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Implementing An Environmental Management System - A Good Practice Guide

Preface

This guide is intended for organisations who have decided to establish an Environmental Management System (EMS). It is written for housing associations but will be equally useful for local authorities.

Copies of our Policy, Register of Significant Effects, Management System, Procedures, Statement and Performance, are available on our website at www.vale-housing.co.uk

1. Summary

Why introduce an Environmental Management System

  • It can help you improve your environmental performance and create real social and economic benefits for tenants.
  • It's value lies in the impetus and organisational framework they create. With these your environmental strategies are more likely to succeed.

Choosing your EMS

  • There are two formal EMS in the UK, ISO14001 and EMAS (the Eco-Management and Audit Scheme).
  • Neither EMS states specific environmental performance criteria, but they do require continuous environmental improvement and compliance with legislation.

What Steps are Involved

  • The Scoping Review – helps you to identify how you affect the environment and decide which of these effects are significant.
  • The Detailed Review – gathers information about each significant environmental effect and whether they are being monitored.
  • The Environmental Programme - sets out the plans for how you are going to improve your environmental performance.
  • The Programme states your environmental objectives and how, when and with what resources you are going to achieve them.
  • The Management System – integrates your EMS into your existing management system through a set of written procedures.
  • The Environmental Policy – is a public document outlining your environmental impacts and objectives and your performance.
  • The Audit – ensures that the EMS has been properly implemented and maintained and that it conforms to the requirements of the Standard.
  • The Public Statement – is a summary of your audit report, which gives details of your environmental performance. This is only required under EMAS, not ISO14001, but it is a good opportunity to advertise achievements and to raise awareness about environmental issues.
  • External Certification / Verification – is the final stage when an external body carries out checks on your system before deciding whether to award ISO14001 or EMAS.

2. Introduction

So you have decided to establish an Environmental Management System (EMS). The aim of this guide is to help you through the practicalities. It suggests the decisions and actions which you need to take at each stage. The guide is based on the process we followed in a pilot project funded by the Housing Corporation South East.

We implemented an EMS through a combination of: -

 

  • Inter-active workshops with key members of staff
  • Research and report preparation between workshops
  • Co-ordination by a ‘Green Team’ comprising of 4-6 senior members of staff
  • Day to day co-ordination by an Environmental Co-ordinator.
     

Remember, although setting-up an EMS can be time consuming, once you have got the system in place maintaining it is much easier. The benefits outweigh the time and effort.

3. Why Bother?

The Government and Housing Corporation are strongly encouraging associations to develop strategies to tackle social, economic and environmental issues, as well as traditional housing issues. The Housing Corporation Corporate Strategy 2001-2004 states that “sustainability will be a requirement for associations when they bid for investment funds”.

They have also set the following targets for 2003/2004:

  • At least 60% of all new-build schemes approved between 2001/02 and 2003/04 to be provided on previously developed (brown-field) land.
  • 50% of new-build schemes approved in 2003/04 to achieve a ‘good’ rating at EcoHomes or equivalent. (EcoHomes is run by the Building Research Establishment ).
  • 40% of all associations to have a formal Sustainable Development Strategy and Action Plan by April 2003 and 70% by April 2004. 
  • 40% of all associations to have an Affordable Warmth Strategy and Action Plan by April 2003 and 70% by April 2004.
  • 60% of all Assisted Development Plan (ADP) funded developments to meet Egan principals by 2002/03 and 100% by 2003/04.
     

Housing associations are ideally placed to promote sustainability due to their role within local communities. They can achieve real social and economic benefits as a result of making environmental improvements. This guide explains how to set up an environmental management system in order to provide the impetus and organisational framework to ensure such strategies succeed.

What can you hope to Achieve?
 

  • Real benefits for tenants - The major concern of most tenants is living costs. Housing associations should not restrict themselves to trying to keep rents down, but should consider the issues of affordable water, heating and transport.
    (Example: Hastoe HA have estimated that simple water saving measures, such as spray taps and low flush WC, can cut a households water consumption by 30%. In metered properties this could result in saving of between £55 - £130 pa, depending on the water authority area).
     We have saved our tenants £60 per household as a result of our energy efficiency work.
  • Better partnerships / co-operation - Housing associations share common goals with other organisations, such as Local Agenda 21 teams. Developing a better dialogue and co-operation with these groups can produce real benefits. (Example: The tenants of the Vale HA received £28,000 of energy efficient light bulbs through a District Council / Southern Electric sponsored project).
  • Improved management and efficiency - Environmental work can help you re-evaluate your organisation’s policies and procedures. Specialisation or departmentalisation often prevents people from standing back and looking at the bigger picture.
    (Example: The Vale HA hopes to substantially reduce the £100 it spends a day on skips with a recycling initiative).
  • Improved public relations - You may already have projects which help local sustainability. Having a Public Environmental Policy and Statement will make your tenants and the general public more aware of the positive work you do and can increase support for your initiatives.
     

