HANDBOOKprinting.emastools.eu/Portals/0/HANDBOOK.pdf · 2017. 3. 11. · HANDBOOK FOR SINGLE ... 3.3.1 Volatile Organic Compounds (VOCs).....39 3.3.2 Greenhouse gases ... 7.3.1 Solvents.....90

CIP Eco‐innovation Call 2009 “Promoting EMAS III in Clusters of Printing SMEs”

ECO/09/256100 PROSPEC

pg 1 of 101

HANDBOOK FOR SINGLE POINT OF

REFERENCE AND CONSULTANCY REGARDING EMAS III

CERTIFICATION AND AUDITING IN PRINTING INDUSTRY


HANDBOOK

FOR SINGLE POINT OF REFERENCE & CONSULTANCY REGARDING EMAS III CERTIFICATION AND AUDITING

CIP ‐ EIP ‐ Eco‐innovation ‐ 2009 Action “Promoting EMAS III in Clusters of Printing SMEs” pg 2 of 101

Table of contents

TERMS & DEFINITIONS 1 INTRODUCTION ........................................................................................................................ 8 2 INFORMATION ABOUT EMAS III................................................................................................ 9 2.1 Environmental Management Systems (EMS)............................................................................ 9 2.1.1 General Information for EMS.................................................................................................... 9 2.1.2 EMAS III in small and medium‐sized printing companies ....................................................... 11 2.2 EMAS III Requirements............................................................................................................ 12 2.2.1 Environmental Policy requirements........................................................................................ 12 2.2.2 Environmental Review requirements ..................................................................................... 13 2.2.3 Environmental Program – Environmental Management System requirements .................... 13 2.2.4 Environmental Statement & Audit requirements................................................................... 17 2.2.5 Registration requirements ...................................................................................................... 17 2.3 EMAS III Implementation ........................................................................................................ 17 2.3.1 Environmental Policy .............................................................................................................. 17 2.3.2 Environmental Review ............................................................................................................ 18 2.3.3 Environmental Management System...................................................................................... 20

3 PRINTING INDUSTRY’S ENVIRONMENTAL ASPECTS & IMPACTS .............................................. 35 3.1 Material & Resource Use ........................................................................................................ 35 3.1.1 Material ................................................................................................................................... 35 3.1.2 Water Consumption................................................................................................................ 35 3.1.3 Energy Consumption ............................................................................................................... 36 3.2 Wastewater & Solid Waste ..................................................................................................... 37 3.3 Air Emissions ........................................................................................................................... 38 3.3.1 Volatile Organic Compounds (VOCs)....................................................................................... 39 3.3.2 Greenhouse gases ................................................................................................................... 39 3.4 Noise ....................................................................................................................................... 40 3.5 Abnormal & Emergency .......................................................................................................... 40

4 LEGAL REQUIREMENTS ‐ ENVIRONMENTAL LEGISLATION ....................................................... 41 4.1 General.................................................................................................................................... 41 4.2 EU Environmental Legislation ................................................................................................. 41 4.3 Greek Environmental Legislation ............................................................................................ 44 4.4 UK Environmental Legislation ................................................................................................. 47

5 POLLUTION PREVENTION & WASTE MANAGEMENT PRACTICES.............................................. 59 5.1 Introduction ............................................................................................................................ 59 5.1.1 Waste Recycling, and Reuse.................................................................................................... 59 5.2 Management Operational Guidelines..................................................................................... 59 5.2.1 Housekeeping.......................................................................................................................... 59 5.2.2 Cleaning & Maintenance......................................................................................................... 60 5.2.3 Preventive Maintenance ......................................................................................................... 61 5.2.4 Management and Communication ......................................................................................... 61


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5.2.5 Customer Relations ................................................................................................................. 61 5.3 Best Waste Management Practices (BMP) by Pollutant......................................................... 62 5.3.1 Waste Management................................................................................................................ 62 5.3.2 Solid Waste Management....................................................................................................... 63 5.3.3 Solvents Management ............................................................................................................ 64 5.3.4 Ink Management ..................................................................................................................... 65 5.3.5 Hazardous Waste Management.............................................................................................. 66 5.3.6 Air Emissions Management..................................................................................................... 67 5.3.7 Noise Management................................................................................................................. 68 5.4 Best Waste Management Practices (BMP) by Printing Method ............................................. 68 5.4.1 Offset....................................................................................................................................... 68 5.4.2 Flexography............................................................................................................................. 70 5.4.3 Screen...................................................................................................................................... 73 5.4.4 Digital ...................................................................................................................................... 76 5.4.5 Gravure.................................................................................................................................... 77 5.5 Site Control.............................................................................................................................. 80 5.5.1 Protecting Waterways............................................................................................................. 80 5.5.2 Storing and Using Chemicals ................................................................................................... 81 5.6 Abnormal & Emergency Response.......................................................................................... 82 5.6.1 General Information................................................................................................................ 82 5.6.2 Preventing and Containing Spills............................................................................................. 83 5.6.3 Dealing with Spills ................................................................................................................... 83 5.6.4 Avoiding Land Contamination................................................................................................. 83 5.7 Water Saving Options ............................................................................................................. 84 5.8 Energy Saving Options............................................................................................................. 85

