Training and Communication

8/3/2019 Training and Communication

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ETIV EMAS Technical Implementation and Verification Page 1 of 104

COMMUNICATION AND TRAINING WHEN ESTABLISHING

AND IMPLEMENTING EMAS

CONTENT

SUMMARY 51 INTRODUCTION 62 COMMUNICATION 82.1. CONSTRUCTION OF EMAS 82.1.1 Getting started 82.1.2 Environmental review 102.1.3 Prioritising of the environmental aspects 132.1.4 Environmental policy 132.1.4.1 What is an environmental policy and why is it done? 132.1.4.2 EMAS requirements for environmental policy 152.1.4.3 Participation in the policy making 152.1.4.4 Put the policy into words 162.1.4.5 Communicate 202.1.4.6 Environmental policy checklist 202.1.4.7 Environmental Policy (sample structure) 222.1.4.8 Example: Stora Enso Oyj s environmental and social responsibility policy 242.1.5 Environmental Program 242.1.6 Documentation, instructions and guidelines 242.1.7 Internal audit 262.1.8 Environmental statement 262.1.8.1 What is an environmental statement? 262.1.8.2 What does EMAS require 272.1.8.3. Planning 272.1.8.4 Content 302.1.8.5 Key-elements and lay-out 372.1.8.6 EMAS statement in relation to other environmental information 372.1.8.7 Feedback and finalisation of the report 382.1.8.8 Verification 382.1.8.9 Dissemination 382.1.8.10 Follow-up 39


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2.1.8.11 Simplified environmental statements 392.1.9 Official recognition 402.2. HOW TO COMMUNICATE? 402.2.1 EMAS requirements Error! Bookmark not defined.2.2.2 Key elements in communication 412.2.3 Internal communication 422.2.4 External communication 442.2.5 Maintaining the Flow of Information 472.2.6 Example: Initiatives to inform and involve employees 472.2.7 Tools for communicating with internal and external stakeholders 502.2.7.1 Employee suggestion sheet 502.2.7.3 The brainstorming method 502.2.7.3 The card method 522.2.7.4. Examples of communication registers 532.2.8 EMS Sample procedures 542.2.8.1 Communication with external parties 542.2.8.2 Sample procedure for environmental communication 563 BACKGROUND INFORMATION ABOUT PERSONNEL TRAINING 593.1. WHO IS IN CHARGE? 593.2. DO WE DO IT OURSELVES OR DO WE BUY IT? 593.3. PERSONAL AND ORGANIZATIONS` TALENT 604 AIM OF THE TRAINING MODEL 605 FINDING OUT THE TRAINING NEEDS 605.1. METHODS FOR MAPPING THE TRAINING NEEDS 605.1.1 User panel discussion 605.1.2 Interviews 615.1.3 Questionnaires 615.1.4 Evaluation of the level of demand in work 61


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5.1.5 The education of personnel 615.1.6 Analysis of development needs 625.2. DEFINING TARGET GROUPS 625.3. CASE: IDENTIFICATION OF NEEDS; PILOT HOSPITAL ST.

JOHANNISSTIFT PADERBORN 625.3.1 Background 625.3.2 Examples and tools 635.3.3 Evaluation of Procedure and Results 676 CONTENT AND METHODS OF THE TRAINING 686.1.1 Goals 686.1.2 Methods 696.1.3 Lecture 696.1.4 Demonstration 706.1.5 Seminar 706.1.6 Conference 706.1.7 Panel 716.1.8 Role Playing 716.1.9 Case Studies 716.1.10 Simulations 716.1.11 Projects 726.1.12 Self-discovery 726.1.13 Movies/videos/cassettes 736.1.14 On-the-job training 736.1.15 Mentoring 736.1.16 E-learning 746.1.16.1 What is e-Learning? 746.1.16.2 Types of e-Learning 746.1.16.3 Delivery Methods 756.1.16.4 Learning Styles 766.1.16.5 Features of e-Learning 776.1.16.6. Benefits of e-Learning 78


