GOOD PRACTICE: Proven technology and techniques for profitable environmental improvement

GG43GUIDE

ENVIRONMENTALMANAGEMENT SYSTEMS IN FOUNDRIES

For more information about the Programme please phone the Environmental Helpline on 0800 585794

The Environmental Technology Best Practice Programme is a joint Department of Trade and Industry

and Department of the Environment initiative. It is managed by AEA Technology plc through ETSU

and the National Environmental Technology Centre.

The Programme offers free advice and information for UK businesses and promotes environmental

practices that:

■ increase profits for UK industry and commerce;

■ reduce waste and pollution at source.

To find out more about the Programme please call the Environmental Helpline on freephone

0800 585794. As well as giving information about the Programme, the Helpline has access to a

wide range of environmental information. It offers free advice to UK businesses on technical

matters, environmental legislation, conferences and promotional seminars. For smaller companies,

a free counselling service may be offered at the discretion of the Helpline Manager.

Foundries are becoming increasingly aware of the measurable cost benefits which result fromimproving their environmental performance. Waste is a sign of inefficiency, and lower operatingcosts are an inevitable benefit of waste minimisation or energy saving programmes. At the sametime, companies which establish continual improvement programmes can:

keep ahead of UK and European Union (EU) legislation;

manage their capital expenditure programme more effectively and according to their ownpriorities and timescales;

gain a competitive advantage.

Small to medium-sized foundries are the companies which most need to be aware of the threatsand opportunities which environmental pressures generate. While they may feel that their prioritieslie elsewhere, these companies are coming under increasing pressure to improve their environmentalperformance, not only from stricter legislation, but also from their customers.

Many companies have previously relied on an ad hoc approach to the environment. They havetended to consider and address issues such as Control of Substances Hazardous to Health (COSHH),health and safety, emission limits and noise pollution in isolation. However, there are manyadvantages to be gained through the adoption of a more integrated approach to managing all ofthese concerns.

Setting up an environmental management system (EMS) will provide your foundry with a frameworkthrough which environmental performance can be controlled and improved. You can either developyour own EMS or follow the guidelines laid down in a recognised national or international standard.

Foundrymen frequently ask:

What is an EMS? An EMS provides a foundry with an integrated approachto managing and monitoring its environmental effectsand complying with environmental regulations.

What is in it for us? An effective and efficient EMS will provide a foundrywith the opportunity to reduce its environmental impact,reduce costs, increase efficiency and enhance itsreputation.

What is involved? This Good Practice Guide provides foundries with apractical framework and methodology whichfoundrymen with no previous experience ofenvironmental management can use to carry out anenvironmental effects review, write a policy, plan aprogramme and implement an EMS.

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T H E B E N E F I T S O F E N V I R O N M E N TA LM A N A G E M E N T S Y S T E M S

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Table 1 summarises the many potential benefits to foundries of implementing an EMS.

Cost savings ■ Reduced raw material costs.

■ Reduced energy consumption.

■ Reduced transportation and disposal costs.

■ Reduced risk of litigation.

■ Lower insurance premiums as risks are reduced.

Marketing benefits ■ Improved public image.

■ Exploitation of opportunities in new markets.

■ Safeguard existing markets.

Benefits for the customers ■ Increased customer confidence in supplier probity.

■ Competitive pricing through reduced waste.

■ Better value for money.

Benefits to the employee ■ Improved working and living environment.

■ Potential improvement to health and hence quality of life.

■ Commitment to a policy of environmental improvement

will enhance their personal commitment to the company.

Benefits to the environment ■ Reductions in:

- raw material consumption;

- emissions;

- waste;

- odours;

- noise;

- energy use;

- impact on eco-systems.

Better relations with regulators ■ Increased ability to display understanding of legislative

requirements and a systematic approach to meeting them.

Table 1 The benefits of implementing an EMS

1.1 OPTIONS AVAILABLE TO FOUNDRIES

When considering a strategy for introducing an EMS, foundries have three options available:

■ to develop their own unique EMS;

■ to follow the model EMS presented in the British Standard for Environmental ManagementSystems, BS 7750 or the International Standard ISO 14001 Environmental ManagementSystems - Specification with Guidance for Use;

■ to develop and incorporate an EMS as part of a wider public commitment to improveenvironmental performance leading to registration under the EC Eco-Management and AuditScheme (EMAS).

While all three options are entirely voluntary, they differ in their scope and approach.

BS 7750 provides a ready-made framework on which foundries can base their environmentalmanagement requirements in the same way that the BS EN ISO 9000 series (formerly BS 5750) isused as a basis for the implementation of Quality Management Systems. Of course, achievingcertification to a recognised EMS standard greatly increases the credibility of your EMS.

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ISO 14001 will be officially launched during 1996 and it is likely that this standard will supersedeBS 7750. In due course, companies already certified1 to BS 7750 will find the transition to ISO 14001relatively straightforward.

1.2 HOW AN EMS HELPS FOUNDRIES

Whichever route a foundry chooses to take, it is worth remembering that a sound, well-conceivedEMS is a practical management tool. A proactive foundry can use this management tool to:

■ reduce its operating costs;

■ improve the bottom line, ie profits;

■ gain market advantage;

■ demonstrate compliance with its legal obligations.

When considering environmental issues, the key questions that foundry management should askregularly are:

■ As far as our processes are concerned, can we:

- use cleaner technologies which are more efficient in their use of resources?

- recover and re-use materials, saving on resources/raw materials/energy?

- recycle materials within the process?

■ About our utilisation of natural resources, can we:

- use more efficient and less environmentally damaging fuel sources?

- recover and re-use energy and water?

- do more to protect and conserve the natural environment?

■ In the case of our product, can we:

- reduce the material input?

- improve the efficiency and useful life of the product?

- use less or alternative packaging?

- distribute it more efficiently?

Implementing an EMS allows all these questions to be addressed systematically, leading to costsavings and other benefits for foundries.

This Guide is intended to help UK foundries that want to take advantage of the benefits of aneffective EMS.

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1 Certification is the conformity of an environmental management system to BS 7750 or ISO 14001 as vouched for by anindependent, accredited certifier.

2.1 THE ELEMENTS OF AN EMS

As discussed in Section 1, when implementing your EMS you can choose to:

■ develop your own EMS;

■ follow the guidelines laid down in BS 7750, ISO 14001 or EMAS;

■ pursue formal certification to these environmental standards.

Although BS 7750 and EMAS do not specify environmental performance criteria for a foundry, theydo require:

■ compliance with legislation;

■ the existence of an environmental policy;

■ an aim of continuous environmental improvement.

The environmental policy simply explains the company’s commitment to understanding its impacton the environment and to improved environmental performance. This leads to the setting ofobjectives and targets through which improvement can be measured and forms the first stepstowards the development of an EMS.

As you design and develop your EMS, you should ensure that the overall effects of the operationsand activities conform to your company’s environmental policy and its associated objectives. As withany management system, this will require the preparation of documented procedures/instructionsand their effective implementation. Any system which you adopt should, of course, take intoaccount all relevant codes of practice.

2.2 BS 7750 AND ISO 14001

Fig 1 shows the stages involved in the implementation of an EMS outlined in BS 7750, the mainelements of which are defined in Table 2. The model EMS presented in ISO 14001 is very similar tothe BS 7750 model.

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W H AT I S A N E M S ?2

Fig 1 Stages in the implementation of an EMS (British Standard BS 7750)

Policy A public statement committing the foundry to an understandingof its environmental effects and achieving continuing improve-ment through the setting of objectives and targets.

Organisation This defines a foundry’s organisational structures and allocatesresponsibilities to staff for various aspects of the EMS.

Environmental effects and legislation The foundry evaluates its environmental impact and identifiesrelevant legislation.

Objectives and targets These are set, depending on the environmental effects, andcommunicated accordingly.

Management Programme A programme set up to achieve the objectives and targetsalongside the pursuit of new developments, projects, products,etc.

Manual and documentation Document(s) describing the EMS and the management pro-gramme including procedural documentation.

Operational control Written work instructions drawn up for those parts of the processwhere environmental impact has to be controlled.

Record system A controlled system of records set up to demonstrate compliancewith the EMS.

Audits The auditing of the system and environmental procedures bytrained staff. Corrective action is taken when applicable.

Management review A full system review to ascertain continuing suitability and identifythe need for any changes and modifications.

Table 2 The main elements of the model EMS in BS 7750

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2.3 EMAS

EMAS, which was established by EC Regulation 1836/93 and came into force in April 1995, iscomplementary to BS 7750. In broad terms, EMAS extends a company’s existing EMS by requiringthe company to produce a public statement on environmental performance, which is independentlyverified2 by an external registration body. Certification to BS 7750 can be used in preparation forregistration to EMAS.

Fig 2 shows the relationship between the different stages in BS 7750/ISO 14001 and EMAS. It alsoindicates where these stages are discussed in the Guide.

With the help of Fig 2, you should be able to identify which sections are relevant to yourchosen approach for implementing an EMS.

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Fig 2 A comparison of BS 7750/ISO 14001 and EMAS and how this Guide can help you

BS 7750/ISO 14001

Review

Policy

EMAS

Review

Policy

Organisationand personnel

Evaluation and Register of

Environmental Effects

Register ofLegislation

Objectivesand targets

Environmentalobjectives

Environmentalprogramme

ManagementProgramme

Managementmanual

Operationalcontrol

Environmentalmanagement system

Records

AuditsEnvironmental

audit

Reviews

Certification Validation

EnvironmentalStatement

Section 3

Section 4

Section 5

Section 6

Section 7

Section 8

Section 9

2 During verification, environmental policies, programmes, management systems, reviews, audit procedures and theEnvironmental Statement are examined to confirm that they meet the requirements of the EMAS Regulation. This activity isperformed by accredited environmental verifiers.

The key steps involved in EMAS are shown in Fig 3. The main components are:

■ An Environmental Effects Review covering all aspects of the foundry site(s) to be registered(see Section 3).

■ An environmental policy which should provide for compliance with existing legislation andinclude a commitment to reasonable, continuous environmental improvement (see Section 4).

■ An environmental programme that sets out quantified objectives for each site to be registered(see Section 5).

■ An EMS. A company can either develop its own system or use a recognised standard such asBS 7750 (see Section 6).

■ An environmental audit cycle that provides regular information on the progress of theprogramme (see Section 7).

■ An Environmental Statement. This is a public statement of progress, issued after the reviewand subsequent audits (see Section 8).

■ Validation3. Independent verification of the Environmental Statement (see Section 9).

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3 The Environmental Statement required by EMAS is endorsed by an independent, accredited environmental verifier.

1. Companyenvironmental policy

2. Initialenvironmental review

Accredited environmentalverifiers

Accreditationsystem

8a. Verification

8b. Validation

3. Environmentalprogramme

Maximum auditcycle 3 years

5. Environmental audit

7. EnvironmentalStatement

6. Environmentalobjectives

4. Environmentalmanagement system

Fig 3 Schematic diagram of the stages in the implementation of EMAS

(Source: EMAS: A Practical Guide, R. Hillary, 1994)

2.4 COMMON FEATURES

Table 3 summarises the similarities and differences between ISO 14001, EMAS and BS 7750. A moredetailed examination of the relationship between the various clauses of the standards is given inAppendix 2.

All three standards require a foundry to have:

■ a sound understanding of its environmental effects or impacts;

■ an environmental policy stating the intention and principles of the foundry in relation to itsoverall environmental performance;

■ objectives and targets which define broad environmental goals and more detailedperformance requirements;

■ an environmental management programme for achieving its objectives and targets;

■ appropriate control procedures covering its activities;

■ internal audits of its EMS.

Issue ISO 14001 EMAS BS 7750

Environmental policy ✓ ✓ ✓

Environmental effects aspects/impacts ✓ ✓

Legislative and other requirements ✓ ✓ ✓

Objectives and targets ✓ ✓ ✓

Programme ✓ ✓ ✓

Define responsibilities ✓ ✓ ✓

Identify training needs ✓ ✓ ✓

Procedures for internal communications ✓ x x

External communications Consider processes Give information xfor significant to public

aspects

Prepare statement x ✓ x

Environmental Statement validated x ✓ x

Maintain documented systems ✓ ✓ ✓

Procedures for controlling all required ✓ x ✓

documents

Records to be kept ✓ ✓ ✓

Conduct audits ✓ At least every ✓

three years

Table 3 Comparison between ISO 14001, EMAS and BS 7750

2.5 DIFFERENCES BETWEEN THE STANDARDS

For EMAS, there is the additional requirement to prepare a publicly available EnvironmentalStatement based on a preparatory environmental review (see Section 8). Other major differencesbetween the standards include:

■ Registers. ISO 14001 does not require the production of Registers of Environmental Effectsor Legislation (although certification bodies will need to see documentary evidence that theseelements of the EMS have been addressed).

■ Public availability. EMAS requires the environmental policy and both the description of theprogramme and the EMS to be publicly available, and to be published as part of anEnvironmental Statement. BS 7750 and ISO 14001 require the environmental policy to bepublicly available; BS 7750 also requires the objectives to be publicly available.

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■ Audits. ISO 14001 requires audits, although the frequency is not specified, nor is the auditmethodology set out in as much detail as in BS 7750 or EMAS. Separate ISO standards -ISO 14010, 14011 and 14012 - set out how audits should be conducted.

■ Contractors. The level of control over this group of workers in BS 7750 and EMAS is notmatched in ISO 14001, which requires only that EMS procedures are communicated to them.

■ Environmental Statement. EMAS requires an independently validated EnvironmentalStatement. BS 7750 and ISO 14001 do not require a statement at all.

2.6 THE BENEFITS OF ACCREDITED CERTIFICATION

Accredited certification by an independent registered authority4 to BS 7750, ISO 14001 and/orregistration to EMAS adds significantly to the credibility of your EMS. Existing and potentialcustomers are likely to be more favourably inclined towards a foundry that offers its managementsystem for independent assessment by a third party.

Also, once your foundry has been registered for EMAS, it will be able to use the official graphic andstatement of participation in letterheads, annual reports and other documents relating to your site.However, the EC Regulation does not allow you to use these symbols to advertise your products orservices because this could give the impression of product conformity to a European Standard.

2.7 LINKS TO THE BS EN ISO 9000 SERIES

Most foundries have now achieved certification to BS EN ISO 9002. The experience and skills gainedin this area will benefit those wishing to develop an EMS. As shown in Appendix 2, there aresignificant similarities between the approach adopted in BS 7750 and that used in theBS EN ISO 9000 series (formerly BS 5750).

However, there are certain fundamental differences between an EMS and a quality managementsystem (QMS). This is because an EMS is based upon managing environmental effects and a QMS isbased upon managing administrative processes.

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4 The United Kingdom Accreditation Service (UKAS) accredits bodies seeking to certify organisations to BS 7750 or to verifythat an organisation’s management process and environmental statement meet the EMAS criteria.

