A large number of companies participating
in the EASS will have gone on to avail of the EMSS to assist with the
achievement of ISO 14001 accreditation. While this scheme has now ceased,
unfortunately, Invest NI were unable to provide information on analysis
undertaken under the EASS programme.
59
4.4.1.2 Building Blocks

Launched in September 2003, funded by Invest NI and delivered by White
Young Green, this Pilot Programme was designed to help companies achieve
certification to BS8555 the phased approach to implementation. Through a
series of workshops, and designated consultancy days, the 11 companies that
were selected to participate all went on to have their systems certified by an
accredited body to Phase 3 of BS8555. Nine of these companies continued
through the later Phases of the Standard, and at the time the evaluation of
the Programme was undertaken (May 2005), six of these had been certified
to ISO 14001.
The evaluation of this Pilot Programme included making contact with all of
the eleven companies which participated in the programme focusing on:
Drivers for undertaking the Programme; Perceived benefits of undertaking
the Programme; and Realised Benefits of undertaking the Programme.
Drivers for Application:
1) 68% due to the availability of funding.
2) 58% to improve legislative compliance.
3) 34% due to customer influence / demands.
Perceived Benefits:
1) 86% thought they would see an improvement in environmental
performance.
2) 46% felt they would benefit from improved liability control.
3) 38% thought they would see financial benefits.
If improved environmental performance was sought, the organisations were
asked to detail how they hoped this would manifest itself:
1) 100% hoped to improve waste disposal routes.
2) 90% expected reduced energy consumption.
3) 80% were targeting a reduction in the waste generated.
Realisation of perceived benefits:
Organisations were to allocate responses on a scale of 1 -4, where 1 equalled
not a lot and 4 equated to a lot. By combining the scores 3 and 4 (i.e. the
positive responses), the top three were as follows:
1) 100% felt they had improved liability control.
2) Just over 80% believed they had improved their environmental
performance.
3) Just over 50% felt they had improved their public image.
Improved Liability Control:
The organisations reported a greater awareness of environmental legislation
applicable to their activities; and felt more able to demonstrate compliance
60
through the measures the EMS had initiated such as a register of legal and
other requirements; demonstration of control measures in place to maintain
compliance and collation of supporting evidence (e.g. Waste Transfer Notes,
and Licenses of waste contractors)
Improved Environmental Performance:
The organisations had initiated a wide range of different measures,
depending on the nature of the industry, but improvements cited by the
participants included: installation of oil / water separators to improve
storm water discharge; improved waste segregation and recycling; and
improved bunding; through to the recruitment of personnel dedicated to
environmental issues.
Improved Public Image:
While only around half of respondents felt they had improved their public
image, all received publicity through their engagement in the scheme and
successful completion up to Phase 3 of BS8555, while others reported that
it enabled them to set an example to sister companies, as well as promoting
a positive image with customers, the public, and demonstrating green
commitment to the supply chain.
4.4.2 STEM
The STEM (Sustainable Together through Environmental Management)
Project was established in 2004 to run until June 2008. Funded by the EU
INTERREG IIIA programme for Ireland / Northern Ireland, nine participating
councils and Southern Group Environmental Health Committee. It had three
key objectives:

Deliver ISO 14001 to the nine councils and SGEHC

Assist 270 businesses (within the council areas) to achieve accreditation
to BS8555 (phase 3)
Offer project management support to businesses that have achieved
BS8555 and are willing to commit extra resources in order to attain ISO
14001
STEM was designed to assist the local authorities in meeting their targets
and to demonstrate the commitment of public bodies to environmental
improvement, and also for those SMEs that sought to reduce their
environmental impact though EMS, but may not have had the resources to
do so, STEM was able to provide a service that could otherwise have been
very costly.
For councils, the key objective was to achieve joint certification to ISO
14001:2004 for a minimum of 3 services in each of the 9 councils and SGEHC
it was exceeded in 2007 when a number of councils completed certification
of their civic buildings and therefore the services within. The below table
demonstrates the councils and certified services / facilities.
61
Council
Env. Health
Technical/
Leisure services
Civic Building
Grounds
Maintenance
Ards Borough Council

Armagh City and District Council
Banbridge District Council
Craigavon Borough Council
Oxford Island Site
Down District Council

Dungannon and South Tyrone
Council
Newry and Mourne District Council
SGEHC
Water Services
Roads Services
Civic Building
Environment Section
Monaghan County Council

Louth County Council
When asked about the motivating factor for businesses to participate in
STEM, the qualitative information available suggests a range of factors. The
free advice and guidance was obviously attractive for those SMEs that were
already considering the implementation of an EMS; and the usual crop of
responses relating to desires to reduce costs and improve efficiencies, as
a marketing tool or due to supply chain pressure were present. There was
also an interesting story relating to legislative requirements for many
EMS represent the best available technique to monitor and demonstrate
legal compliance, though for some others, legislation was seen as a barrier
to implementation, based on the cost to comply but also regarding the
potential of becoming visible to the regulator and therefore leaving
themselves open to prosecution. In terms of businesses, the below table
shows the breakdown of total participants in the scheme and associated
employee numbers:
NI
ROI
Total
Business Participants
253
63
316
Employees
5306
2070
7376
A further split shows the recruitment of businesses from both sides of the
border and by business sector.
62
Northern Ireland Businesses by Sector
ROI Businesses by Sector
Business Sector
Number of
businesses
Number of
employees
Business Sector
Number of
businesses
Number of
employees
Construction
45
872
Construction
194
Engineering
18
354
Engineering
109
Food and Drink
29
1085
Food and Drink
11
461
Garage/Repair
67
Garage/Repair
Horticulture
10
110
Horticulture
95
Hotel/Tourism
11
474
Hotel/Tourism
403
Manufacturing
37
1070
Manufacturing
10
427
Quarry
18
433
Quarry
80
Recycling
12
83
Recycling
60
Services
44
338
Services
10
120
Transport
81
Transport
32
Wholesale /Retail 18
339
Wholesale /Retail 5
89
Total
5306
Total
2070
253
63
63
STEMs second key objective was to assist 270 businesses to achieve

accreditation to BS8555 (phase 3): the programme fell slightly short of this
target due to drop out rates. Below is the data relating to total businesses
accredited to BS8555 throughout the life of the project.
Business Sector
Number of businesses
Construction
43
Engineering
17
Food and Drink
26
Garage/Repair
Horticulture
Hotel/Tourism
12
Manufacturing
33
Quarry
18
Recycling
11
Services
42
Transport
Wholesale/Retail
19
Total
233
The graph on the next page depicts the amount of business participants that
received accreditation, plotted against total business participants and the
associated percentage.
In total, almost three-quarters of participants in the scheme (233 businesses)
were successfully certified to BS8555 (phase 3) and 11 of these went on to
become certified to ISO 14001 (3% of total participants).
64
The STEM project demonstrates that there is demand among NI Businesses

for support in the implementation of EMS and that the reasons for
participation range from desire for improvements in environmental
performance through to legal compliance and customer demand. The
twenty-five percent drop out rate could suggest that for some SMEs it was
felt that benefits could be derived without a certified EMS
Further information relating to the rates of re-certification for the above
companies is slightly more limited since due to the nature, and timing, of
the re-inspection process, some organisations have yet to receive their
first surveillance audit. Therefore information is only available for those
companies certified by the end of December 2006, and have subsequently
undergone the surveillance process by the end of December 2007.
65
In total, only 47% of those certified prior to end December 2006 were
successfully re-audited. This could demonstrate that upon certification, and
therefore the end of STEMs involvement, SMEs were unwilling to dedicate
the necessary resources to maintain the system. If this figure were to be
extrapolated for total businesses certified within the life of STEM, then only
110 of the originally accredited participants can be expected to retain this
after the original certification audit. It is possible therefore that an absence
of any financial support to keep the EMS up to date has had a detrimental
impact on the going registrations to BS8555: 2003 within the STEM project.
Interestingly, as the graph below and table demonstrate, there is a definite
trend regarding the likelihood of an organisations propensity to maintain
the system when considered in relation to employee numbers: as employees
numbers increased, so too did the proportion of successful re-audits. This
would indicate that it is likely that there is a dedicated resource available
within larger organisations to assist in the ongoing implementation process.
66
Number of
Employees
Certified
Re-certified
Percentage
1-10
36
12
33.33%
11-50
48
21
43.75%
51-100
19
13
68.42%
101-150
100.00%
>150
100.00%
Total
106
49
Percentage of Companies Re-certified
Percentage re-certified
100.00%
80.00%
Percentage
60.00%
40.00%
20.00%
0.00%
1-10
11-50
51-100
101-150
>150
Employee Numbers
67
4.4.3 Bites
Business Improvements through Environmental Solutions (BITES) is a
programme funded by Belfast City Councils Economic Development Unit
and Better Belfast the Landfill Communities Fund Distribution programme
which was administered by Bryson Charitable group on the behalf of Belfast
City Council. The programme was developed by Belfast City Council, Arena
and Queens University. The aim of BITES is to help companies create an
environmental management system which is tailor made for their own
business. By doing this they will both improve their carbon footprint and
make financial gains. The programme has at this stage only been run once,
(though recruitment is currently under way for the second programme) and
six organisations (public and private sector) took part. The programme lasts
for a year and comprises five modules: EMS; Resource and Efficiency; Energy;
Water and; Purchasing and Transport. Throughout the programme, the
organisations develop management systems in line with Green Dragon.
Of the 6 organisations which participated, all successfully attained Level
3 of the Green Dragon standard and most received Waste Awareness
Certificates from CIWM and an IEMA Associate Certificate in Environmental
Management. All organisations reported improvements in resource
efficiency, and environmental performance, for instance; Patient and Client
Support Services of The Royal Hospitals made savings of 22,000 through
better waste recycling; and ASG (a marketing solutions company) diverted
30 tonnes per annum of waste from landfill through improved recycling,
as well as identifying and implementing a solution to a boiler which was
running inefficiently thereby improving their environmental performance
as well as making cost savings of 300 per annum. Other companies also
reported how changes implemented had reduced the potential of pollution
incidents, and subsequently reducing risk of non-compliance with applicable
environmental legislation.
4.4.4 CEF Easy Access

