· Environment protection awareness booklet placed in each guest room to spread the message.
· A Welcomenviron newsletter which contains `Happenings’ also placed in guest rooms.
SmithKline Beecham
The Smith Kline Beecham site in Currabinny, on the Southern shores of Cork Harbour makes a variety of ethical Pharmaceutical compounds which are then tabletted or made into injectibles in several of the SmithKline Beecham secondary plants.
The Integrated Pollution Control Licence – Application Process
The application process began in early May 1994 and ended with the lodging of the application in early July. In addition, an EIS (Environmental Impact Study) had to be completed and submitted with the IPC Application . The IPC Application documentation comprised of six substantial volumes containing extensive information on air emissions and control and abatement measures, water emissions control and abatement, noise, environmental management systems, waste minimisation . This information had to be supported with internal / external reports, maps, and drawings.
Compilation of such information in the time required (May to July) necessitated a team of five people working full time on the task. Several meetings were held with the EPA Inspectorate during the course of the Application and these were most useful in getting the document into shape for final submission.
Consultation
In addition to the technical information needed in the application, the IPC guidelines included an emphasis on consultation. We decided to adopt the most comprehensive consultation process possible. Accordingly, we met with 16 external organisations, including Cork County Council, Cork Chamber of Commerce, Ringaskiddy Residents Association ( Local Community Body) and Cork Environmental Alliance. In each case, detailed briefings were given to these organisations, including details on the IPC application, EIS and on the expansion programme The amount of information requested by these organisations varied and in each case, we responded fully.
The IPC application process was insistent on transparency at all stages and submission to the EPA on the application were invited from interested parties. The application and EIS were lodged with the Agency on the 8th.July and copies of these were also provided to the Cork Environmental Alliance at their request. All the documents provided were also made available in the Public File by the Agency.
Processing of the Application
The EPA commenced detailed examination of the IPC Application and EIS in early July 1994 and came back with requests for further information in the third week of August. As well as this, the Cork Environmental Alliance wrote to the EPA with detailed comments on the Licence Application / EIS.
There was regular contact between the EPA Inspector and the Company especially in the period coming up to the issuing of the proposed Licence which took place on the 28th, October 1994. The statutory period of 21 days for third party appeals and 28 days for appeal by the Applicant passed with no objections and SmithKline Beecham became the first company in the state to come under IPC with the formal issuing of the Licence on 6th, December 1994.
Layout of the Licence
The Licence has two main sections :
· The front section comprises of fourteen sections
· The second section has six schedules.
The sections in the front part of the Licence incorporate the following :
· Environmental Management Programme which requires plans for the following :
· Reduction of Wastes at Source.
· Improved cleaning procedures.
· Improvements in abatement systems.
· Reduction in fugitive Emissions.
· Savings in energy and material usage.
· Solvent Mass Balance for certain substances.
· Access to Information by the Public.
· Notification of Incidents.
· General Conditions for Emissions to Air, Water.
· General conditions for waste storage and Disposal.
· Toxic and Dangerous Waste Disposal.
· Noise Emission Limits
· Surface / Groundwater Emissions Monitoring.
· Reporting Schedule .
The six Schedules in the Second Part of the Licence comprise of the following :
1. Emissions to Atmosphere – Emission Limit Values.
· Atmospheric Emissions – Abatement /Treatment Control.
· Monitoring of Atmospheric Emissions.
2. Emissions to Waters – Emission Limit Values.
· Effluent Treatment Control
· Monitoring of Emissions to Waters.
3. Toxic and Dangerous Waste Disposal – Off Site.
· Other Wastes.
· Analysis of wastes for disposal off site by Landfill.
· Monitoring of Wastes before incineration on site.
4. Noise Emission Limits.
5. Surface Water Emissions Monitoring.
· Ground Water Monitoring on Site.
6. Reporting Schedule.
Working with the IPC Licence
As detailed above, the licence went into force in early December 1994 and this entailed a considerable change in the format of reporting of the monthly site environmental performance. As well as this, we had to start work on the reporting obligations on the following over a phased period of 19 months with the main part of the Programme to be completed within 12 months.
The required reports have all been submitted within the time required by the Licence. The reports which had to be furnished within three months, especially the Environmental Management Programme, imposed a considerable pressure on time and the Company enlisted the services of a Consultancy to compile this report.
Monthly Report
The report format had to be changed from that required by the Cork County Council to a format which would satisfy the IPC Licence. The major changes were in the Atmospheric emissions part of the report as additional information was required by the Agency on Incinerator Emissions as well as some atmospheric vents on site.
It was our experience that it was vital to draw up a detailed schedule of which months certain tests had to be done as some have to be done each month and others four, twice, and once per year. etc.