3.1 WHERE DO I START?

To a greater or lesser extent, all foundries have an impact on the environment, eg through dust andfume emissions, effluent discharges, solid waste and noise generation.

The main reason for establishing an EMS is to reduce the effect your foundry has on theenvironment. Before you can focus on the main issues, however, you need to have a clearunderstanding of your foundry’s processes and the way in which they affect the environment. Youcan then rank them in terms of their environmental importance and use the EMS to address thesignificant environmental effects.

This process of measuring and ranking the environmental effects of your foundry is known as theEnvironmental Effects Review. The key steps and requirements involved in completing theEnvironmental Effects Review are summarised in Fig 4. The format of this review is similar to anyother review of business operations. Once you have finished your Environmental Effects Review, youcan start to compile your Register of Environmental Effects (see Section 3.3).

Fig 4 Key steps in completing the Environmental Effects Review

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U N D E R TA K I N G A NE N V I R O N M E N TA L E F F E C T S R E V I E W

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Overview

■ Select review team

■ Define objectives

■ Set scope of review

Preparation

■ Assign responsibilities

■ Prepare checklists

■ Review background material

■ Communicate

Information gathering

■ Identify information sources

■ Collect data

Reporting

■ Collate results

■ Create register

■ Present to senior management

■ Agree follow-up

Evaluation

■ Compile list of allenvironmental effects

■ Identify significant and non-significant environmental effects

Issues to address

■ Company issues

■ Business functions

■ Office-based activities

3.1.1 Before you start

The Environmental Effects Review will provide you with a snapshot of the impact your business hason the environment. This will help you maintain compliance with environmental legislation andimprove environmental performance throughout your business activities. Through the reviewprocess, you will generate actions to be undertaken by your business.

Before embarking upon an Environmental Effects Review, it is important to communicate with thefoundry workforce. Let them know what you are planning to do and encourage them to startthinking about the part they can play.

Ways of communicating with employees include:

■ notice-boards;

■ internal magazines;

■ internal memos;

■ meetings (team, management, departmental);

■ briefings;

■ letters to employees at their home addresses.

You should also:

■ Consider how your business normally tells people about initiatives or new ideas and decidehow you can use these systems.

■ Even if the plan is to target specific parts of your business, still let everyone know about thereview but provide more information for those areas on which you are going to focus.

■ Not be frightened to ask employees for their ideas. Remember you want to improveperformance; those doing the job every day normally have ideas about how to do thingsmore effectively.

■ Consider communications between team members, even though your team may be small.Set up short, but frequent, meetings and make sure line managers are brought into theprocess.

■ Timetable review meetings well in advance.

■ Arrange a meeting with those senior managers who are not part of the team to ‘sell them’the review.

■ Identify who is responsible and make them aware that, on completion, they will have to signoff the review and thereby acknowledge responsibility. You may also need their authority toget other people to co-operate.

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3.1.2 Areas covered by the Environmental Effects Review

Fig 5 lists the areas which should be covered in your company’s Environmental Effects Review.

Fig 5 Checklist of issues to be addressed in the Environmental Effects Review

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Company issues Legal compliance ■■Emergency/contingency plans ■■Management structure ■■Employee awareness and training ■■Public relations ■■Market pressures ■■Purchasing policy ■■Contractor relations ■■

Business functions Process design/operation ■■Waste disposal ■■Solid waste management ■■Emissions/discharges ■■Water use/discharge ■■Raw materials ■■Storage on site ■■Transport and distribution ■■Energy sources/use ■■Product design ■■Packaging ■■

Office-based activities Energy use ■■Waste disposal ■■Paper use ■■Water use ■■

3.1.3 Sources of information

A considerable amount of useful information will already exist on site; Table 4 indicates a numberof possible sources.

Type Source How it will help

Regulatory consents. Operations manual. Records compliance or otherwise and indicatesareas of environmental concern.

Bills. Billing department. Shows the spend profile and indicates highestPurchasing department. area of spend. Indicates areas of largest potential

savings.

Operating procedures. Production manager. Shows how your business is operating and helpsPlant manager. understand processes and activities.Site manager.

Customer information. Sales manager. May indicate interests which customers have onenvironmental issues.

Waste disposal records. Production manager. Shows quantities and different types of wasteWaste manager. produced and disposed of. Also gives wasteRegulators. disposal costs and indicates possible areas where

waste reduction opportunities should be examined.

Records of past incidents. Site manager. Indicator of potential problem areas. Should alsoPlant manager. highlight existing management systems.Managing director.

Supplier information. Purchasing manager. Provides product specification sheets for rawmaterials and consumables.

General advice. Environmental Helpline. Provides advice on environmental issues andguidance on industrial best practice.

Table 4 Possible sources of information

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Environment Agency.

Scottish EnvironmentProtection Agency.

Environment andHeritage Service(Northern Ireland).

Trade associations.

3.1.4 Gathering information

There are a number of methods at your disposal for gathering information (see Table 5). You willprobably need to use a combination of these methods.

Method Advantages Disadvantages

Time consuming.If not handled well can raise unnecessary concerns.

Open to misinterpretation.Does not build commitment.Can provide mixed quality information.Will require validation.You only get what you ask for.

Likely to be superficial.May require follow-up.

Difficult to be systematic.Time consuming.

Will require follow-up.Can be open to misinterpretation andtherefore likely to be unsystematic.Limited opportunity to gather largequantities of information.You only get what you ask for.

Table 5 Methods of gathering information

Whichever approach you adopt, remember to set a timetable and allocate responsibilities. A GanttChart (see Fig 6) is a useful tool in this respect.

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Face-to-face interviews.

Questionnaire.

Telephone calls.

Meetings and discussion groups.

Letters.

Best and most reliable information.Builds commitment and understandingof why you are collecting information.Can be designed to be very systematic.Offers the opportunity to solveproblems.

Provides a consistent approach.Large quantities of information can begathered.Can provide focus in difficult areas.Very useful when the purpose is clear.

Immediate response.Useful for setting things in motion.Opportunity for feedback.

Informal.Good opportunity for feedback.Opportunity to build partnerships.Builds interest and commitment over the longer term.

Useful for getting things started.Simple way of reaching large numbersof people.Not time consuming.

3.2 WHAT CONSTITUTES AN ENVIRONMENTAL EFFECT?

The types of effect foundries need to consider include:

■ Controlled and uncontrolled emissions to atmosphere. For example, particulateemissions from a cupola furnace can normally be controlled by a filtration plant. Breakdownof the filtration plant or allowing the coke bed to be burnt away may lead to much higher,uncontrolled particulate emissions.

■ Controlled and uncontrolled discharges to water. In normal operations, the foundrycontrols its discharges to comply with its consents for trade effluent discharge to foul sewersor to surface drains. Equipment failure or deviation from planned operating procedures maylead to uncontrolled discharges above the foundry’s consent limits.

■ Solid and other wastes, eg packaging, waste sand, metal dross, slag.

■ Contamination of land, eg leakage of oil from storage sites, burial of foundry wastes,chemical leakage from drums.

■ Use of land, water, fuels and energy, and other natural resources. Foundries shouldconsider the visual impact of their site (buildings, car parks, waste skips, etc) and aim tominimise consumption of water, fuels and energy. Other natural resources used by foundriesinclude sand, metal, chemicals and gases.

■ Noise, odour, dust, vibration and visual impact (where these have not already beenaddressed).

■ Effects on specific parts of the environment and ecosystems. This covers any specificconditions which are relevant to your particular site, eg your site may be home to a rareorchid, toad or other protected species.

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Fig 6 Gantt Chart for an Environmental Effects Review

Assignment tasks

Scoping

Define objectives and scope

Preparation

Select review team

Prepare checklists

Review background material

Communication

Information gathering

Identify information sources

Collect data

Evaluation

Environmental effects

Reporting

Report to management

Agree action plan/performance targets

1 2 3 4 5 6 7 8 9 10

Week

Environmental effects fall broadly into two categories:

■ Direct. These are effects which are the immediate result of actions or operations by thefoundry, eg the emission of fumes and particulates to the atmosphere.

■ Indirect. These are effects which occur upstream or downstream of the foundry’s ownactivities. An upstream indirect effect might be one associated with a supplier’s operation; adownstream indirect effect might occur through the use of packaging, such as pallets andplastic sheeting, little of which is returned to the foundry for re-use.

Any environmental effects arising from incidents, accidents and potential emergency situationsshould also be included in the Environmental Effects Review.

3.3 REGISTER OF ENVIRONMENTAL EFFECTS

The Environmental Effects Review involves listing all your foundry’s environmental effects andassessing their significance using a systematic and rigorous methodology.

The environmental effects are documented in a Register of Environmental Effects which gives detailsof all those identified as significant.

This Register of Environmental Effects will play a central role in the formulation of the foundry’senvironmental objectives and targets, and subsequently its environmental programme. It is thesesignificant environmental effects which the EMS is intended to control.

The methodology for evaluating significant environmental effects will also identify the non-significant effects and justify why these are not subject to control by the EMS. In the first instance,these non-significant effects may include many of the foundry’s indirect effects. As the methodologyis repeated and as environmental performance is improved, some of the significant effects maysubsequently be deemed to be non-significant and vice versa.

The methodology for evaluating significant environmental effects is crucial to the effectiveness ofany EMS - whether or not it has been designed with BS 7750, ISO 14001 or EMAS in mind.

3.3.1 How do I set up a Register of Environmental Effects?

The steps involved in setting up a Register of Environmental Effects are:

■ prepare a list of all existing and potential environmental effects caused by your foundry;

■ assess their significance using a systematic ranking system;

■ compile the lists of environmental effects and completed evaluation forms into onedocument.

3.3.2 Preparing a list of environmental effects

The simplest way of gathering information about environmental effects is to consider eachdepartment, or each section within a department, in turn. Some issues, eg land contamination,energy and paper use, will need to be examined for the site as a whole.

Appendix 6 contains a blank checklist for you to photocopy and customise to create your own setof checklists. Fig 7 shows examples of the types of checklist you could produce.

The data from the checklists can then be used to prepare a list of environmental effects for eachdepartment. Fig 8 shows examples of the kind of effects that can be identified within a typicalfoundry coreshop or finishing shop. A blank environmental effects form is given in Appendix 6 foryou to photocopy and complete for the different departments of your foundry.

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Fig 7 Example checklists for establishing environmental effects

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CHECKLIST: WASTE MANAGEMENT

What waste is generated?

AREA: CONTACT: DATE:

Sheet.......of.......

DESCRIPTION OF PROCESS(ES):

Question Response Action Required

Are there restraints (financial, technical etc) preventing improvement?

What opportunities exist to minimise waste?

Are your staff aware of and involved in waste management?

How do you control and manage removal of waste?

What are the quantities and costs involved?

Do any statutory limits/requirements exist?

What are the problems arising from the current practice?

CHECKLIST: SITE MANAGEMENT

What would be a visitor’s first impression of the site?

AREA: CONTACT: DATE:

Sheet.......of.......

DESCRIPTION OF PROCESS(ES):

Question Response Action Required

Do potential problems exist with surrounding sites?

Have you received any complaints?

Have you any plans for improvement or development of the site?

Do you have records of previous land usage?

What are the current activities on the site?

What procedures exist for site management?

Who is responsible for site management and maintenance?

CHECKLIST: EMISSIONS TO ATMOSPHERE

What emissions are generated?

AREA: CONTACT: DATE:

Sheet.......of.......

DESCRIPTION OF PROCESS(ES):

Question Response Action Required

Do emissions create problems with the local community?

How could these emissions be reduced (by control or at source)?

Are there restraints(financial, technical etc) preventing a reduction in emissions?

How are they generated?

Which (if any) are released into the external environment?

Who monitors emission levels and by what method?

What data exist and what limits are applicable?

Fig 8 Examples of environmental effects in a foundry

The environmental effects list should be prepared by a senior member of staff or small task groupsset up to identify environmental effects by department or section. In some cases, it may be helpfulto combine both approaches. You will find it preferable to concentrate initially on the foundry’s‘direct’ effects before evaluating the ‘indirect effects’.

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DEPARTMENT: Finishing shop DATE: 12 Nov REF: FS

PROCESS ENVIRONMENTAL RECEIVING NOTES/COMMENTS

EFFECT ECOSYSTEM

Mould knockout Silica dust local atmosphere reduced by only knocking outVOCs local atmosphere moulds when fully cold

Casting decore Silica dust local atmosphere reduced by local ventilation system

Shot blasting Dust local atmosphere reduced by local ventilationsystem

Grinding

Hand dressing

Visual inspection

Final inspection

Radiography

N DT

Rework

IDENTIFYING ENVIRONMENTAL EFFECTS

DEPARTMENT: Coreshop DATE: 11 Nov REF: CS

PROCESS ENVIRONMENTAL RECEIVING NOTES/COMMENTS

EFFECT ECOSYSTEM

1 SHELLa) Material handling Dust local atmosphere reduced by sand bulk

handling system

b) Core manufacture Phenol local atmosphere reduced by control ofFormaldehyde local atmosphere process, eg box temperatureAmmonia local atmosphere

2 PEPSET

a) Material handling

i) Silica sand Silica dust local atmosphere reduced by use of silo systemii) Resin materials Solvent fume local atmosphere bulk handling system reduces

effectSpillage water via drains bund wall around storage area

b) Sand mixing Solvent fume local atmosphere

c) Core manufacture Pyridine local atmosphereMDI local atmosphere

3 COLD BOX

a) Material handling

i) Silica sand Dust local atmosphere pneumatic sand system minimises emissions

ii) Resin material fumes local atmosphere

b) Core manufacture MDI local atmosphere Amines local atmosphere effect reduced by use ofAromatic solvent local atmosphere local ventilation system andPhenol local atmosphere monitored on a monthly basisFormaldehyde local atmosphere

4 ALKALINE PHENOL

a) Material handling Dust

b) Core manufacture Phenol local atmosphereFormaldehyde local atmosphere

IDENTIFYING ENVIRONMENTAL EFFECTS

This list of environmental effects should be discussed with departmental managers or section leadersand amended as necessary. Input from various members of staff will help to foster a feeling ofinvolvement in the EMS from an early stage.

As a ‘Best Practice’ approach, you may want to involve other interested parties in establishing thelist of environmental effects, for example:

■ Local environmental regulators. As well as confirming that all regulatory requirementshave been addressed this would demonstrate openness and further improve your relationswith the regulator.

■ Local interest groups. By consulting local residents and others affected by your site’soperations (noise, dust, smells, etc) you would communicate your intentions to reduce yourfoundry’s environmental impact and further improve public relations.

