Integrated permitting and inspections EMS as part of Integrated permitting and inspections Rob Kramers Senior advisor InfoMil

Content What is an EMS Relation to integrated permitting Relation to integrated inspection

What is an EMS (1) Environmental Management System Management tool for the company Structured framework to identify, evaluate and manage environmental aspects and improve environmental performance

What is an EMS (2) Helps to ensure the implementation of overall environmental goals, as set out in its environmental policy Helps to ensure that employees, contractors and suppliers know their roles and responsibilities Makes sure regular monitoring and auditing of the environmental performance and of the system takes place Provides management with a basis to evaluate the effectiveness of the EMS

What is an EMS (3) DEMING CIRCLE plan do act check Environmental aspects Legal and other requirements Objectives and targets Environmental programmes DEMING CIRCLE Continuous improvement Structure / responsibilities Training / communication Operational control Emergency response Documents and control plan do Performance act check Monitoring and measurements Non-compliance and corrective and preventive actions Records EMS audits Assurance Management review Time

What is an EMS (4) BS 7750 ISO 14001 EMAS

Relation to integrated permitting (1) Subjects of interest in permitting: operational control measurement and monitoring maintenance emergency response environmental programmes reporting

Relation to integrated permitting (2) Why stimulate EMS: puts the responsibility at the address of the company self regulation continuous improvement of performance compliance with legislation

Relation to integrated permitting (3) How can we stimulate EMS, what are the incentives: customize the permit to the level of environmental care different inspection/enforcement approach

Relation to integrated permitting (4) Customised permitting = Permitting process where the flexibility of the permit is adjusted to the level of environmental care within the company Framework permit Most flexible form of customised permitting

Relation to integrated permitting (5) Customised permitting Flexibility Traditional permit Framework permit Customised permitting Level of env. care

Relation to integrated permitting (6) What means a “flexible permit” - Material - Procedural - Temporal

Relation to integrated permitting (7) Target / objectives rather than technical measures EMS part of the permit, but selective references to the vital elements (procedures) of the EMS Strict requirements on monitoring and registration Only parts of the application incorparated in permit

Relation to integrated permitting (8) Application: Do not make the whole application part of the permit - Technical part - only what is important (part of the permit) - EMS - only the what, not the how (part of the permit) - Information part (no part of the permit)

Relation to integrated permitting (9) The flexible permit But be aware: not a vague permit it should be enforceable contract for good and bad times Make sure: the enforcer and the permitting writer should co-operate closely together in the permitting procedure

Relation to integrated inspections (1) Inspection approach The way inspection is carried out could change Inspection type depends on trust in EMS More attention to performance Central position EMS during inspections how it works how it is implemented in organisation not the non-compliance itself but the way EMS responds to this is important Be aware not to step in the role of certifier / verifier

Relation to integrated inspections (2) Concequences Agreement with company on the inspection Change approach on data given (voluntarily) by the company Inspection tasks become more difficult Advantages Non-compliance is better traceable (transparent) Allocation of resources to “bad guys”

Relation to integrated inspections (3) The inspection Test important procedures from EMS (audit) Access to internal and external audit reports Assess internal and external audits But also: Verify company’s environmental report Inspect the monitoring and registration system

Questions ?

What do you consider important to regulate in the permit? Discussion (1) What do you consider important to regulate in the permit?

What do you think of a “Framework permit”? Discussion (2) What do you think of a “Framework permit”?

Discussion (3) What do you think about the enforceability of a Customised permit - “Framework permit”?

Discussion (4) What do you think about the different approach / different role of the enforcer?