6 EMAS III AUDITING & CERTIFICATION ..................................................................................... 86 6.1 General.................................................................................................................................... 86 6.2 Verification Methodology ....................................................................................................... 86 6.2.1 Preliminary Discussions........................................................................................................... 86 6.2.2 Sending the contract and the general terms of conditions – audit scheduling ...................... 86 6.2.3 Conduction of Verification audit ............................................................................................. 86 6.2.4 Total evaluation of results and validation............................................................................... 88 6.2.5 Registration ............................................................................................................................. 88 6.2.6 Obligations for registered organizations................................................................................. 88 6.2.7 Conduction of 1st surveillance audit........................................................................................ 89 6.2.8 Conduction of 2nd surveillance audit....................................................................................... 89 6.2.9 Conduction of Re‐Verification audit........................................................................................ 89

7 INTERESTING ISSUES............................................................................................................... 90 7.1 General.................................................................................................................................... 90 7.2 Technology upgrades .............................................................................................................. 90 7.2.1 Computer‐to‐plate technology ............................................................................................... 90 7.3 Alternative Materials .............................................................................................................. 90 7.3.1 Solvents ................................................................................................................................... 90


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7.3.2 Recycling Inks .......................................................................................................................... 91 7.3.3 Alternative Inks ....................................................................................................................... 91 7.4 Cost Saving .............................................................................................................................. 95 7.5 Inks and cleaning agents ......................................................................................................... 96

8 INFORMATION ‐ RESOURCES .................................................................................................. 97 Appendix A: ENVIRONMENTAL INDICATORS ................................................................................... 99

Tables

Table 1: Environmental Management System requirements & compliance ................................. 21 Table 2: Printing industry main waste........................................................................................... 38 Table 3: European Legislation ........................................................................................................ 41 Table 4: Greek Legislation .............................................................................................................. 44 Table 5: UK Legislation ................................................................................................................... 47 Table 6: Indicators ........................................................................................................................ 101


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TERMS AND DEFINITIONS Organization: a company, corporation, firm, enterprise, located inside or outside the Community, or part or combination thereof, whether incorporated or not, which has its own functions and administration Small organizations: micro, small and medium‐sized enterprises as defined in Commission Recommendation 2003/361/EC of 6 May2003 concerning the definition of micro, small and medium‐sized enterprises Site: a distinct geographic location under the management control of an organization covering activities, products and services, including all infrastructure, equipment and materials. A site is the smallest entity to be considered for registration Cluster: a group of independent organizations related to each other by geographical proximity or business activities jointly implementing the environmental management system

Environment: surroundings in which an organization operates, including air, water, land, natural resources, flora, fauna, humans and their interrelation. Environmental Policy: the overall intentions and direction of an organization relating to its environmental performance as formally expressed by top management including compliance with all applicable legal requirements relating to the environment and also a commitment to continuous improvement of environmental performance. It provides a framework for action and for the setting of environmental objectives and targets Environmental Performance: the measurable results of an organization’s management of its environmental aspects Legal Compliance: full implementation of applicable legal requirements, including permit conditions, relating to the environment Environmental Aspect: an element of an organization’s activities, products or services that has or can have an impact on the environment Significant Environmental Aspect: an environmental aspect that has or can have a significant environmental impact; Environmental Impact: any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s activities, products or services


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Environmental Review: an initial comprehensive analysis of environmental aspects, environmental impacts and environmental performance related to an organization’s activities, products and services Environmental Program: a description of the measures, responsibilities and means taken or envisaged to achieve environmental objectives and targets and the deadlines for achieving the environmental objectives and targets Environmental Objective: an overall environmental goal, arising from the environmental policy, that an organization sets itself to achieve, and which is quantified where practicable Environmental target: a detailed performance requirement, arising from the environmental objectives, applicable to an organization or parts thereof, and that needs to be set and met in order to achieve those objectives Environmental Management System: the part of the overall management system that includes the organizational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy and managing the environmental aspects Best Environmental Management Practice: the most effective way to implement the environmental management system by organizations in a relevant sector and that can result in best environmental performance under given economic and technical conditions Environmental Performance Indicator: a specific expression that allows measurement of an organization’s environmental performance Environmental Statement: the comprehensive information to the public and other interested parties regarding an organization’s:

• structure and activities • environmental policy and environmental management system • environmental aspects and impacts • environmental program, objectives and targets • environmental performance and compliance with applicable legal obligations relating to

the environment Internal Environmental Audit: a systematic, documented, periodic and objective evaluation of the environmental performance of an organization, management system and processes designed to protect the environment Auditor: an individual or group of individuals, belonging to an organization itself or a natural or legal person external to that organization, acting on behalf of that organization, carrying out an assessment of, in particular, the environmental management system in place and determining


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conformity with the organization’s environmental policy and program, including compliance with the applicable legal requirements relating to the environment Environmental Verifier: a conformity assessment body as defined in Regulation(EC) No 765/2008 or any association or group of such bodies, which has obtained accreditation in accordance with this Regulation or any natural or legal person, or any association or group of such persons, which has obtained a license to carryout verification and validation in accordance with this Regulation Verification: the conformity assessment process carried out by an environmental verifier to demonstrate whether an organization’s environmental review, environmental policy, environmental management system and internal environmental audit and its implementation fulfils the requirements of Regulation (EC) No 1221/2009 Validation: the confirmation by the environmental verifier who carried out the verification, that the information and data in an organization’s environmental statement and updated environmental statement are reliable, credible and correct and meet the requirements of Regulation (EC) No 1221/2009 Accreditation Body: a national accreditation body appointed pursuant to Article 4 of Regulation (EC)No 765/2008 which is responsible for the accreditation and supervision of environmental verifiers

