Environmental management systems (EMS) are becoming an increasingly hot topic in the waste management sector.
This is partly due to the Environment Agency (EA), which has begun to enforce and audit the requirement to have an EMS at regulated sites. As consultants specialising in environmental permitting for waste management facilities, we have noticed an increasing demand for help in the production and implementation of such systems.
An EMS is a structured, written system which helps an organisation to identify the potential environmental effects resulting from its activities. It should also help to manage and minimise those effects so that the overall environmental performance of an organisation or facility is improved. An EMS can be an electronic system if it is suitable for the particular site; some waste facilities are not equipped with computers, so a paper copy is essential.
There are external bodies which provide certification or verification schemes for EMSs. The EA supports registration to such schemes, the most well-known of which are the international standard ISO14001 and EMAS, which is mainly a European standard. Formal certification by an independent body can be advantageous, but for many small to medium- sized waste management firms, an in-house system can be more suitable and just as effective.
Operators can produce their own EMS or seek help from a consultant who has experience with these systems.
To give operators some guidance, the EA has issued an EMS toolkit specific to the waste sector, setting out what it wants to see in an EMS. The guidance is informative, but we believe it is also important to take a more adaptable, site-specific approach to create an EMS which is useful on a day-to-day basis. The format recommended in the EA’s guidance differs from that required by ISO14001 and EMAS, so it can be a challenge to meet the requirements of both.
An EMS is normally made up of key sections that will be applicable to most organisations or facilities, such as document control systems, environmental risk assessments, maintenance procedures, operational procedures and accident management plans.
As an EMS must be site-specific, all the procedures within it must be tailored to suit the permitted activity and the environmental risks associated with it. After all, the potential environmental effects and the legal obligations associated with waste facilities depend on the nature of the operation. For example, an EMS for a composting facility may include a section on the management of odour, whereas this would not be appropriate at an inert aggregates recycling facility. As consultants, we find it is best to visit the site, meet its management staff and gain a complete understanding of how the facility works before we produce an EMS.
By working with clients to prepare these systems for a diverse range of waste management facilities, we have come to realise that the benefits of implementing an EMS can extend far beyond legal compliance. Additional benefits include improved environmental performance, increased staff engagement with company policies and procedures, and streamlined record keeping systems. The experience of MDJ Light Brothers, a waste management company based in Sussex, is discussed in the case study.
We would encourage every waste management company that has not yet put an EMS in place to consider doing so because implementing an EMS can greatly contribute to the effective operation of a waste management facility.
Jessica Allan is a consultant and Samantha Smith is a principal consultant at WYG in its waste planning and permitting team
MDJ Light Brothers
MDJ Light Brothers is a well-known waste management company in Lewes, East Sussex, specialising in the recycling of scrap metal and waste electronic and electrical equipment. It operates several facilities and is therefore required to have an EMS place at each site.
WYG recently assisted the company in updating an EMS for one of its facilities. The aim was to ensure that the EMS met the current Environment Agency (EA) requirements in time for an audit at this facility. WYG spoke to Julia Watts, operations manager at MDJ Light Brothers, about its experience of EMS.
What motivated you to implement an EMS at your site?
Initially, we produced the EMS because the EA requested that we do so. It is important to us to be operating in compliance with the requirements of the EA.
Has the EMS provided any benefits to your operations?
As well as ensuring we are compliant with the EA’s requirements, the EMS allows us to document and record all of the measures we have in place to minimise our impact on the environment. As a responsible company, we welcome the opportunity to measure and improve our environmental performance wherever practicable.
The EMS also means that when our local EA officer conducts a site audit, it is easier to demonstrate that we do take all reasonable efforts to prevent environmental impacts. Our EMS contains step-by-step procedures for our activities, which help us to explain the processes we undertake to the EA officer and to new staff members.
Has your EMS enabled you to secure any contracts or work that you would not otherwise have won?
It is difficult to say for certain whether having an EMS has secured us contracts. But in addition to the development of a more positive relationship with the EA, the EMS has been well received by external auditors from producer compliance schemes and other major clients.