4. Setting Up Costs

The table below indicates the amount of time and money we spent implementing our environmental management system over 2 years. This is based on an organisation with 150 staff and 5,000 properties. Now the system is up and running it will require far less resources. Clearly if you have this guide you may not need to spend money on consultants.

  Total amount of time / money spent (in 2 years)   
 Environmental Co-ordinator   650 hours
 Environmental Committee  160 hours 
 Staff time attending workshops / seminars   270 hours
 Staff time preparing reports and procedures  200 hours
 Staff time implementing system   270 hours 
 Staff training   150 hours 
 Travel   £1,200 
 Consultancy fees   £8,000 
 Purchase of publications/good practice guides  £200 

5. Choosing Your Environmental Management System

The Available Environmental Management Systems

There are two formal EMS operating in the UK: -

  • International standard ISO14001.
  • European Eco-Management and Audit Scheme (EMAS).

Since April 2001, EMAS has been open to all organisations. Prior to this it was only open to industry and local government. ISO14001 has always been open to all organisations.

We started by applying EMAS, which is already adapted to local government. As a result all the terminology in this guide and on our web site is based on EMAS. We were certified under ISO14001 because in 1999 it was the only formal EMS open to housing associations.

In order to help provide signposts to the standards, there are places in this guide where reference numbers are given in brackets.

The Differences Between Them

Although ISO14001 and EMAS are presented in different formats, they are essentially very similar. (The box on page 6 compares the structure of the two schemes). The main differences are:

  • ISO14001 does not require a Public Statement. However it is worthwhile preparing a Public Statement to report on your environmental performance even if you are registering under ISO14001.
  • ISO14001 theoretically requires more frequent internal audits and external checks. According to the EMAS Regulation audits and verification are only required every 3 years. However, in practice you must have annual ‘surveillance’ after you have been verified/certified for both systems. It is anticipated that the EMAS Regulation will be amended to conform with ISO14001 on this point.
  • The requirements for contractors to conform to similar environmental standards as your own are stricter under EMAS than for ISO14001. ISO14001 requires you to “communicate relevant procedures and requirements to suppliers and contractors” (ISO14001 - 4.4.6c). EMAS requires you “to ensure that contractors working on (your) behalf apply environmental standards equivalent to (your) own” (EMAS - Annex I, D11)
  • As a written document ISO14001 is clearer, shorter and therefore easier to follow and understand. This is partly because ISO14001 was always intended as a standard, where as EMAS is a piece of legislation. It originally started life as a European directive.

6. The Role of Your Board and Your Tenants

Both your Board and tenants will have important parts to play in the EMS.

The Role of Your Board

ISO14001 and EMAS both insist that key components of your EMS must be approved by ‘top management’ (ISO14001 - 4.2, 4.4.1, 4.6). For housing associations, ‘top management’ means your Board. As a minimum, when you are establishing the system, the Board should approve the Environmental Policy, Register of Significant Effects and the first Environmental Programme.

Once the system is established the Board should review and approve: -

• The annual Environmental Programme and Public Statement.
• Monitoring reports on the previous Environmental Programme.
• Monitoring reports on trends in your significant effects.
• The reports of the Auditors and Certifiers.

The Detailed Review & Management System should be approved by the Green Team. They do not need Board approval because they include a lot of detail and do not effect any crucial decisions on the priorities or expenditure of the EMS.

The Role of Your Tenants

Tenants should also have an opportunity to be involved. There are numerous ways: -

• By including articles on the EMS in tenant newsletters and inviting comments.
• Circulating (summary) copies of the Environmental Policy and Statement to all tenants.
• Involving tenant representatives in the Environmental Review and Programme preparation (see page 9 ‘Organising Workshops’).
• As part of your Environmental Programme, raising tenants’ awareness of how they can improve their environmental impact.

7. First Steps

Co-ordinator (ISO14001 - 4.4.1/ EMAS – Annex I - B2)

You will need one person to co-ordinate the setting-up and maintenance of the EMS. Their task will be to organise workshops and make sure that documentation is produced by staff in between workshops. This person does not need to be a specialist in environmental issues. It is more important that they understand your structure and operations, and that they have good networking and project management skills.

‘Green Team’

There should also be a small EMS co-ordinating team comprising of a senior representative from each of your departments/directorates. Ideally the EMS team should be chaired by your Chief Executive, and certainly by a very senior member of your staff. The team should meet regularly (monthly) and:

  • Give authority and guidance to the work of the EMS co-ordinator.
  • Ensure that staff are participating in the process by attending workshops and taking follow-up action as necessary.
  • Review drafts of the Register of Significant Effects, the Environmental Programme and the Public Statement, before they are taken to your Board for approval.
  • Help to draft corporate documents such as the Environmental Policy, Corporate Management System procedures and the Public Statement.
  • Approve the Detailed Review and Effects Management System.