Interested party: person or group concerned with or affected by the environmental performance of an organization

Prevention of pollution: use of processes, practices, techniques, materials, products, services or energy to avoid, reduce or control (separately or in combination (the creation, emission or discharge of any type of pollutant or waste, in order to reduce adverse environmental impacts VOCs: Volatile Organic Compounds HAPs: Hazardous Air Pollutants


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1 INTRODUCTION The printing industry covers a broad range of printing types. They all have potential environmental impacts because of the raw materials and chemicals they use and the waste they generate. The following printing types are covered in this book:

• Lithographic • Gravure • Flexographic • Digital • Letter press • Screen printing • Label printing • Web and sheet fed • Other associated printing types

This book is designed to help printers:

• Understand the environmental risks and responsibilities associated with the printing industry. • Take action to improve the environmental management of their operations. • Take advantage of the business benefits that result from improved environmental practices.

This book provides information for owners, managers and personnel. The book does not provide legal advice but will provide printers with an understanding of regulatory requirements & European environmental legislation.


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2 INFORMATION ABOUT EMAS III

2.1 Environmental Management Systems (EMS)

2.1.1 General Information for EMS

Environmental management system (EMS) refers to the management of an organization's environmental programs in a comprehensive, systematic, planned and documented manner. It includes the organizational structure, planning and resources for developing, implementing and maintaining policy for environmental protection.

An Environmental Management System (EMS): • Serves as a tool to improve environmental performance • Provides a systematic way of managing an organization’s environmental affairs • Is the aspect of the organization’s overall management structure that addresses immediate and

long‐term impacts of its products, services and processes on the environment • Gives order and consistency for organizations to address environmental concerns through the

allocation of resources, assignment of responsibility and ongoing evaluation of practices, procedures and processes

• Focuses on continual improvement of the system

An EMS follows a Plan‐Do‐Check‐Act Cycle, or PDCA. The process is of first developing an environmental policy, planning the EMS, and then implementing it. The process also includes checking the system and acting on it. The model is continuous because an EMS is a process of continual improvement in which an organization is constantly reviewing and revising the system.

This is a model that can be used by a wide range of organizations — from manufacturing facilities to service industries to government agencies.

An EMS is flexible and does not require organizations to necessarily “retool” their existing activities. An EMS establishes a management framework by which an organization’s impacts on the environment can be systematically identified and reduced. For example, many organizations, including counties and municipalities, have active and effective pollution prevention activities underway. These could be incorporated into the overall EMS.

There are a number of standards available, around which an organization can model its Environmental Management System (EMS).

There is ISO 14001, a standard issued during 1996 (revised 2004), and forms part of the ISO14000 series of standards providing not only a specification but guidance and advice on a wide range of environmental issues including auditing, labeling, life‐cycle assessment etc.


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There is also the Eco‐Management and Audit Scheme (EMAS) a voluntary environmental management system (EMS), under which companies and other public organizations evaluate, manage and continuously improve their environmental performance. The scheme has been available for participation by companies since 1995 (Council Regulation (EEC) No 1836/93). The latest revision of EMAS came into effect on 11 January 2010. The elements of Regulation (EC) No 1221/2009 (EMAS III) improve the applicability of the scheme and strengthen EMAS’s visibility and outreach. EMAS III makes registration to the scheme also possible for organizations and sites located outside the EU and EEA (European Economic Area— Iceland, Liechtenstein, and Norway).

The benefits of an effective environmental management system can be realized in:

• Legislation. The scope and severity of environmental legislation is ever increasing. A management system that ensures recognition of the requirements and compliance with them will ensure that fines are avoided and personnel is not imprisoned in addition to avoidance of the publicity that inevitably follows an environmental prosecution.

• Cost Savings. Successful environmental management will evaluate all opportunities for cost savings, the most common benefits derive from a review of resource/ energy utilization and its efficiency, forcing full consideration of alternative energy sources and their cost effectiveness. The other primary element will be minimization of waste and result and cost of disposal.

• Customer Requirements. Many companies have addressed the management system for customer requirements related to quality and ISO 9001. The range and diversity of customer needs and expectations is constantly growing with many customers increasing preference for use of suppliers and sub‐contractors who can demonstrate that they are good environmental citizens. No customer would want to risk a tarnished reputation (or non‐compliance to legislation) from the poor environmental performance of their suppliers and sub‐contractors. The safest option for the customer is to use suppliers and sub‐contractors who can demonstrate their positive environmental performance.

• Marketing Opportunities. All companies seeking growth obviously want their product and services attractive to a widest possible market. Poor environmental performance will encourage many potential customers to decide not to buy from the company; good environmental performance will ensure continuation of the widest possible market.

• Investment. The investors are increasingly moving to green portfolio’s, and it is interesting that the financial performance of these portfolios has been good in comparison to more traditional investment. In seeking additional investment for the organization it is sensible to ensure the widest scope and this is only aided by a demonstrably sound environmental performance

• Image. The ability to demonstrate a responsible environmental attitude can dramatically improve the image of the corporation fostering better relations with the company’s stake holders. Even more importantly, adverse publicity about the organizations environmental performance is always highly damaging.


