A report on the implementation of an environmental management system for a scottish paper mill and a review of its environmental activities along with an economic evaluation between two different investment opportunities.
EXECUTIVE SUMMARY
The introduction of Environmental Management Systems (EMS) in organisations has been as a result of different pressures or drivers. The EMS itself has gone through several changes and evolvement as early environmental management systems were developed 'in-house' alongside quality management and took many characteristics of the quality standard, ISO 9001. In 1992 the first nationally recognised and universally applicable standard was published by the British Standards Organisation, BS 7750 and took the four step total quality systems approach, the plan-do-check-act system developed by Walter Shewhart and made popular by Edward Deming.
Increasing environmental awareness and resulting legislations have led to many organisations implementing EMS in order to control and improve environmental performance. The EMS thus becomes desirable for the Scottish paper mill in line with their objectives of controlling environmental performance to comply with environmental legislation and regulations. Apart from achieving compliance the paper mill will also be able to gain some financial benefits through cost savings from increased efficiency of its process activities and other financial spin offs from positive public interest and perception by their implementation of an EMS which shows a great sense of responsibility towards the environment.
A review of the activities of the paper mill has led to significant environmental aspects being identified with targets and objectives developed in line with that, considering relevant legislation as relates to the activities of the mill. All these are vital in any EMS and the documentation of such and operation of the EMS to meet identified targets will guarantee improved environmental performance.
Based on the aspects and impacts identified, an economic evaluation has been made to decide on which of two available investment options should be carried out for improving future performance. The options available to the mill are a water treatment plant and combined heat and power plant.
INTRODUCTION
This report is to enable a Scottish paper mill control and improve its current environmental performance with a view to achieving compliance with regulations and environmental legislation as relevant to the scale of its activities.
It is to touch on areas of what an Environmental System Management is and how it can help achieve the management's objective. The benefits of implementing such a system will be also highlighted.
An initial environmental review has been carried out for the paper mill with the aim of identifying impacts and aspects which are significant and need to be improved on to achieve the overall goal.
A trade-off between two investment opportunities available to the paper mill has also been made using the environmental and economic issues available.
1.0 ENVIRONMENTAL MANAGEMENT SYSTEM
Measuring and controlling environmental performance to achieve compliance with regulations and environmental legislation is increasingly gaining popularity with organisations. A tool or technique which can be used in evaluating and improving environmental performance is an environmental management system. (EMS)
An environmental management system consists of a range of interrelated elements which function together for the purpose of effectively and efficiently managing the activities, products and services of an organisation which have, or can have, an impact on the environment. (Welford 1998)
BENEFITS OF AN EMS
An EMS helps to identify, assess and reduce the impacts on the environment of the organisation and also improve health and safety conditions of its work processes. When implemented it can deliver the following gains:
Compliance with regulations and for achieving operational efficiency in terms of energy and resources
Increase the involvement and environmental awareness of an organisation's employees and their improved understanding of its operating procedures
Improved public perception and competitive advantage
More appropriate assessment of its risk and liabilities
Financial benefits can usually be derived from all of the above as an appropriate assessment of risks and liabilities can reduce them in terms of costs that could result from accidents and fines from being found guilty of regulatory breaches. Also through the enhanced competitive edge from public perception income streams can be improved. More efficient management of resources like water and energy and an improved work process will result in cost savings.
All these benefits above are clearly in line with the paper mill's management to achieve control of their environmental performance to satisfy legislation and regulations and at the same time save some cost towards offsetting the maintenance of the EMS.
1.2 KEY ACTIVITIES OF AN EMS
There are different types of EMS options available to organisations. Examples of these include; ISO 14001, Eco Management and Audit Scheme (EMAS), BS 8555, Sector Specific E.g. Green Tourism Business Scheme, In- House systems. Every EMS system goes through the 4 step cyclical process of Plan-Do-Check-Act designed to structure the process of continuous improvement of process quality which takes into account the key activities of an EMS in order to deliver gains and continual improvement of the system. The main activities using the ISO 14001 model are;
Environmental policy - This is a policy statement which delivers the organisations intent towards environmental performance improvement
Planning - In planning, environmental aspects and their significance are usually identified and the relevant legislation of present and future within the scale of its activities are related to the environmental aspects. Objectives and targets for the delivery of environmental goals shall also be developed.
Implementation and Operation - Implementation of a set of plans, that is actionable blueprints to deliver on objectives and targets. Will include the definition of responsibilities and authority, training staff on competencies at improving environmental performance, documenting all aspects of the EMS and control of this documentation, communication of same to relevant internal and external interested parties and operational control to ensure the right thing is being done by whoever is supposed to be doing it.
Checking and corrective action - The EMS is monitored and measured by comparing performance with targets and improving where needed. Also to see if there is compliance to legislation by internal auditing.