Timetable for Implementing an EMS

 

Timetable for implementing an EMS in diagramatic form

 

The first task of the EMS co-ordinator and team should be to agree a timetable for the EMS implementation. Setting a strict (but realistic) timetable for implementation helps to ensure that the process keeps moving and that staff don’t get bogged down. We found that it took about 12 months to get the system fully in place and to prepare the first Public Statement.

Allow about 2 months each to complete the Scoping Review and Environmental Programme, 3 months each to complete the Detailed Review and Management System, and another 2 months to draft both the Policy and Public Statement. We recommend that dates be agreed in advance for all the workshops and the deadlines for information to be returned to the co-ordinator.

Key Publications

  • You need to get hold of key publications. These are:
    The ISO14001 standard - “Implementation of ISO14001 : 1996; Ref. BS EN ISO 14001; From BSI, 389 Chiswick High Road, London, W4 4AL Tel: (020) 8996 7000

or

  • The EMAS regulation – “EEC Council Regulation No. 1836/93 Community Eco-Management and Audit Scheme; Official Journal of the European Communities No. L186 10th July, 1993.
  • The Local Government Management Board (LGMB) EMAS Help Desk has also published numerous guidance notes on EMAS. Many of these will be equally useful for those putting ISO14001 into place. Contact the LGMB on (020) 7296 6600.
  • The Institute of Environmental Management & Assessment is the Competent Body responsible for administering the EMAS scheme in the UK. It maintains a register of all organisations which have EMAS in this country. They can be contacted at St Nicholas House, 70 Newport, Lincoln, LN1 3DP, Tel: 01522 540069, Fax: 01522 540090 or at www.emas.org.uk.

Organising Workshops

Next decide which staff should attend the workshops. There should be at least one representative from each of your activities that is likely to have distinct environmental impacts. This probably means that you will need at least one representative from each section or group. Representatives should be sufficiently senior that they understand most of the operations in their section and have the authority to involve colleagues in discussions about the EMS and their section’s role.

Aim to have the same representatives attending all four workshops. (All except the workshop on Corporate Management Systems.) Inconsistent attendance can waste a lot of time because new arrivals must be briefed on what has happened before at the beginning of each workshop.

Decide whether you want to invite Board members and / or tenant representatives to attend the workshop. We invited our Tenant Board Members to attend all of our workshops. They contributed a very valuable tenant perspective on our work.

Preparing / Informing Staff

Hold a briefing meeting or meetings for your Board and senior managers. Explain the structure of an EMS, the timetable, and the staff commitment required. Make sure that senior managers are prepared to release staff to attend workshops and to prepare documents in between workshops.

Send a circular to all staff, Board members and tenant representatives who have been selected to attend the workshops. The circular should explain the timetable and emphasise that participants will be expected to draft parts of the EMS for their section in between workshops.

Once you have completed all of the above you are ready to begin! The next sections briefly summarise what you should cover for each stage of the EMS.

8. The Scoping Review

Identifying Environmental Effects (ISO14001 - 4.3.1 / EMAS – Section 3b, Annex I - B3, D2, D3)

The aim of the Scoping Review is to determine your significant environmental effects (referred to as aspects in ISO14001), and to prepare a Register of Significant Effects. Every organisation will have a variety of impacts on the environment, but many of these will be very small. An EMS requires an organisation to focus on and manage its significant environmental effects. Smaller effects do not have to be formally managed within the EMS.

Both ISO14001 and EMAS indicate what environmental impacts must be considered. These can be summarised as: -

  1. Consumption of energy
  2. Consumption of water
  3. Use of environmentally significant materials/resources
  4. Use of transport
  5. Production of solid waste, liquid effluents, gas emissions and noise
  6. The natural environment: landscape, habitats and green space
  7. The built environment/ heritage

Environmental Management Systems distinguish between environmental effects, which an organisation directly controls, and those which it can only influence. The terms ‘direct’ (control) and ‘service’ or ‘indirect’ (influence) effects are also used.

Control effects are your effects on the environment which are directly under your control. They are the direct result of activities by your own staff, and your contractors. Examples of control effects are - purchase of hardwoods, emissions from your vehicles and energy consumption in your offices.

Influence effects are those effects which arise from the services you provide. They are not under your direct control, but reflect your potential to influence the impact on the environment of other people or organisation. Probably the three groups that you have the most potential to influence are your tenants, staff and contractors. Examples of influence effects are energy and water consumption by tenants, waste disposal by tenants, and fuel consumption by staff travelling to work.

Do not worry if it is sometimes unclear whether an environmental effect should be classified as control or influence. The distinction is only a convenience to help organisations to systematically identify their significant effects.