The Constructors Employers Federation (CEF), in partnership with CIRIA and
White Young Green, provide an EMS training programme tailored to meet the
needs of the Construction Sector. The programme is known as Easy Access.
The programme follows the BS8555 methodology. Training is provided over
the course of a 12-18 month period on each of the 6 phases of BS8555.
Up to ten firms can be accredited at any of the six phases of Easy Access.
However most use Easy Access to prepare them for ISO14001 the
international Environmental Management standard.
A key focus of the programme is compliance with environmental legislation.
A full day training session is dedicated to helping companies identify and
comply with environmental legislation. As environmental compliance is a
minimum requirement for an EMS, the topic is also covered throughout the
course of the programme,
68
4.4.5 Green Dragon

Coleraine Borough Council was the first Council in NI to offer support to
businesses to implement Green Dragon. In partnership with Arena Network
and part funded by the EU Building Sustainable Prosperity Programme, it was
able to provide the service to some local businesses free of charge.
Approximately 40 organisations in NI have implemented EMS to the Green
Dragon standard. Of these around 80% have been inspected to level 2, and
the remaining 20% have undergone inspections at level 3. In the region
of 90% of these organisations have received support through funded
programmes including BITES and Coleraine Borough Council initiatives.
4.4.6 Arena Network Survey

Published in late September 2008, the 10th Annual Arena Network Survey
represents the largest annual environmental survey in Northern Ireland. 250
of NIs largest organisations are invited to take part in the online survey which
culminates in the publicly available document which ranks organisations into
quintiles depending on their performance in the Survey.
The Survey underwent a significant revision which was in recognition of the
fact that as the performance of NIs organisations improved Arena Network
needed to raise the bar (Arena, 2008) This 10th Survey:

- places more emphasis on performanceless about policy and

processes and more about delivering actual improvements on the
ground
- New sections were added to cover areas such as compliance,
advocacy and transport requiring evidence for the first time in
some areas
- Verification also became a more rigid process, with 15% of
participants subjected to an independent review.
13 industry sectors were represented by 128 organisations a fall on

previous years, though this was expected due to the changes to the survey
and rationalisation among the public sector participants. The overall score
fell also, again attributable to the revised process thus the results of this
report are due to form a new baseline to facilitate future comparisons.
However, though comparisons are made difficult, some of the results which
were found prove interesting as stand alone issues: for instance;

98% of organisations have an environmental policy, the same percentage

have also appointed a senior manager with environmental responsibility.
97% have set environmental objectives and targets. Arena believes these
to be the basic tenets of an EMS
91% of participants claimed to have an EMS, or were developing one;
and 49% of all businesses had a certified EMS in place
The new questions relating to compliance addressed whether
organisations had registers of applicable environmental legislation
(4% had) though there were no further questions relating to noncompliance / prosecutions or enforcement actions.
69
Due to the revision of the Survey, it is difficult to ascertain whether or not

performance has improved across the organisations this will become
apparent as the Survey is undertaken again in subsequent years. Though the
survey does not actively consider whether or not an EMS contributes to legal
compliance and enhance environmental performance, it did ascertain that
94% of organisations have a formal register of environmental legislation, and
two-thirds of participants engage with decision makers to influence policy or
take an active stance to promote environmental practice (Arena, 2008).
In-Brief

There have been large increases internationally in the uptake of

accredited EMS
In the UK, more than 6,070 certificates have been awarded to

organisations with EMS to ISO 14001:2004, and 69 organisations
(encompassing 366 sites) to EMAS.
Northern Ireland Support Schemes have been very successful in

terms of numbers of organisations applying, and where available, the
analysis of these schemes have generally demonstrated benefits (both
environmental and financial) for the organisations.
However, analysis of the information available from STEM suggests

that smaller businesses are less likely to maintain an EMS following
withdrawal of the support structure.
The revision of the Arena Survey and the subsequent results demonstrate
the growing commitment of the leading NI organisations in towards
environmental management systems with 98% having in place the basic
tenets of an EMS and 49% of respondents operating certified EMS.
70
5.0 Research into EMS

The effectiveness of Environmental Management Systems has been long
debated and there has been a significant body of research undertaken in
recent years. Relevant research papers have been considered for this review
and summarised in this chapter. Research relating to the effectiveness of EMS
in relation to legislative compliance and improvements in environmental
efficiencies have been closely regarded below.
5.1 SME-nvironment Survey, 2007

In 2007, NetRegs Undertook the SME-nvironment Survey the purpose was
to examine progress and knowledge advancements since the similar surveys
undertaken in 2003 and 2005. Including England, Scotland, Wales and NI,
the survey is a useful tool in comparing SMEs across the UK with regards to
perceived environmental performance.
As the graph demonstrates knowledge across all SMEs regarding their

environmental impact was very low, with a UK average of 15% of businesses
which thought their activities could cause environmental harm, this rose
to an average of 49% when prompted with a list of harmful activities:
businesses in Northern Ireland were least likely to admit to undertaking
any activities that were deemed to be harmful to the environment
(44%)(NetRegs, 2007). This demonstrates a lack of understanding at the
vast majority of organisations as to the effects their activities can have on the
environment.
71
*Should be noted that multiple responses were accepted under the Motivations category.
In Northern Ireland and England, businesses were the least likely to have
taken actions to improve their environmental performance (46%). The
main driver common for all regions was general environmental concern
rather than to ensure legislative compliance. This is perhaps unsurprising
when further questions probe the respondents awareness of environmental
legislation only 23% of NI businesses were able to name a piece of
environmental legislation 36% of those who could, cited the Packaging
Waste Regulations. It is even less surprising then, that when questioned
about the main business benefits of addressing environmental issues, 81%
strongly agreed / agreed with reduced risk of prosecution.
Environmental Policies and Management Systems:
Businesses with between 50-249 employees were much more likely than
those businesses with 9 or fewer members of staff to have an environmental
policy in place: 71% compared to 28% respectively. Northern Irish businesses
were the least likely to have an environmental policy in place (35%) when
compared to the other regions (39% in England and Wales, and 43% in
Scotland).
The take-up rates of EMS throughout the UK was consistent, with around
15% already having one in place, and a further 6% planning to introduce one
in the future.
72
5.2 EVER Evaluation of EMAS and Eco-label for their revision

Carried out on behalf of the European Commission, and published in
December 2005, the Ever Report aimed to provide recommendations for
the revision of EMAS and the EU Eco-Label. With reference to EMAS, it
specifically considered the impact of EMAS on environmental performance.
Environmental performance was classified into four sub-sectors:
- Absolute Improvement
- Continuous Improvement
- Relative Improvement
- Target-led improvement
Using three different methodological techniques, the authors considered
Quantitative Analysis of eco-efficiency and impact indicators,
environmental management indicators and interview and survey
data to draw their conclusions. Despite the variety of methodologies,
it was still found that whether and to what extent EMAS improves the
environmental performance of organisations is difficult to assess... This may
appear surprising, given that the continual improvement of environmental
performance is a key objective of the EMAS Regulation and given that EMAS
organisations are required to publish environmental data (EVER, 2005). It
is their belief that the difficulty stems from issues regarding the definition of
performance improvement, establishing cause/effect relationships and the
availability of data.
The findings in relation to the four improvement sub-categories are
summarised below:
EMAS and Absolute Improvement
Based on interview results, the authors found that EMAS is perceived to have
a positive effect on environmental performance, especially in facility-related
aspects such as waste, water and air pollution but that other areas such as
environmental regulation and technical progress have a greater impact on
performance.
EMAS and Continuous Improvement
Again based on interview results, the large majority of respondents (89%)
hold the view that their EMS contributes to environmental improvement year
on year.
EMAS and target-led Improvements
Targets tended to be set on the basis of economic and technical feasibility
rather than public policy objectives, and the targets tended to be qualitative
rather than quantitative. Two-thirds of those surveyed believed they
obtained their targets often, while just under a quarter said they always
met theirs.
73
EMAS and Relative Improvements

Conducting a comparison between EMAS registered and non-EMAS
registered organisations (of whom, 22.5% had no EMS); it was found that very
little difference existed in perceptions about performance. In fact, the only
area of questioning where there was divergence was in relation to targetsetting. EMAS organisations were less likely to consider public policy targets
when setting their own objectives than non-EMAS organisations, but were
twice as likely to always achieve their targets.
Summary:
The survey found that EMAS has a positive effect on environmental
performance, and that for those that have adopted it, it is seen as a
useful tool, however, it is not one of the most important determinants of
environmental performance and it appears not to be a strong autonomous
driver for improvement.
It also suggests that ISO 14001:2004 is as strong as EMAS as regards
facilitating and stimulating environmental performance improvement.
5.3 Environmental Management Systems and Company Performance:
Assessing the case for extending risk-based regulation.
Prior to the issue of ISO 14001:2004 and looking exclusively at sites regulated
under Industrial Pollution Control (rather than its successor IPPC and
subsequently Environmental Permitting - EP) in England and Wales, this
study sought to examine the case for regulatory relief for those companies
with formal, certified EMSs. It also took place prior to the variety of changes
to the Opra methodology which have subsequently seen it become Opra
however, it produced some interesting findings pertinent to the questions
posed by NIEA, in that the authors sought to answer many of the same
questions such as the links between certified EMS and environmental
performance and legislative compliance.
The validity of the Opra scheme in England and Wales was considered along
with its incentivisation of the uptake in EMSs through reduced compliance
assessment activities and with the potential to reduce regulatory monitoring
where there is overlap between the outputs of an EMS and regulatory
reporting requirements, i.e. to prevent the duplication of effort on behalf of
the operator.
EMS and Company Performance
In order to assess whether sites with an EMS were associated with higher
levels of Operator Performance, the sample was split into three groups:
Sites without a certified EMS; Sites certified to ISO 14001; and sites certified
to ISO 14001 and EMAS. Comparing the most recent Overall Performance
Assessment (OPA) scores at the time of publication; it found that mean OPA
scores are significantly higher for sites with an externally validated EMS than
for those without, and that EMAS registered sites score higher than sites
certified only to ISO 14001. Differences were also noted with regards to the
range of scores attained: with fewer poor performers, as judged by fewer
low scores and a higher concentration of high OPA scores, among the groups
74
with externally validated environmental management systemshaving an