The effect of different operating conditions

It is necessary to consider each of the environmental effects, eg airborne emissions, under normal,abnormal and accidental operating situations. These are defined as follows:

■ normal operating conditions exist as a result of routine operation according to thefoundry’s normal operating procedures;

■ abnormal operating conditions are planned deviations from normal procedure, eg frittinga coreless induction furnace lining, or start-up situations following a shutdown;

■ incidents or accidents are unplanned events having effects beyond those normallyencountered.

The influence of past and future site activities should also be considered when determining theoverall significance of an environmental effect. Past activities relate to previous site operations whichmay have led to contamination of land or water.

3.4 ASSESSING THE SIGNIFICANCE OF YOUR ENVIRONMENTALEFFECTS

The next task is to assess the significance of each of the environmental effects you have identified.Use of a numerical ranking or rating system is generally recommended.

An environmental effect may be considered significant if it:

■ is controlled by legislation;

■ has the potential to cause demonstrable damage to the environment;

■ is of concern to interested parties (these include environmental regulators, local residents, thefoundry’s workforce, investors, insurers, customers, environmental interest groups and thegeneral public).

3.4.1 An example methodology for evaluating significantenvironmental effects

The points scoring system described in this Guide is similar to the methodology advocated by theInstitute of Environmental Management5. While it provides an example of the type of methodologyyour foundry will need to develop, there is no universally applicable approach.

You should choose, and be able to justify, an approach which is appropriate for yourorganisation and develop a methodology which is tailored to the particular circumstancesof your site.

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5 A similar methodology was used by Wolstenholme International Ltd to obtain BS 7750 and registration to EMAS. Thissuccess is described in GC49 which is available free through the Environmental Helpline on 0800 585794.

The two-step process presented here awards a numerical score to each environmental effect toquantify the relative importance of different criteria. You should adjust and review the scoringsystem to suit the circumstances of your company and your particular site.

Step 1: Normal operating conditions

For normal operating conditions, each environmental effect is awarded a score to reflect the relativeimportance of:

■ legislation (both current and forthcoming);

■ environmental damage, eg toxicity, acidity, greenhouse gas emissions, ozone-depletingsubstances;

■ interested parties, eg the reaction of the local residents, environmental interest groups;

■ quantity, eg the volume of the waste stream or the frequency of occurrence at the foundry.

The matrix shown in Table 6 illustrates the way in which a particular environmental effect can bescored under normal operating conditions.

The scores are multiplied by a weighting factor, which reflects the overall importance of the criterionat a particular site or within a particular company. You should adjust these as necessary to reflectyour foundry’s concerns. Adding the four multiplications together produces a total score for thisenvironmental effect under normal operating conditions. This total score is then used to rank theparticular environmental effect under normal operating conditions.

Table 6 Matrix to rank environmental effects under normal operating conditions

Step 2: Other operating conditions

The same environmental effect is also awarded a numerical score under other operating conditionsto reflect the importance of four further criteria:

■ abnormal operations, eg factory start-up after a holiday shutdown period;

■ accident/emergency, eg fire, accidental damage;

■ past activities, eg activities of former site occupant, burial of foundry waste on site;

■ planned activities, eg new product or production line, site development.

The four scores are again added to produce a total score under other operating conditions (seeTable 7). This total score is used to rank the environmental effects under other operating conditions.

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Score Weighting

3 2 1 0 factor

Legislation Existing Impending None x 2 = a

Environmental Known Possible Limited No x 3 = bdamage detriment detriment detriment detriment

Interested Considerable Moderate Little No x 2 = cparties interest interest interest interest

Quantity High Medium Low Nil x 3 = d

Normal operating conditions total score = (a + b + c + d)

Table 7 Matrix to rank environmental effects under other operating conditions

An example of a completed environmental effect evaluation sheet is shown in Table 8. Appendix 6contains a blank form which you may wish to photocopy for use in your foundry.

Table 8 An environmental effects evaluation form completed using ranking matrices

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EVALUATION OF ENVIRONMENTAL EFFECTS

EFFECT: Airborne emissions DATE: 20 Nov REF: CP

DEPARTMENT/PROCESS: Metal melting cupola plant

NORMAL OPERATING CONDITIONS

Score Weighting

3 2 1 0 factor

Legislation 3 x 2 = 6

Environmental damage 3 x 3 = 9

Interested parties 3 x 2 = 6

Quantity 1 x 3 = 3

Normal operating conditions total score = 24

Score

12 6 3 0

Abnormal Increased No change Reduced = aoperations environmental environmental

impact impact

Accident/ Increased No change Reduced = bemergency environmental environmental

impact impact

Past activities Evident/ Possible No damage = crequires action damage/difficult

to evaluate

Planned Increased No change Reduced = dactivities environmental environmental

impact impact

Other operating conditions total score = (a + b + c + d)

EVALUATION OF ENVIRONMENTAL EFFECTS

EFFECT: Airborne emissions DATE: 20 Nov REF: CP

DEPARTMENT/PROCESS: Metal melting cupola plant

OTHER OPERATING CONDITIONS

Score

12 6 3 0

Abnormal operations 6 = 6

Accident/emergency 6 = 6

Past activities 6 = 6

Planned activities 3 = 3

Other operating conditions total score = 21

3.4.2 What is significant?

A significant environmental effect is one which scores more than a certain number of points eitherunder normal or other operating conditions. Some effects may be significant in only one category,others in both.

Using this methodology, the maximum possible score in either normal or other operating conditionsis 30. In the example shown in Table 8, significant environmental effects were taken as those whichscored 15 or more points. Airborne emissions from the metal melting cupola plant of this fictitiousfoundry therefore have a significant environmental effect under both normal and other operatingconditions.

It is the foundry’s responsibility to set the threshold score for environmental significance.

As a result of this process, you will identify the significant environmental effects which you will planto control through your EMS and this should be reflected in your environmental policy (see Section 4). The next step is to produce a programme of action by setting objectives and targets foreach significant environmental effect (see Section 5). The programme must be realistic and thetimescales for achieving objectives and targets should reflect the commercial needs of yourcompany. For certification or registration to an EMS standard you will need to demonstrate yourcommitment to reducing the environmental impacts of all your significant environmental effects.However, economic constraints may play a role in prioritising which environmental effects areaddressed first.

3.5 COMPILING YOUR REGISTER OF ENVIRONMENTAL EFFECTS

The collection of completed lists of environmental effects and evaluation forms you have producedconstitutes your Register of Environmental Effects. The format of the Register makes it readilyaccessible and easily referred to during subsequent reviews.

The completion of an environmental review is only the first stage in the development of an EMS.While the ultimate goal is to implement an EMS, you are recommended to initiate any no-cost orlow-cost, effective actions identified during the course of the review.

It is also important that the procedures to prepare a list of environmental effects, assess theirsignificance and compile the Register of Environmental Effects are documented (see Section 6).

The method used to compile the Register described in this Guide is not the only one that can beused. However, it is important that the approach adopted:

■ is systematic;

■ can be explained and justified by the Management Representative.

This is particularly important if the EMS is to be audited for accredited certification.

The Environmental Effects Review establishes the foundry’s priorities and leads directly to thedevelopment of the company’s environmental policy statement, followed by setting objectives andtargets as part of the overall EMS. In this way, the Review forms a key part of the foundry’s overallbusiness strategy.

3.6 REGISTER OF LEGISLATION

It is important to be aware of and understand the environmental legislation affecting your foundry.This knowledge will also help you to highlight the key processes which are likely to have an impacton the environment.

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A Register of Legislation is a requirement of BS 7750 and is a very useful method of summarisingyour obligations for compliance. This register should also list approved codes of practice.

For BS 7750, the site must have in place a procedure to ensure that the Register of Legislation isupdated regularly to reflect changes in legislation, new legislation and any changes in the foundry’sprocesses or activities. Advice on current and proposed legislation governing foundries is availablefrom the Environmental Helpline on 0800 585794.

Advice on how to develop a Register of Legislation is given in Appendix 3, which alsocontains an example completed Register. A blank form for you to photocopy and use inyour foundry can be found in Appendix 6.

Maintaining a Register of Legislation can help you to:

■ ensure continued compliance with existing legislation;

■ be aware of any future relevant legislation.

The Register of Legislation is therefore an important strategic tool for your foundry.

EMSs are of increasing interest to Regulators who appreciate that such systems incorporate acommitment to legal compliance and a systematic approach to maintain awareness of regulatoryrequirements and ensuring that they are met. A good EMS will allow management to monitor legalcompliance with confidence and allow for the rapid correction of variations from regulatoryrequirements. Provided that compliance can be routinely demonstrated, it is likely that, in time,Regulators will acknowledge these advantages in the way that they schedule inspections. This couldbe reflected in reduced regulatory charges.

It is important to remember that environmental effects not covered by legislation shouldalso be included in the Environmental Effects Review.

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Every aspect of a foundry’s operation - from accounting and purchasing, to product design,manufacture, sales and marketing, and distribution - has an impact on the environment. However,not all aspects will be evaluated as having a significant environmental effect. Your company’senvironmental policy should reflect your recognition of this fact and the findings from yourEnvironmental Effects Review.

4.1 THE ENVIRONMENTAL POLICY STATEMENT

A foundry’s Environmental Policy Statement is the cornerstone of its entire EMS. TheEnvironmental Policy Statement:

■ states the aims and principles of action with respect to the foundry’s impact on theenvironment;

■ enables the foundry’s management to communicate its environmental priorities to bothemployees and other interested parties.

Your foundry’s environmental policy should show a commitment to maintaining compliance withrelevant environmental regulations and to continual environmental improvement. The policy shouldbe reviewed regularly in line with management reviews and in the light of internal or external auditfindings (see Section 7).

An Environmental Policy Statement should be:

■ realistic and practicable;

■ as concise and definitive as possible;

■ relevant to the foundry’s activities and products and its significant environmental effects.

The policy will be used to set objectives and targets (see Section 5). It is important, therefore, thatthe policy is adopted at all levels within the foundry and there is a clear and demonstratedcommitment to the policy at the highest managerial level.

While the aim is to work towards limiting the foundry’s environmental impact through a programmeof continual improvement, each foundry should set its own targets taking into accountlegislation and incorporating its own objectives. It is important that the foundry should notoverstretch its resources in improving its environmental performance.

4.1.1 The content of an environmental policy

Although there is no standard format for an environmental policy, different policies normally containthe same themes, ie:

■ a commitment from senior management;

■ a recognition of responsibilities;

■ a commitment to train employees and disseminate information regarding the policystatement;

■ a willingness to implement initiatives to achieve objectives and targets.

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P R E PA R I N G Y O U RE N V I R O N M E N TA L P O L I C Y

4

The principles listed in Fig 9 may help you to produce a draft policy appropriate for your business.Try to make the statements you include as specific as possible to your business.

It is important that the document is signed by the senior person in the company, or in the case of amulti-site operation, by the chief executive of the ultimate holding company. In the case of a multi-site operation, there may be a number of group or divisional operating statements which, whencombined, represent the view of the holding company.

An example of an Environmental Policy Statement is shown in Fig 10 overleaf.

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Fig 9 Principles to be addressed in an environmental policy

Your business should:

■ Comply with the requirements of environmental legislation and approved codes ofpractice.

■ Assess the environmental impact of all past, current and future operations and setobjectives/targets to reduce these impacts.

■ Continuously seek to improve its environmental performance.

■ Reduce pollution produced in all parts of the business.

■ Include environmental considerations in investment decisions.

■ Foster the commitment of all employees to improve the environmental performance ofthe business.

■ Aim to reduce the use of all materials, supplies and energy and, wherever possible, userenewable or recyclable materials and components.

■ Report publicly on environmental objectives and targets.

■ Strive to adopt the highest environmental standards.

■ Expect similar environmental standards from all third parties (suppliers, vendors,contractors).

■ Assist customers to use the company’s products and services in an environmentallysensitive way.

■ Liaise on a continuous basis with the local community.

■ Assist in developing economically viable solutions to environmental problems in thefoundry industry.

Fig 10 Example of an Environmental Policy Statement

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As a result of your Environmental Effects Review (see Section 3), you will have identified andprioritised specific areas which need to be addressed to improve environmental performance. Thenext step is to set specific short-term and long-term objectives and then break these down intorealistic targets or milestones.

5.1 OBJECTIVES AND TARGETS

BS 7750 defines objectives as ‘broad goals arising from the environmental policy and effectsevaluation that an organisation sets itself to achieve and which are quantified wherever practical’.

The British Standard states that targets are ‘detailed performance requirements, quantifiedwherever practical, applicable to the organisation or parts thereof, that arise from the environmentalobjectives and that need to be set and met in order to achieve these objectives’.

Objectives and targets should be set with a view to realising, over a period of time, improvementsin environmental performance. They should be both measurable and achievable. For example, theaim of reducing the disposal of foundry sand by 25% in the first year should be adopted only if thereis a realistic possibility of achieving it.

5.1.1 Setting objectives and targets

As your foundry’s objectives are based on the Register of Environmental Effects, your company isdeclaring its intentions regarding environmental matters by setting and publishing its objectives.

It is vital that objectives are reviewed regularly and that your environmental policy is updated toreflect any amendments. However, all objectives and targets should be capable of being revised toreflect any significant change in business activity or environmental effects.

5.1.2 Using an Information Matrix

For goals to be realised, employees have to be given responsibility for achieving them within anallotted timescale. Preparing an Information Matrix, such as the one shown in Fig 11, can help. It isimportant to set specific completion or reporting dates. As well as setting specific dates, objectivesshould provide for continuing improvement in overall environmental performance - though notnecessarily in all areas simultaneously.

S E T T I N G G O A L S5

Fig 11 Example Information Matrix

5.1.3 Monitoring environmental performance

Having set your objectives and targets, it is necessary to measure performance against them. Just asyour company’s accounts department monitors the foundry’s financial performance, soenvironmental performance can be monitored by reference to environmental records.

In this context, your accounts department can provide valuable support services to your foundry’sEMS, through:

■ the ability to gather and analyse data;

■ the identification of likely areas of cost or waste control;

■ assistance in setting objectives and targets over various time spans.

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Objective Responsibility Target Completedcompletion date

Objective 1 Stanley Smith 6 June (Year 2)- Reduce energy use for

electric meltingTarget 1 5% reduction Paul Jones 25 Aug (Year 1) ✓

Target 2 7.5% reduction Paul Jones 25 Dec (Year 1) —Target 3 10% reduction Paul Jones 6 June (Year 2) —

Objective 2 Stanley Smith 20 Oct (Year 1)

- Reduce new sand consumption in moulding bay

Target 1 10% reduction Jerry Twose 16 April (Year 1) ✓

Target 2 15% reduction Jerry Twose 10 July (Year 1) ✓

Target 3 20% reduction Jerry Twose 20 Oct (Year 1) —

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Although your foundry is free to develop its own EMS, most foundries will probably follow theexisting guidelines laid down in British Standard BS 7750 and the International Standard ISO 14001.For the purpose of this Guide, the format of BS 7750 is followed.