Determining Their Significance

There is no simple rule for deciding which effects are significant, but the following should be considered:

• The size of the environmental impact - is it large compared with the impact of other activities by the Association?
• The importance of the impact - does it contribute to an issue of global or national environmental concern, or to a severe local environmental pressure?
• The size of the environmental impact - is it large in relation to the activity being considered?
• Are you required to manage the impact by legislation or statutory regulations?

It is for you to judge what is ‘significant’. However, if you decide to register under a formal environmental management scheme, the external certifiers must establish that you had a sound basis for determining what environmental effects were significant. You need evidence that you have, in a structured way, applied either the above criteria, or your own criteria for determining significance. The evidence could be workshop notes and explanations in the Register of Significant Effects.

Do not be tempted into registering a large number of significant effects. The Environmental Management System is likely to be more effective if you really focus on and manage well a relatively small number of your most important environmental effects. You can at a later date extend the system to cover smaller impacts.

Scoping Review Workshop

For the workshop we recommend that participants should brainstorm any environmental effects which they think their section might have on the environment. They should mark these on a flipchart, distinguishing between control (C) and influence (I) effects.

In all cases consider normal and abnormal situations and potential emergency conditions. This requirement, which is common to both ISO14001 and EMAS, is really aimed at industrial processes, which could have devastating environmental impacts if things go wrong. For most associations it is important to consider the impact of accidents and abnormal conditions on areas such as development sites.

Once each section has brainstormed all of their potential environmental effects, they should ring those which they consider to be significant. The end result should look something like this: -

 

Scoping review wokshop sheet diagram

 

The choice of significant effects should be discussed in the workshop, and then participants draft their part of the Register of Significant Effects following the workshop. It is perfectly acceptable for some sections to have no significant effects. However anything legislative or statutory is significant and should be listed.

Register of Significant Effects

The co-ordinator should put the separate sections into a single Register for review by the EMS Co-ordinating team and approval by the Board. We suggest that the Register takes the format illustrated below. Each significant effect is given a unique number, eg. HM2 for the second significant effect arising from Housing Maintenance. The same numbering system should be followed in the Detailed Review, Programme and Management System. Once the Register is approved, all remaining parts of the EMS should only consider significant effects.

Example of a Register of Significant Effects

Association Activity  Significant Effects Reason why Significant
The Activity  One of the 7 issues listed on page 11  Explanation of how the activity impacts on the issue 
Example:-     
Control Effects      
Housing Maintenance HM1. Consumption of environmentally significant products and materials Use of PVC, hardwoods, items produced with HCFCs 
Influence Effects      
Housing Maintenance  HM2. Tenants' Energy Consumption Servicing & replacement of central heating systems can influence amount of energy used by ... number of tenants 
  HM3. Tenants' Water Consumption Loss of water from leaking pipes & design of kitchen & bathroom fittings 
Modernisation of properties MP1. Tenants' Energy Consumption  Standards of thermal insulation achieved during refurbishment 

9. The Detailed Review

The purpose of the Detailed Review is to investigate in more detail what is known about each significant effect, whether it is being monitored, and what you have already done to improve the environmental impact of the effect. The information collected in the Detailed Review will form the basis for your Environmental Programme and Management System as well as your first Public Statement.

Detailed Reviews should be kept short. If they are available statistics on trends in the effect should be included. You are more likely to have quantified information for control effects than for influence effects.

For each significant effect the Detailed Review should record:

• What measurement / monitoring of the effect are you currently carrying out.
• What are the trends in the environmental effect (if known).
• What action have you already taken to control and improve the environmental impact of the significant effect - including measurement where possible.
• Any legislation, regulations or association policies which have an impact on the effect.

It may be easiest to set this out in a table for each significant effect.

Do not spend a huge amount of time trying to get hold of information which is not available. Simply record in the Review that the information is not available. Usually in the first year a major component of your Environmental Programme will be to establish systems for collecting data on the trends in the significant effects where this is not already available.

Detailed Review Workshop

The Detailed Review workshop is the best time to introduce staff to the idea of Best Practice. Although an EMS does not impose externally set standards on an organisation, it does require participants to work towards Best Practice (see Introduction to ISO14001). Sustainable Homes (www.sustainablehomes.co.uk / Tel:(020) 89434433) have a list of good practise examples from other housing associations. A list of sources of information on Best Environmental Practice relevant to a housing association is also included in Appendix I. We suggest that an updated version of the list is handed out at the workshop, and that participants are encouraged to investigate the Best Practice which is relevant to their significant effects prior to preparing their Environmental Programmes.