EMS cuts off a tail of poor performance (Dahlstrom et al, 2003). However,
further analysis demonstrated that five of the six questions that the OPA
scores referenced at this point were related to aspects of performance that
a management system is intended to improve, while for the one attribute
related to incidents, complaints and non compliance events there was no
significant difference between the three groups. This could support one
of the findings of remas (see below) that a certified EMS could appear to
raise levels of non-compliance events as the EMS increases awareness of the
organisations compliance status.
EMS and Continuous Improvement
To analyse this, the study compared the first and last OPA scores for sites
assessed more than once, and discounting those which occurred within
twelve months of each other, leaving a sample of just over 400 sites. Of
these, almost 40% experienced no change, 46.4% improved with the
remainder deteriorating. There were significant differences in the rate of
improvement of OPA scores between the three groups. Sites with either ISO
14001 or EMAS started from a higher baseline than those withoutand
improved more rapidly.
EMS and Enforcement Action
From a regulatory perspective, legal compliance is a key aspect of
environmental performancehowever, the available dataset to enable a
comparison of the links between EMS and compliance was too small to allow
accurate analysis of the links, thus fails to provide evidence that sites with an
externally validated EMS are more or less likely to be subject to enforcement
action.
Summary:
Sites with a certified EMS have higher levels of operator performance
than those without, with EMAS registered sites out-performing those with
ISO 14001. However, they do not have a lower likelihood, as assessed by
enforcement officers, of suffering from incidents, complaints and noncompliance events. The context within which this study was undertaken
should be noted, in that it pre-dated ISO 14001:2004, and was prior to the
expansion in coverage of the PPC Regulations.
5.4 REMAS
remas was a three-year project designed to examine environmental
management systems (EMSs) currently in place in business and industry
across EU Member States. remas aimed to demonstrate that companies and
organisations that implement environmental management systems, such
as EMAS and ISO 14001, show better environmental performance overall.
The IEMA is one of the project partners, along with the Environment Agency,
Scottish Environment Protection Agency and the Irish EPA. Unfortunately,
DOE EHS were not part of the remas review and so opportunities to examine
the effectiveness of EMS with a proportional representation of Northern
Ireland companies were not utilised during this three year period.
Businesses around the world are facing increasing demands for improvement
75
in environment performance. They are exposed to greater pressures from

customers, employees and competitors and are having to deal with a
plethora of rapidly changing regulations and guidelines in their field. To
deal with these pressures, many companies have chosen to implement
environmental management systems (EMS) that essentially allow the
environmental impact of a company or organisation to be more easily
controlled.
Implementing an EMS should improve a companys environmental
performance, but prior to the remas project there has been little data to back
this up. remas commenced on 1 November 2002 and remas collected data
from European sites until October 2005. remas sought data from sites with
formal, informal and no EMS. remas used this information to demonstrate
ways of avoiding duplication from the overlap of regulatory process work
and EMS implementation.
remas set out to achieve the following objectives:

Demonstrate mechanisms to meet Article 10 of the Eco-Management

and Audit Scheme (EMAS) (relates to the consideration of how to avoid
unnecessary duplication of effort by both organisations and enforcement
authorities)
Demonstrate where EMAS improves performance and compliance with
environmental regulation
Demonstrate how effective implementation of EMAS improves
environmental performance faster or further than command and control
regulation
Encourage uptake of the approach through dissemination with key
European Community stakeholders
remas findings
The project used a bespoke mathematical model to interpret the
relationships between the adoption of a particular type of EMS and the
management activities or behaviours a regulator expected on a good
site, and then the subsequent impact of these on regulatory compliance
performance and environmental performance. The latter metric was
normalised to allow comparisons against raw materials and emissions
benchmark levels defined as best available techniques within the European
Unions Integrated Pollution Prevention and Control Directive. Whereas the
benchmarks were known, the derivation of the model and comparisons
techniques is groundbreaking with a number of spin-off learning points
established during the work which adds to the value of the project.
The data gathered was subjected to a number of quality control audits,
including site visits by the team and cross reference to local regulatory
inspectors. The website used to gather data remains available as an
additional project deliverable, and is translated into five languages.
Data on various types of EMS were collected, but these were classified into
five:
1. Sites with no defined EMS approach
2. Sites with an informal EMS but no third party auditing
3. Sites that had achieved certification to ISO14001 using an accredited
76
certification body
4. Sites within group (3) that had also taken the steps to reach EMAS but have
not registered under the scheme
5. Sites registered under EMAS.
remas results - link between EMS and performance (based on data from
320 sites in Europe)
In summary the project measured the relationship between implementing
different types of EMS and:

The change in behaviours at a site, (defined as site environmental

management activities)
The impact of these on emission levels, (benchmarked against best
available techniques)
Compliance with legislation.
Behaviours are measured against those expected on a well managed
site as defined by IMPEL (European network of regulators). Collectively
these are known as the remas criteria (those elements of an EMS that
are considered to be key to improving environmental performance and
regulation.
Improved self knowledge of permit breaches (better detection usually
means increased numbers of non-compliances)
Compliance management (better management leads to reduction of
non-compliance events).
remas Summary Results

There is strong evidence that the adoption of an accredited certified

EMS improves site environmental management activities. Overall
environmental management is better under ISO14001 than under an
informal system; which in turn is better than under no system at all.
There is evidence that overall site environmental management is better
under EMAS than under ISO14001; driven largely by better performance
in performance monitoring, documentation control and (self ) reporting
of environmental performance.
There is some evidence that improved site environmental management
leads to lower average emission levels. However, the strength of the
evidence differs significantly between receiving media, regions of Europe
and sectors.
There is strong evidence that improved environmental management
has an impact on the number of self recorded permit / licence
breaches. The impact may be observed both as positive (i.e. reducing the
number), or as negative (i.e. increasing the number), and varies between
regions and sectors.
The mix of positive and negative impacts for the two compliance
indicators demonstrates that improved site environmental management
results both in a reduction of the rate at which non-compliance
incidents (such as permit breaches) occur and in an improvement in the
detection and reporting of incidents when they do occur.
77
remas conclusion
The remas project concludes that there is a relationship between EMSs
and performance driven through better site management activities. An
interesting point to note is that the authors assert that high levels of noncompliance issues (for instance in respect of emission levels) may not be a
bad thing, and suggest that a comparison of whether a site has an EMS and
whether these result in lower numbers of compliance, is too simplistic. This
is explained in terms of the below diagram:
(remas, 2006)
This illustrates that higher levels of non-compliance may occur under an
EMS not due to slipping management standards, but because of a greater
awareness of non-compliance. [O]ne of the better behaviours expected
on a site is looking for non-compliance events and registering these where
they occurClearly where the better behaviour identifies non-compliance
events that were previously unknown, this may lead to an increase in the
number this is not necessarily seen as a bad thing since identification of
non-compliance is necessary in order to correct any issues, and remas seem
to suggest that the implementation of a robust EMS can greatly contribute to
a greater extent of self-regulation.
78
5.5 Measuring Environmental Performance in Industry (MEPI)

It should be noted that whilst the MEP1 and subsequent studies carried out
robust sampling methodologies and statistical analysis, the work related to
the old EMS standard ISO14001 : 1996. This predicted the changes made to
the 2004 standard. Furthermore the dataset is over ten years old and only
covered two years past adoption of the 1996 standard. If a follow up survey
was to be carried out, the quality and availability of information may have
improved significantly, and facilitate the drawing of clear conclusions, as well
as encompassing the changes made in the way that EMS are implemented
and certified.
Funded under the ECs fourth framework research programme, the
groundbreaking measuring environmental performance in industry (MEPI)
project was coordinated by the Science Policy Research Unit (SPRU) at the
University of Sussex (www.sussex.ac.uk).
In cooperation with six other European research institutes, it set out to
compare the economic and environmental performance of 280 companies
and 430 production sites in six industrial sectors - electricity generation,
pulp and paper, fertilisers, book and magazine printing, textile finishing
and computer manufacture - across six countries: the UK, the Netherlands,
Germany, Austria, Belgium and Italy covering the years 1985, 1990 and 1994
to 1998.
A lack of reliable data due to the large proportion of overseas manufacture of
components forced the re-searchers to drop computer manufacture from the
results.
Researchers extracted technically sound data from publicly available
sources and fed these into core economic and environmental indicators for
each sector and even sub-sector, where there were significant differences in
the production technology used.
The MEPI project aimed to answer several questions dogging policymakers, including whether several years of EC regulation have succeeded in
narrowing differences between companies performance; whether large firms
perform better than small ones; whether there is a link between economic
and environmental performance; and whether environmental management
systems have improved performance.
On this last question, the report concludes: Firms and sites with a certified
environmental management system [ISO14001 or EMAS] did not appear
to perform better than those without. For example, it points out that
fertiliser manufacturers with certified systems produced higher levels of NOx
emissions than those without, although their discharges of nitrogen to water
were lower. For the other four sectors, the researchers could not find any
statistically significant results to demonstrate improved performance
(www.endsreport.com).
79
However, the survey finds as a key conclusion that the level of publicly
available, robust information was insufficient to enable many conclusions
to be firmly made, and that the lack of a clear link between companies with
certified EMS and improved environmental performance could be down to:

A lag effect in which companies with an EMS do not immediately

experience an environmental performance improvement
A catching up effect in which companies which perceive themselves to
be poor performers are those that seek to implement a system as a way
of reaching the best practice frontier
The requirement for continuous improvement is interpreted weakly by
verification agencies
Additional research
In a follow up research study published in March 2008 using the MEPI
dataset, the authors (Hertin et al, 2008) found that while it is not appropriate
to conclude either that EMS are ineffective or that policy support for
EMS should be withdrawn. Any conclusion about the link between EMS
and environmental performance is necessarily preliminarymoreover
EMS may have other benefitsregulatory certainty, internal or external
communication or awareness raising that may justify policies encouraging
their diffusion Though, they further add the weak link between EMS and
performance is a matter of concern if EMS are envisaged as serving as a
substitute for other policy instrumentsit could be argued that there is
currently no evidence to suggest that EMS have a consistent and significant
positive impact on environmental performance.
5.6 ISO 14001 Experiences, Effects and Future Challenges: a