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6.1.16.7 Teachers and students roles and e-learning 796.1.16.8 E-learning methods offer a personalized approach 806.1.16.9 Match content to training method 826.1.16.10 e-Learning & Technical Terms 827 DEFINING THE FINAL TRAINING PLAN 888 TRAINING EVALUATION 938.1. EXAMPLES ON TRAINING EVALUATION 938.1.1 EMS training evaluation sheet 938.1.2 Other training feedback forms 958.1.3 Example: EMS training received record sheet 999 TRAINING BUDGET 1009.1. MONEY RESOURCES 1009.2. TIME RESOURCES 10010 PROFILE OF THE TRAINER 10011 CASE: QESTRAIN 10111.1. BACKGROUND 10111.2. OBJECTIVE 10111.3. PRODUCTS 10211.4. ENVIRONMENTAL TRAINING IN HOSPITALS GOOD IDEAS 10211.5. MORE INFORMATION 103


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SUMMARY

Good communication is vital to the success of environmental management system (EMS)

implementation. A good communication system should reach all levels and functions of the

organization. Such a system demonstrates the companys commitment to environmental issues,

gains the support of employees and the external intrest groups, raises employee awareness, and

enhances participation in the EMS implementation.

Regular communication is also the way to gain employee involvement in developing and

implementing an EMS. It motivates the workforce, demonstrates management commitment and

informs all personnel about the results of EMS performance.

A good communication system includes both internal and external lines of communication. It is

important that employees and those outside the company (such as investors, customers, suppliers,shareholders, the local community, environmental groups, government, control authorities and the

general public) are aware of the organizations commitment to sound environmental management.

A positive communication process improves the organizations image, facilitates future business

relationships, increases employee satisfaction and pride in working for the company and

encourages public understanding and acceptance of the companys efforts to improve its

environmental performance.

Since employees are often an excellent source of information and ideas, create ways for staff to

communicate their ideas. External help such as consultants and other companies can also be used.

Communicate progress as it is made. A good internal and external communication system helps

build trust and gain support.

Training is an essential and cost-saving investment for the company to ensure all personnel are

aware of EMS benefits, objectives, procedures and targets. Training also enhances team work,

improving personal relationships and encouraging collaboration to find solutions. Importantly,

training helps employees feel that they have been recognized, motivating their performance and

stimulating their thinking.

Staff training significantly and immediately improves staff competency and quality of service. Well-

trained staff can better understand how to perform in a focused manner with available resources.


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1 INTRODUCTIONEnvironmental management is the management of an organisation's activities that have an impact

on the environment (e.g. organic waste -> landfill -> methane -> climate change).

An environmental management system (EMS) is a continual cycle of planning, implementing,

reviewing and improving the environmental performance of an organisation.

Verification

Continuous

im rovement

Environmental programme

EMS

Audit

Environmental statement

Environmental policy

Environmental review

Figure 1 - Continuous improvementEMAS is a voluntary environmental management and audit scheme and it is based on Regulation

(EC) No 761/2001. To receive EMAS registration an organisation must comply with the following

steps:

conduct an environmental review considering all environmental aspects of the organisations

activities, products and services, methods to assess these, its legal and regulatory framework

and existing environmental management practices and procedures.

establish an effective environmental management system (EMS) aimed at achieving the

organisations environmental policy defined by the top management. The management system

needs to set responsibilities, objectives, means, operational procedures, training needs,

monitoring and communication systems.

carry out an environmental audit assessing in particular the management system in place and

conformity with the organisations policy and programme as well as compliance with relevant

environmental regulatory requirements.


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provide a statement of its environmental performance which lays down the results achieved

against the environmental objectives and the future steps to be undertaken in order to

continuously improve the organisations environmental performance.

The environmental review, environmental management system (EMS), audit procedure and the

environmental statement must be approved by an accredited EMAS verifier and the validated

statement needs to be sent to the EMAS Competent Body for registration and made publicly

available.

Organisation

Verifierverifies the EMSand validates theenvironmentalstatementt

NationalCompetent Bodyregisters theorganisation in theEMAS registry

registration number EMAS-logo EMAS certificate

AccreditationBody isresponsible for theaccreditation andsupervision ofenvironmentalverifiers

environmental review,environmental policy,environmental

programme,EMS,environmental audit,environmentalstatement

approvedenvironmentalstatement,

EMAS-logo

Publicity

Stak

eholders

statement of the environmentalauthority on the compliance ofenvironmental legislation

verification registration

stake

holder

dialogue

Figure 2 - The structure of the EMAS scheme

Participation in EMAS is open to all companies and all other organisations of the private and public

sector, e.g. industrial or primary production, the service sector, the public sector or non-

governmental organisations, which are dedicated to improving their overall environmental

performance and which are located in the European Union Member States and the other countries

of the European Economic Area (EEA).