10. The Environmental Programme (IS014001 - 4.3.3, 4.3.4 / EMAS – Section 3c, 3e, Annex I - A4, A5)

The purpose of the Environmental Programme is to improve your environmental performance. It must focus on your significant environmental effects, but need only tackle some of them each year. You may already be dealing effectively with some of your significant effects. If this is the case you will only need to control and monitor them, not improve them. The Programme should consist of:

Objectives - A set of environmental objectives, ie. the overall goals to improve the environmental impact of the significant effect.
Actions - A set of environmental improvement activities and measures, ie. actions to work towards the objectives.

The improvement activities may include actions to:

  • Improve environmental performance - aiming for ‘Best Practice’. 
  •  Establish or improve systems to monitor trends in the significant effect. 
  •  Investigate the current situation or research good practice, in advance of deciding on 
  •  improvement activities. 
  •  Improve the management / control of the impact, ie. operational control.

Initially the improvement activities often focus on monitoring trends and researching good practice. Improving performance usually comes later when more information on the current situation and good practice has been collected.

For each action / improvement measure the Programme should specify:

Indicators - by which the performance of the activity will be evaluated.
Targets - the specific achievement targets for each indicator.
Timetable - the timetable and deadlines by which the activity will be undertaken.
Responsibility - the section(s) or individual(s) responsible for implementing the activity.
Resources - the resources (staff time and budget) made available for the activity.

Environmental Programme Workshop

We recommend that after your workshop you summarise your Programme in a matrix as illustrated below. It should follow the numbering used in the Register of Significant Effects.

The Programme should normally cover a year. As far as possible it should be integrated within your existing planning systems, and integrated into your budgeting cycle. It must be approved by your Board. Example of an Environmental Programme

ObjectiveActionTargetIndicatorResponsibilityResources
HM1.1 To reduce the use of hardwood from unsustainable sources 1. Investigate sources of sustainable hardwoods & comparative costs. Report to Board by Sept 1998  Board receives report  H. Buckstop  1 week staff time
HM1.2 To stop using products produced with or containing HCFCs  1. Investigate which products used by HM are produced with or containing HCFCs Report to Board by June 1998  Board receives report A. Dogsbody 1 week staff time

11. The Management System – Writing Procedures (ISO14001 - 4.4.6, 4.4.7 / EMAS – Annex I - B4, C10, D5, D8, D11)

The Management System is that part of an EMS which integrates good environmental practice into your existing management system. Environmental management should no longer be something which runs in parallel to your other activities. Like financial management or service quality, it should become integral to your day to day activities and decision making. Unlike the Environmental Programme, which should be updated regularly, once the Management System is approved it does not have to be changed, although over time you will probably want to revise or improve parts of the System.

There are two parts to the EMAS Management System:

  • Corporate Co-ordination - procedures to keep the EMS running.
  • Operational Control System - procedures to manage and monitor significant effects.

Each level comprises a set of Procedures.

Corporate Co-ordination and Operational Control Workshops

The workshop for Corporate Co-ordination should involve senior managers, usually members of the EMS Co-ordinating Team, plus other relevant managers. Usually the basics of the corporate co-ordination procedures can be drafted in the workshop. Operational Control / Effects Procedures workshops should be attended by the same staff who attended earlier workshops.

Unless you have already introduced Quality Management Systems, procedures will seem unfamiliar to most staff, so allow a fair amount of time for staff to get to grips with procedures and to prepare their drafts. One pit-fall to avoid is the creation of additional paper work. It is not necessary to create, say, a new form which demonstrates that the Environmental Programme has been approved by the Board. The Board minutes are quite enough. Always try to avoid the creation of new forms or records, and integrate procedures into your existing systems.

You must have all your Corporate Co-ordination Procedures documented and operating before you can go to certification, but this is not the case for Operational Control Procedures. It is recognised that it will take any organisation some time to get its significant effects management system fully operational. It is best to prepare a limited number of procedures initially. Otherwise you may never get the Management System in place. It will be much easier to expand the system over time.

Initially you will be expected to document your existing procedures for managing your environmental impacts, ie. any systems referred to in the Detailed Review, plus have a timetable for developing new procedures. (Often new procedures will arise from research, such as described in the example Programme above.) You should be able to show the certifier a timetable for preparing those procedures which are not already in place. Action and responsibility for preparing the procedures should be included in the relevant Environmental Programme.

Responsibility for Writing Procedures

Make sure that you involve the staff who will have to implement the procedures in drafting them. This will ensure that the procedures are realistic and they are likely to encounter much less resistance. Staff should also be made aware that procedures are not ‘set in stone’, and that if they have a suggestion for a better way of doing things, then they should raise this with managers, and the procedure can be revised.

Document Control (IS014001 - 4.4.5 / EMAS – Annex I - B5)

Certifiers tend to be very strict about the document control of procedures. Each procedure must have a unique number, a version number, the date of issue, and show the number of pages in the procedure. For example, a procedure number might be numbered
 

HM1.1 / V2 / Aug99 / 1/2
 

ie Housing Maintenance Procedure/Version 2/issued Aug 1999/page 1 of a 2 page procedure

The reason for this strict documentation is to ensure that staff are not working to out of date procedures. Someone in your organisation (usually either the EMS co-ordinator or an administrator) should have responsibility for withdrawing all old versions and issuing new versions to relevant staff whenever a procedure is revised.