National Study in Austria
This study undertaken by Schylander and Martinuzzi sought to explore the
perspectives of Austrian ISO 14001 organisations. It was identified that there
were 501 ISO 14001 certified sites, with 297 environmental mangers (due
to multiple site certifications). All were contacted, and 71 responses to the
questionnaire were received. While the survey looked at issues including
future tools to assess environmental performance, and the role of integrating
management systems, it also considered the questions of legal compliance
and environmental performance improvement. Using a Likert Scale, the
organisations were asked how important 10 different motives were for
deciding to implement ISO 14001 [and]how well these expectations
were fulfilled (Schylander and Martinuzzi, 2007).
Results of the survey are demonstrated in the below table, where the
left y-axis shows the differences between expected benefits and received
benefits in order to investigate the degree of happiness or frustration related
to each motive; the values are expressed in terms of number of organisations.
The right y-axis shows the averages of how the organisations assessed their
expectations (4 = very high expectation) and perceived benefits (4 = very
high benefits). (Schylander and Martinuzzi, 2007)
80
Expectations and Perceived Benefits of ISO 14001 (Schylander and Martinuzzi, 2007)
The expectations regarding ensuring legal complianceseemed to be
fulfilled by the implementation, [as did] improvements in environmental
performance, a systemization of environmental activities, and risk
minimization (Schylander and Martinuzzi, 2007). The survey also found
that the largest environmental improvements were made within waste and
recycling, and that in-depth analyses show a high correlation between
the awareness of environmental issues and improvements in energy
consumption, waste and recycling (Schylander and Martinuzzi, 2007).
5.7 USA National Database

A national database on environmental management systems (NDEMS)
has been set up with the aim of determining whether an EMS delivers
environmental performance improvements (www.ndems.cas.unc.edu).
The project is funded by the Environmental Protection Agency and a
consortium of state governments interested in using ISO14001 and other
systems to further their policy goals. Their primary purpose was to answer
the question What effects does the implementation of an EMS have on a
facilitys environmental performance, regulatory compliance and economic
performance?
So far, it has collected comprehensive baseline data on 50 public and private
facilities, which describe their structure, past environmental performance,
compliance history, and extent of public outreach efforts and the nature of
the management system being used but no conclusive recommendations
have been reached as the study is currently ongoing.
81
5.8 Urban Government review of the use of EMS (Japan)

(www.gdrc.org)
Many cities in Japan are turning to the approach of developing an EMS
with the goal of attaining certification to ISO14001. The establishment
of an EMS is seen as a tool for creating the structures to integrate
changed responsibilities for the urban government to plan and allocate
the resources to implement and deliver services so that they address
community priorities. The development of an EMS provides a number of
general benefits. It creates structured management systems, from which
a cycle of continuous improvement can be established. It brings the many
environmental issues of concern expressed by the community into daytoday operations and development of long term work plans and programs
of the urban government. It also improves the understanding amongst an
urban governments personnel of where operations interact with the natural
environment and the role that various groups play in the delivery of urban
services.
The Japan studies have concluded that there are several internal and
external benefits for urban governments if they seek ISO certification. While
internal benefits ensure wider and deeper participation on the part of an
urban governments employees, it is the external benefits that form the key
justification for an urban government seeking to obtain ISO certification. The
view from Japan report states the external benefits of ISO certification as:

With growing prioritization of the global and local environment, ISO

14001 acquisition demonstrates a citys green face to its citizens and also
helps in emphasizing the need for greater environmental action on the
part of urban stakeholders at the local level.
A citys acquisition of ISO certification helps in serving as a model for
other urban and regional governments to emulate and replicate. An
urban government that has obtained ISO certification can, from a
position of strength, promote replication of acquiring ISO Certification
from other stakeholders in the city, particularly private sector businesses
and industry, where a properly and
strategically implemented EMS can have far-reaching and long-term
impacts. It emphasizes the concept, environmental-action-starts-athome, where local and immediate actions at the grassroots have longterm global implications.
82
6.0 Conclusions
The project as commissioned by the NI Environment Agency aims to address
two key questions relating to the role of EMS and to guide future strategies
in Northern Ireland as to whether a more risk-based policy of environmental
regulation could be adopted. Generated by the needs of the Better
Regulation programme this desktop review of existing studies forms one
part of a process to address the questions of:

How effective is an EMS in contributing to improvements in an

organisations environmental performance; and
How effective is an EMS as a measure of legal compliance.
This desktop study has considered the history of environmental management

systems, along with the most commonly implemented systems. Reviewing
the different types of standards which are most prevalent: from what is seen
as perhaps the most stringent, though Euro-centric (EMAS), to the most
widely adopted standard internationally (ISO 14001:2004) through to those
systems such as BS8555 and Green Dragon which implement EMS through
staged approaches and are perhaps more suited to SMEs.
The certification process for each of these types of EMS has also been
considered, to ascertain how robust in nature certifications are. This
evaluation found that while EMAS certifications undergo a more thorough
process culminating in the production of a public statement and comments
on the degree to which objectives and targets have been met, this may
not be appropriate for all organisations due to the time and therefore cost
implications that may occur. For most, ISO 14001:2004 is seen as sufficient to
ensure a high level of environmental management, and in fact, the standard
has become incorporated within EMAS to facilitate those companies that
wish to be accredited to the EU approved scheme doing so. BS8555 is the
most recent of the three standards and has been specifically designed
with SMEs in mind. The staged approach to implementation provides a
more obviously structured method of managing environmental impacts
and also enables recognition of progress at each stage, which means the
organisations which implement it, can do so to the level of their own
requirement. Similar to Green Dragon in many ways, it differs in that it
is audited by an accredited certification body sanctioned, and therefore
endorsed, by UKAS.
The accreditation process is also considered since while informal EMS are
often encouraged, it is the view of DEFRA among others, that an EMS is
demonstrated to be sufficiently robust if certified by a body accredited by
UKAS. This allows for a greater degree of quality assurance and trust to be
placed on an EMS since the certification body which awards the certificate,
must also conform to an international standard (ISO 17021:2006).
The current situation regarding the uptake of management systems on
a worldwide and local scale has also been addressed through this desk
study, along with the drivers to the implementation of an EMS. The UK
has the third highest uptake of ISO 14001 in Europe (2006) with Spain and
Italy ahead however, levels of uptake remained constant over the 2005 /
06 period in comparison to high levels of growth over the same period in
both Spain and Italy. Levels of uptake of EMAS in the UK are significantly
83
lower than ISO 14001 (380 against 6000) with the UK coming 4th in the
uptake tables behind Germany, Italy, Spain and Austria. There have been
a number of local, Northern Ireland initiatives and programmes regarding
environmental management systems over the last decade however, there
is limited evaluation of data and no collation of overall statistics relating
to improvements or compliance assistance. Northern Ireland businesses
have been involved in some EMS key projects over the last 5 years including
the introduction of BS8555 to Northern Ireland (Invest NIs Building Blocks
programme) and STEM, the expansion of BS8555 to business and local
authorities in the border council areas.
The Environment Agency in England and Wales has already asserted the view
that effective environmental management systems aid risk management in
permitting and have developed the Opra methodology for this purpose.
In tandem with this EMS Evaluation research, the SNIFFER project has looked
at how best regulatory bodies should target their resources in the future,
finding that SMEs would be less able to respond to reflexive law instruments.
This has been borne out through the work of the STEM project indicating
significant drop out rates when consultancy support is withdrawn from the
SME companies.
There have been a range of international and national independent studies
into Environmental Management Systems and a number of key studies
have been included within this desk top research. This review established
to what extent the questions relating to performance improvements and
legislative compliance have been addressed, and a summary of the findings.
A summary table of the findings has been produced below which aims to
address how they dealt with the two key questions under consideration.
Indicative of neutral role of EMS

Indicative of positive role of EMS
Indicative of negative role of EMS
84
International Findings
The survey found that EMAS has a positive effect on environmental

performance, and that for those that have adopted it, it is seen
as a useful tool, however, it is not one of the most important
determinants of environmental performance and it appears not to
be a strong autonomous driver for improvement.
The remas project concludes that there is a relationship between

EMSs and performance driven through better site management
activities. An interesting point to note is that the authors assert
that high levels of non-compliance issues (for instance in respect
of emission levels) may not be a bad thing, and suggest that a
comparison of whether a site has an EMS and whether these result
in lower numbers of compliance, is too simplistic.
While it is not appropriate to conclude either that EMS are

ineffective or that policy support for EMS should be withdrawn.
Any conclusion about the link between EMS and environmental
performance is necessarily preliminarymoreover EMS may
have other benefitsregulatory certainty, internal or external
communication or awareness raising that may justify policies
encouraging their diffusion Though, it could be argued that there
is currently no evidence to suggest that EMS have a consistent and
significant positive impact on environmental performance.
The expectations regarding ensuring legal complianceseemed

to be fulfilled by the implementation, [as did] improvements in
environmental performance, a systemization of environmental
activities, and risk minimization (Schylander and Martinuzzi, 2007).
The survey also found that the largest environmental improvements
were made within waste and recycling, and that in-depth analyses
show a high correlation between the awareness of environmental
issues and improvements in energy consumption, waste and
recycling (Schylander and Martinuzzi, 2007).
Ever - EMAS
remas
MEPI and follow

up study
ISO 14001
Experiences,
Effects
and Future
Challenges: a
National Study
in Austria
EMS and
Company
Performance
Sites with a certified EMS have higher levels of operator

performance than those without, with EMAS registered sites outperforming those with ISO 14001. However, they do not have a
lower likelihood, as assessed by enforcement officers, of suffering
from incidents, complaints and non-compliance events.
SME-nvironment Among SMEs there is a gap in understanding regarding the

Survey 2007
environmental impact of activities - principally due to the low
uptake of EMS among SMEs
Summary of Main Findings
Survey
Sufficient
Coverage
of Legal
Compliance?
Indicative
of Legal
Compliance?
Sufficient Coverage
of environmental
performance?
Indicative
of improved
Environmental
Performance?
National Findings
85
86
The STEM project demonstrates that there is demand among NI