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2 COMMUNICATION2.1. Construction of EMAS

Construction of an environmental management system (EMS) includes the following stages:

Getting started

Environmental review

Prioritising of the environmental aspects


Environmental Program

Documentation, instructions and guidelines

Internal audit

Environmental Statement

Official recognition

2.1.1 Getting startedThe successful implementation of an EMS calls for the commitment of all employees of the

organisation. Roles, responsibilities and authorities shall be defined, documented and

communicated in order to facilitate effective environmental management.

In the very beginning of the EMS work everybody in the organisation is informed about the

construction of system. Everybody has to be aware of what is done and why. Its good to set the

goals of the work together. Results from environmental questionnaires show that people

understand things in really different ways if they are not defined together and also the concepts

related to EMS can be unfamiliar. It is important to inform how the system construction process

goes on and what it means to different personnel groups in the organisation. To motivate people its

good to underline the benefits of putting effort to environmental issues: How does this benefit our

organisation and my own work?

Promote two-way communication e.g. with suggestion boxes. Add space for environmental issues

in the companys journal where employees can write their ideas, accomplishments, contributions

and experiences during EMS execution.

A new project and a fear of getting more work cause easily resistance. Resistance against changes

is not only a bad thing because at its best it keeps the direction and amount of the change suitable

(good for the purpose). Often resistance against change is caused by lack of information and that


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the personnel of the organisation hasnt been given a chance to tell their own views and ideas. An

open conversation is a good way to win such a resistance. If everyone in the organisation is offered

a chance to participate and have an influence on the work, the approval and commitment to the

work is higher.

The resistance against changes can often be won by changing the negative issues to positive

issues.

New things often provoke suspicions and resistance

Again a new task besides all the other work

How does this benefit me and our organisation?

Its not my job!

Have I done things in a wrong way before

Listen, its always done this way and itll be done in that way also in the future!

Who are you to advise me

Its work for the green persons!

It is worth to remember that


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Taking care of environmental work is an issue that belongs to everyone.

Everyone has a responsibility of ones own work and what one leaves behind.

From the operational and economical point of view it is sensible to take into consideration

environmental issues.

Everyone of us is the expert in his/her own work - now there is a possibility to have an

influence on that work.

You, me, him and her - we all can influence.

Management and the person in charge of environmental issues have an important role in the

success of communication. The examples set by these key persons either reinforce or undermine

the importance of the EMS. It is important to understand that communication does not apply only to

the start of the process. To ensure the success and continuence of EMS, the communication

should be ongoing, well planned and timely.

Example

The CEO from a company personally signed over 250 letters to all his employees, explaining the

importance and benefits an EMS would add to the company and asking for their commitment and

participation. Employee response was extremely positive. Staff from all levels were involved in the

process, and suggestions and feedback came from all departments.

2.1.2 Environmental reviewBuilding up an environmental management system is always started with an environmental review

because it is the tool to clarify the present state of the organisations environmental issues. With theenvironmental review an organisation recognizes environmental aspects which can have either a

positive or negative impact on the environment, and becomes aware of the issues which are

already in order or the ones which are not. One person cannot carry out a review. Teamwork and

communication are the keys to success.

How to gather information

Method Advantages Weaknesses

face to face interviews gives most reliable information

and can be designed to be very

time consuming


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systematic

questionnaire provides consistent approach

and can gather a lot of

information

open to confusion

you only get what you ask for

will require validation

telephone calls can provide immediate

responses

useful for making initial

approaches

may be superficial

may require follow up

meetings and discussions good opportunities for feedback

can build longer term interest

good for team building

difficult to be systematic

time consuming

letters economical in time

can reach large number of

people simply

will require follow up

open to confusion

you only get what you ask for

A special event for the personnel is a good starting shot for EMS work by means of

communication, because everyone gets the information at the same time. For example, personnel

is invited to have an afternoon together and the persons responsible for the EMS work (the

environmental team) present the goals and steps of the EMS work and roles of the different

personnel groups. An environmental review form can be used in the presentation. After that there

can be open discussion or group work. Group work is more efficient when there are a lot of people

present. In this kind of work lively discussion occurs and it often bonds people building up the

system and gives everyone a change to take part actively. Different personnel groups get

knowledge from each others everyday practises and the discussion is experienced fruitfull.