12. The Policy, Audit and Statement

The Environmental Policy (ISO14001 - 4.2 / EMAS – Section 3a, Annex I – A, D)

Although preparing the Environmental Policy is formally the first stage of an EMS, we recommend that it is prepared after the Programme is completed. The information contained in the Register of Significant Effects and the Programme naturally forms the basis for the Policy. However, the Policy should be kept short. It probably only needs to be two sides of A4. It should summarise your main environmental impacts (the Register) and the long-term objectives of the Environmental Programme. The Policy must also contain some key commitments in order to comply with ISO14001. These include commitments to: -

• Comply with relevant environmental legislation and regulations.
• Continual improvement and prevention of pollution.

In addition EMAS requires that you:

• Ensure that contractors apply environmental standards equivalent to your own.
• Foster a sense of responsibility towards the environment amongst employees and provide staff with adequate information and training to manage the Association's environmental impact.

These phrases can of course be reworded to suit the style of the document that you are preparing. The Environmental Policy must be approved by the Board and all staff must be made aware of its contents. You might also choose to circulate a copy or summary to tenants.

The Environmental Audit (ISO14001 - 4.5.4 / EMAS – Section 4, Annex I - B6, C, A2)

An Audit is a check by internal or external staff that the EMS is operating correctly. ISO14001 doesn’t specify the frequency of Audits, whilst EMAS specifies every 3 years. However the trend is now to carry out yearly Audits for both schemes. Most organisations choose to use internal staff for the Audit, but these staff must be independent of the section that they are auditing, and properly trained in EMS auditing. (The Local Government Management Board run audit courses open to local authorities and stock transfer associations). Audits are carried out by a combination of interviewing relevant staff, looking at written records, and where appropriate, observing operations. Try to use the Audit as an opportunity to recognise achievements and to make constructive suggestions on how things might be improved. It should not be seen
by staff as solely an exercise to highlight failure.

The Audit should consider: § Does the Environment Programme and Management System meet the commitments made in the Environmental Policy? § Are the Environment Programme and Management System managing all the significant environmental effects? (Initially you may not be managing all of your significant effects, but you should have plans to do so.) § Are all statistics or results reported as part of the monitoring programme accurate and based on auditable records? § Are procedures being followed? § Is the organisation complying with all relevant environmental legislation and regulations? The requirements for the Audit are set out in Annex A5.4 of ISO14001.

The first Audit will need to be fairly detailed, and it will almost certainly identify many failings in the new system. The first Audit is usually the event which gets most of the systems operating. In future years the Audit should be quicker, and focus most effort on areas of the EMS where consistent failures have been identified in the past. The more rigorous the Audit, the less work for (and therefore the cheaper) the Certification process. Certifiers will normally only sample aspects of the Audit to check for its accuracy, not repeat the whole Audit process.

The Public Statement (ISO14001 - na / EMAS – Section 3f, 3g, Section 5)

A Public Statement is only a requirement of EMAS, not ISO14001. However we would recommend anyone implementing an EMS to produce one. Formally, the Public Statement is a summary of your Audit report, which reports on your environmental performance for the previous year. Of course the Statement is also an opportunity for you to advertise your achievements and to raise awareness about environmental issues more generally. It does not need to be long, probably only about 10 pages.

If you are going for EMAS the Verifier will want to see the Public Statement in draft format. They may require amendments to be made before it is printed or publicised. Once these have been made copies should go to local interested organisations. You may also choose to circulate summaries to tenants and to staff. The notes on the website explain exactly what must be included in the Public Statement. It must be approved by your Board.

13. Documentation (ISO14001 - 4.4.4 / EMAS – Annex I, B5)

The Environmental Management Manual

The Co-ordinator should maintain an Environmental Management Manual available for inspection by the Certifiers and any staff on request. This need be no more that a ring binder containing the:

  • Environmental Policy.
  • Register of Significant Effects. 
  • Detailed Review + any Review of new activities undertaken since the initial Review. 
  • Current Environmental Programme (back copies are probably also worth keeping). 
  • Corporate Co-ordination Procedures. 
  • A list of Effects Procedures, the current version number, and which staff should have copies of the procedure.

14. Training and Awareness - Briefing for Staff and Board Members (IS014001 - 4.4.2 / EMAS – Annex I, B2, D1)

Once you have completed the Management System it is time to explain to both your staff and your Board Members the structure of your EMS and their particular role within the process. Staff and Board Members should have (access to) copies of procedures which are relevant to them and should understand why these procedures are important for environmental performance. Staff might be issued with paper copies of procedures, or where appropriate the procedures could be converted into wall posters. In most cases this initial briefing should only take one to two hours. In future all new staff and Board members should receive a similar briefing.