Businesses for support in the implementation of EMS and that
the reasons for participation range from desire for improvements
in environmental performance through to legal compliance
and customer demand. Though the high drop out rates could
undermine the effectiveness with regards to the benefits realised by
businesses
All 6 companies involved reported and demonstrated

improvements in environmental performance and legal compliance
issues - principally in the areas of waste management. Thereby
securing annual cost savings and reduced resource use.
Analysis of the scheme revealed two prevalent themes, both in

terms of reasons for undertaking the audits, and in benefits derived
- these related to improving legal compliance and cost savings
through improved efficiencies.
100% of those that took part in the Building Blocks Programme felt
they had improved liability control and 80% felt they had improved
their environmental performance through the implementation of
BS8555.
There is no data relating to comparison in performance between

the 49% of organisations with certified EMS compared to the51%
without. This means that the Survey contributes little to the debate
regarding the effectiveness of an EMS in addressing the questions of
performance and compliance.
STEM
BITES
EASS
Building Blocks
Arena Survey
Sufficient
Coverage
of Legal
Compliance?
Indicative
of Legal
Compliance?
Sufficient Coverage
of environmental
performance?
Indicative
of improved
Environmental
Performance?
The research summary indicates that in general, environmental management systems do provide environmental improvements (7 of the 11 no. research
papers). Overall, the research is inconclusive regarding an EMSs ability to provide improvements in legislative compliance with 4 of the 11 no. research
papers highlighting this, however 3 of the papers did not include compliance within the evaluation criteria. Interestingly, 3 of the 4 local (Northern Ireland)
studies suggest that an EMS has both a positive impact on environmental improvements and compliance with environmental legislation.
Summary of Main Findings
Survey

7.0 Recommendations
It is not been possible to fully ascertain the effectiveness in EMS in delivering
environmental improvements and compliance with environmental legislation
within a local context (Northern Ireland. A gap in the data is evident, since
the Northern Ireland studies include figures that are very project specific,
and tend towards being anecdotal evaluations. To date, there has not been a
Northern Ireland wide survey or statistical analysis of data relating to EMS. In
addition, the SME-nvironment Survey that was carried out sheds some light
on the uptake of EMS in Northern Ireland, suggesting it to be around 15% of
SMEs, but it also exposed huge areas of misunderstanding and knowledge
gaps among SMEs regarding the environmental legislation relevant to them,
and the impacts their activities can have on the environment. This is the
only instance where some analysis was conducted comparing organisations
with an EMS against those without, but this was done at a cursory level, and
merely differentiated those who were deemed to be actively involved in
addressing issues i.e. those which have an EMS are planning to introduce
one, have an environmental policy or have introduced a practical measure
to address environmental harm (SME-nvironment 2007) from those which
had none of the above. It will therefore be necessary to carry out an in depth
analysis of organisations within NI to enable a comparison of organisations
with an EMS (of any type, formal or informal) to be compared to those with
no EMS against environmental or compliance improvements.
Further research has been commissioned alongside this desk top review to
provide some additional verification and detail relating to EMS, compliance
and environmental improvements in Northern Ireland business and public
sector organisations. The basis of this research has been questionnaire survey
of 1000 organisations in Northern Ireland, with statistical analysis of the
results of the survey. In addition, it has become apparent that there is a need
for validation of this research against factual statistics held by the Agency
and also by the certification bodies operating in Northern Ireland. This data
has been requested for use in the final report.
NB. The results of this research and data analysis will be published under
separate cover as part of this project, for NIEA.
87
References
Acorn Trust, The (2003):
New British Standard (BS 8555) and phased implementation of environmental management
http://www.theacorntrust.org
Arnold, R., and Whitford, A., (2006)
Making Environmental Self-Regulation Mandatory in Global Environmental Politics 6:4, November 2006
Bansal, P and C Bogner (2002):
Deciding on ISO 14001: Economics, Institutions, and Context, Long Range Planning
Business in the Community (2006):
Environmental Index 2006 Report
ww.bitc.org.uk
Business in the Community (2006):
Coleraine Green Dragon: Case Studies in Environmental Management
www.colerainebc.gov.uk
BS8555:2003:
Environmental Management Systems Fact Sheet 4 www.pasa.nhs.uk/pasaweb/nhsprocurement/
sustainabledevelopment/environment/iso14001ems/BS85552003.htm
British Standard (2003)
BS 8555:2003, Environmental Management Systems Guide to the phased implementation of an environmental
management system including the use of environmental performance evaluation
British Standard (2004)
BS EN ISO 14001:2004 : Environmental Management Systems Requirements with Guidance for Use
British Standard (2006):
BS EN ISO/IEC 17021:2006: Conformity assessment Requirements for bodies providing audit and certification of
management systems
Dahlstrm, K., Howes, C., Leinster, P., and Skea, J.,(2003):
Environmental Management Systems and Company Performance: Assessing the case for extending risk-based regulation;
in Eur. Env. 13, 187203 (2003)
Department for Environment, Food and Rural Affairs (DEFRA) (2003):
An Introductory Guide to EMAS: The Pinnacle of Environmental Management
www.defra.gov.uk
Department for Environment, Food and Rural Affairs (DEFRA) (2008):
DEFRA Position Statement on Environmental Management Systems
www.defra.gov.uk
Delmas, Magali, A. (2002):
Journal Article, Policy Scenes. Volume 35, Number 1, March 2002
www.springerlink.com
Eco-Mapping:
http://www.ecomapping.com
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Elliott, C (2001):
A WWF perspective on ISO 14001 (ISO Management Systems)
ENDS Report 347 (2003):
EMS survey reveals widespread concerns over certification
www.endsreport.com
EMS credibility is at the crossroads
www.endsreport.com
EMS auditors face increased scrutiny
www.endsreport.com
Envirocentre:
www.envirocentre.ie
Environment Agency (2008):
Environmental Permitting Regulations Operational Risk Appraisal (Opra for EPR)
www.environment-agency.gov.uk
Environment Agency (2007):
Analysis of final REMAS project datasheet
www.remas.info
Europa:
http://europa.eu/
European co-operation for Accreditation (2007)
EA-7/04 Legal Compliance as a part of Accredited ISO 14001:2004 certification
www.ukas.com
EVER (2005)
Evaluation of EMAS and Eco-Label for their Revision,
http://ec.europa.eu/environment/emas/index_en.htm
Fresner, J (2004):
Small and medium enterprises and experiences with environmental management
Journal of Cleaner Production, 12(6), pages 545-547.
Green Dragon:
www.greendragonems.com
Gunningham, N (2002)
Regulating Small and Medium Sized Enterprises
Journal of Environmental Law, 14(1), pages 3-32.
Hertin, J., Berkhout, F., Wagner, M., and Tyteca, D., (2008):
Are EMS environmentally effective? The link between environmental management systems and environmental
performance in European companies; in, Journal of Environmental Planning and Management, 51:2 259-283
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Hillary, R (2004):
Environmental management systems and the smaller enterprise
Journal of Cleaner Production, 12(6), pages 561-569.
Hillary, R (1999):
Evaluation of study reports on the barriers, opportunities and drivers for small and medium sized enterprises in the
adoption of environmental management systems
(Network for Environmental Management and Auditing. Paper submitted to UK Government. Department of Trade
and Industry: Environment Directorate (5/10/99). London)
Institute of Environmental Management and Assessment:
www.iema.net/acorn.
IEMA Practitioner, Vol 6, (2005):
Managing compliance with environmental law: a good practice guide
www.iema.org
LRQA (2004):
How can EMAS benefit my organization
http://www.lrqa.co.uk
LRQA (2005):
IEMA Acorn Scheme
http://www.lrqa.co.uk
Marks and Spencer (2008)
How we do Business Report 2008
corporate.marksandspencer.com
National Database on Environmental Management Systems and University of North Carolina at Chapel Hill (2003):
Environmental Management Systems: Do they improve environmental performance.
http://ndems.cas.unc.edu
National Standards Authority of Ireland:
www.nsai.ie.
Northern Ireland Environment Agency (2008):
EHS Better Regulation Programme: Better Regulation for a Better Environment
NetRegs:
www.netregs.gov.uk
Office of Government Commerce (2005):
Achieving Excellence in Construction, Procurement Guide 11 Sustainability
www.ogc.gov.uk
Roberts, H., and Robinson, G. (1998):
ISO 14001 EMS Implementation Handbook
Russomanno, G (2004):
EMAS: SMEs specific barriers and needs
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ISO 14001 Experiences, Effects and Future Challenges: a national study in Austria. In;
Business Strategy and the Environment 16, 113-147
Schaltegger, S., Burritt, R., and Petersen, H., (2003):
An Introduction to Corporate Environmental Management:- Striving for sustainability.
Science and Technology Policy Research University of Sussex (2000)
Measuring Environmental Performance of Industry (MEPI)
www.sussex.ac.uk
Scotland and Northern Ireland Forum For Environmental Research (SNIFFER) (2009)
UKCC20 - Targeted Risk Based Approaches to Compliance Assessment
www.sniffer.org.uk
Sheldon, C (2003):
The Acorn Trust and BS8555
http://www.groundwork.org.uk
Sustainable Development Strategy for Northern Ireland (2006):
First Steps Towards Sustainability
www.ofmdfmni.gov.uk
Starkey, R (1998):
The Standardization of Environmental Management Systems: ISO 14001, ISO14004 and EMAS, in Corporate Environmental
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United Kingdom Accreditation Service (UKAS)
www.ukas.com
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Cities, Environmental Management Systems and ISO 14001: A View from Japan
http://www.gdrc.org
Walley, L (2000):
The environmental champion: making a start. Westfield: an SME success story in Small and Medium-Sized Enterprises and
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91
APPENDIX ONE : Chapter 1 : NI Sustainability Strategy Targets

Chapter 1 Sustainable Consumption and Production
Strategic Objectives
Key Targets
Important Steps
To become more
resource efficient
Northern Ireland
economy will achieve
85% resource
efficiency by 2025
Progressive reduction of quantities of biodegradable waste going to landfill

and reduction of waste in general across all sectors
Stabilise Northern
Ireland ecological
footprint by 2015 and
reduce it thereafter
Promote materials recovery, re-use, and recycling through initiatives such as

the Waste and Resources Action Plan (WRAP)
To make the Northern

Ireland public sector
a UK regional leader
in sustainable
procurement
To minimise the
unsustainable
impacts of
consumption
Encourage and incentivise the business case for resource efficiency and waste
minimization
Progressive reduction in leakage of mains water
Develop training and guidance on sustainable procurement for all public