The agency visited site on a regular basis to sample the Treated Effluent from the Biological Plant . As well as this, several samples were taken from Incinerator and Plant atmospheric Vents. There was also a Noise survey carried out early this year .
Audits, Environmental Management Systems, Waste Minimisation.
Audits
The Agency carried out a baseline Audit in December 1995. This comprised of a one day visit by an Agency Auditor who was accompanied by the EPA Inspector normally assigned to deal with SmithKline Beecham . Compliance with the terms of the Licence was examined in detail and no non compliances were noted. The EPA team placed a strong emphasis on items such as :
· Waste Minimisation.
· Document Control
· Environmental Management Systems.
· Preventative Maintenance Systems.
They were supportive of those systems on site which were proactive and which incorporated proper planning and review techniques as they stressed that such systems serve to underpin the type of Environmental Management Systems desired by the Agency.
KEYS TO SUCCESS
§ Design the ISO 14000 EMS around the culture of the company: this is crucial to success
§ Success should be defined properly and in measurable terms? It should be actual achievement of progress toward sustainability or an appearance rather than meeting public and “standards” requirements? Measurements include reducing the amount or severity of needed permits, producing less waste, and reducing emissions. In the long run, pursuing measurable, actual success provides real information for real decisions, which can result in real savings. As the saying goes, if you don’t know where you are going, you can end up anywhere. SO 14000
§ Reluctant managements can be persuaded that ISO 14000 is beneficial if they understand the strengths and weaknesses of your current way of doing environmental management. “Highlight the weaknesses of the existing approach, the business and financial implications of these weaknesses and how an EMS according to ISO 14000 could add value.
§ Middle management and operations employees can have important input to the value of EMS and ISO 14000, but they may see it as an additional burden. So, look for ways that it benefits them to gain their support and creative input.
§ “Focus in the early stages on identifying win-win initiatives in order to reinforce and deliver the bottom line opportunities for your organization. ISO 14000
§ A program in Taiwan will support companies interested in ISO 14000. This concept may be a key to the success of ISO 14000 in general: support by government agencies
§ Self certification may be the best first step for many companies.
The Texas Natural Resource Conservation Commission (TNRCC), the state EPA has a very aggressive program to help industries set and achieve effective pollution prevention. TNRCC will send several of their registered engineers to your plant, not as enforcement officers, but as pollution prevention consultants.The TNRCC also has a Small Business Assistance Program which offers small businesses free environmental consulting to achieve environmental compliance. The voluntary consultants are referred to as ‘enviromentors’.
§ Targets and objectives: tying environmental effects to targets gives a company (and the people who work there) something to work towards and be proud of when they achieve their targets. It helps create “champions” who will do a great deal of work on their own, without cattle prodding from the EHS management. 14000
§ According to SGS, an international certification organization, these have been the major areas of nonconformance to the standard found in audits: establishing procedures for identifying environmental aspects, integrating the EMS into existing management system elements, identifying appropriate operational controls , and procedures for identifying problems and taking action to eliminate them . Extra attention to these areas during EMS development and a high quality phase I or gap analysis can speed the registration process. ISO 14000
§ In the policy statement, use words that can be audited and connect to significant aspects and impacts. Words such as “not”, “never”, always, and ” empowered” are inappropriate. ISO 14000
§ One difference between many existing environmental programs and an ISO 14000 EMS is that the program may not be a a system integrated into all parts of the company. The ISO 14000 system spreads environmental responsibility throughout the organization.
§ There are many gray areas in the ISO 14000 standard. Registrars vary in the way they interpret some things when performing audits. For example, a “major finding” means that there is an important nonconformance with ISO 14000. The nonconformances that are called major findings and what they mean to registration will vary among registrars. So, compare registrars in this area before choosing one.
§ The ISO 14000 EMS is a system where each part is related to and integrated with the others. Environmental aspects, those elements of a company’s activities, products, or services that can interact with the environment, are the key to the whole system. Impacts, policy, objectives, training, emergency preparedness, procedures, and documentation must all relate to the aspects.
§ Many companies are moving easily into ISO 14000 because they were already doing many of the things it requires. So, even if a company is uncertain about its timing and commitment for ISO 14000, it can identify those aspects of the standard that can benefit it now and begin phasing them in over time. This “cherry picking” can bring immediate benefits and the phased approach will minimize disruption. If the market or regulators encourage registration, progress will be faster because of this foundation. For example, Rockwell Automation’s registration effort was made easier because it was based upon environmental systems already in place. Modifications were all that was necessary.