Management review - The level of management that defined the policy, its objectives and procedures should review and evaluate it at different intervals to maintain continual improvement and effectiveness.
Fig.1 ISO 14001 5-box-model
Source: Quality Matters (Online)
ISO 14001 and EMAS are standards that are recognised internationally as they have both been set by the International Standards organisation and the European commission respectively. The BS 8555 has been set by the British Standards Organisation while other types are more of a custom built model specific to particular needs of the organisation.
In implementing the EMS, the appropriate model is selected and operated according to its specification and once the EMS is in effective operation, external certification can be sought. If certified after inspection by the relevant institutions, regular checks are still carried out to confirm that the EMS is still being operated accordingly to standards of conformity. Failure of any of these surveillance checks could result in being deregistered.
It is important to note that the ISO 14001 EMS standards are process and not performance standards. The standards do not mandate an organisation's optimum environmental performance but describe a system to help an organisation achieve its own environmental objectives and ultimately improve its environmental performance. (Melnyk, Sroufe, Calantone 2002)
1.3 EMS OPTION TO ADOPT (THE EMS MODEL BS 8555)
Based on the financial limitations of the paper mill, I recommend the adoption of the BS 8555 as it is not as capital intensive as the EMAS and ISO 14001. Also being a Scottish mill, the BS8555 being a British standard would be appropriate for implementation.
This is a British Standard which actually breaks down the ISO 14001 and EMAS into 6 phases which makes for easier implementation by organisations. It is in consideration of smaller organisations or those that do not have the kind of financial strength for embarking on a full ISO 14001 or EMAS option straightaway. There is usually phased acknowledgement at each stage by the United Kingdom Accreditation Service (UKAS) and this can effectively be used in measuring progress. The six stages are:
Commitment and establishing a baseline
Identifying and ensuring compliance with legal and other requirements
Developing objectives, targets and programmes
Implementation and operation of the environmental management system
Checking, audit and review
Environmental management systems acknowledgement
Fig. 2 BS 8555 stages
Source: Institute of Environmental Management and Assessment (IEMA) (Online)
1.4 RESOURCE TO IMPLEMENT
A key challenge to any EMS being implemented is dependent on the ability of top management of the organisation to commit fully the resources to the project that will translate to success. The resources to commit to the system and time taken to complete it are usually dependent on such factors as the availability of experienced and knowledgeable staff on environmental matters, process complexity, the availability of other standards of management such as the quality standard ISO 9001, the condition of the site and indeed the availability of outside consultancy support. (NQA 2009)
The resources required include human resources and specialised skills, financial and technological resources, and an appropriate organizational infrastructure for the definition of roles, responsibilities and authority.
Planning activities of the EMS will require about 30% of resource and effort. The review by management, drawing up of the policy statement, and checking and correcting the system where necessary requires a further commitment of 30% of the project resource and effort.
The actual implementation and operation of the EMS requires about 40% of the required project resource and time.
2.0 THE ENVIRONMENTAL REVIEW
In order to implement an EMS successfully, the environmental performance of the organisation must be established. A baseline which indicates current performance should be drawn in order to measure improvement against future performance which will enable improvements to be carried out in the future on the current scheme of things. It usually involves considering the activities of the organisation and considering the physical inputs and outputs of each activity during normal and abnormal operations, whether intended or not, for the purpose of establishing what the environmental aspects are. This is vital so the EMS can focus on the key environmental issues, that is, the significant environmental aspects so that adequate resources are directed at handling them in order to improve the organisations environmental performance. (Brady, 2005) Examples of the environmental aspects that could be identified include ; use of energy, raw materials and natural resources, disposal of waste and land contamination, emissions to air, e.t.c.
In order to determine the significant environmental aspects relevant legislation, regulation and environmental requirements as affects the organisation should be identified for the purpose of effectively addressing such issues with the EMS. The significant aspects of the activities will help in establishing what impacts they have and in giving direction on how they should be tackled. These activities and associated aspects can then be transferred to a summary table for further assessment of their impacts on the environment.
2.1 ASSSESING SIGNIFICANCE
The determination of the significance of the aspects and their impacts is about the most challenging aspect of the environmental management system. Consultation with different professionals and stakeholders on the different impacts and significance will be needed as their input will help in correctly assessing the situation. Different tools and techniques are used but the technique to be used in this report is one known as the significance methodology developed by the Urban Water Technology Centre. It allows for a systematic ranking of the impacts by allocating values to the aspects. This is done by considering factors as;
Frequency of the environmental aspect
Volume of the environmental aspect
Short vs long term pollution of the environmental aspect
Stakeholder concerns or perceptions as relates to the environmental aspect
Environmental legislation relating directly to the environmental aspect
Potential emergency situations that can be reasonably foreseen as relates to the environmental aspect
An identification of the activity being a normal or abnormal part of the organisations operations
The organisation's level of control over the aspect or not
The potential for environmental accident from the aspect
2.2 THE SIGNIFICANCE METHODOLOGY
The significance methodology addresses these factors by specific questions which are answered as appropriate in the particular context.