By 2008 ensure that
sector purchasing officers
all public sector
procurement is
Embed whole life costing into procurement decisions and policy
channelled through
recognised Centres of
Procurement Expertise
(COPEs)
By 2008 ensure that
SD principles guide
capital investment
decisions on all
major publicly
funded building and
infrastructure projects
Underpin the Investment Strategy for Northern Ireland with excellence in

construction programmes that integrate SD principles
By 2008 produce
a Sustainable
Procurement Action
Plan for Northern
Ireland
Consider how the recommendations from Sustainable Procurement Task

Force can be applied to Northern Ireland with particular reference to access
for Small Medium Enterprises and Social Economy Enterprises
By 2008 produce
Sustainable
Consumption Action
Plan for Northern
Ireland
Work with the Food Standards Agency and other partners to promote more
sustainable food procurement in the public sector
By 2008 put in place

measures which
optimize the flexibility
of retained and
refurbished buildings
Make it easier for consumers to make more reasonable, less damaging

choices
Ensure that public sector housing and public properties are constructed or
refurbished to maximise sustainability and flexibility of use
Promote market Transformation initiatives and the work of WRAP
Consider how the recommendations from the Sustainable Consumption

Roundtable can be applied to Northern Ireland
Implement Workplace 2010 on the Government estate

SD action plans for each Government department
Reduce demand for potable water
Press for amendments to VAT rates for new versus refurbished buildings and
support amendments to planning and building regulations
92
APPENDIX TWO : Chapter 6 : NI Sustainability Strategy Targets

Chapter 6 : Governance and Sustainable Development
Strategic Objectives
Key Targets
Important Steps
To mainstream sustainable
development across
government
By 2007 introduce a statutory duty on

relevant public bodies to contribute to the
achievement of sustainable development
Embed sustainable development principles

into the governance arrangements of new
councils
By 2007 ensure that all policy development

actively considers sustainable development
Develop a revised sustainable development

input to OFMDFM Practical Guide to
Policymaking
By 2007 link sustainable development

objectives to the Priorities and Budgets and
Comprehensive Spending Review Processes
By 2007 ensure all Departments have a
sustainable development Action Plan in place
Deliver a training programme focusing on

sustainable development knowledge and
skills across the NICS
By 2007 develop and pilot the use of and
Integrated Impact Assessment for use by all
Government Departments
By 2007 have in place a system of information
provision, support and guidance on
sustainable development for those involved
in policy and decision-making
Strengthen the network of

accountability for governance
for sustainable development
By 2009 ensure that community planning is

implanted within the revised local authority
By 2008 strengthen and modernise
environmental regulation
By 2006 finalise appropriate monitoring
and reporting arrangements for
sustainable development and establish an
implementation role for the Ministerial Led
Group
Agree the role of a sustainable development
Forum by 2006
Agree the way forward on the review of
environmental governance in respect of
sustainable development by summer 2007
By 2009 build capacity to enable meaningful
civic participation and identify participatory
mechanism for decision making
By 2006 ensure that the principles and

objectives of sustainable development have
been incorporated into the Regional
Development Strategy and planning
legislation
Determine how best to develop an
appropriate audit/scrutiny role to ensure
implementation of the objectives of the
strategy
Determine how best to utilise the role of the
Sustainable Development Commission in
Northern Ireland
Ensure planning legislation and Planning
Policy Statements are updated to reflect
sustainable development principles and
provide guidance on key areas
Consider the outcomes of the review of
environmental governance in respect of
sustainable development by 2007
93
APPENDIX THREE : Implementation of EMAS outside EU (List of Figures)

Appendix 4 Implementation of EMAS outside the EU
94
APPENDIX FOUR: PPC Permits Northern Ireland

Northern Irish PPC Permits Determined and Pending
PPC No.
Site Operator Name
Council Area
Determined/Pending
0143/01A
Du Pont ( UK ) Ltd
Derry CC
Determined
0163/01A
Queens Isand
Belfast CC
Determined
P0043/04A
North West Galvanising

Ltd.
Derry CC
Determined
P0044/04A
Drumee Landfill Site
Fermanagh DC
Determined
P0046/04A
NK Coatings Ltd
Newtownabbey BC
Determined
P0050/04A
Silverwood Enterprise Ltd.
Craigavon BC
Determined
P0051/04A
Ultra Building Products Ltd Strabane DC
Determined
P0052/04A
Lafarge Cement (Ireland)

Ltd
Cookstown DC
Determined
P0053/04A
Quinn Glass Ltd
Fermanagh DC
Determined
P0054/04A
Gortmullan Cement Works
Fermanagh DC
Determined
P0055/04A
Calcast Ltd
Derry CC
Determined
P0056/04A
Montupet ( UK ) Ltd
Lisburn BC
Determined
P0057/04A
Michelin Tyre PLC
Ballymena BC
Determined
P0058/04A
Ryobi Aluminium Castings

(UK) Ltd
Carrickfergus BC
Determined
P0059/04A
Sperrin Galvanisers Ltd.
Magherafelt DC
Determined
P0060/04A
Tyrone Brick Ltd
Dungannon DC
Determined
P0061/04A
Huhtamaki (Lurgan) Ltd.
Craigavon BC
Determined
P0062/04A
Kiel Pharma Ltd.
Carrickfergus BC
Determined
P0063/04A
S & B Production Limited
Newtownabbey BC
Determined
P0064/05A
Police Service of Northern

Ireland
Carrickfergus BC
Determined
P0065/05A
Lisburn Proteins
Lisburn BC
Determined
95
P0066/05A
Ulster Farm By-Products
P0067/05A
Grampian Country Pork Ltd Cookstown DC
Determined
P0068/05A
Omagh Meats
Omagh DC
Determined
P0069/05A
WD Meats
Coleraine BC
Determined
P0071/05A
OKane Poultry Ltd.
Ballymena BC
Determined
P0072/05A
Dunbia
Dungannon DC
Determined
P0074/05A
Stevenson and Company
Ballymena BC
Determined
P0075/05A
Foyle Meats/Proteins
Derry CC
Determined
P0076/05A
Linden Foods Ltd.
Dungannon DC
Determined
P0077/05A
Langford Processors Ltd.
Antrim BC
Determined
P0078/05A
ABP Lurgan
Craigavon BC
Determined
P0079/05A
ABP Newry
Newry & Mourne DC
Determined
P0080/05A
Moy Park Ltd.
Dungannon DC
Determined
P0081/05A
Belfast Sewage Sludge

Incinerator Facility
Belfast CC
Determined
P0084/05A
The Royal Group of

Hospitals
Belfast CC
Determined
P0086/05A
Linergy Ltd
Dungannon DC
Determined
P0087/05A
Craigmore Landfill Site
Coleraine BC
Determined
P0089/05A
Dairy Produce Packers Ltd
Coleraine BC
Determined
P0090/05A
Cottonmount Landfill
Newtownabbey BC
Determined
P0091/05A
Glanbia Cheese Ltd
Craigavon BC
Determined
P0092/05A
Dale Farm Ltd (Dromona)
Ballymena BC
Determined
P0093/05A
Dale Farm Ltd

(Pennybridge)
Ballymena BC
Determined
P0094/05A
Dale Farm Ltd

(Dunmanbridge)
Cookstown DC
Determined
P0095/05A
TMC Dairies (NI) Ltd
Strabane DC
Determined
96
Lisburn BC
Determined
P0096/05A
Armaghdown Creameries
Ltd
Banbridge DC
Determined
P0097/05A
Scotts Feeds Ltd
Omagh DC
Determined
P0098/05A
Diageo Global Supply IBC

Group
Castlereagh CC
Determined
P0099/05A
ABN Knockmore
Lisburn BC
Determined
P0100/05A
John Thompson and Sons

Ltd
Belfast CC
Determined
P0101/05A
G.E. McLarnon & Sons Ltd
Antrim BC
Determined
P0102/05A
United Feeds Limited
Belfast CC
Determined
P0103/05A
Moy Park Ltd
Craigavon BC
Determined
P0104/05A
Ballyrashane Co-op
Coleraine BC
Determined
P0105/05A
Coca Cola Bottlers (Ulster)

Ltd
Lisburn BC
Determined
P0107/05A
Whitemountain Quarries
Ltd
Lisburn BC
Determined
P0108/05A
ENVA (NI) Ltd
Castlereagh CC
Determined
P0109/06A
Biofuels Carryduff
Castlereagh CC
Determined
P0110/06A
Aughrim Landfill Ltd
Lisburn BC
Determined
P0118/06A
3M (UK) PLC
North Down
Determined
P0119/06A
Almac Sciences
Craigavon BC
Determined
P0120/06A
Kilroot Power Ltd
Carrickfergus BC
Determined
P0121/06A
Ulster Carpet Mills Ltd
Craigavon BC
Determined
P0123/06A
Polypipe (Ulster) Ltd
Craigavon BC
Determined
P0124/06A
Tennants Textile Colours

Limited
Belfast CC
Determined
P0125/06A
Premier Power Ltd
Larne BC
Determined
P0126/06A
Coolkeeragh ESB Ltd.
Derry CC
Determined
P0127/06A
Langford Lodge
Engineering
Antrim BC
Determined
97
P0128/06A
Clinty Chemicals Ltd
P0129/06A
Invista Textiles (UK) Limited Derry CC
Determined
P0130/06A
Ulster Industrial Explosives
Carrickfergus BC
Determined
P0131/06A
Balcas Timber Ltd
Fermanagh DC
Determined
P0132/06A
Norbrook Laboratories Ltd
Newry & Mourne DC
Determined
P0133/06A
Norbrook Laboratories Ltd
Newry & Mourne DC
Determined
P0134/06A
Shorts Brothers PLC