15. Pitfalls to avoid

There are a few common pitfalls to avoid when establishing an EMS:

The EMS Co-ordinator tries to do it all

It is important that all relevant staff get involved in establishing the EMS. The aim of an EMS is to integrate environmental management into the day to day practice of all staff, not just one member of staff. The concept that staff are responsible for their own environmental performance should be instilled from the start. The role of the EMS Co-ordinator is to co-ordinate the EMS.

Losing Sight of Significance

Organisations often lose sight of the fact that the Detailed Review, Environmental Programme and Management System are only concerned with significant effects. It is important to avoid expanding the system to cover relatively minor effects. The consequence is likely to be that:

(i) you will end up with an EMS which is so large that it is unmanageable;
(ii) you may focus a lot of effort on minor impacts while larger impacts are being ignored.

Too Many Significant Effects For the same reason, it is better to opt for a small number of really important environmental impacts, rather than to register a large number of effects as significant.

Getting Buried in the Detailed Review

You could potentially spend a huge amount of time collecting information for the Detailed Review. Spending too long on the Detailed Review loses momentum, and many organisations have got stuck at this stage. Just include readily available information in the Detailed Review. If it looks as though there will be a need for significant further research then include this as an action in the Environmental Programme.

16. Choosing and Managing A Certifier

Certification (known as Verification for EMAS) can only be undertaken by accredited Certifiers. The United Kingdom Accreditation Service (UKAS) accredit EMS Certifiers and Verifiers, and can send you a list of accredited organisations. They can be contacted at:

UKAS 21- 41 High Street Feltham Middlesex TW13 4UN Tel: (020) 8917 8400

There are far more organisations which are accredited as Certifiers for ISO14001 than as Verifiers for EMAS. If you have decided to register under both schemes, then make sure that you choose an organisation which is accredited for both.

Most accredited organisations are used to working with industry and may be unfamiliar with public/voluntary sector organisations. It may be preferable to opt for an organisation which has already certified a local authority or housing association. On the other hand, you can sometimes negotiate a ‘low cost’ certification from organisations which want to build up their public sector experience. We suggest that you ask several organisations to tender, and choose one on the basis of cost and their understanding of housing associations.

Remember that you will always know your organisation better than the Certifier will. Secondly, most Certifiers are far more familiar with industry than with housing associations. So, do not take everything they say as ‘gospel’. If you disagree with their point of view then explain why. Commonly industry Certifiers tend to over emphasise relatively minor control effects and lose sight of the fact that many of the really important effects of housing associations and local authorities are their influence effects.

The initial Certification will be fairly detailed, but after that, as with the Audit, Certifiers are likely to focus on areas of known weakness in the EMS.

17. Conclusion

Are environmental improvements by housing associations worthwhile? Yes, environmental legislation is getting tighter and public concern about the environment is growing. Above all tenants’ standard of living can be improved by well targeted environmental initiatives.

Is it necessary to put a formal EMS into place? In our view the answer is yes. The fact that at the end of the process an external body will actually come into your organisation to validate your system helps to concentrate minds! It also provides impetus.

How long will it take? This will depend very much the size and nature of your organisation. However, to properly involve all the relevant members of staff in workshops and follow up work is time consuming. We would suggest allowing at least one year.

Which standard should I use? Both EMAS and ISO14001 are now available to housing associations (from April 2001). However ISO14001 is far easier to follow, so use it as a guide during the process, which ever accreditation you eventually want to seek. Just remember that if you want to be awarded EMAS you must have a public statement.

Joan Bennett
CAG Consultants

Communications and Research Team
The Vale Housing Association
The Old Maltings
Vineyard
Abingdon
Oxon
OX14 3UG
Tel: (01235) 536001
Fax: (01235) 536116

E-mail: info@vale-housing.co.uk
Website: www.vale-housing.co.uk
 

Supported by an Innovation & Good Practice Grant from the Housing Corporation South East
 

Appendix I – Sources of Good Practice Information

Purchasing

General

1. Environmental Data Services (ENDS), Monthly journal with regular “Marketplace” section. Finsbury Business Centre, 40 Bowling Green Lane, London, EC1R One. (020) 72784745 (£145 pa first year / £235 pa subsequent years)

Office

2. Environmental Produce Information Centre. Advice on paper products and office equipment (copiers, printers, faxes, PCs). Tel: (01734) 665665

Other including via Contracts

3. The Peat Alternatives Manual: A guide for the Professional Horticulturist and Landscaper. Friends of the Earth, 26-28 Underwood Street, London N1 7JQ. £25.95

4. World Wide Fund for Nature (Forest Unit). Information on labelling of timber – the Forest Stewardship Scheme. WWF UK, Panda House, Weyside Park, Godalming, Surrey, GU7 1XR. Forestry Stewardship Council Information Hotline. Tel: (01686) 413916

5. Greener Building: Products and Services Directory. Association of Environment Conscious Building. Phone Sally Hall (01559) 370908

6. Aggregates Advisory Service (DoE sponsored), providing advice on efficient use of aggregates, waste minimisation and the use of secondary materials. Call Richard Smith, Symonds Travers Morgan, (01342) 327161.