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2.1.2 EMAS III in small and medium‐sized printing companies

Participation in EMAS III is open to organizations operating in all economic sectors. Special emphasis is placed on encouraging SMEs (small and medium‐sized enterprises with fewer than 250 employees) to participate in the scheme. SME‐specific support by the Member States and on the EU level is achieved by facilitating access to information, to existing support funds and to public institutions, and by promoting technical assistance measures. In addition, EMAS III has introduced revised audit cycles, which will further improve applicability of the scheme for SMEs. EMAS III also includes provisions that allow EMAS registration to clusters of organizations such as regional chambers of commerce. A cluster approach may help save financial and human resources in the registration process, which is particularly beneficial for SMEs. For printers, improving environmental performance is about managing risk and taking advantage of opportunities that will boost efficiency and profits. A good starting point is to identify and prevent risks to their business from poor environmental management. A chemical spill or high solvent emissions for example could pose the risk of:

• Environmental prosecutions and fines • Damage to company reputation • Harmful effects on the health, safety and productivity of personnel. A spill or other

environmental incident could also harm the local environment, which belongs to all members of the community and impacts on their quality of life

Improving environmental management also provides opportunities to make a business more profitable and viable in the long‐term. Even small changes can save money. For example, many printers have cut costs by installing or cleaning skylights, filtering press water and reusing it for several weeks and working with designers to avoid excessive trim. The benefits of a high standard of environmental management go beyond ‘housekeeping’ and efficiency. They also include benefits from:

• An enhanced reputation as a company that is well‐managed and a valuable long‐term business partner

• Becoming a ‘supplier of choice’, particularly to corporate and government clients who are starting to consider environmental performance of suppliers and products as part of their green procurement policies

• Improved employee satisfaction, retention and productivity. Companies with a good environmental record are more likely to win the ‘battle for talent’ in attracting and retaining personnel. As well, employees are generally happier and more productive in a workplace that is clean, healthy and environmentally responsible

Successful printers are coming to understand that good environmental practice is a business opportunity. These opportunities are maximized when management of environmental issues is integrated with other business planning and becomes part of continuous improvement. Better results


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are also likely when personnel at all levels are involved in identifying and delivering environmental projects.

2.2 EMAS III Requirements

EMAS III requirements are recorded in the Regulation (EC) No 1221/2009 of the European Parliament and of the Council of 25 November 2009.

To receive EMAS registration an organization must comply with the following steps:

1. Adopt an environmental policy containing commitment both to comply with all relevant environmental legislation and to achieve continuous improvements in environmental performance.

2. Conduct an environmental review considering all environmental aspects of the organization’s activities, products and services, methods to assess these, its legal and regulatory framework and existing environmental management practices and procedures.

3. In the light of the results of the review, establish an environmental program and an effective environmental management system aimed at achieving the organization’s environmental policy defined by the top management. The management system needs to set responsibilities, objectives, means, operational procedures, training needs, monitoring and communication systems.

4. Carry out an environmental audit assessing in particular the management system in place and conformity with the organization’s policy and program as well as compliance with relevant environmental regulatory requirements.

5. Provide a statement of its environmental performance which lays down the results achieved against the environmental objectives and the future steps to be undertaken in order to continuously improve the organization’s environmental performance.

6. The environmental review, EMS, audit procedure and the environmental statement must be approved by an accredited EMAS verifier, and the validated statement needs to be sent to the EMAS Competent Body for registration and made publicly available before an organization can use the EMAS logo.

The environmental review, the EMS, the audit procedure and the environmental statement must be approved by an accredited EMAS verifier and the validated statement needs to be sent to the EMAS Competent Body for registration and made publicly available before an organization can use the EMAS logo.

2.2.1 Environmental Policy requirements Organization’s top management shall define the environmental policy and ensure that it:

• is appropriate to the nature, scale and environmental impacts of its activities & services • includes a commitment to continual improvement and prevention of pollution


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• includes a commitment to comply with relevant environmental legislation and regulations and with other requirements to which the organization subscribes

• provides the framework for setting and reviewing environmental objectives and targets • is documented, implemented and maintained and communicated to all employees is available to

the public

2.2.2 Environmental Review requirements The environmental review is an initial comprehensive analysis of the environmental problems caused by an organization’s activities. The outcome is a report that includes data about consumption of raw materials and energy and the production of wastes and emissions; information on the environmental impacts of the organization’s activities; and an outline of the management structures in place to deal with these impacts. The purpose of the initial review is to identify the most significant environmental impacts and to lay down a benchmark to measure future success in reducing these impacts.

2.2.3 Environmental Program – Environmental Management System requirements The environmental program translates the general objectives and targets established in the environmental policy into specific targets, determining concrete measures, timeframes, responsibilities, and the resources necessary in order to meet them. The measures laid out in an environmental program can be of a technical and/or organizational nature. All of the company's activities – from top management to the lower levels – should be involved in these measures. To ensure the successful implementation of the environmental program, an organization is required to establish operating procedures and controls, or an environmental management system. The EMAS environmental management system is defined according to the ISO 14001 Standard. The requirements of ISO 14001 Standard are the following:

The company shall establish and maintain a procedure(s): • to identify the environmental aspects of its activities, products, and

services within the defined scope of the environmental management system that it can control and & those that it can influence, taking into account planned or new developments, or new or modified activities, products & services

• to determine those which have or can have significant impacts on the environment.