(Newtownards)
Ards BC
Determined
P0135/06A
Short Brothers PLC (Belfast) Belfast CC
Determined
P0137/06A
Bio Fue
Moyle BC
Determined
P0138/06A
Spanboard Products Ltd
Coleraine BC
Determined
P0139/06A
Clinty Regen Ltd
Belfast CC
Determined
P0140/06A
Dalkia Utilities Service Plc
Belfast CC
Determined
P0148/06A
Craigahullier Landfill Site
Coleraine BC
Determined
P0167/07A
Antrim Area Hospital
Antrim BC
Determined
P0001/03A
Harland and Wolff Heavy

Industries Ltd
Belfast CC
Pending
P0082/05A
P Clarke & Sons Ltd
Fermanagh DC
Pending
P0143/06A
Magheraglass Landfill Site
Cookstown DC
Pending
P0145/06A
Lisbane Landfill Site
Armagh City & DC
Pending
P0151/06A
Sales Corner Landfill Site
Lisburn BC
Pending
P0152/06A
Aughnagun Landfill Site
Newry & Mourne DC
Pending
P0153/06A
Ballymacombs Landfill Site
Magherafelt DC
Pending
P0154/06A
Drumanakelly Landfill Site
Down DC
Pending
P0155/06A
Kilroot Landfill Site
Carrickfergus BC
Pending
P0156/06A
Ballyduff Landfill Site
Newtownabbey BC
Pending
P0158/07A
The Old Mill - Drumaness
Down DC
Pending
P0160/07A
Clooney Road Landfill Site
Derry CC
Pending
98
Ballymena BC
Determined
P0161/07A
Duncrue Street
Belfast CC
Pending
P0162/07A
Colinglen Road - Belfast
Lisburn BC
Pending
P0178/07A
33 Greenogue Road
Banbridge DC
Pending
P0179/07A
Killough Road Industrial

Estate
Down DC
Pending
P0184/07A
Tullyvar Landfill Site
Dungannon DC
Pending
P0186/07A
Duncrue Street - Belfast
Belfast CC
Pending
P0187/07A
Caulside Drive
Antrim BC
Pending
P0235/07A
Blue Circle Industries PLC

t/a Lafarge Cement
Cookstown DC
Pending
P0236/07A
Ballyhome Road Landfill

Site
Coleraine BC
Pending
P0237/07A
McParlands Landfill
Newry & Mourne DC
Pending
P0238/07A
Dunmurry WWTW
Lisburn BC
Pending
P0239/07A
Newtownbreda WWTW
Belfast CC
Pending
P0240/07A
Enniskillen WWTW
Fermanagh DC
Pending
P0242/07A
New Holland WWTW
Lisburn BC
Pending
P0244/07A
Omagh Sludge Treatment

Plant
Omagh DC
Pending
P0245/07A
Dupont Maydown Works

Landfill Installation
Derry CC
Pending
P0246/07A
Colinglen Road Landfill
Lisburn BC
Pending
P0247/07A
Rumbling Hole Landfill Site Lisburn BC
Pending
P0248/07A
Ballynacor Sludge
Dewatering Centre
Craigavon BC
Pending
P0257/07A
Mr D Robinson
Derry CC
Pending
P0259/07A
Blackmountain Phrase II/III

Landfill Site
Lisburn BC
Pending
P0260/07A
Eastwood Envirowaste
Belfast CC
Pending
P0277/07A
Michael McAlary
Strabane DC
Pending
99
P0278/07A
Michael McAlary
Derry CC
Pending
P0281/07A
Ever Green Energy Biofuel
Belfast CC
Pending
P0287/08A
Coca Cola Bottlers (Ulster)

Limited
Lisburn BC
Pending
P0288/08A
AES Kilroot Generating

Limited
Carrickfergus BC
Pending
P0289/08B
Murphys Construction
Materials Ltd.
Limavady DC
Pending
P0290/08B
Ltd
N/A (Mobile)
Pending
PPC0002/08B
Belfast Terminal
Belfast CC
Pending
PPC0006/08B
NuStar Terminals Limited
Belfast CC
Pending
PPC0012/08B
Calor Gas Northern Ireland

Ltd
Belfast CC
Pending
PPC0013/08B
M.P. Coleman Ltd.
Cookstown DC
Pending
PPC0014/08B
Lisbane Quarry
Craigavon BC
Pending
PPC0014/08B
Lisbane Quarry
Craigavon BC
Pending
PPC0016/08B
J Robinson & Sons Ltd
Ballymena BC
Pending
PPC0017/08B
Sounding Hill Quarry
Magherafelt DC
Pending
PPC0018/08B
Grange Limestone Mills
Armagh City & DC
Pending
PPC0019/08B
Charles Tennant & Co (NI)

Ltd
Belfast CC
Pending
PPC0020/08B
Cashel Quarry
Castlereagh CC
Pending
PPC0021/08B
Kilwaughter Chemical
Company Ltd
Larne BC
Pending
PPC0022/08B
R J Mitten & Sons
Fermanagh DC
Pending
PPC0023/08B
R J Mitten & Sons
Fermanagh DC
Pending
PPC0024/08B
W & J Chambers Ltd
Derry CC
Pending
PPC0025/08B
James Stevenson (Quarries) Ballymena BC

Ltd
Pending
PPC0026/08B
Cootes (Concrete
Products) Ltd
Pending
100
Armagh City & DC
PPC0027/08B
Northstone (NI) Ltd Concrete Division
Down DC
Pending
PPC0029/08B
Banbridge DC
Pending
PPC0030/08B
Castlereagh CC
Pending
PPC0031/08B
Northstone (NI) Ltd
Ballymena BC
Pending
PPC0032/08B
Northstone (NI) Ltd
Omagh DC
Pending
PPC0033/08B
Northstone (NI) Ltd
Coleraine BC
Pending
PPC0034/08B
Northstone (NI) Ltd
Cookstown DC
Pending
PPC0035/08B
Northstone (NI) Ltd
Magherafelt DC
Pending
PPC0036/08B
Northstone (NI) Ltd
Omagh DC
Pending
PPC0038/08B
Northstone (NI) Ltd
Ards BC
Pending
PPC0039/08B
W J McCormick & Sons Ltd
Down DC
Pending
PPC0040/08B
Ballymena BC
Pending
PPC0041/08B
Knockloughrim Quarry
Magherafelt DC
Pending
PPC0042/08B
Craigantlet Quarry
North Down
Pending
PPC0043/08B
Aughrim Quarry
Lisburn BC
Pending
PPC0044/08B
Clinty Quarry
Ballymena BC
Pending
PPC0045/08B
Glassdrummond Quarry
Down DC
Pending
PPC0046/08B
Mallusk Coating Plant
Newtownabbey BC
Pending
PPC0047/08B
Newtownabbey BC
Pending
PPC0048/08B
Edentrillick Quarries Ltd
Banbridge DC
Pending
PPC0049/08B
Legavannon Quarry
Limavady DC
Pending
PPC0050/08B
Kennedy Concrete
Products Ltd
Coleraine BC
Pending
PPC0051/08B
Budore Quarries
Lisburn BC
Pending
PPC0052/08B
Barrack Hill Quarries Ltd
Dungannon DC
Pending
101
PPC0053/08B
B McCaffrey & Sons Ltd
Fermanagh DC
Pending
PPC0054/08B
Craigall Quarry
Coleraine BC
Pending
PPC0054/08B
Craigall Quarry
Coleraine BC
Pending
PPC0055/08B
B Mullan & Sons

(Contractors) Ltd
Coleraine BC
Pending
PPC0056/08B
ALT Quarry
Newry & Mourne DC
Pending
PPC0058/08B
Lagan Bitumen Ltd.
Belfast CC
Pending
PPC0059/08B
Moyard Properties Limited
Newry & Mourne DC
Pending
PPC0060/08B
James Boyd & Sons (

Carnmoney ) Ltd
Newtownabbey BC
Pending
PPC0061/08B
M W Johnston & Son
Lisburn BC
Pending
PPC0062/08B
Acheson & Glover Ltd
Fermanagh DC
Pending
PPC0063/08B
Crievehill Quarry
Fermanagh DC
Pending
PPC0064/08B
Douglas Acheson Ltd
Armagh City & DC
Pending
PPC0065/08B
Tynan Quarry
Armagh City & DC
Pending
PPC0066/08B
Armagh City Quarries
Armagh City & DC
Pending
PPC0067/08B
Ardverness Quarry
Coleraine BC
Pending
PPC0068/08B
Loughside Quarries
Larne BC
Pending
PPC0069/08B
John Finlay (Concrete