BS 7750 and ISO 14001 provide a specification for an EMS for ensuring compliance with statedenvironmental policies and objectives. The specifications are designed to enable any organisation toestablish an effective management system as a foundation for both sound environmentalperformance and participation in environmental auditing schemes. The EMS does not need to beindependent of existing management systems and can, for instance, share common principles withthe BS EN ISO 9000 series, the internationally recognised quality system standards.

6.1 PREPARATIONS AND PLANNING

Before starting to implement your EMS, you should take time to plan and consider important issues.

6.1.1 Aims

You should be clear about:

■ the main reasons for implementing an EMS;

■ what you will aim to achieve;

■ whether or not you wish to pursue accredited certification.

The foundry should also decide whether the EMS will incorporate existing quality management orhealth and safety systems.

6.1.2 Resources

Establishing an EMS requires the allocation of resources, in particular, of time and people.

The Management Representative

Senior management should nominate a Management Representative to manage and co-ordinatethe programme, drawing on the skills of others as required. If possible, the ManagementRepresentative should be supported by an advisory group of two or three people, eg the QualityManager plus the Plant Manager.

The Management Representative should be given the necessary responsibility and authority toensure that the requirements of the EMS are implemented and monitored. Some knowledge ofenvironmental matters and quality systems is useful for this position. If this is not the case, trainingshould be provided.

In small to medium-sized foundries, the position of Management Representative is likely to be apart-time responsibility. If this is the case, it is important to ensure that there is no conflict of interest.It is also wise to nominate a deputy who is able to act, if necessary, on behalf of the ManagementRepresentative.

6.1.3 Employee involvement and communication

The success of your EMS depends ultimately upon gaining the commitment and involvement, of notonly senior management, but also the entire workforce. All employees should understand that thiscommitment is not short-term and that the development of an EMS is the first step on the road to

I M P L E M E N T I N G Y O U RF O U N D R Y ’ S E M S

6

continuing improvement - ‘a journey without a destination’ in the parlance of Total QualityManagement.

An effective EMS requires:

■ a top-down commitment from senior management;

■ an efficient two-way communication system that allows all employees to be kept fullyinformed of environmental matters.

In addition to commitment from senior management, good leadership is also paramount. If theenvironmental policy and EMS are to become firmly established, they should be a regular item onthe agenda of the foundry’s board meeting and subject to regular management review.

All employees should be aware of the significance of the foundry’s EMS and clearly understand theirown roles in respect to its environmental policy and objectives. The foundry management shouldexplain:

■ why it is going down this route;

■ the benefits to the company, its employees and the environment;

■ how the employees can contribute;

■ who will manage the programme.

Proven techniques can be used for communicating the management message, including:

■ team briefings;

■ one-to-one conversations;

■ notice-boards;

■ company newsletters.

Maintaining good communications with external authorities is also important, particularly whenresponding to enquiries regarding the foundry’s environmental effects and EMS.

The scope and depth of knowledge and understanding will vary throughout the company. Themanaging director is likely to have a broad overview of environmental matters while shopflooroperators need to realise the particular environmental effect of their own activities. Employeesshould be encouraged to make suggestions for improvement which can subsequently be built intothe system. In this way, employees will both ‘buy into’ the system and assume ownership of it.

Obtaining commitment generates motivation throughout the workforce.

6.1.4 Training

Many employees and potential employees already have a commitment to the environment in theirhome life which they are keen to extend to their working life. That commitment can prove avaluable resource. Experience has shown that following training, staff are more likely to come upwith useful ideas which can be translated into workplace action.

Many breaches in regulatory consents and authorisations occur as a result of human error ratherthan equipment failure. Training your workforce will help your company avoid such breaches. It willalso make your EMS more effective in terms of saving you money.

Everyone in the foundry will be involved in developing, resourcing, reviewing or complying with thefoundry’s environmental policy. They should all be given adequate training in the relative technicaland legislative issues. This should also apply to all new employees. An employee’s job descriptionand performance appraisal should include those activities which affect environmental performanceand take into account the company’s objectives and targets.

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An environmentally ‘literate’ workforce offers a number of other benefits to the company. Youremployees are often your best ambassadors. Understanding the issues and being able to talk topeople in the community about your progress in improving your environmental performance willenhance the public image of your foundry.

Determining training needs

Each employee may require different elements of education and training. These can be identifiedthrough a process of Training Needs Analysis. Each foundry will require flexible and ongoing trainingprogrammes covering different issues and operations.

The areas of the training programme can be divided into:

■ developing environmental awareness for all;

■ building a strategic understanding of the EMS for managers (breadth of knowledge);

■ explaining work instructions and developing technical skills for operators.

The Management Representative may also require training and regular ‘updating’ on legislative,environmental and market developments.

As a starting point in determining training needs, you may find it useful to ask questions such as:

■ Does our workforce fully understand the content and implications of the foundry’senvironmental policy?

■ Do managers possess a good understanding of how the EMS provides control overthe company’s significant environmental effects?

■ Do operators understand the environmental effects of their own activities?

■ Is there general awareness of:

- the relationship between energy use and the environment?

- the need for waste minimisation and recycling?

■ Are marketing and sales staff aware of the competitive advantages to be gained fromadopting a ‘green image’?

Training methods

There are a variety of methods of developing environmental awareness, knowledge and skills in yourworkforce. They include:

■ newsletters/house magazines;

■ internal seminars, workshops and lectures;

■ video presentations;

■ external seminars, workshops and conferences.

When choosing a training method, the foundry should consider its target audience and the level ofunderstanding needed. Environmental training should be included in the induction programme fornew employees.

Training needs should be identified and records kept as evidence for BS 7750, ISO 14001 and EMAS.Feedback and follow-up to any training activity is essential; increased awareness and skills followingthe training activity can only be assessed through interview and discussion.

6.2 WHERE DO WE START?

The process of implementing an EMS should be based upon an effective project managementframework to make optimum use of the foundry’s resources.

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6.2.1 The Management Programme

This is at the heart of the EMS. The Management Programme is the key to the foundry achievingcompliance with its environmental policy and provides a structured approach to meeting thefoundry’s objectives and targets.

The Management Programme should be allocated sufficient money and effort.

The Management Programme ensures that a suitable organisational structure exists to allow thedelegation of responsibilities for achieving the objectives and targets.

As described in Section 5.1.2, creation of an Information Matrix (see Fig 11) allows scheduling ofthe actions necessary to meet the company’s objectives. The Matrix makes it clear who has beenassigned specific tasks, together with the agreed timescales for meeting targets. In this case theManagement Representative would combine all the individual information matrices into an overallschedule to form the Management Programme.

Any of the foundry’s activities carried out by outside contractors could be covered by theManagement Programme and managed as individual projects. You could also show your suppliersthe company’s environmental policy and assess the likely impact of their activities on your foundry’soperations.

The Management Representative is responsible for monitoring the progress of the ManagementProgramme and this provides valuable information for the Environmental Management Reviewprocess (see Section 7.7).

6.2.2 Documentation

Documentation is necessary to describe and support the EMS. As part of its EMS, the foundry hasto maintain procedures for controlling its documentation. It is important that any documentation isreadily identifiable and undergoes periodic revision and review.

Senior management has the task of deciding the format of the EMS documentation. However, itshould normally consist of the seven layers listed in Fig 12.

Fig 12 Documentation hierarchy

(Source: EMAS Pilot Report, R. Hillary, 1995)32

Policy,objectives

and targets

Statement

System manual

Register ofEnvironmental

Effects

Register ofLegislation

Procedures

Work instructions

Records

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The Management System Manual

This Manual forms the basis of your foundry’s EMS and should, therefore, be relevant to theoperations and processes employed. It provides a central point of reference to the implementationand maintenance of the overall system. It is usually produced, maintained and controlled by theManagement Representative.

The Management System Manual should be:

■ concise and well structured;

■ able to be used as a key reference document for third party assessment to BS 7750,ISO 14001 or EMAS.

The Manual and associated documentation can either be produced as a paper copy or be availableon computer. It should be sufficiently detailed to prove to any auditor of the management systemthat it is fit for purpose, given the nature of the environmental effects involved.

The Manual can cover your entire operation or, if the foundry is an operating division of a largerorganisation, be on a divisionalised or even departmental basis. It should:

■ contain a brief introduction to the foundry and its activities;

■ outline the company’s environmental policy, and summarise its significant environmentaleffects, objectives and targets, and its Management Programme;

■ define key roles and responsibilities;

■ identify the role of the Management Representative;

■ indicate how the requirements of the EMS standard will be met;

■ cross-reference procedures, eg process authorisations, work instructions and other relevantdocumentation;

■ highlight any emergency plans.

Procedures

A range of procedures and work instructions supports the EMS, including those for:

■ organisational responsibilities;

■ communication;

■ training;

■ management manual;

■ production of registers;

■ non-compliance and corrective actions;

■ complaints;

■ records and archiving;

■ document control.

A more complete list is given in Appendix 4. This can be used as a comprehensive guide.

Foundries wishing to pursue certification to BS 7750/ISO 14001 or registration to EMAS will needto provide written evidence to enable the certification body to demonstrate that each of theseprocedures is established and in operation. Where suitable procedures already exist, eg complaintsor training procedures, there is no need to duplicate them for the EMS. However, the proceduresand supporting documentation must be clearly referenced in the Management System Manual.

If your foundry has already implemented BS EN ISO 9002, you will find that some of theseprocedural requirements, eg document control, records and archiving, are also applicable to the

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needs of your EMS. For other EMS procedures, the documentation can often be designed to addressseveral procedures at once. For example, a well-written and disseminated environmental policyshould address all the procedural requirements of the ‘policy’ clause in BS 7750 (see Appendix 4)and may also address many of the procedural requirements of the ‘communications’ clause.

6.2.3 Operational control

As part of your foundry’s EMS, you need to ensure that the foundry’s significant environmentaleffects are being controlled on a daily basis.

Good business practice in your foundry should already have created work instructions to provideoperational control of your processes and activities. For your EMS you should ensure that employeeson the shopfloor are provided with detailed work instructions that cover processes which havesignificant environmental effects. The application of work instructions and procedures should, ifnecessary, be extended to cover suppliers and any contractors working on site.

Document control is paramount, and work instructions should be:

■ identifiable;

■ current;

■ available on location;

■ destroyed when obsolete.

There are three aspects to operational control, as shown in the control loop in Fig 13.

Fig 13 The operational control loop

Following the evaluation of significant environmental effects, a control measure or procedure isagreed to minimise a particular adverse effect and corrective action is carried out to establishcontrol. A process of verification is then performed to establish the effectiveness of control.

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Control

Verification Corrective action

Statutory measurements are generally regulated through equipment procedures, records and results.You have to provide, through your Management System Manual and work instructions, details ofthe verification methods employed.

Your documentation must also indicate clearly - in the event of a non-compliance arising eithersuddenly or over a period of time - who has the responsibility for initiating an investigation andsubsequently instituting the necessary permanent corrective action. Problems can arise in a numberof ways, including:

■ plant failures or deficiencies;

■ human error;

■ shortcomings in the EMS itself.

Any changes to the previously adopted procedures arising from an investigation should be recorded.In addition, the appropriate work instructions should be amended and circulated, those previouslyissued being deleted and withdrawn.

6.2.4 Records

The purpose of the foundry’s record system is to:

■ demonstrate compliance with the requirements of EMS standards;

■ determine the extent to which targets and objectives have been met in line with the foundry’soverall environmental policy.

Records are the evidence of the ongoing operation of the foundry’s EMS. They should be conciseand avoid unnecessary documentation; those records arising from other parts of the organisation’smanagement system, eg BS EN ISO 9002, need not be duplicated - although they must be clearlyreferenced.

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Example of operational control

A foundry continuously desulphurises its cupola-melted cast iron as a prerequisite forproducing nodular cast iron. The foundry decides, after carrying out an environmentaleffects evaluation, that the atmospheric release of acetylene gas (resulting from thereaction between unused calcium carbide and moisture in the air) is significant.

Control. May involve achieving greater efficiency of mixing between the calciumcarbide and the iron, less variation in the addition of carbide, and more effectivedamping-down of the slag generated from the reaction.

Corrective action. Improved procedures may be introduced together with specificsupervisor/operator training relating to the recalibration of the calcium carbidefeeding system, resetting and control of the nitrogen flow rates in the reaction vessel,and a system introduced to prevent unauthorised access to the control system.

Verification. Could include closer monitoring of the process, ie carbide addition levels,reaction times, handling times for the processed slag. Having successfully improvedcontrol, the work instructions and procedures are amended accordingly.

Types of records required for an EMS

The records to be maintained are generally decided by the Management Representative, with theadvice of the Quality Manager (if applicable). The Management Representative should also decideupon the retention time for the various records. This must take into account any statutoryrequirements and guidelines and must also be documented.

Your record system should include:

■ the Register of Legislation;

■ the Register of Environmental Effects;

■ reports of audits and reviews;

■ details of any failures to comply with policy and corrective actions taken;

■ details of any incidents and follow-up actions taken;

■ details of any complaints and follow-up actions taken;

■ appropriate supplier and contractor information;

■ inspection and maintenance reports;

■ raw material identification and composition data;

■ monitoring data;

■ environmental training records.

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An environmental audit should not be confused with the initial Environmental Effects Review. Whilethe Environmental Effects Review ‘kickstarts’ the EMS, internal audits maintain its momentum. Theaim of this Section is to help your foundry develop a framework for conducting its own internalenvironmental audits and management reviews.

In addition to ensuring that your EMS is operating correctly, a further benefit of environmentalauditing is maintaining increased environmental awareness and a sense of responsibility among youremployees.

7.1 AIMS

The aim of an internal audit (see Fig 14) is to assess whether your foundry’s current activitiescomply with the manuals, work instructions and procedures which form part of the EMS and theorganisation’s environmental policy, objectives and targets.

Fig 14 The audit process

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71. Select audit team

2. Prepare audit checklists

1. Perform audit

2. Evaluate audit findings

3. Identify non-compliances

1. Issue non-compliance report

2. Identification of corrective actions by management

3. Follow-up activities

Planning the audit

Conducting the audit

Post-audit action

To be effective, an audit should be:

■ an integral part of your environmental management system;

■ carried out in a systematic, documented and objective manner.

The findings and recommendations of any audit must be reviewed and assessed; follow-up actionsshould be implemented according to a specified programme. In some cases, action must be takenimmediately, eg where a lapse in procedures has led to possible non-compliance with legislativerequirements.

External audits provide the basis by which accredited third parties assess a company’s EMS againstnational and international standards such as BS 7750 and ISO 14001. This assessment is a precursorto a company achieving and then maintaining registration/certification. This topic is discussed inmore detail in Sections 8 and 9.