Finding everyones own works environmental aspects can be done as group work; participants are

divided into groups of 3 -5 persons and each group consists of persons from the same personnelgroup. The groups are given the following questions to discuss:

What environmental aspects are concerned in the daily tasks of the group?

What kind of needs of improvement related to environmental issues has the group found out?

A suitable work time for the groups is about one hour. As a summary every group presents those

environmental issues that they have recognized and the needs for improvements. In the end those

issues are discussed together and conclusions are made and written down for filling in the review

form.


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The other option is to have an open discussionwith the personnel groups in order to find out the

environmental issues that their daily work concerns and the needs of improvement. The

environmental team takes care that the conversation stays in the right path and that everyone is

given a possibility to talk and that no ones opinions are judged. The environmental team collects a

memo of the results of the discussions. The memo will be used to fill in the review form.

The members of the environmental team can carry out interviewsof different personnel groups or

their representatives especially when it is not possible to participate in common meetings.

Interviews can be used also to collect information from external interest groups for example from

the waste management company. Interviews can be done face to face or by phone.

When there is a need to collect information from a big personnel or interest group, questionnaires

can be used. Questionnaire gives everyone a change to participate and at the same time it works

as a means of communication for the EMS. Answering should be encouraged in order to get goodanswer percentage.

In order to be consistent, the questions asked will have to be the same for all departments receiving

the questionnaire. If you want to have some flexibility in approach to different departments, then

your alternative is to have numerous different questionnaires with different points of emphasis.

Good practice in the design of the questionnaire is essential. Well-phrased questionnaires should

provide you with an easy job of listing environmental aspects but there may have to be some

interpretation or further investigation with some responses.

Consider the question and response:

Q: Is there any guidance in the laboratory about disposal of waste solvent?

R: Yes. We are within the law.

The response should not be taken as meaning that there is no environmental aspect about the

disposal of waste solvent. The statement about being within the law means that there is an

environmental aspect here but the view is being taken that it does not pose a problem. The fact that

there are laws to be complied with means that there is an environmental aspect.

The major weakness of a questionnaire is that you only get what you ask for. If you are seeking a

particular type of response, then your question must provide an opportunity to get that response.

Imagine that your question concerns the use of electricity and that you are looking for a response

which tells you how/how much that department uses electricity. What is wrong with this question:

Does your department use a lot of electricity? The correspondent can quite correctly answer YES or

NO. This is not what you wanted. How would you rephrase the question?

However a simple YES/NO answer can be useful when it is used as an aid to prioritising. Make

sure that a NO response indicates that some action could be taken.


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2.1.3 Prioritising of the environmental aspectsIn carrying out the environmental review, many issues that could be improved and further

developed are usually identified. However, due to the limited resources, the most significant

aspects need to be prioritised.

Because the environmental impacts are not measurable in one scale there is not either one expert

or one mathematical model to put all the aspects in an absolute order. An environmental group that

has enough people with different skills can do the prioritising of the aspects itself. Also voting can

be used in certain kinds of organisations for example in educational establishments. Voting is a

good prioritising method because everyone gets to say his/her opinion. The environmental group

makes a list of the environmental aspects and in the voting occasion everyone chooses three most

important ones. These environmental aspect lists can slightly differ for each personnel group.

Voting also gives personnel information about the results of the review and continuation of the

work. Commitment to the common objectives also gets better as everyone gets a chance to

influence on their selection.

2.1.4 Environmental policy2.1.4.1 What is an environmental policy and why is it done?

Statement of intentions and principles

Environmental policy is a statement made by the organisation of its intentions and principles in

relation to its overall environmental performance. It can also be thought of as an environmental

vision that defines how the relationship between the environment and the actions of the

organisation is wanted to develop in the future.

Top managements declaration of its environmental commitment

Environmental policy is managements commitment to the continuous improvement of the

organisations environmental performance. Making the policy means that the organisation

recognises its responsibility for the effects that its actions have on the environment. Therefore it isimportant that the organization and management are aware of the state of organisations

environmental issues before making the policy. This is the reason why it is recommended that the

environmental review is carried out before the policy construction.