Pipes) Ltd
Armagh City & DC
Pending
PPC0070/08B
Eden Quarry
Limavady DC
Pending
PPC0071/08B
Clady Quarry
Armagh City & DC
Pending
PPC0072/08B
Miskelly Bros Ltd
Ards BC
Pending
PPC0073/08B
Sean Quinn Group Ltd
Fermanagh DC
Pending
PPC0074/08B
Sean Quinn Group Ltd
Fermanagh DC
Pending
PPC0075/08B
P Clarke & Sons Ltd
Fermanagh DC
Pending
PPC0077/08B
Leod Quarry
Newry & Mourne DC
Pending
PPC0078/08B
T H Moore (Contracts) Ltd
Newry & Mourne DC
Pending
PPC0080/08B
Gibsons Bros Ltd
Banbridge DC
Pending
102
PPC0081/08B
Portadown Quarry
Craigavon BC
Pending
PPC0082/08B
ICB Emulsions Ltd.
Craigavon BC
Pending
PPC0083/08B
Aughrim Quarry
Newry & Mourne DC
Pending
PPC0085/08B
Aughafad Quarry
Strabane DC
Pending
PPC0086/08B
Hightown Quarry
Newtownabbey BC
Pending
PPC0089/08B
Patrick Keenan
Magherafelt DC
Pending
PPC0091/08B
Craigantlet Quarry
North Down
Pending
PPC0092/08B
Bonds Glen Quarries
Limavady DC
Pending
PPC0093/08B
Patrick Keenan
Magherafelt DC
Pending
PPC0094/08B
Gortree Quarry
Derry CC
Pending
PPC0095/08B
Patrick Keenan
Cookstown DC
Pending
PPC0097/08B
Martins Quarry
Down DC
Pending
PPC0098/08B
Letterloan Quarry
Coleraine BC
Pending
Castlereagh CC
Pending
PPC0099/08B
PPC0100/08B
Lisowen Quarry
Down DC
Pending
PPC0101/08B
Castlenavan Quarry
Down DC
Pending
PPC0102/08B
OMYA ( UK ) Ltd
Larne BC
Pending
PPC0103/08B
Corkey Quarry
Ballymoney BC
Pending
PPC0104/08B
Ballyboyland Quarry
Ballymoney BC
Pending
PPC0106/08B
Banbridge Quarry Complex Banbridge DC
Pending
PPC0107/08B
Carrowdore Quarry
Ards BC
Pending
PPC0108/08B
Tullyraine Quarry
Banbridge DC
Pending
PPC0109/08B
Ltd
Belfast CC
Pending
PPC0110/08B
Ltd
Lisburn BC
Pending
PPC0111/08B
Ltd
Lisburn BC
Pending
PPC0113/08B
Ltd
Ards BC
Pending
103
PPC0114/08B
Outlack Quarry
Armagh City & DC
Pending
PPC0115/08B
Tullyraine Quarries Ltd
Banbridge DC
Pending
PPC0116/08B
Loughran Rock Industries
Armagh City & DC
Pending
PPC0117/08B
WG Ballantine
Strabane DC
Pending
PPC0118/08B
Francis McCone & Sons Ltd
Armagh City & DC
Pending
PPC0119/08B
Carn Quarry
Fermanagh DC
Pending
PPC0120/08B
Dunaree Quarry
Omagh DC
Pending
PPC0121/08B
Drogan Quarry
Fermanagh DC
Pending
PPC0122/08B
M Leer
Armagh City & DC
Pending
PPC0123/08B
Glebe Quarry
Armagh City & DC
Pending
PPC0123/08B
John OHagan
Newry & Mourne DC
Pending
PPC0124/08B
Irish Asphalt Ltd
Armagh City & DC
Pending
PPC0128/08B
Mobile Crushing Unit
N/A (Mobile)
Pending
PPC0131/08B
Ltd
Lisburn BC
Pending
PPC0133/08B
Conway Bros
Coleraine BC
Pending
PPC0135/08B
FP McCann Ltd
Newtownabbey BC
Pending
PPC0140/08B
Technical Metals Ltd
Ards BC
Pending
PPC0147/08B
Tyrone Crystal Ltd
Dungannon DC
Pending
PPC0152/08B
G & G Ross (Mobile Stone

Crushing )
N/A (Mobile)
Pending
PPC0155/08B
Milburn Concrete Ltd.
Cookstown DC
Pending
PPC0156/08B
LSS Ltd.
Derry CC
Pending
PPC0157/08B
DCC Energy (NI) Ltd (

Flogas )
Belfast CC
Pending
PPC0167/08B
Deane Public Works Ltd
N/A (Mobile)
Pending
PPC0168/08B
DARD - Veterinary Science

Division
Belfast CC
Pending
PPC0169/08B
Roadmix Ltd
N/A (Mobile)
Pending
104
PPC0174/08B
Patrick Megoran
N/A (Mobile)
Pending
PPC0175/08B
Boville - McMullan Ltd
Antrim BC
Pending
PPC0177/08B
Clady Quarries
N/A (Mobile)
Pending
PPC0178/08B
Cairnhill Quarry (Mobile

Plant)
Ards BC
Pending
PPC0179/08B
McCaffrey Concrete
Products Ltd
Fermanagh DC
Pending
PPC0182/08B
Eskra Quarry
Omagh DC
Pending
PPC0183/08B
HMG Powder Coatings Ltd
Castlereagh CC
Pending
PPC0184/08B
Dromalane Quarry
Newry & Mourne DC
Pending
PPC0185/08B
Rockmount Quarries/
Mobile Crusher
N/A (Mobile)
Pending
PPC0187/08B
Robert George McCullough N/A (Mobile)
Pending
PPC0188/08B
Northstone (NI) Ltd
N/A (Mobile)
Pending
PPC0189/08B
Harold Graham
Fermanagh DC
Pending
PPC0190/08B
Stoneyford Concrete/
Flomix Ltd
Lisburn BC
Pending
PPC0191/08B
Crocknamolt Quarry
Coleraine BC
Pending
PPC0194/08B
Chris McCormick Contracts N/A (Mobile)
Pending
PPC0195/08B
Toneymore
Fermanagh DC
Pending
PPC0196/08B
Northstone (NI) Ltd
N/A (Mobile)
Pending
PPC0197/08B
Swan Rock Quarries
Newry & Mourne DC
Pending
PPC0198/08B
McGeown International Ltd Newry & Mourne DC
Pending
PPC0199/08B
Northstone (NI) Ltd
N/A (Mobile)
Pending
PPC0200/08B
B Mullan & Sons

(Contractors) Ltd
Limavady DC
Pending
PPC0201/08B
Loughran Quarries
Omagh DC
Pending
PPC0202/08B
Eskrahoole Quarry
Omagh DC
Pending
PPC0203/08B
Stanley Bell & Sons
N/A (Mobile)
Pending
PPC0205/08B
Shaughan Quarries Ltd.
Newry & Mourne DC
Pending
105
PPC0207/08B
Portadown Quarry
Craigavon BC
Pending
PPC0208/08B
Patrick Keenan
N/A (Mobile)
Pending
PPC0209/08B
Castle Contracts Ltd
N/A (Mobile)
Pending
PPC0210/08B
Colton Quarries Ltd
Fermanagh DC
Pending
PPC0211/08B
MGR Crushing Ltd
N/A (Mobile)
Pending
PPC0212/08B
MAR Properties Ltd
N/A (Mobile)
Pending
PPC0213/08B
Fox Building and

Engineering Ltd
N/A (Mobile)
Pending
PPC0214/08B
Omagh Minerals Ltd
Omagh DC
Pending
PPC0215/08B
C E Stevenson & Sons
Down DC
Pending
PPC0216/08B
CE Stevenson and Sons
N/A (Mobile)
Pending
PPC0217/08B
F.P. McCann Ltd
N/A (Mobile)
Pending
PPC0219/08B
King Brothers
Armagh City & DC
Pending
PPC0220/08B
Conexpo (NI) Ltd
N/A (Mobile)
Pending
PPC0221/08B
S. McConnell & Sons Ltd
N/A (Mobile)
Pending
PPC0222/08B
Gerry McManus Plant Hire

Ltd
N/A (Mobile)
Pending
PPC0223/08B
G&G Ross
N/A (Mobile)
Pending
PPC0224/08B
DJ McAleese & Co.
N/A (Mobile)
Pending
PPC0225/08B
Martins Quarry (Mobile)
N/A (Mobile)
Pending
PPC0226/08B
P.T. McWillams
N/A (Mobile)
Pending
PPC0228/08B
Norman Emerson & Sons

Ltd
Craigavon BC
Pending
PPC0231/08B
Geotech Construction Ltd
Dungannon DC
Pending
PPC0232/08B
Ltd
Coleraine BC
Pending
PPC0233/08B
Klargester Ireland
Newry & Mourne DC
Pending
PPC0234/08B
P.T. McWillams
N/A (Mobile)
Pending
PPC0235/08B
Craigantlet Quarry
North Down
Pending
106
APPENDIX FIVE: NIEA Organisational Structure
107
108
Northern Ireland Environment Agency

Klondyke Building
Cromac Avenue
Gasworks Business Park
Belfast BT7 2JA
T. 0845 302 0008
Our aim is to protect, conserve and promote the

natural and built environment for the benefit of
present and future generations.
Printed on 100% post consumer waste
ISBN No. 978-1-905127-81-8

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Measuring the effectiveness of

Environmental Management Systems

Phase 1: Desktop Report, June 2009

THIS PAGE IS INTENTIONALLY LEFT BLANK

Measuring the Effectiveness of Environmental Management Systems: Phase 1

Measuring the effectiveness of

Background to the Project

Measuring the Effectiveness of Environmental Management Systems: Phase 1

Background to the Project

EMAS (Eco-Management and Audit Scheme)

Measuring the Effectiveness of Environmental Management Systems: Phase 1

and evidence of this commitment is usually found in the setting of

Measuring the Effectiveness of Environmental Management Systems: Phase 1

Whilst research and evaluation of the above programmes has been on

ISO 14001 - a National Study in Austria

Measuring the Effectiveness of Environmental Management Systems: Phase 1

What is an Environmental Management System

Management Systems and Legal Compliance

Drivers to Implementation of an EMS

Overview of legislation and policy

Enforcement in Northern Ireland

Procurement Policy and Promotion of EMS

Central Procurement Directorate

Other Local Procurement Drivers

Compliance Drivers in England and Wales

Other Drivers for Implementing an EMS

The International Scene

4.4.1.1 Support Schemes

4.4.1.2 Building Blocks

Green Dragon Coleraine Borough Council

Arena Network Survey

Measuring the Effectiveness of Environmental Management Systems: Phase 1

SME-nvironment Survey (NetRegs)

Ever Evaluation of EMAS and Eco-label for their revision

EMS and Company Performance

ISO 14001 Experiences, Effects and Future Challenges:

a National Study in Austria

USA National Database

Urban Government Review in Japan

Chapter 1 Key Targets Northern Ireland Sustainability Strategy

Chapter 6 Key Targets Northern Ireland Sustainability Strategy

Implementation of EMAS outside EU List of Figures

NIEA Organisational Structure

Key elements of legal compliance in an EMS

Regulatory value of an EMS

Green Dragon EMS

EMAS Registration process

ISO14001:2004 Assessment process

Evolution of EMAS organisations

Measuring the Effectiveness of Environmental Management Systems: Phase 1

Measuring the effectiveness of

Measuring the Effectiveness of Environmental Management Systems: Phase 1

Measuring the Effectiveness of Environmental Management Systems: Phase 1

been witnessed in terms of the encouragement on those firms appraised

Data Analysis &

Final Report with

Measuring the Effectiveness of Environmental Management Systems: Phase 1

2.0 What is an Environmental Management System?

Measuring the Effectiveness of Environmental Management Systems: Phase 1

Procedures are drafted to ensure legal compliance of the activity as a

improved risk management

These benefits are further support by findings from a NetRegs survey

Reduced risk of prosecution (81% strongly agree / agree);