7.2 SELECTING AUDITORS

In selecting suitable people to carry out your internal audits, two main factors should be taken intoaccount:

■ they should not have direct management responsibility for the part of the organisation beingaudited;

■ they must have sufficient expertise to carry out the audit effectively.

Achieving both of these aims can sometimes be difficult. If there is conflict, it is often better tochoose an auditor with appropriate expertise even if this means some loss of independence.

7.2.1 Skills required by auditors

Whatever the case, the employees chosen to be auditors need skills and experience in the areas of:

■ management systems auditing;

■ the relevant EMS standard(s);

■ industry knowledge;

■ appropriate knowledge of environmental legislation and issues.

Many external organisations offer suitable environmental auditing training courses. Some foundriesmay encourage employees to become affiliate members of the Institute of EnvironmentalManagement.

If you already have employees with knowledge and experience of the auditing process forBS EN ISO 9002, these people would be well-suited to become internal auditors for the EMS.However, it is important to remember the fundamental difference between an EMS and a QualityManagement System (QMS). A QMS is based upon managing administrative processes, whereas anEMS is based upon managing environmental effects.

7.3 SCOPE

Your Management Representative should design the scope of your internal audit based on your EMSprocedures and work instructions. The audit should be related to the achievement of the foundry’senvironmental policy, objectives and targets. One of the first tasks should be to address the currentstate of legal compliance.

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If your foundry is already running other management systems and provided the EMS has beensufficiently integrated into them, it should be possible to audit the systems simultaneously. Theadvantages of this include:

■ saving time and money;

■ fewer auditors;

■ a better understanding of the areas where the management systems could be furtherconsolidated in the future;

■ highlighting specific areas where the management systems are not compatible.

The disadvantages include:

■ the auditor(s) may not be competent to audit all the management systems;

■ the complexity of the auditors’ task is increased.

Thinking about certification/registration?

If you intend ultimately to seek certification/registration to one of the accepted environmentalstandards, you should bear in mind that the third party assessment will place considerable emphasison the effectiveness of your internal audit process. Good quality internal auditing will save time,effort and money if the certifier/verifier can rely on it with confidence as the basis for their ownassessments. In particular, the assessors will consider:

■ the frequency at which internal audits are carried out;

■ the competence, experience, training and independence of the auditors involved;

■ audit procedure and methodology;

■ references and standards employed;

■ any checks and verifications performed;

■ the resources available for the audit.

7.4 FREQUENCY

The frequency of audits should be based upon the significance of the associated environmentaleffects. In the case of a foundry, emissions to air are likely to be audited more frequently than thoseto water.

To comply with the requirements of EMAS, you must audit all parts of the EMS between successiveenvironmental statements, ie at least once every three years.

The frequency and sequence of audits should be compiled into an audit timetable which shows thearea to be audited, the date/time and the auditor(s) involved. The audit timetable is normallyprepared and co-ordinated by the Management Representative.

7.5 THE AUDIT PROCESS

The auditor investigates whether the foundry’s EMS is effective and fulfils the company’s objectives.Auditors normally conduct an audit trail following several parts of the system from start to finish,speaking to different employees throughout the foundry to satisfy themselves that the system isworking.

It is helpful if the auditor or audit team prepares checklists at the beginning of the audit. This ensuresthat all areas within the scope of the audit are covered. Each checklist should list all the EMSprocedures relevant to the area under review. The procedures to be audited may vary betweendifferent operational areas.

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The content and scope of the checklists should be reviewed at the beginning of each audit.

Documents for recording non-compliances and other audit notes should also be prepared. Theauditor should also gather reference information about the area under surveillance such as plans,lists of procedures and records.

An example audit checklist for the coreshop of a fictitious foundry is shown in Fig 15 and thecorresponding non-compliance/observation note in Fig 16. A blank checklist for an internalenvironmental audit and a blank non-compliance/observation note are given in Appendix 6 for youto photocopy and use in your foundry.

Fig 15 An example environmental audit checklist

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ENVIRONMENTAL AUDIT CHECKLIST

AUDIT NO: CS/4 DATE OF AUDIT: 18/6

AUDIT CONDUCTED BY: J. Richards AUDIT AREA: Coreshop

Proc/BS 7750 Ref. BS 7750 requirement Compliance Comments/NotesY/N

4.3.4 Training Y

4.4.1 Communications Y

4.4.2 Environmental effects N New process employedbut environmentaleffects not re-evaluated(See Non-ComplianceNote CS/4)

4.5 Objectives & targets N Ref. 4.4.2

4.6 Programme N Ref. 4.4.2

4.7.1 Manual N Ref. 4.4.2

4.7.2 Documentation N Ref. 4.4.2

4.8.2 Operational control N Ref. 4.4.2

4.8.3 Verification & testing Y

4.8.4 Corrective action Y

4.9 Records Y

4.10 Audits Y

Fig 16 An example non-compliance/observation note

7.6 REPORTING

An audit report is produced to help ensure that:

■ the results from the audit can be communicated effectively;

■ any need for corrective action is identified.

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NON-COMPLIANCE/OBSERVATION NOTE

AUDIT OF: AUDIT NO:

Acme Foundry Co Ltd CS/4

AREA UNDER REVIEW: DATE:

Coreshop 18/6

NON-COMPLIANCE/OBSERVATION:

New process implemented on 25/5, but environmental effects not re-evaluated.

Documented procedures and work instructions are now out of date.

AUDITOR(S): REPRESENTATIVE: INITIALS:

(1) (2) NAME: P. Brown PB

J. Richards TITLE: Environmental Representative

CORRECTIVE ACTION:

1. Review and re-evaluate the environmental effects arising from the new process for their possiblesignificance.

2. Amend objectives and targets, programme and manual, if required.

3. Amend existing procedures and work instructions, if required.

AGREED TIME LIMIT: RESPONSIBILITY INITIALS:FOR ACTION:

One month NAME: J. Smith JS

TITLE: Departmental Manager

The audit report normally consists of:

■ a brief description of the audit’s objectives, the areas that have been audited and who wasinvolved in auditing them;

■ a review of the audit areas, highlighting:

- non-compliances, ie lapses in either the content or implementation of procedures andrecords;

- opportunities for improvement, eg waste minimisation, cleaner processes.

7.7 ENVIRONMENTAL MANAGEMENT REVIEW

This is the formal evaluation by management of the status and adequacy of the organisation’senvironmental policy, systems and procedures in relation to environmental issues, regulations andchanging circumstances.

7.7.1 Frequency

Your Management Representative should liaise with senior management to advise how frequentlyreviews are needed, depending on:

■ how successfully the EMS is running;

■ whether or not any major changes in process or product have taken place, eg a newproduction line;

■ whether or not any other external issues of importance have arisen, eg new/revisedregulations, complaints from neighbours.

It is then up to the management team to decide how often the reviews should be undertaken. Asa guide, management reviews should be undertaken at least annually; this is in line with goodpractice for foundries certified to BS EN ISO 9002. Reviews can be requested at any stage if thereare known to be fundamental changes which could affect the achievement of the foundry’sobjectives and targets.

7.7.2 Attendance

Management review meetings should be attended only by those individuals with either executiveresponsibility or specialist responsibility, eg:

■ Managing Director;

■ Management Representative;

■ Line Managers (production, finance, personnel, etc).

Although management reviews involve a number of people, they are relatively infrequent andtherefore should not create a strain on resources.

7.7.3 Agenda

In preparation for the management review meeting, your Management Representative shouldprepare an agenda. A typical example is shown in Fig 17.

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Fig 17 Typical agenda for an Environmental Management Review meeting

When planning the review meeting, time should be allowed for the team to discuss broader issuesrelating to the EMS, eg new technologies and manufacturing methods, new legislation and anyeconomic pressures.

During the review meeting the team should consider:

■ whether or not the EMS is meeting either the foundry’s requirements or those set out in EMSstandards (BS 7750, ISO 14001 and EMAS);

■ whether or not your foundry is meeting policies, objectives and targets for the site and, ifapplicable, for the corporate group;

■ whether or not the EMS is working to complement the foundry’s overall activities and helpingthe company to achieve its business goals.

The review meeting should be minuted and a copy of these minutes kept as a record.

The recommendations produced as a result of this evaluation should form the basis of an action planformulated by senior management. This plan should:

■ highlight the areas where improvements to the EMS are required;

■ name the individual who should implement them.

All actions resulting from the review should also be monitored and recorded.

Audits help ensure that your foundry’s EMS has been fully integrated into the company’s overallmanagement control system and is being fully utilised to provide a constant review ofenvironmental performance against stated objectives and targets.

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ENVIRONMENTAL MANAGEMENT REVIEW MEETING

To be held in Conference Room on Tuesday 15 August at 2.00 pm

AGENDA

1 Actions arising from previous meeting

2 External audits

3 Internal audits

4 Training requirements

5 Effectiveness of Environmental Management System

- environmental policy

- objectives and targets

- operational control

- environmental manual

6 Any other environmental management-related business

Circulation:

8.1 WHAT’S INVOLVED?

As explained in Section 2, EMAS extends a company’s existing EMS by requiring your company toproduce a public statement on environmental performance, which is independently verified by anexternal body. The Environmental Statement is the means by which you can publicly communicateyour progress in managing and improving the environmental impacts of your foundry’s activities.Your Statement should provide an overview of your foundry’s operations, outline the environmentalimprovements you are trying to achieve and highlight the progress you are making.

EMAS specifies minimum requirements for the content of Environmental Statements and these,together with guidance, are reproduced in Fig 18.

8.2 PRESENTATION

EMAS does not specify any standard length for Environmental Statements, nor the form that theyshould take. EMAS simply requires that your Statement be designed for the public, written in aconcise and comprehensible form and disseminated as appropriate.

The main points to remember when you are preparing the Environmental Statement are:

■ it should be simple, consistent and balanced;

■ it contains reliable information and is accurate - you will have to demonstrate this to theverifier;

■ it is comprehensive, covering all the relevant issues;

■ it should not simply edit out bad news;

■ it should be positive and include the good news;

■ it does not include irrelevant detail - appendices can be used for technical detail, if necessary;

■ it avoids jargon.

Make sure that the facts are presented realistically and clearly as your target audience may not beas familiar as you are with your business activities. Graphs, charts and diagrams should be used toillustrate complex processes.

Careful choice of terminology may help, eg you may find the words ‘reduced’ or ‘increased’ easierto defend than ‘minimised’ or ‘maximised’. Likewise, the word ‘all’ may catch the verifier’s attention.

Some attention to presentation is worthwhile since you are trying to enhance your company’simage, not only to the verifier, but to the outside world in general. While you do not need toproduce a glossy brochure, at least make sure that:

■ the Statement is bound;

■ all the pages are numbered.

There may be considerable public interest and hence demand for copies of your Statement. Youshould weigh the style of presentation against the costs of making it widely available in largenumbers. Given the public availability of the Statement, you need to consider the issue ofcommercial sensitivity. However, this can be overcome without the company feeling that it is givingaway sensitive commercial information. You should, however, remember that your customers andcompetitors will have access to your company’s Environmental Statement.

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E N V I R O N M E N TA L S TAT E M E N T S8

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Environmental Statements - minimum requirements

1. A description of the foundry’s activities.

The essential requirement here, as with the rest of the Statement, is that thedescription of the site’s activities should be understandable; the use of technicalterms should be kept to a minimum and industry jargon should be avoided; amap or aerial photograph may be helpful for illustration.

2. An assessment of all the significant environmental issues of relevance to theactivities.

As well as identifying and describing, in non-technical language, the relevantenvironmental issues, there needs to be an accompanying explanation as to howand why these were assessed as being significant.

3. A presentation of the environmental policy, programme and managementsystem implemented at the foundry.

This should explain what the management at the site is trying to achieve andhow - both in general terms (ie the policy aims and objectives) and in specificterms (the programme of action, targets and deadlines). The policy, programme,objectives and targets should relate to and address the significant effectsidentified above. It may also be helpful to show the structure of responsibilitiesand identify contact points.

4. A summary of the figures on pollutant emissions, waste generation, consump-tion of raw material, energy and water, noise and other environmental effects.

This is intended to be a summary of emissions etc, presented in a way which isunderstandable. It may be appropriate to group emissions according to broadcategories which indicate their environmental impact (eg waste to land mightbe subdivided into hazardous and non-hazardous, release to air expressed asacid gases, VOCs, ozone-depleting substances). In presenting data it should alsobe clear to what year or period these relate. While for some it may be too soonto present trends in their first Environmental Statements (notably those withrecently established EMSs), trend data will be expected from those with maturesystems. In subsequent Statements trend data should be included as a means ofillustrating improvements in environmental performance.

5. Other factors regarding environmental performance.

This provides an opportunity for sites to present other issues of significance,such as changes in processes to take advantage of new clean(er) technologies,or consideration of indirect impacts etc.

6. The deadline set for the submission of the next Statement.

It is important to state clearly the deadline when the next Statement is due (inorder to maintain the site’s registration under EMAS). Deadlines should state themonth and the year, for example ‘before the end of June 1998’.

7. The name of the accredited environmental verifier.

The name of the accredited verifier must be included in the Statement and thecopy submitted to the Competent Body needs to carry the verifier’s signature.

Fig 18 The minimum requirements for an Environmental Statement for EMAS

8.3 EXAMPLE PHRASES

These example phrases are taken from the Environmental Statement produced for National Power’sDrax site, which was one of the first UK sites to be registered for EMAS.

The example shows two significant environmental effects which National Power had identified andthe means by which they are being tackled. This method of presentation, ie using a table, is clearand easy to follow (see Fig 19).

Fig 19 Extract from an Environmental Statement

8.4 FREQUENCY

First-time Statements can be prepared once the EMS is in place and as long as the audit programmehas started. Subsequent Statements should be produced on completion of each external assessmentcycle. The assessment cycle at the site will be established by the company management and agreedby the verifier. The maximum assessment interval and hence gap between verified Statements isthree years. However, in this case the verifier may require that you produce an annual simplifiedStatement for the intervening years. In some cases the verifier may agree to waive the need toproduce an interim Statement:

■ when the nature and scale of a small or medium-sized foundry does not warrant one;

■ or where there have been few significant changes since the last full Environmental Statement.

Simplified Statements must draw attention to significant changes since the last Statement. They toohave to be validated when the next full Environmental Statement is validated. While such statementsdo not need to be submitted to the Competent Body, copies should be available to anyone whorequests one.

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Significant Effects Control and Improvement Programme

The plant can be noisy, especially on We monitor and control start-up noise.start-up. Mobile plant has been fitted with

silencers and their working hours havebeen limited. We are looking at how toimprove further.