Recognition of the environment as a basic value of the organization

Environmental policy has a direct connection to the values of the organisation. Construction of a

policy implies that the organisation recognises the environment as one of its core values. In

addition, the policy should reflect the other values of the organisation. It should give an answer to

the question what is the significance of the environment for our organisation.


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Issues to consider

What are the relationships between the actions of your organisation and the environment?

Has the management of the organisation recognised the importance of the environmental

issues?

Has the organisation defined its values? What are these values and what connections do they

have with the environment? How do the strategies of your organisation consider the

environment?

Message to the personnel and interest groups

Environmental policy is the managements commitment to continuous improvement of the

organisations environmental standards. It is a message to the entire organization that the

importance of the environment is recognised by the management. For the staff of the organization itsimultaneously represents an obligation as well as an incentive for considering environmental

issues in their work.

Environmental policy has an important external dimension. From the viewpoint of the public and

interest groups, the policy is considered as the organisations declaration of the importance of

environmental values and the concerns of stake holders. The groups concerned about the

environment usually feel the policy as a positive sign that helps building confidence between the

groups and the organisation. Environmental policy plays an important role as a tool of

communication.

Issues to consider

What kind of message should the environmental policy send to the staff of your organisation

What should be highlighted in the policy?

What are the most important interest groups of your organisation?

What needs or concerns do you think these interest groups may have with regard to the

actions of the organisation?

What kind of message would you send to the interest groups with the policy?

Framework for action and development

The policy forms a framework for action and for the setting of organisations environmental

objectives and targets. It highlights the important environmental aspects of the organization and

provides principles of operation. The principles may take a stand e.g. for prevention of

environmental damage or communication and co-operation with the interest groups.


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The policy should be thorough and wide-reaching. It should give answers to the questions what are

our intentions with regard to improving our environmental performance and how we are going to

achieve our objectives.

The policy should be future-oriented, i.e. it should give answer to the question how we want our

organization to be in the future. Therefore, the policy becomes a driving force for continuous

improvement.

2.1.4.2 EMAS requirements for environmental policy

Top management shall define the organisations environmental policy and ensure that it

fits with the nature, scale and environmental impacts of its activities, products and services;

o it is not only a formal EMAS requirement but also common sense!

includes a commitment to continual improvement;

o EMAS does not stop once an organisation is registered!

includes a commitment to prevention of pollution;

o the principle is to prevent the pollution not to deal with pollution once it has happened!

includes a commitment to comply with relevant environmental legislation and regulations, and

with other requirements to which the organisation subscribes;

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

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

is available to the public

o whether in writing or in the internet

2.1.4.3 Participation in the policy making

Management of the organisation should have a main role when writing the environmental policy

because it is a strategic statement. By going through the policy process, the management has a

chance to really think about what the environmental policy and EMAS will mean to the organisation.

In practice a team usually has the main responsibility for drafting the policy. The management must

decide who will take part in the process (e.g. representatives of the management and personnel,

environmental team, possible external experts). Inviting an external member from some of the

interest groups into the policy meetings can be a fruitful idea. This brings an outside view into the

policy issues and helps in taking the concerns of the interest group more into account.

The policy construction requires a lot of preparation which is best to left to the team. It can make a

summary of the environmental review, collect information and material, or make surveys of the

concerns and needs of the interest groups. It is generally best to have an open and creative

discussion before writing a first draft of the policy. The draft will get the process going on and is


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used as a basis for discussions with top management and preferably with involvement from

employees throughout the organisation (e.g. organise a workshop for a small group of employees).

2.1.4.4 Put the policy into words

The policy process requires material and information about organisations internal and external

environment. To get a feel for what is needed, have a look at existing environmental policies from

different types of companies and organisations. Don't be tempted to recycle policies but remember

that environmental policy should fit uniquely with the organisation in question.

Internal factors are e.g. the vision, mission, strategies and values of the organisation and the

summary of the environmental review. Employee involvement is recommended and one could

organise a workshop for a small group of employees and ask two key questions:

Why are we committed to the environment?

What are we trying to achieve?

To answer the first question, try a brainstorming session using cards and a flipchart to note the

answers. You can group the answers into such categories as what is 'useful', what is a

'requirement' and what is a 'responsibility'. To answer the second question, make a list of

environmental concerns that could be addressed in the environmental policy and discuss where the

organisation wants to go with this.