The company shall document this information & keep it up‐to‐date

The company shall establish and maintain a procedure: • to identify and have access to legal and other requirements to which the

company subscribes related to its environmental aspects, • to determine how these requirements apply to its environmental

aspects


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The company shall establish and maintain documented environmental objectives and targets, at each relevant function and level within the company

The company’s environmental program (s)shall be established, implemented and maintained to achieve its objectives & targets. Program (s) shall include

• designation of responsibility for achieving objectives & targets at relevant functions & levels of the company

• the means & the time – frame by which they are to be achieved

Roles, responsibilities and authorities shall be defined, documented and communicated in order to facilitate effective environmental management The organization’s top management shall appoint a specific management representative(s)

Personnel performing the tasks which can cause significant environmental impacts shall be competent on the basis of appropriate education, training and/or experience. The company shall identify training needs associated with its environmental aspects & its environmental system. It shall provide training or take other actions to meet these needs & shall retain associated records It shall establish, implement and maintain procedures to make its employees aware of:

• the importance of conformity with the environmental policy and procedures and with the requirements of the environmental management system

• the significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance

• their roles and responsibilities in achieving conformity with requirements of the environmental management system

• the potential consequences of departure from specific procedures

With regard to its environmental aspects and environmental management system, the company shall establish and maintain procedures for:

• internal communication among the various levels and functions of the company

• receiving, documenting and responding to relevant communication from external interested parties.

The company shall decide whether to communicate externally about on its significant environmental aspects and shall document its decision. If the decision is to communicate the company shall establish & implement a method for this


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communication

The environmental management system documentation shall include: • the environmental policy, objectives & targets • description of the scope of the environmental management system • description of the main elements of the environmental management

system & reference to related documents • documents include records required by EMAS III • documents, including records, which the company considers necessary

to ensure the effective planning, operation & control of process that relate to its significant aspects

Documents required by EMAS III & the environmental management system should be controlled. The company shall establish, implement & maintain a procedure (s) to:

• approve documents prior to use • review and updated as necessary • ensure that changes and the current versions are identified • ensure that relevant versions of applicable documents are available at

points of use • ensure that documents remain legible & identifiable • ensure that documents of external origin are identified and their

distribution controlled • prevent the unintended use of obsolete documents

The company shall identify those operations and activities associated with the

identified significant environmental aspects consistent with its policy, objectives and targets in order to ensure that they are carried out under specified conditions by:

• establishing, implementing and maintaining documented procedures to control situations where their absence could lead to deviations from the environmental policy and the objectives and targets

• stipulating the operating criteria in the procedures establishing and maintaining procedures related to the identifiable significant environmental aspects of goods and services used by the organization and communicating applicable procedures and requirements to suppliers and contractors


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The company shall establish and maintain procedures to identify potential emergency situations and potential accidents that can have an impact on the environment & how it will respond to them. The company shall respond to actual emergency situations & prevent or mitigate associated environmental impacts The company shall periodically review & when necessary revise these procedures particular, after the occurrence of accidents or emergency The company shall also periodically test such procedures where practicable

The company shall establish and maintain documented procedures to monitor and measure, on a regular basis, the key characteristics of its operations that can have a significant impact on the environment. This shall include the documenting of information to monitor performance, applicable operational controls and conformity with the company’s environmental objectives and targets. Monitoring equipment shall be calibrated and maintained and records of this process shall be retained.

The company shall establish, implement & maintain a procedure(s) for periodically evaluating its compliance with applicable legal requirements & other requirements to which it subscribes. The company will need to keep records of these periodic evaluations.

The company shall establish, implement & maintain a procedure(s) for dealing with actual & potential nonconformities and for taking corrective & preventive action. Actions taken should be appropriate to the significance of the problems. Necessary changes to environmental management system should be made.

The company shall establish, implement & maintain a procedure(s) for the maintenance of records, and for ensuring that records are identifiable, retrievable, safely stored, and legible, retained as appropriate, and traceable.

Internal audits of the environmental management system should be contacted to determine systems’ compliance with EMAS III requirements & systems proper implementation. Internal audit’s program should be planned, established, implemented and maintained.

Company’s top management shall review the environmental management system’s performance in order to ensure it is operating as planned and is suitable, adequate, and effective.


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Results and records of management review include agendas, attendance records and minutes and documented agreed upon action items.

2.2.4 Environmental Statement & Audit requirements

Finally, an environmental audit is conducted to assess the management system in place and the whole process is then described in the environmental statement. The statement has to include the following information:

• Extend employee involvement to the process of continually improving the organization’s environmental performance

• A description of the organization, its structure and its activities, products and services • An assessment of all the significant direct and indirect environmental issues. • A summary of year‐by‐year figures on pollution emissions, waste generation, consumption of

raw material, energy and water, and noise. • A presentation of the organization’s environmental policy, programs and management system. • The deadline for the next statement. • The name and accreditation number of the environmental verifier and the date of validation

When the environmental management system has been implemented and the environmental statement has been prepared, the organization must have them validated by an independent accredited verifier, an independent external party that examines the organization’s environmental policy, management system, audit procedure(s) and environmental statement to ensure that they meet EMAS requirements. If the verifier is satisfied that the requirements are met, he or she validates the information contained in the company’s environmental statement.