Particulates from the combustion process We operate effective controls on the (emitted through the chimney) and dust burners to assure compliance with HMIP(produced by on-site materials handling) requirements. Procedures are in place tocould affect local air quality. minimise dust releases during materials

handling.

Source: DRAX, National Power. 1995

BS 7750, ISO 14001 and EMAS all aim to test the integrity of your environmental managementsystems. To gain official recognition to one of these standards, a company has to have its EMSexamined for conformity by an independent body.

In the case of BS 7750 and ISO 14001, this body is called a certifier, while for EMAS thecorresponding body is termed an environmental verifier. In turn, these bodies must, having metcertain pre-determined criteria, be accredited by the United Kingdom Accreditation Service (UKAS)- formerly the National Accreditation Council for Certification Bodies (NACCB).

In the case of EMAS, a Competent Body oversees the whole registration process. In the UK thistask is undertaken by the Department of the Environment. A foundry aiming for EMAS registrationhas to produce an Environmental Statement which must be validated by a verifier. The statementis then submitted to the Competent Body, which checks with the enforcement authorities that thereis no reason for withholding registration of the site due to lack of compliance with environmentalregulations.

Table 9 provides definitions of the terms used in relation to EMS standards.

Term Definition

Accreditation The United Kingdom Accreditation Service (UKAS) accredits bodies seeking to

certify organisations to BS 7750 or verify that an organisation’s management

processes and Environmental Statement meet the EMAS criteria.

Certification The conformity of an EMS to BS 7750 or ISO 14001 is certified by independent,

accredited certifiers.

Verification The environmental policies, programmes, management systems, reviews or audit

procedures, and the Environmental Statement are examined to verify that they

meet the requirements of the EMAS Regulation. Independent, accredited

environmental verifiers carry out this activity.

Validation The Environmental Statement required by EMAS is validated by an independent,

accredited environmental verifier.

Table 9 EMS terminology

The routes to obtain certification to BS 7750 and registration under EMAS are summarised in Fig 20.

Because the development of EMAS and BS 7750 overlapped, there is a high degree of compatibilitybetween them. So while the use of BS 7750 is not essential for EMAS purposes, it has some realpractical advantages.

The compatibility between the two means that, if your foundry site has been certified to BS 7750,its management system will also satisfy the corresponding management system requirements ofEMAS. Your company should not, therefore, need to incur further expenditure having these aspectsseparately verified. Although BS 7750 and EMAS are compatible, the place which ISO 14001, thenew International Standard, will eventually occupy is not yet clear.

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9.1 THE CERTIFICATION PROCESS TO BS 7750

An individual foundry has complete freedom of choice in its selection of a certification body. If yourfoundry has already achieved certification to the international quality management systemBS EN ISO 9001, the certification body which you employed then is likely to be in a position to quotefor assessing your EMS to BS 7750 - assuming that you were satisfied with their work.

Before entering into a contract to assess your EMS, the certification body is likely to ask you tocomplete a simple questionnaire of the type shown in Appendix 5.

Although the various certification bodies use a variety of approaches, certification to BS 7750 istypically a two-stage process:

■ an initial assessment;

■ main assessment (including a desk-top study).

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Fig 20 The routes to obtaining certification to BS 7750 and registration for EMAS

Competent body for EMAS (DOE)

Accreditation body (UKAS)

Accredited verifierAccredited certifier

Preparatory review

Reviews

Audits

Records

Operationalcontrol

Managementmanual

Organisationand personnel

Evaluation andRegister of

Environmental Effects

Register ofLegislation

Objectivesand targets

ManagementProgramme

Policy

Company/Site

Regulators

Statement

Public

Public

Accreditation

Certification Verification

Validation

Registration

BS 7750

EMAS

9.1.1 The initial assessment

The objectives of the initial assessment are to provide a focus for planning the main assessment. Theaim is to gain an understanding of:

■ your EMS in the context of relevant environmental effects and regulations;

■ whether you are fully prepared for assessment.

During the initial assessment, the certification body will:

■ Ensure that your EMS is:

- based on the evaluation of environmental effects;

- intended to control and improve the foundry’s environmental performance;

- auditable.

■ Assess the reliance that can be placed on your internal audit.

■ Plan and allocate resources for further document review where required and for the mainassessment.

■ Provide an opportunity for immediate feedback of information to you which may assist in theremainder of the assessment process.

The time taken for this initial assessment will depend on the size and complexity of yourorganisation. However, in the case of a small to medium-sized enterprise (SME), it will probablyentail one day on site.

At the end of this first stage, a representative of the certification body may give you a documentoutlining some useful development points.

9.1.2 Main assessment

Desk-top study

Following a satisfactory outcome to the initial assessment, you are usually required to send a copyof the foundry’s Environmental Manual and Procedures - together with any process authorisationsand waste discharge consents - to the certification body. These documents are needed for a desk-top study undertaken by the lead assessor, which indicates whether or not your foundry is ready formain assessment. In many cases, the desk-top study can be completed within a day.

The certification body will notify you of any omissions identified during the desk-top study. Thesehave to be corrected before the main assessment is undertaken.

Site visit

The main assessment by the team from the certification body represents the final stage in thecertification process. Given that the documentary evidence associated with the foundry’s EMS willhave already been checked during the desk-top study, the main purpose of the site visit is to confirmthat what is written actually represents what is occurring in practice.

The objectives of the main assessment are to:

■ confirm that the EMS complies with all the elements of BS 7750;

■ determine whether the management system is designed to achieve, and is achieving,performance improvement and regulatory compliance;

■ confirm that the foundry complies with its own policies and procedures.

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To achieve these objectives, the assessment will focus on the foundry’s:

■ identification and evaluation of environmental effects;

■ consequent objectives and targets;

■ performance monitoring, measuring, reporting and review against its objectives and targets;

■ auditing to ensure the system’s effectiveness.

Any non-conformance with BS 7750 identified during the site visit will be brought to the foundry’sattention by the certification body. The certification body will also set a timetable or date by whichany necessary corrective action must be carried out. Generally, a foundry would only fail thecertification process at this stage if the corrective action demanded by the certification body was notcompleted during the permitted period.

The time needed for the certification team to carry out a site visit in an SME is typically about twodays. As with any assessment visit, it is necessary to provide the assessors with office space.

9.1.3 Costs of certification

The costs of certification vary from one certification body to another and it is recommended that anumber of different quotations should be sought.

The costs of registration to BS 7750 and ISO 14001 are likely to be 1 - 11/2 times those of obtainingregistration to BS EN ISO 9002. For the foreseeable future however, the Government is offeringfinancial support to assist SMEs to carry out an environmental review and develop an EMS. Detailsof the funding available through the Small Company Environmental and Energy ManagementAssistance Scheme (SCEEMAS) are given in Section 10.3. Free advice on environmentalmanagement is also available from the Environmental Helpline on 0800 585794.

To renew certification to BS 7750, your foundry will need to demonstrate that its EMS is beingmaintained. This involves routine surveillance visits by the certification body. Again, the approachtaken by the various certification bodies differs. While most visit at six-monthly intervals and reviewaspects of the EMS, some renew the certificate every three years; a number carry out a full re-assessment after this time. An additional fee is payable for renewal.

9.2 THE VERIFICATION PROCESS FOR EMAS

By the time you apply to register for EMAS, you will have a programme in place to ensure:

■ compliance with all relevant environmental legal requirements;

■ achievement of continuous improvement in environmental performance.

You will also be aware of the need to prepare a regular Environmental Statement to reportimprovements in the foundry’s environmental performance to the public.

Accreditation awarded by the United Kingdom Accreditation Service (UKAS) enables an independentenvironmental verifier to check that:

■ your EMS meets the standard required by EMAS;

■ your public statements of environmental performance are accurate.

Following the verification process, and providing checks with environmental regulatory bodies aresatisfied, the foundry can be entered on the EMAS register held in the UK by the DOE.

There can be a marked difference between producing a company Annual Environmental Report andan EMAS Statement which is to be validated. Having a validated Statement means that all parties

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can have faith in what you are declaring and confidence in your company’s commitment to theenvironment, both locally and on a wider scale.

9.2.1 The role of the verifier

The verification process for EMAS differs from the certification process for BS 7750 and ISO 14001in that it concentrates on:

■ the content of your Environmental Statement;

■ whether there is sufficient information to support it.

The appointed verifier will check whether or not:

■ an environmental policy has been established;

■ an EMS and programme are both in place and operational;

■ the necessary environmental review and audit procedures are being carried out;

■ the data and information contained in the Environmental Statement are reliable;

■ the Environmental Statement covers all the foundry’s significant environmental issues.

Although the external verification process is carried out every three years, most companies willreview their Environmental Statement annually. This enables them to adopt a more proactiveapproach to changes at the site regarding their significant environmental effects. In the case ofcorporate operations, the Environmental Statement is verified annually. In practice, seniormanagement will suggest a verification cycle which will be discussed and agreed with the appointedverifier.

9.2.2 The verification process

Remember that in seeking registration to EMAS through the verification process, you cannoteffectively fail. The verification process can only be put on ‘hold’ until any non-compliances havebeen resolved.

An EMS certified to BS 7750 will certainly meet the requirements of EMAS. However, should youcontemplate using ISO 14001 as the model, talk to your verifier at an early stage about anyadditional details which may be required.

For an SME, the verification process generally involves two stages - a desk-top study followed by amain assessment. A general approach will be adopted by the verifier, who will be looking forconfidence in your EMS and Environmental Statement.

During the desk-top study, the scope of the Statement is reviewed to ensure that the Statementreflects the areas covered by the EMS. This stage normally takes between one and two days. At thispoint, the history of the foundry’s EMS will also be examined.

The verifier may give prior notice to the Management Representative of any particular areas to beaddressed before making the site visit. Should this not occur, you are advised to request feedbackon the desk-top study from the verifier when setting a date for the verifier’s visit.

Costs of verification

If your EMS is not certified to either BS 7750 or ISO 14001, then the verification process may takelonger and incur higher costs.

Generally, the costs of verification are similar to those of the EMS certification process, but withoutthe ongoing costs of surveillance. The internal costs of achieving registration to EMAS are estimatedto be 10 - 15% of those involved in developing and implementing an EMS.

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For SMEs, financial help towards developing an EMS and obtaining registration under EMAS isavailable under SCEEMAS. Details are given in Section 10.3.

Choosing a verifier

There are now a number of external bodies which have been accredited by UKAS to act as EMASverifiers within the foundry industry. However, you should not assume that because a companyclaims it can validate your Environmental Statement that it is actually accredited. It is wise to checka company’s scope of accreditation when you first contact it - without accreditation you will bewasting both time and money.

You are advised to contact a number of potential verifiers and, after checking their scope ofaccreditation, to request an application form and a quotation.

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A number of other sources of help and information are available to assist you to develop your EMS.For SMEs, both practical help and financial assistance are available. Obtaining as much free help aspossible will make the process even less onerous.

10.1 BS 7750 AND ISO 14001

Copies of British Standard BS 7750 and ISO 14001 can be purchased from:

BSI Information Centre389 Chiswick High Road, London W4 4ALTel: 0181 996 7000Fax: 0181 996 7001

10.2 EMAS

The Department of the Environment (DOE) is the Competent Body responsible for EMAS in the UK.Requests for further information should be made to:

DOE EMAS HelplineTel: 0171 276 3377

Application forms and guidance notes can be obtained from:

The EMAS Registration OfficeThe Competent Body for the EC Eco-Management and Audit SchemeDepartment of the Environment, Room C11/09, 2 Marsham Street, London SW1P 3EBTel: 0171 276 3377Fax: 0171 276 4739

The guidance notes are available free of charge and include:

The Eco-Management and Audit Scheme, a Participant’s Guide

Guidance Note Number 1: Breaches

Guidance Note Number 2: Environmental Statements

Applications for registration should also be sent to the EMAS Registration Office.

10.3 SCEEMAS

The Small Company Environmental and Energy Management Assistance Scheme (SCEEMAS) is agrant scheme offered by the DOE to help SMEs:

■ establish a recognised EMS;

■ register their site(s) under EMAS.

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To be eligible for SCEEMAS a foundry must:

■ employ fewer than 250 staff worldwide, ie it is not part of a larger group;

■ not be more than 25% owned by any other business(es);

■ have an annual turnover of less than £32 million or have an annual balance sheet of less than£21 million.

SMEs that choose to use consultants to help them register for EMAS are eligible for grant assistanceunder this scheme.

10.3.1 Financial assistance

Financial support is provided in three stages leading towards EMAS registration (see Table 10).

The grant covers up to 50% of the cost of hiring external consultants and is paid according to thefollowing schedule:

■ 40% of the cost of hiring a consultant to carry out Stage 1;

■ 40% of the cost of hiring a consultant to carry out Stage 2;

■ 50% of the cost of hiring a consultant to carry out Stage 3 and 50% of an independentverifier’s costs and registering under EMAS.

The balance from Stages 1 and 2, ie the outstanding 10%, is paid when the foundry is registeredunder EMAS. Payments are made when each stage is complete. The scheme is flexible, allowing youto apply for assistance for one or more stages, or for one or more sites. For instance, if you only wanthelp to undertake an environmental review, you need only apply for help to carry out Stage 1.

As most of the steps involved in EMAS, apart from the Environmental Statement, coincide with therequirements of BS 7750 and ISO 14001, SCEEMAS can help you achieve both. However, SCEEMASdoes not cover the cost of certification to the British and International Standards.

SCEEMAS EMAS What’s involved

Stage 1

Environmental Review 1. Environmental Review Reviewing the significant environmental effects

and all environmental legislation relevant to

the site.

2. Environmental Policy Using the review to develop the company’s

environmental policy in respect of the site - a

public commitment to comply with environ-

mental legislation and to continuous

improvement in environmental performance.

Stage 2

Environmental 3. Environmental Programme Establishing an environmental programme

Management System with targets.

4. Environmental A management system to deliver the

Management System programme.

5. Environmental Audit Auditing the system.

Stage 3

Environmental Statement 6. Environmental Statement Auditing progress.

7. Validation and Registration A report validated by an accredited verifier

registering the site with the Competent Body.

Table 10 How SCEEMAS links with EMAS

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10.3.2 Applications to SCEEMAS

Grant applications must be made before starting the stage for which assistance is sought.Application forms and further information can be obtained from the scheme’s administrators at theaddress below.

The SCEEMAS OfficeNIFES Consulting GroupNIFES House, Sinderland Road, Broadheath, Altrincham, Cheshire WA14 5HQTel: 0345 023 423Fax: 0161 926 8718e-mail: sceemas@nifes.demon.co.uk

Completed application forms should be returned to the SCEEMAS Office, together with a projectproposal indicating how the work is to be carried out. The SCEEMAS Office will consider yourapplication and then inform you if you have been successful in obtaining financial assistance. Workcan then commence.