An important internal factor is the desired level of environmental protection. The minimum level is

defined by the legislation and the local regulations, but there are also voluntary improvements thatthe organisation can accomplish based on its own interests. These improvements are dependent

on the available resources and means of implementation.

External factors to consider are relevant environmental legislation, programmes and agreements to

which the organisation is committed, concerns of interest groups, local circumstances and future

development of environmental issues.

The external factors may cause threats to the organisation whilst they may also provide new

possibilities. Usually, the threats are due to differences between the organisations own perception

of its action and the viewpoints of the interest groups. It is highly recommendable to carry out at

least some kind of analysis of the interest groups concerns and needs before making the policy.

Actions and environmental impacts of the organisation

The environmental policy should be suitable for the activities and products of the organisation. This

means that the organisations line of activities should be recognisable by reading the policy. A

company with massive industrial production may include prevention of air or water pollution in its

policy. On the other hand, the policy of an educational establishment may highlight the importance

of incorporating environmental issues into curricula and teaching.


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A good environmental policy includes issues that are linked to the significant environmental aspects

and impacts of the organisation. Not that issues outside the influence of the organisation should be

excluded from the policy. The policy thus examines the activities within the scope of the

organisation.

Values of the organisation

The core values of the organisation should be recorded in the policy. It is important to understand

that constructing an environmental policy does not mean that the purpose of the organisation has to

change. Instead, the values on which the actions of the organisation are based attain a new

dimension.

It is not extraordinary that conflicts may occur while reconciling the environment with the other

values. Consider a company which has growth of production as one of its core values or objectives.

This implicitly means that achieving the goal leads to increasing consumption of natural resources

which creates a conflict with the environmental image. Another example: an organisation cannot be

committed to energy efficiency on paper, while using obsolete energy-intensive production

processes in practice.

To solve this conflict, the company must develop more environmentally sound ways of production.

At the policy level this means e.g., commitment to seek new alternative renewable raw-materials, or

commitment to continuously improve the effectiveness of use of materials.

Thus, the environmental policy should include the core values of the organisation and must not be

in conflict with them. The idea of the policy is not the change the purpose of the organisation.

Instead, it tells the staff and the public how the organisation is going to improve its actions in a more

environmentally sound direction.

Commitments

EMAS regulation requires that certain commitments are in the policy (see chapter 2.1.4.2) but an

organisation may add its own commitments to the policy as well. These can be e.g., commitments

to the reduction of the organisations significant environmental impacts, such as material

consumption. The policy can also include commitments to the national or international

environmental programmes or agreements that the organisation has proclaimed to follow.

Positive value

The positive value and the contribution that the organisation can provide to the environment and

society is a strong argument to be presented in the environmental policy. This can mean e.g. in the

case of an educational establishment the effects that the education has on the behaviour and

choices of the students in their lives.


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Principles of communication and co-operation with the interest groups

One aim of the organisations environmental policy is to serve as a message to the society and

interest groups. Therefore it may be wise to take the concerns of these groups into account in thepolicy. This can be done by specifying the most important interest groups and the issues that

should be discussed in co-operation with these groups.

Future orientation

People usually tend to possess a conservative approach when the future is considered. This means

that it feels comfortable and safe to lean on the traditions and old practices of the organisation.

However, when creating visions of the future, it would be good to disengage oneself from the past.

Otherwise the vision becomes nothing but a picture of the present, or at best case a result of linear

progress.

The environmental policy is the organisations vision with regard to environmental issues. It should

express the will of the organisation, i.e. how the environmental issues of the organisation are

envisaged to be in the future. An important function of the policy is to be a driving force for the

organisation towards a better environmental performance. An important question to assess the

policy is to ask if it really does so.


Vision, mission, strategies and

values of the organisation

Programmes and agreements

to which the organisation is

committed

Desired level of environmental

protection vs. resources/possible

means of implementation

Analysis of the interest

groups: relation to the

organisation, needs, concerns,

co-operation, etc.