§ The biggest challenge and opportunity for success is to change the way a company thinks about the environment. It must be seen as a business issue: what benefits does the environment bring the company and its customers? This is a change from reactive, command and control thinking. Since everything comes from the environment, this change in thinking leads to protection of the sources of
business prosperity. ISO 14000
§ 3M is well known for its success in reducing pollution. One key to its success is focusing on four high impact areas: product reformulation, process modification, equipment redesign, and recycling or reuse of waste materials. The most important is the first: to design pollution out of the product. ISO 14000
§ Top management’s commitment to ISO 14000 must include visible concern over environmental issues and high standards for which people are held accountable. Most important is the commitment of adequate financial, organizational, and technological resources. If the “walk” doesn’t match the “talk”, credibility will be lost along with individual effort and results.
§ There will be conflicts between environmental management and business operations. Management must truly consider all sides with an eye to win-win solutions. Since most people can sense when a “spin” is being given to a situation, rigorous honesty is required in the communication of problems and solutions. ISO 14000
§ Setting high standards can help a company achieve more than it thought possible. Many companies are setting a standard of “zero waste.” This may not be realistic for some. It is important that goals be a stretch and achievable. The bar can always be raised later. Achievement of goals builds confidence and momentum. An employee suggestion program is a good first step to getting people involved and harnessing the power of local knowledge. Two things that can add to the power of this program are (I) giving employees the ability to implement their own suggestions and rewarding them for their efforts. Follow-up is also important; give timely feedback. (ii) Companies can turn their wastes into profits when their wastes can be input to the processes of other companies, and companies can reduce their materials costs when they use the wastes of another company as their input. This requires coordination among purchasing, product design, and waste management. The President’s Council on Environmental Quality found that frequently employees thought they were doing everything they could to reduce waste when a recycling program was in place. In reality, much more could be done. This is a problem of perception that management leadership, communications, and special programs can overcome.
§ Communication by top management is critical. The intent of the project, its benefits to company and individual, the overall vision, and the plan for accomplishment must be clearly communicated. ISO 14000
§ The pace of EMS development and implementation should be fast enough to keep employees interested and excited, but not so fast that errors occur or that it is a superficial effort. ISO 14
§ The level of discipline and structure will be higher than exists with most existing environmental systems. This requires greater education and management attention. ISO 14000
§ For organizations with ISO 9001, the existing management process can be applied to 14000. The technical and regulatory aspects of an ISO 14000 EMS are combined with the existing management system, discipline, audit process, and continual improvement process of ISO 9000. Unique aspects of ISO 14000 will be visible against the 9000 background. This approach leverages the investment in ISO 9000 and reduces the cost of ISO 14000. The way each organization practices environmental management is unique. Success is achieved by tailoring the system to recognize internal and external characteristics.
§ The benefits of an ISO 14000 EMS are both short and long term. To maximize long term benefits, a long term view must be taken and supported by management. If the long term is traded off for short term objectives, long term benefits will suffer. ISO
§ ISO 14000 stresses the creation of a “system.” This means that all parts of the program must be connected for them to survive. Connection to the organizational policy and the benefits must be visible and maintained.
§ Explain environmental facts and the EMS in an interesting way to help employees maintain their enthusiasm. Present information using marketing and communications techniques. ISO 1
§ Even though a program has been established and responsibilities assigned, this does not mean that environmental concerns have been addressed or benefits achieved. Implementation must be thorough and management committed to ongoing support for the program to succeed. ISO 14000
§ Align goals and objective setting process with quality (ISO 9000) and operations programs. Team with quality and manufacturing improvement programs to build on their success and gain their support. Include saving money, reducing cycle time, and making a good product. ISO 14000
§ ISO 14000 registration alone is not enough to assure success. The EMS must become an integral part of the organization to reap maximum benefits. This may require a new way of thinking about the business and its stakeholders. Top management must be committed to the environmental policy and environmental management system. Their commitment must be visible to the whole organization so that each employee contributes fully. ISO 14000
§ Identifying as many environmental aspects as possible is very important. The plan may choose not to address some aspects, but having identified them provides the opportunity to determine their impact and decide if the impact is great enough to warrant action. ISO 14000
§ Implementation should be pushed to the lowest level possible and as widespread as possible. Responsibility for environmental protection would no longer reside with a single group. ISO 14000
§ Participation by many different stakeholders will increase the chances for success. These could include employees, stockholders, customers, insurance carriers, and suppliers. ISO 14000
§ Pollution control moves from an ?end of the pipe? objective to one involving all stages of production. Product development, service delivery, materials purchasing, product design, and manufacturing operations must all be included. I Auditors will look for continuous improvement in the system. These improvements can include better education of employees, better communication of ideas from and to employees, better reporting of environmental impacts within the company, and improved identification of environmental aspects. ISO 14000
§ The benefits of ISO 14000 may be new to the organization, so they may not be recognized or pursued. Since there is a cost to ISO 14000 registration, pursuit of benefits must be aggressive. In organizations that have an environmental management department, their role will change from one of just responding to laws and regulations to one that includes leadership and education for all members of the organization. ISO 14000