2.2.5 Registration requirements Once the environmental statement has been verified, the organization then should sends its validated statement to the EMAS National Competent Body for registration. The organization is then listed in the register of EMAS organizations and has the right to use the EMAS logo. Organizations are required to update their environmental statement annually, although in exceptional circumstances, for example, small organizations, this renewal period can be extended with the agreement of the verifier, normally up to three years.

2.3 EMAS III Implementation

2.3.1 Environmental Policy The formulation of an environmental policy, reflecting top management's commitment to continuous improvement in environmental performance inside the legal framework is the first visible step of the process. The environmental policy is a document that describes the organization’s overall aims and principles of action with respect to the environment. Developed at the highest managerial level, the environmental policy is intended to be revised periodically. It should contain at least two central


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elements: compliance with relevant environmental regulations and a commitment to continuous improvement. The Company’s top management shall mandate the establishment of Environmental Policy which should account for the following:

• Reflect the moral and ethical basis for the company’s actions • Account for regulatory/self‐imposed requirements • Stress commitment to continual improvement • Provide coordination to other company policies • Be relevant to the operation’s products and services as they impact the environment • Be clear, concise, and implemented at all levels of operations • Be publicly available • Strive toward prevention of and continual reduction of adverse environmental effects, thus

supporting sustainable development. • Set and allow for publication of environmental objectives and targets, improvement plans

and management reviews • Satisfy the requirements of concerned third parties • Be updated and revised

An environmental policy statement is the communication of organization’s policy internally within its personnel and externally to its customers, suppliers and interested parties. Once the organization has understood the principles involved and has accepted responsibility for the pollution generated by it, the first step on the journey towards sustainability is to create a written commitment in the form of an Environmental Policy Statement. This should acknowledge the reasons for doing it, be specific and achievable and clearly written for an audience of personnel, suppliers, customers, interested parties and general public. It must be signed by a senior executive (top management) to demonstrate that it is an Organization Policy and reviewed at regular intervals The environmental policy ideally should be like a company mission statement in that it's set on one sheet of A4 paper and contains the key commitments the policy undertakes. All goals should be measurable, achievable, realistic and time bound.

2.3.2 Environmental Review The purpose of carrying out an environmental review is to understand exactly how the activities, products and services of the organization interact with the environment. The information generated will then form the foundation for the Environmental Policy, Program and Management System. In essence, the review is a baseline survey and an opportunity for an organization to answer the questions "What does environment mean for us?" and "What significant issues are we going to manage within our EMAS?"

The steps of carrying out an Environmental Review are:


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• Planning. Before undertaking the review it is extremely important to plan the process and to assess what the exercise is meant to achieve. The pace and style of the review will be influenced by the level of commitment from chief officers and members, the presence of existing management systems (e.g. business planning), the existence of an environmental coordinator. These factors combined provide the background framework to planning the review. This step includes:

definition of the team to carry out the review overview of the physical layout including buildings, tanks, storage facilities and other significant installations The ecomapping tool will help to develop a visual map of the site.

overview of the organization’s activities preparation of a process map. Most organizations can be simplified into three main areas: supply, production, sale

Study of legal and regulatory requirements definition of a method for data collection. The methods presented here are complementary and should be used together as part of an overall approach for carrying out your environmental review: ecomaps, interviews, questionnaires

a time schedule development • Collecting information. This step provides the opportunity to examine the activities of an

organization and the associated environmental impacts, identifying the significant ones which will need to be managed by the EMS. This step includes:

• Identification of environmental aspects and impacts through interviews, questionnaires and layouts or flowcharts which show imputes, that is materials in use and recourses (electricity, fuels, etc) & outputs, that is wastes (solid, liquid) & air emission

• Identification of environmental aspects and impacts that can be controlled or influenced • Analyzing data. This step provides the opportunity to identify the significant aspects and impacts

which will need to be managed by the EMS. This step includes: • Evaluation of the significance of the impact, carried out by setting Evaluation criteria

such as: size of the problem, likelihood of the problem occurring, regulatory requirements, what will customers say, what will the public say, etc. and a Classification system such as an ABC scale with A means an environmental impact that would cause major distress to environment or business and C means the issue is of no concern.

• Definition of the significant impacts • Reporting. The report shows the findings of the environmental review and includes areas of

strengths and weakness within the environmental performance of the organization. A sample of an environmental review frame is presented below:

1 INTRODUCTION 1.1 Scope – Objectives 1.2 Approach – methodology 2 COMPANY & REVIEW DETAILS 2.1 Company Profile


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2.2 Current activities & operations 2.3 Site history & description 3 ENVIRONMENTAL REVIEW 3.1 Material Use 3.2 Resource Use 3.2.1 Water Consumption 3.2.2 Energy Consumption 3.3 Production 3.3.1 Introduction 3.3.2 Facilities & Equipment Error! Bookmark not defined. 3.3.3 Printing Process 3.4 Company’s environmental aspects 3.4.1 Waste Diagrams 3.4.2 Wastes 3.4.2.1 Wastewater 3.4.2.2 Solid Waste 3.4.2.3 Emissions 3.4.3 Noise 3.5 Abnormal & Emergency 3.6 National and European legislation 4 COMPANY’S ENVIRONMENTAL ASPECTS & CURRENT MANAGEMENT 4.1 Wastewater 4.2 Solid Waste 4.3 Emissions 4.4 Noise 4.5 Water Consumption 4.6 Energy Consumption 5 EVALUATION OF ENVIRONMENTAL ASPECTS’ SIGNIFICANCE 6 ENVIRONMENTAL MANAGEMENT SYSTEM GAP ANALYSIS

2.3.3 Environmental Management System

2.3.3.1 Environmental Management System Structure

All EMS requirements are recorded in the Regulation (EC) No 1221/2009 of the European Parliament and of the Council of 25 November 2009 (EMAS III).