The significance methodology ranks different activities on a scale of 1-5 based on the factors above. For example, in determining what to answer to a question such as; Is electricity use associated with any environmental legislation or code of practice?
A score scheme could be 1 where no legislation exists, 2 if an economic instrument is planned in the near future e.g. 2-4 years, 3 if an economic instrument or green tax or tariff exists, 4 if legislation or code of practice(COP) is planned in the near future and 5 if a legislation or COP exists.
Volume, where none or minimal is rated 1 and where considerable 5 with intermediate levels of slight, moderate and significant rated 2,3,4 respectively.
Also, pollution issue of long term disastrous significance is rated 5, while minor pollution issue or none at all is rated 1 with intermediate levels of serious, moderate or slight rated 4,3,2 respectively.
Using this technique, the scores of each activity can be aggregated by addition or multiplying and weighed against a preselected figure which is known as the significant threshold. The relevance of this significance threshold is that it allows for selection of the activities which have the greatest environmental impact so that they can be improved upon.
This report will apply the addition method to the scores of each activity and weigh against 20 as the significant threshold. All environmental aspects with a score above 20 are the significant environmental aspects to be considered.
2.3 ENVIRONMENTAL LEGISLATION
Creating and maintaining a register of legislation and regulations that apply to an organisation for easy reference is a fundamental part of the planning and implementation process of an EMS. (Tinsley and Pillai, 2006)
The process activities of the paper mill have been examined and environmental aspects and impacts determined. There are a number of legislation concerning some of the identified environmental aspects and impacts of the activities of pulp making. They range from activities that generate noise, to those whose effects depreciate the quality of the air thus endangering health and safety. Also there are specific legislation targeted at protecting land from contamination by industrial activities with pollutants such as heavy metals and chemical spills. Water is one aspect of legislation that has also been broadly promulgated and such aspects of water such as bathing water, surface water, and that available to aquatic life are broadly covered in such legislation.
Some of the legislation that covers the issues highlighted above have been identified and listed below;
PROCESS ACTIVITY
ENVIRONMENTAL ASPECT AND IMPACT
LEGISLATION
BLEACH
Sodium hypochlorite is used in bleaching and this process releases harmful gases to the atmosphere which pollute the air quality and threaten human health
SI 1989/317 Clean air, the air quality standard regulations 1989
PREPARATION OF RAW MATERIALS
Water is used for diluting waste paper suspensions and dispersing the inks and quantity is quite large. And also BOD/COD could be in the water which is eventually sent out in the drains.
PREPARATION OF RAW MATERIALS
Chemicals which are stored for the process can accidentally spill and the spilled chemical could impact on the quality of groundwater, land and human safety.
SI 1999/743 Control of Major Accidents Hazards Regs
3.0 EVALUATION OF INVESTMENT OPPORTUNITIES
Two investment opportunities namely a water treatment plant and a combined heat and power plant have been evaluated for their potential costs to the paper mill. The evaluated costs of installing and running a water treatment plant for a period of about 60 years at rates of 11%, 13% and 15% will come to £4,527,829, £4,264,002 and £4,078,086 respectively. See appendix III.
For running and installing the combined heat and power plant under the same conditions of risk and period of time will cost the paper mill £6,300,988, £5,959,376 and £5,722,055 accordingly. See appendix III.
Clearly the combined heat and power plant would be more constraining financially for the paper mill.
However, taking into consideration the significant environmental aspects that were identified as a result of its activities there is clearly a great amount of energy being used. Most of this energy used for its processes is generated through combustion of coal, oil and gas and therefore there is a depletion of finite resources as well as the impacts to the climate as a result of greenhouse gas emissions that go with the combustion of such fossil fuels. It is imperative then that a combined heat and power plant should be installed for the simultaneous generation of energy and useful heat and energy recycling.
This can be supported by looking at work put forward by Hernandez where in sanctioning energy systems based on economic-environmental selective-adaptive criteria he concluded that the initial investment surplus towards a renewable energy system must be compensates within a reasonable period of time with savings of fuel and environmental damages accumulated during that period. (Hernandez 1995)
CONCLUSION
An EMS being put in place by the paper mill will be of immense usefulness to the organisation. It will provide a structural framework through which the organisation's internal capabilities can be harnessed, organized and directed in a unified manner to address the top priority objectives of the management.
The EMS will ensure that the environmental performance improvement in order to satisfy legislation and regulations will be achieved as top goals will constantly be given due attention at all operating levels and developed targets will be followed through till they are implemented.
Financial benefit of EMS systems arise from cost savings and this will also be achieved through the costs that will be saved from energy generation and use by the combined heat and power plant that was decided upon investing towards due to the environmental management system being in place.
