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

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

3. 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

4. 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

5. 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

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

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

8. 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

9. 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

10. 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

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

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

13. 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

14. 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)

15. 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

16. 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

17. 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”

18. 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

19. Questions ?

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

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

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

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