Waste

Office

7. Working Away at Waste at Work - £9.95. Advice on waste reduction and recycling. Waste Watch (020) 7248 0242.

8. Paper, Paper! An Office Guide to Recycled Paper and Paper Recycling. Waste watch contact number as above.

9. Managing and Minimising Construction Waste – A Practical Guide, Thomas Telford Services Ltd, Thomas Telford House, 1 Heron Quay, London E14 4JD.

Other including via Contracts

10. Waste Minimisation and Recycling in Construction, Site Handbook, Designers’ Handbook and Boardroom Handbook - £44.00. Published by the Construction Industry Research and information Association (CIRIA). 1996. (020) 77993243

11. Recycling Waste from the Construction Site. Keith Snook et al. Chartered Institute of Building. 1996 - £24.00. Tel: Mandy Godfrey (01344) 630700.

12. The Warmer Bulletin Very useful journal on waste issues available from the World Resources Foundation, Bridge House, High Street, Tonbridge, Kent, TN9 1DP.

13. Wasteline (0171) 2459718. Free telephone advice line run by Waste Watch. Can advise on local companies which will collect waste for reuse / recycling.

Energy and Water

14. Energy Efficient Homes: A Guide for Housing Professionals, Association for the Conservation of Energy and the Chartered Institute of Housing.

15. Energy Efficiency in New Housing: Low Energy Design for Housing Associations, National Federation of Housing Associations and BRECSU, 1993.

16. Building Research Energy Conservation Support Unit (BRECSU) publish a wide range of information on energy efficiency in buildings including good practice case studies. Enquiries Bureau, BRECSU, Building Research Establishment, Garston, Watford, WD2 7JR.

17. The Journal of Energy and Water Management, Eclipse Group Ltd, 18-20 Higbury Place, London, N% 1QP. (020) 7354 5858 £105.00pa. (Information on new developments, good practice examples, policy and legislation, and technical matters.)

18. The Energy Efficiency Office. Part of the Department of the Environment. Publish a wide variety of guides. Contact them through your Regional Government Office.

19. Environmental Action Guide Advisory Notes 4: Water Use in Accommodation and Estates Work, Department of the Environment, 1993. (020) 72760900 £4.00 ISBN 00117528501 * See next page

20. Environmental Action Guide Advisory Notes 6 : Lighting in Buildings: Environmental Aspects, Department of the Environment, 1993. £2.90 ISBN 0117528706 * See next page

Transport

21. The Fuel Management Guide. The Freight Transport Association, Hermes House, St. John’s Road, Tunbridge Wells, Kent TN4 9UZ (01892) 526171

22. Environmental Transport Association. Advice on environmental impact of different models of vehicles (01932) 828882

23. Alternative Road Transport Association: A Preliminary Life-cycle Study for the UK. HMSO, 1996 (020) 78730011 Vol I ISBN 00115154108 £11.95 Vol II ISBN 00115154116 £29.95

24. Fuel Consumption in Freight Haulage Fleets 1996 ETSU, Harwell, Oxon, OX11 0RA (01235) 436747

25. Efficient Corporate Transport: A Review. 1996- £40.00 Centre for Exploitation of Science and Technology, 5 Burners Road, Islington, NW2 0PW, (020) 7354994

Other

26. Housing and the Environment: A New Agenda, Chartered Institute of Housing, Octavia House, Westwood Way, Coventry, CV4 8JP (01203)694433, £14.95 plus £1.50 p&p.

27. Sustainable Settlements: A Guide for Planners, Designers and Developers by Hugh Balton. LGMB and University of the West of England, 1995 (0117) 9656261

28. The Pesticides Trust give advice and publish guidance on ground maintenance practices to minimise pesticide use (0171) 2748895. Two publications at £2.50 each.

29. Environmental Action Guide Advisory Notes 5: Grounds Management, Department of the Environment, 1993. £2.90 ISBN 00117528714*

30. Cohen M.A.et al. Environmental and Financial Performance: Are they related? April 1995. Investor Responsibility Research Centre, Washington DC, USA.

31. Wildlife on Site – A Guide for Developers and Planners. Babtie Group 1996. Send cheque of £5.00 to Mrs E Turner, Babtie Group, Shinfield Park, Reading, RG2 9XG (01734) 758844.

* The Stationery Office, PO Box 276, London, SW8 5DT