A brief list of activities which an organization should carry out to succeed compliance with EMS requirements is presented.

• Environmental policy — Develop a statement of your organization’s commitment to the environment. Use this policy as a framework for planning and action.


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• Environmental aspects — Identify environmental attributes of your products, activities and services. Determine those that could have significant impacts on the environment.

• Legal and other requirements — Identify and ensure access to relevant laws and regulations, as well as other requirements to which your organization adheres.

• Objectives and targets — Establish environmental goals for your organization, in line with your policy, environmental impacts, the views of interested parties and other factors.

• Environmental management program — Plan actions necessary to achieve your objectives and targets.

• Structure and responsibility — Establish roles and responsibilities for environmental management and provide appropriate resources.

• Training, awareness and competence — Ensure that your employees are trained and capable of carrying out their environmental responsibilities.

• Communication — Establish processes for internal and external communications on environmental management issues.

• EMS documentation — Maintain information on your EMS and related documents. • Document control — Ensure effective management of procedures and other system

documents. • Operational control — Identify, plan and manage your operations and activities in line

with your policy, objectives and targets. • Emergency preparedness and response — Identify potential emergencies and develop

procedures for preventing and responding to them. • Monitoring and measurement — Monitor key activities and track performance. Conduct

periodic assessments of compliance with legal requirements. • Nonconformance and corrective and preventive action — Identify and correct problems

and prevent their recurrence. • Records — Maintain and manage records of EMS performance. • EMS audit — Periodically verify that your EMS is operating as intended. • Management review — Periodically review your EMS with an eye to continual

improvement. The table below presents analytically the activities which an organization should carry out to succeed compliance with EMS requirements.

Table 1: Environmental Management System requirements & compliance

Requirement Compliance Company’s top management shall define the environmental policy and ensure that it:

• is appropriate to the nature, scale and environmental impacts of its activities & services

The Company’s top management shall mandate the establishment of Environmental Policy which should account for the following:

• Reflect the moral and ethical basis for the company’s actions


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Requirement Compliance • includes a commitment to continual

improvement and prevention of pollution • includes a commitment to comply with

relevant environmental legislation and regulations and with other requirements to which the organization subscribes

• provides the framework for setting and reviewing environmental objectives and targets

• is documented, implemented and maintained and communicated to all employees

• is available to the public

• Account for regulatory/self‐imposed requirements

• Stress commitment to continual improvement

• Provide coordination to other company policies

• Be relevant to the operation’s products and services as they impact the environment

• Be clear, concise, and implemented at all levels of operations

• Be publicly available • Strive toward prevention of and continual

reduction of adverse environmental effects, thus supporting sustainable development.

• Set and allow for publication of environmental objectives and targets, improvement plans and management reviews

• Satisfy the requirements of concerned third parties

• Be updated and revised

The company shall establish and maintain a procedure(s):

• to identify the environmental aspects of its activities, products, and services within the defined scope of the environmental management system that it can control and & those that it can influence, taking into account planned or new developments, or new or modified activities, products & services

• to determine those which have or can have significant impacts on the environment.

The company shall document this information & keep it up‐to‐date

The Company’s top management shall mandate the establishment of a procedure to identify the environmental aspects of its activities, products, and services and determine the significant ones. The procedure shall determine:

• the method & the criteria for identifying the environmental aspects in normal, abnormal operation & emergency situation

• the method & the criteria for evaluating the aspects & determining the significant ones

• the method & the criteria to outline environmental objectives and targets when the significant aspects have been determined

• the personnel involved & each ones’


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Requirement Compliance responsibilities for the identification & evaluation of environmental aspects

The company shall establish and maintain a procedure:

• to identify and have access to legal and other requirements to which the company subscribes related to its environmental aspects,

• to determine how these requirements apply to its environmental aspects

A procedure to identify legal requirements of the company should be established and maintained. This should include all European & Greek laws and other self‐imposed requirements to which the company adheres. These requirements can be partially established by reviewing the previously completed aspects and impacts. The procedure shall also determine:

• the company’s access to European & National legislation

• how the legal requirements apply to its environmental aspects

• the frequency of audits which shall take place in order to certify the company’s compliance with legal requirements

• the personnel involved & each ones’ responsibilities

The company shall establish and maintain documented environmental objectives and targets, at each relevant function and level within the company

A procedure to determine & document f the company’s environmental objectives and targets should be established and maintained. The procedure shall determine:

• the method & the criteria to outline environmental objectives and targets

• the frequency of revising environmental objectives and targets

• the personnel involved & each ones’ responsibilities

Environmental objectives and targets should: • be specific when necessary & measurable • be consistent with the company’s

Environmental Policy & Business Plan • quantify the organization’s commitment

to environmental improvement with time


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Requirement Compliance The company shall establish, implement and maintain an environmental program (s) to achieve its objectives & targets. Program (s) shall include

• designation of responsibility for achieving objectives & targets at relevant functions & levels of the company

• the means & the time – frame by which they are to be achieved

Once the company establishes its environmental objectives and targets, then planning begins to develop a Program for achieving them. This Program should be integrated into the existing environmental management practices at the company and should be tied into the strategic plan of the company as well. Issues such as scheduling, resource allocation, revision and responsibilities should be included in the Program to allow for the successful achievement of the Objectives and Targets. Relevant records should be kept The Program should always reflect the organization’s environmental Policy.