Payment will be made once the SCEEMAS Office has received signed confirmation from you (on theappropriate forms) that the work has been carried out to your satisfaction.

10.3.3 Hiring external consultants

To be eligible for assistance under SCEEMAS, you will need to hire external consultants. You shouldensure that your chosen consultant is:

■ familiar with the foundry business;

■ familiar with EMAS, BS 7750 and/or ISO 14001;

■ formally contracted to your company;

■ prepared to give you regular updates on progress.

While foundries are free to use the consultant of their choice, SCEEMAS will require the consultancyto demonstrate that it has adequate knowledge of EMS and EMAS.

Make sure you obtain competitive quotes from more than one consultant because yourcompany will have to pay 50% of the cost.

10.4 ORGANISATIONS OFFERING HELP AND GUIDANCE

Further advice about EMSs may be obtained from the Environmental Helpline on 0800 585794and from the organisations listed below. The list is not exhaustive and has been compiled frominformation currently available to the Environmental Technology Best Practice Programme. Thelisting of an organisation should not be regarded as an endorsement of its services or products bythe Programme. Similarly, the Programme makes no claim for the competence or otherwise of anyorganisation not listed.

Association of Bronze and Brass Founders (ABBF)Tel: 0121 454 4141 Fax: 0121 454 4949

Provides advice on all matters relating to the production of copper alloy castings.

Association of British Certification Bodies (ABCB)Tel: 0181 295 1128 Fax: 0181 467 8091

Represents organisations that have been accredited to carry out third party certification.

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British Investment Casting Trade Association (BICTA)Tel: 01527 584770 Fax: 01527 584771

Represents the interests of the investment casting industry.

British Library Environmental Information ServiceTel: 0171 323 7955 Fax: 0171 412 7495

Provides a free enquiry service and carries out detailed research on a fee basis. Document supply,online searches, official publications, science and technology literature, patents, and businessinformation in the environmental field are all available.

British Standards Institution (BSI)Tel: 0181 996 7000 Fax: 0181 996 7001

The BSI Standards Catalogue lists many standards relating to environmental protection. The BSIprepared the BS EN ISO 9000 series on quality management and BS 7750, the world’s first standardfor EMSs.

Business in the Environment (BiE)Tel: 0171 224 1600 Fax: 0171 486 1700

BiE produces a range of publications and videos to help businesses improve their environmentalperformance.

Casting Development Centre (CDC)Tel: 0114 272 8647 (formerly Castings Technology International) Fax: 0114 273 0852Tel: 01527 66414 (formerly BCIRA) Fax: 01527 585070

The CDC, which was formed by the merger of BCIRA and Castings Technology International in1996, is a research and technical organisation serving the castings industry.

Centre for Environment and Business in Scotland (CEBIS)Tel: 0131 555 5334 Fax: 0131 555 5217

CEBIS was established in 1991 to provide impartial, authoritative, environmental information tobusinesses in Scotland.

Chartered Institution of Water and Environmental Management (CIWEM)Tel: 0171 831 3110 Fax: 0171 405 4967

A professional body formed to advance the practice of water and environmental management. TheCIWEM publishes manuals on the treatment and disposal of water and wastewater.

CBI Environmental Business ForumTel: 0171 379 7400 (extn 2995) Fax: 0171 240 1578

Provides environmental advice and information to all Confederation of British Industry (CBI) membercompanies, with the Environmental Newsletter keeping members up-to-date on relevant issues.Publications on a range of environmental issues are also available to both members and non-members.

Department of the Environment (DOE)Tel: 0171 276 3000 (enquiries) or Regional Offices

The DOE is responsible for the setting and enforcement of national and international standards onenvironmental protection.

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Department of Trade and Industry (DTI)Tel: 0171 215 5000 or Regional Offices

The DTI’s Environment Directorate helps businesses respond to environmental challenges and marketopportunities.

Energy Efficiency Best Practice programme (EEBPp)Tel: 01235 436747 (Energy Efficiency Enquiries Bureau) Fax: 01235 433066

On behalf of the DOE, the EEBPp runs seminars and produces a range of free publications (similarto those of the Environmental Technology Best Practice Programme) to promote energy efficiency.

Engineering Employers Federation (EEF)Tel: 0171 222 7777 Fax: 0171 222 2782

Offers a national network of health, safety and environmental advisers who provide training andconsultancy services. The EEF also provides up-to-date literature relating to legislation.

Environment AgencyTel: 0645 333111 (General Enquiry Line) Fax: 01189 500388Tel: 01454 624400 (Head Office, Bristol) Fax: 01454 624409Tel: 0171 820 0101 (Head Office, London) Fax: 0171 820 1603e-mail: enquiries@environment-agency.gov.ukWeb page: www.environment-agency.gov.uk

Provides a single point of contact through its regional and local offices for companies in Englandand Wales previously regulated by a number of different agencies.

North West Region Tel: 01925 653999 Fax: 01925 415961

Midlands Region Tel: 0121 711 2324 Fax: 0121 711 5824

North East Region Tel: 0113 2440191 Fax: 0113 2461889

Anglian Region Tel: 01733 371811 Fax: 01733 231840

Thames Region Tel: 01734 535000 Fax: 01734 500388

Southern Region Tel: 01903 820692 Fax: 01903 821832

South West Region Tel: 01392 444000 Fax: 01392 444238

Welsh Region Tel: 01222 770088 Fax: 01222 798555

Environmental HelplineTel: 0800 585794

The Environmental Helpline provides free up-to-date advice on a wide range of environmentalissues, legislation and technology. The Environmental Helpline can:

■ send you copies of relevant Environmental Technology Best Practice Programme publications;

■ suggest other sources of information;

■ arrange for an environmental adviser to contact your company.

For SMEs, the Helpline offers a free counselling service.

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Green Business ClubsGreen Business Clubs provide a forum for discussing environmental matters with other businesspeople. For details of your nearest Green Business Club, contact:

Department of the EnvironmentRoom C11/21, 2 Marsham Street, London SW1P 3EBTel: 0171 276 3733 Fax: 0171 276 3731

Institute of British Foundrymen (IBF)Tel: 01527 596100 Fax: 01527 596102

Serves the interests of foundrymen and promotes training in the castings industry.

Institute of Environmental Management (IEM)Tel: 0131 555 5334 Fax: 0131 555 5217

Offers a professional support programme and provides a forum for the exchange of informationbetween people with environmental responsibilities. Also produces a regular journal and organisesseminars and workshops.

Institute of Wastes Management (IWM)Tel: 01604 20426 Fax: 01604 21339

Professional association which provides information and training on all aspects of wastemanagement.

Light Metal Founders Association (LMFA)Tel: 0121 454 4141 Fax: 0121 454 4949

Represents the interest of aluminium and magnesium casting producers.

National Society for Clean Air and Environmental Protection (NSCA)Tel: 01273 326313 Fax: 01273 735802

A non-government organisation that encourages the reduction of air pollution, noise and othercontaminants. Publishes a range of booklets and briefing material.

Northern Ireland Environmental Enquiry PointTel: 0800 262227 Fax: 01846 676054

Provides an environmental information and signposting service for companies in Northern Ireland.

Scottish Environment Protection Agency (SEPA)Tel: 01786 457700 (Head Office, Stirling) Fax: 01786 446885

Provides a single point of contact through its regional and local offices for companies in Scotlandpreviously regulated by a number of different agencies.

North Region Tel: 01349 862021 Fax: 01349 863987

East Region Tel: 0131 449 7296 Fax: 0131 449 7277

West Region Tel: 01355 238181 Fax: 01355 264323

Welsh Office Business Services UnitTel: 01222 825172 Fax: 01222 823661

The Welsh Office Business Services Unit helps businesses in Wales address environmental issues andtake advantage of the expanding market in environmental technology.

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Waste Management Information Bureau (WMIB)Tel: 01235 463162 Fax: 01235 463004

Provides an information retrieval service on all aspects of non-radioactive waste management. WMIBproduces the comprehensive WasteInfo database and publishes the monthly journal Waste andEnvironment Today.

10.5 RECOMMENDED READING

This list is not intended to be exhaustive. For advice and information on the latest developments inenvironmental management systems and current legislation affecting your foundry, you are advisedto contact the Environmental Helpline on 0800 585794.

10.5.1 Journals

Regular updates on legislation and general environmental issues are provided by the followingjournals, which you may find useful.

EEF Health, Safety and Environmental Newsline (six issues per year)Engineering Employers FederationTel: 0171 222 7777Fax: 0171 222 2782

Environment Business (fortnightly)Information for Industry LtdTel: 0181 944 2930Fax: 0181 944 1982

Environment Information Bulletin (monthly within Health, Safety and Environment Bulletin)Industrial Relations Services (IRS)Tel: 0171 354 5858Fax: 0171 226 8618

Environmental Manager (ten issues per year)Monitor PressTel: 01787 378607Fax: 01787 880201

Integrated Environmental Management (ten issues per year)Blackwell Scientific LtdTel: 01865 206206Fax: 01865 721205

The ENDS Report (monthly)Environmental Data ServicesTel: 0171 278 4745/7624Fax: 0171 415 0106

10.5.2 General references

Croner’s Environmental ManagementCroner Publications Ltd, Croner House, London Road, Kingston-upon-Thames, Surrey KT2 6SRSubscription package provides looseleaf reference book with updates and special reports.

Croner’s Environmental Policy and ProceduresCroner Publications Ltd, Croner House, London Road, Kingston-upon-Thames, Surrey KT2 6SRSubscription package provides looseleaf reference book with updates and special reports.

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Croner’s Waste ManagementCroner Publications Ltd, Croner House, London Road, Kingston-upon-Thames, Surrey KT2 6SRSubscription package provides looseleaf reference book with updates and special reports.

EMAS: A Practical Guide, R Hillary, 1994Stanley Thornes, Ellenborough House, Wellington Street, Cheltenham, Gloucestershire GL50 1YD

Environmental Legislation and Policy for the ManagerInstitute of Environmental Management, 58/59 Timberbush, Edinburgh EH6 6QH

Pollution Handbook National Society for Clean Air and Environmental Protection, 136 North Street, Brighton BN1 1RGRevised annually

The Environmental Managers’ ManualInstitute of Environmental Management, 58/59 Timberbush, Edinburgh EH6 6QH

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BATNEEC Best Available Techniques Not Entailing Excessive Cost. Anobjective established by Section 7 of the EnvironmentalProtection Act 1990.

BPEO Best Practicable Environmental Option. A conceptintroduced by the Royal Commission on EnvironmentalPollution.

Continual improvement Year-on-year enhancement of overall environmentalperformance (not necessarily in all areas of activity) resultingfrom continuous efforts to improve. Achieved by measuressuch as:

- enhanced product quality, operational efficiency andresource utilisation;

- developments in products, services, processes andfacilities;

- improved waste management.

Environment The surroundings/external conditions in which anorganisation operates and which influences thedevelopment or growth of people, animals or plants. Theenvironment of a foundry extends from within theworkplace to the global ecosystem.

Environmental audit A management tool to assess the effectiveness of the EMS,the achievement of the environmental objectives and toensure compliance with environmental standards (BS 7750,ISO 14001 and EMAS).

Environmental effect Any direct or indirect impingement of the activities,products and services of an organisation upon theenvironment, whether adverse or beneficial.

Environmental effects evaluation A documented evaluation of the environmental significanceof the effects of an organisation’s activities, products andservices (both existing and planned).

Environmental management Those aspects of the overall management function(including planning) that develop, implement and maintainthe organisation’s environmental policy.

Environmental Documentation which describes the overall environmentalmanagement manual management system and indicates the procedures for

implementing the organisation’s environmentalmanagement programme.

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G L O S S A R YAppendix 1

appx

A1

Environmental management The organisational structure, responsibilities, practices,system (EMS) procedures, processes and resources for implementing

environmental management.

Environmental performance A measure of an organisation’s achievements in protectingthe environment by reducing the environmental impact ofits activities, eg by reducing pollution through better wastemanagement practices. When environmental performancefails to meet specified requirements, the occurrence(s)which caused this are referred to as non-compliances.

Environmental policy A written public statement of the intentions and principlesof action of the organisation regarding its environmentaleffects. Gives rise to its objectives and targets.

Environmental Statement A written statement of an organisation’s clear intention toachieve continuous improvement in environmentalperformance. When verified by an accredited third party,acts as a main criterion of the EMAS regulation.

Interested parties Those with an interest in the environmental effects of anorganisation’s activities, products and services. Includesregulators, local residents, employees, investors, insurers,customers and consumers, environmental interest groupsand the general public.

Management Programme A description of the means and timescales for achievingenvironmental objectives and targets.

Management Representative The employee nominated by management who hasresponsibility for initiating, monitoring and controllingenvironmental initiatives. Those appointed to this role needsome knowledge of environmental issues to be able toperform their duties effectively.

Management review The formal evaluation by management of the status andadequacy of the organisation’s environmental policy,systems and procedures in relation to environmental issues,regulations and changing circumstances.

Objectives The broad goals, arising from the environmental policy andeffects evaluation, that an organisation sets itself to achieveand which are quantified wherever practicable.

Observation An isolated lapse in the content or implementation ofprocedures or records.

Organisation Any organised body or establishment, eg a business,company, government department, charity or society. Forbodies or establishments with more than one site, a singlesite may be defined as an organisation.

Policy A public statement of the intentions and principles of actionof the organisation regarding its environmental effects.Gives rise to its objectives and targets.

62

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A1

Quality management The provision made by management to ensure that qualitysystem (QMS) is protected and promoted throughout an organisation’s

activities.

Register of Environmental Effects A list of significant environmental effects, related to theactivities, products and services of an organisation.

Registration Application to the Competent Body of an EU Member Stateto become an Eco-Management and Audit Scheme (EMAS)registered site.

Responsible individual Individuals identified by the Management Representative ashaving responsibility for a particular environmental effect,objective, target, programme, procedure or workinstruction.

Targets Detailed performance requirements (quantified whereverpracticable) applicable to the whole or parts of theorganisation. Targets arise from the environmentalobjectives and need to be set and met in order to achievethose objectives.

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A1

Requirements of BS 7750

4.1 4.2 4.3 4.4 4.5 4.6 4.7 4.8 4.9 4.10 4.11

Requirements of the BS EN ISO 9000 series

4.1 Management responsibility • • • •

4.2 Quality system • •

4.3 Contract review • • •

4.4 Design control • • •

4.5 Document control •

4.6 Puchasing • •

4.7 Purchaser supplied product •

4.8 Product identification •

4.9 Process control •

4.10 Inspection and testing •

4.11 Inspection, measuring and test equipment •

4.12 Inspection and test status •

4.13 Control of nonconforming product •

4.14 Corrective action •

4.15 Handling, storage, packaging and delivery • •

4.16 Quality records •

4.17 Internal quality audits •

4.18 Training •

4.19 Servicing • •

4.20 Statistical techniques •

LINKS BETWEEN BS 7750 AND THE BS EN ISO 9000 SERIES

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L I N K S B E T W E E N D I F F E R E N TS TA N D A R D S

Appendix 2

Man

agm

ent

syst

em

Envi

ronm

enta

l pol

icy

Org

anis

atio

n an

d pe

rson

nel

Envi

ronm

enta

l eff

ects

Obj

ectiv

es a

nd t

arge

ts

Man

agem

ent

Prog

ram

me

Man

ual a

nd d

ocum

enta

tion

Ope

ratio

nal c

ontr

ol

Reco

rds

Aud

its

Revi

ews

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A2

LINKS BETWEEN ISO 14001 AND THE BS EN ISO 9000 SERIES

ISO 14001 ISO 9000

ENVIRONMENTAL POLICY QUALITY POLICY

PLANNING PLANNING

Environmental aspects Quality planning

Legal and other requirements

Objectives and targets

Environmental Management Programme

IMPLEMENTATION AND OPERATION

Structure and responsibility Organisation

Training, awareness and competence Training

Communication

Environmental documentation General

Document control Document and data control

Operational control Quality system procedures

Contract Review

Design control

Purchasing

Control of customer-supplied product

Process control

Handling, storage, packaging, preservationand delivery

Servicing

Emergency preparedness and response Product identification and traceability

CHECKING AND CORRECTIVE ACTION

Monitoring and measurement Inspection and testing

Inspection and test status

Statistical techniques

Monitoring and measurement Control of inspection, measurement and testequipment

Non-conformance and corrective and Control of non-conforming productpreventive action

Non-conformance and corrective and Corrective and preventive actionpreventive action

Records Control of quality records

Environmental management system audit Internal quality audits

ENVIRONMENTAL MANAGEMENT REVIEW QUALITY MANAGEMENT REVIEW

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A2

Foundries are faced with a wide range of legislation dealing with environmental issues. Any EMSmust ensure compliance with relevant legislation, regulations and other policy requirements.

A simple, well-presented Register of the main items of relevant environmental legislation and codesof practice will provide foundry management with a comprehensive, yet accessible, document.Foundries will find the Register a useful tool to help them achieve regulatory compliance.

SOURCES OF INFORMATION

You should refer to any relevant:

■ operational permits;

■ discharge consents;

■ local authority consents;

■ planning consents;

■ other regulatory consents or authorisations.

One publication which companies will find helpful in identifying all the relevant legislation is Registerof Environmental Regulations ‘96 - A directory of significant environmental legislation affecting themanufacturing sector in England and Wales. Its introduction states that: ‘This publication is intendedto provide management with an accessible comprehensive and simple Register of the principalenvironmental legislation that could affect their organisation. It should be helpful to allmanufacturing companies and particularly small and medium-sized concerns. Specifically, it shouldbe of assistance to those businesses which are introducing an EMS’.

The 1996 edition is up to date as of 1 January 1996. The directory is available from:

Customer Services DepartmentThe Engineering Employers Federation (EEF)Broadway House, Tothill Street, London SW1H 9NQTel: 0171 222 7777 extn 2269/2296Fax: 0171 222 2782

ISBN 0 901700 05 3. 84 pages. Price (1996 edition): £25.00 to EEF members, £50.00 to non-members.

Other sources of help

If you are not sure which legislation, regulations and codes of practice apply to your foundry, youshould seek advice from:

■ the Environmental Helpline on 0800 585794;

■ the Environment Agency (in England and Wales), the Scottish Environment Protection Agency(SEPA) and the Environment and Heritage Service (in Northern Ireland);

■ your trade association;

■ your local authority.

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P R E PA R I N G A R E G I S T E R O FL E G I S L AT I O N

Appendix 3

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FORMAT OF THE REGISTER

The Register of Legislation can simply consist of a list of the relevant legislation (including a briefsummary of the key points of the legislation) followed by an indication of the particulardepartment(s) or process(es) to which it applies.

Alternatively, you can build up a suitable document by using a table similar to the one shown inFig A1, which is an extract from the Register of Legislation of a fictitious foundry. Your Register couldbe several pages long. A blank table suitable for preparing a Register of Legislation is given inAppendix 6 for you to photocopy and use in your foundry.

Some foundries may find it useful to demonstrate operational control aspects within the Register ofLegislation by cross-referencing to the appropriate work instructions. This approach is illustrated inthe extract from Wolstenholme International’s Register of Legislation shown in Fig A2.

Fig A1 Extract from the Register of Legislation of a fictitious foundry

67

REGISTER OF LEGISLATION FOR .............................

PREPARED BY: DATE: SHEET: OF

Legislation/regulationcode of practice

Applicable to whichprocess/service/product

Held where andby whom

Responsibility forcompliance

Related workinstructions

Environmental Protection Act 1990. Process Guidance Note PG 2/4

Moulding, casting, knockout, finishing

P. BrownEnvironmentalRepresentative

P. BrownEnvironmentalRepresentative

P. BrownEnvironmentalRepresentative

Moulding ShopSupervisor

1, 3, 4, 6

EnvironmentalProtection Act 1990.Process GuidanceNote PG 2/5

Cold blast cupola Melting Shop Manager 2, 3, 8, 9

Noise at WorkRegulations 1989

Knockout and finishing

Moulding Shop SupervisorMelting Shop Manager

3, 10, 11

9. North West Water Trade Effluent Consent dated 26 May 1993

Regulates discharges of effluent from the site, via the foul drains.

Action for Wolstenholme International Ltd: The Engineering and Purchasing Directoris to ensure that all discharges of trade effluent from the steam cleaning pit, oilcontaminated compressor blowdown and cooling water towers to foul drains aredischarged in conformance with the above consent. Production, Engineering andTechnical Management are to ensure that no other effluent streams from processeson site, are allowed into the foul sewer. Reference Environmental Instructions Nos EI 2, 7, 9 and 17.

Fig A2 Extract from Wolstenholme International’s Register of Legislation

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P R O C E D U R A L R E Q U I R E M E N T S F O RB S 7 7 5 0

Appendix 4

CLAUSE IN AREA SUBJECT FOR PROCEDUREBS 7750

4.1 Management System

4.2 Policy • policy reviews

• publication of policy and objectives

• communication of policy

4.3 Organisation • organograms

• management representative

• responsibility for contingency response, emer-gency actions

• resources and responsibilities for verification

• verification requirement and procedures

4.3.4 Training • review of requirements for training

• updating and review of induction programme

• records of training

• communication regarding system, objectives,programme, significant effects and impact ofemployees’ activities on this and consequencesin the event of failure to adhere to systemrequirements

• communication to employees regarding theirroles and responsibilities for achieving comp-any objectives

• control and review of employees’ competencefor specific tasks

• update and review of communication pro-grammes to staff

4.3.5 Contractors • ensuring contractors are aware of and adhereto relevant management system requirementand provisions

4.4.1 Communications • communications to interested parties

• information to regulators and authorities

• information to surrounding inhabitants

• communications with authorities

• soliciting views from interested parties, bothinternal and external prior to settingobjectives

• receipt, analysis and action on views andinformation received from interested partiesboth internal and external

appx

A4

69

CLAUSE IN AREA SUBJECT FOR PROCEDURE

BS 7750

4.4.2 Environmental effects • identification, evaluation and examination ofeffects including guidance on significance

• development, review, maintenance and up-dating of the register

• identification, examination, evaluation andcontrol of effects from new processes/productsand new developments

4.4.3 Regulatory register • recording of legislative, regulatory and otherspecific items such as codes of practice

• development, review, maintenance and up-dating of register

4.5 Objectives and targets • establishment and maintenance of objectivesand targets

• evaluation and revision of objectives andtargets

• taking account of interested parties’ viewswhen setting objectives and targets

• means by which objectives and targets are tobe achieved

4.6 and 4.7.1 Risk management • development, maintenance, review andupdating of contingency plan, escape plansand evacuation plans

4.6 Programme • development and maintenance of pro-grammes and assignment of responsibility

• means by which programmes are to beachieved

• annual reviews of programmes and achieve-ments

• information to employees on programmeprogression and changes

• separate programmes for new/modifieddevelopments, processes and projects

4.7.1 Manual • establish and maintain a manual to collatepolicy, objectives, targets and programmes

• document roles and responsibilities

• describe how the system interrelates

• provide direction to related documentation

4.7.2 Documentation • description of document layout, developmentprocess, review, authorisation, distribution,changes, collection, identification andregistering of documents and manuals

• responsibility for modification of documents

• archiving

• regular updating of technical documentation

• regular updating of operational documenta-tion

• availability within and outside theorganisation of documents

• how to write procedures

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70

CLAUSE IN AREA SUBJECT FOR PROCEDURE

BS 7750

4.8.2 Operational control • identification of activities with significantcurrent or potential effects

• planning to control above identified activities

• development, maintenance, review andupdating of relevant work instructions fornormal, abnormal and incident conditionsassociated with operations

• development, maintenance, review andupdating of relevant procedures and workinstructions for purchasing, contract control,goods received, material handling, storage,disposal, effluent treatment, air emissionreduction equipment, despatch, transporta-tion, laboratory

• dealing with procurement and contractedactivities to ensure compliance with systemand policy requirements

• verification of subcontractor and suppliers’work/behaviour

• measurement and control of all relevantprocess parameters related to the EMS

• internal approval of new process/equipment

• supplier/contractor assessments

4.8.3 Verification and testing • identification and documentation of thefrequency, place and accuracy of EMS controland measurements

• quality control procedures for calibrationcontrol and calibration register

• data control and handling and its inter-pretation

• action when results are unsatisfactoryincluding what is acceptable and what is not

• how to treat measurement data if the controlsystem proves not to have been functioningcorrectly

4.8.4 Corrective action • identification and reporting of non-compliances

• corrective action, how identified, imple-mented and responsibility for correctiveactions

• management representative’s role in thecorrective action process

• initiate preventive actions and ensure they areeffective

• complaint handling

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71

CLAUSE IN AREA SUBJECT FOR PROCEDURE

BS 7750

4.9 Records • identification, collection, indexing, filing,storage and maintenance of records

• registration of relevant information and data

• archiving/storage of records, information anddata including retention time

• availability of information to interestedparties both internally and externally

4.10 Audits • auditing procedures

• planning, documentation, protocols andmethod of carrying out audits

• reporting audit findings including distribution

• action on audit findings

• auditor competence requirement and inde-pendence

• audit team composition

• regular reviews that operations are adheringto laws etc

• schedule and programme for internal audits

• distribution of corporate audit findings/reportfindings

• action on corporate audit findings

4.11 Management review • schedule, programme, method, responsibilityand agenda for carrying out managementreviews

appx

A4

72

T Y P I C A L C E R T I F I C AT I O NQ U E S T I O N N A I R E

Appendix 5

appx

A5

73

appx

A5

74

appx

A5

75

appx

A5

These blank forms are intended for you to photocopy and use to develop your own EMS.

Table A1 lists the forms and the corresponding illustrative example given in the Guide.

Form Illustrative example

Checklist for establishing environmental effects Fig 7

Identifying environmental effects Fig 8

Evaluation of environmental effects Table 8

Internal environmental audit checklist Fig 15

Non-compliance/observation note Fig 16

Register of Legislation Fig A1

Table A1 Forms for developing an EMS

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F O R M S F O R Y O U T O U S E T OD E V E L O P Y O U R E M S

Appendix 6

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A6

77

CHECKLIST:

AREA: CONTACT: DATE:

Sheet.......of.......

DESCRIPTION OF PROCESS(ES):

Question Response Action Required

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78

DEPARTMENT: DATE: REF:

PROCESS ENVIRONMENTAL RECEIVING NOTES/COMMENTS

EFFECT ECOSYSTEM

IDENTIFYING ENVIRONMENTAL EFFECTS

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GG43 published by the Environmental Technology Best Practice Programme. Environmental Helpline: 0800 585794

EVALUATION OF ENVIRONMENTAL EFFECTS

EFFECT: DATE: REF:

DEPARTMENT/PROCESS:

NORMAL OPERATING CONDITIONS

Score Weighting

3 2 1 0 factor

Legislation x =

Environmental damage x =

Interested parties x =

Quantity x =

Normal operating conditions total score =

EVALUATION OF ENVIRONMENTAL EFFECTS

EFFECT: DATE: REF:

DEPARTMENT/PROCESS:

OTHER OPERATING CONDITIONS

Score

12 6 3 0

Abnormal operations =

Accident/emergency =

Past activities =

Planned activities =

Other operating conditions total score =

80

ENVIRONMENTAL AUDIT CHECKLIST

AUDIT NO: DATE OF AUDIT:

AUDIT CONDUCTED BY: AUDIT AREA:

Proc/BS 7750 Ref. BS 7750 requirement Compliance Comments/NotesY/N

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NON-COMPLIANCE/OBSERVATION NOTE

AUDIT OF: AUDIT NO:

AREA UNDER REVIEW: DATE:

NON-COMPLIANCE/OBSERVATION:

AUDITOR(S): REPRESENTATIVE: INITIALS:

(1) (2) NAME:

TITLE:

CORRECTIVE ACTION:

AGREED TIME LIMIT: RESPONSIBILITY INITIALS:FOR ACTION:

NAME:

TITLE:

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REGISTER OF LEGISLATION FOR .............................

PREPARED BY: DATE: SHEET: OF

Legislation/regulationcode of practice

Applicable to whichprocess/service/product

Held where andby whom

Responsibility forcompliance

Related workinstructions

GG

43 published by the Environmental Technology Best Practice Program

me. Environm

ental Helpline: 0800 585794

‘At a time when there is a thirst for knowledge of environmental management systems, thisdocument presents good practical guidance for implementation in the foundry industry.’

Jeff DowsonSGS Yarsley and David PowleyDNV QA Ltd representing the Association of British Certification Bodies

‘As Chairman of BMCC and its constituent associations and their member companies, I welcome the publication of this Guide, which we recommend to companies that are seekingpractical advice on implementation of environmental management systems. The applicationof these systems will assist in meeting the industry’s environmental objectives and improveour image with the public.’

Austin W ScottChairmanBritish Metal Castings Council

‘This document provides useful and down-to-earth guidance for those seeking to inform themselves on BS 7750, EMAS and ISO 14001 and what implementation involves.Although focused on the foundry industry, its contents are relevant to any companyconsidering the implementation of formal environmental management processes – the Guidewill act as an excellent launch pad for many future environmental management successes.’

Alexander PeckhamDirectorInstitute of Environmental Management

‘Through my research into environmental management systems (EMS) I have reviewed nearlyall the sector application guides available in the UK and this Guide is by far one of the mostpractical and helpful guides to EMS implementation.’

Ruth HillaryResearcherCentre for Environmental TechnologyImperial CollegeLondon