• Roles, responsibilities and authorities shall be defined, documented and communicated in order to facilitate effective environmental management

• The organization’s top management shall appoint a specific management representative(s)

For an environmental system to be effective, individual roles and responsibilities must clearly be defined as they relate to the achievement of environmental objectives and targets and the overall operation of the environmental system. Top management must supply the necessary resources, both financial and personnel, to ensure that the environmental system is effectively implemented. They are also responsible for appointing a Management Representative to oversee the operation of the environmental system. Company’s structure should be defined in writing. An organizational chart will be helpful for illustrating many of the environmental responsibilities that must be addressed. The key roles that effect environmental performance should be documented & included in the employee’s job description.


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Requirement Compliance • Personnel performing the tasks which can

cause significant environmental impacts shall be competent on the basis of appropriate education, training and/or experience.

• The company shall identify training needs

associated with its environmental aspects & its environmental system. It shall provide training or take other actions to meet these needs & shall retain associated records

• It shall establish, implement and maintain

procedures to make its employees aware of:

the importance of conformity with the environmental policy and procedures and with the requirements of the environmental management system

the significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance

their roles and responsibilities in achieving conformity with requirements of the environmental management system

the potential consequences of departure from specific procedures

The basic intent of training is to explain the importance of the environmental system to personnel, and to explain their responsibilities for environmental system operations. In order for responsibilities to be effectively understood, adequate training is essential. A training system should also include training for executives to ensure that they understand the environmental system, know their responsibilities and have the knowledge to carry those responsibilities out. Training should include communication of the following:

• requirements of the system, the importance of regulatory compliance and the importance of compliance with environmental policy

• The potential negative environmental effects of the employee’s work. The positive effects of improved performance on their part

• Their responsibilities in achieving compliance with the policies, regulations and environmental system requirements

• Consequences of failure to comply with the above

These trainings should be scheduled, documented & recorded. The Company’s top management shall mandate the establishment, implementation & maintenance of a procedure of the employees’ awareness.

With regard to its environmental aspects and environmental management system, the company shall establish and maintain procedures for:

• internal communication among the various levels and functions of the company

• receiving, documenting and responding to relevant communication from external interested parties.

This section refers to the communication that is related to the environmental aspects & the environmental management system. To fulfill this element of the standard, both internal and external communication must be addressed. The Company’s top management shall mandate the establishment, implementation & maintenance of:


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Requirement Compliance The company shall decide whether to communicate externally about on its significant environmental aspects and shall document its decision. If the decision is to communicate the company shall establish & implement a method for this communication

• a procedure for Internal Communication on Environmental Matters

• a procedure for External Communication on Environmental Matters

The records of doth internal & external communication should be maintained.

The environmental management system documentation shall include:

• the environmental policy, objectives & targets

• description of the scope of the environmental management system

• description of the main elements of the environmental management system & reference to related documents

• documents include records required by EMAS III

• documents, including records, which the company considers necessary to ensure the effective planning, operation & control of process that relate to its significant aspects

The environmental management system should be designed into the existing organizational structures such as financial management, purchasing, legal, operational, and management information systems structures. This is essential if environmental management is to become an integral portion of overall general business management. Moreover, the environmental management system documents can and should be integrated with other management documents wherever possible. Existing quality and health & safety procedures should have environmentally related information in them. The environmental management system documentation should include the company’s structure, planning, roles, responsibilities, practices, procedures, work instructions and resources for the development, establishment, implementation, control, filing, and maintenance of its system. The documentation of the environmental management system should be like a pyramid. At the top of the pyramid should be the Environmental policy and then follows:

• The Environmental Management System Manual

• The environmental procedures & work instructions

• The forms • The environmental records


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Requirement Compliance Documents required by EMAS III & the environmental management system should be controlled. The company shall establish, implement & maintain a procedure (s) to:

• approve documents prior to use • review and updated as necessary • ensure that changes and the current

versions are identified • ensure that relevant versions of applicable

documents are available at points of use • ensure that documents remain legible &

identifiable • ensure that documents of external origin

are identified and their distribution controlled

• prevent the unintended use of obsolete documents

The environmental management system documents could be codified as follows:

• issue/revision date • effective date • approval (i.e., signature) • revision number • document number (or • other identifier • copy number • cross‐references

External documents are recognised by their own codification elements.

The company shall identify those operations and activities associated with the identified significant environmental aspects consistent with its policy, objectives and targets in order to ensure that they are carried out under specified conditions by:

• establishing, implementing and maintaining documented procedures to control situations where their absence could lead to deviations from the environmental policy and the objectives and targets

• stipulating the operating criteria in the procedures establishing and maintaining procedures related t