Overview of the trends and

future development of

environmental issues

Summary of the environmental review:

significant environmental aspects, needs

for improvement

Relevant environmental

legislation

Overview of the local

circumstances concerning

environmental issues

Figure 3 - The internal and external factors that affect the policy processSource: Education for sustainable development (Eco-Professionals, EU Leonardo da


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Vinci Programme FIN/98/1/67003/PI/II.3.a/FPC, 2001

A check-list to help construction of the environmental policy

A. Record the organizational core values and principles of operation

What is the purpose of your organisation?

What are its core values and what is their relation to the environmental issues?

What are the most important environmental aspects and impacts of the actions of the

organisation? How the organisation is going to manage them?

B. Check that the key (compulsory) commitments are included

Continual improvement

Pollution prevention

Compliance with relevant laws and regulations

Employee involvement

Add to the voluntary commitments

the reduction of the significant environmental impacts

the national or international environmental programmes etc.

D. Explain how the concerns of the interest groups will be taken into account

Specify the most important interest groups of your organisation

Name the issues which your organisation will focus on in the co-operation with the interestgroups

Take the local circumstances and issues into consideration

Record the principles of communication and co-operation

E. Consider the positive value your organisation can provide to the environment and society

What is the additional value that your organisation or its products and services provide to the

customers and society?

What opportunities does your organisation have to promote sustainable development or better

environment?

What actions is your organisation willing to take to realise this positive value?

F. Confirm that the policy is future-orientated

Does the policy work as a driving force for the organisation?

Does it say how things are envisaged in the future rather than describe how they are right

now?

Does it take into account the trends and development of environmental issues and society?

Prepare a first draft of the policy for internal use only. Make sure all copies are marked up as 'draft

only' and 'confidential'.


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Remember, the environmental policy can be a stand-alone document, but it can also be integrated

with your health and safety, quality, or other organisational policies.

Remember - A good environmental policy

is written clearly and concisely.

is credible and realistic and doesn't make promises the organisation cannot keep.

motivates - the employees are pleased, not surprised.

addresses top priorities for being an efficient environmental performer, avoiding 'activism'.

gives a clear direction and can be achieved through objectives and targets.

2.1.4.5 Communicate

All employees must be informed about the environmental policy and it must be made easily

available. Options for communicating your policy internally include presenting it during regular

meetings, posting it on notice-boards, at the reception, in the canteen, including it in staff hand-

books, putting it on the intranet, sending the policy with pay-slips, and including the policy in

introductory training or materials for new employees. Don't forget to send a copy of the final policy

to everyone involved in the preparation process.

The policy must also be made publicly available. Due to the demands of the consumers, who are

increasingly environmentally conscious, modern companies will have to respond appropriately bycommunicating their environmental policy. Decide whether you want to actively promote the

environmental policy to external stakeholders, e.g. customers, local authorities, banks, etc. Think

about publishing the policy in your organisation's annual reports or other relevant communications

and sending a copy to your suppliers and customers. The means used will depend on the

organisation and the importance of image and external stakeholders. A large international

company, which is doing EMAS not only for the environmental benefits but also to position itself vis-

-vis customers, will launch the policy on the internet, write a press release and organise a media

event.

2.1.4.6 Environmental policy checklist

Source: B.A.U.M. EPAG, Zukunftsorientiertes Umweltmanagement in kleinen und mittleren

Unternehmen, 1998 according to VDI-OIKOS, Effektives Umweltmanagement, II-6.3.5 and Wruk,

Praxishandbuch Umweltmanagement-System, 1996.

To what extent do the following statements apply to your

policy?

1= not at all = 1 point, 5 = absolutely = 5 points

1

2 3

4 5


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1. The environmental policy of your company is written

2. It is defined by management

3. Employees participated in defining the policy

4. It is reviewed at regular intervals

5. When changes occur in the company it is adapted

6. Employees are informed about the policy

7. It covers compliance with environmental legislation

8. It covers commitment to continuous improvement of

environmental performance

9. The following site-related areas are taken into account:

a) energy

b) raw materials and water

c) waste

d) noise

e) production process/es

f) product planning

g) environmental performance of contractors and suppliers

h) prevention of accidents

i) dealing with accidents

j) environmental protection and personnel

k) environment and public relations

10. The policy is understandable for employees

11. It is understandable for those outside of the company

12. It is goal oriented

13. It is credible and meaningful

14. It serves as a guide for employees


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15. It helps employees to identify with the company

16. It is followed up with concrete measures and goals

17. It fits with the ability of management and employees

18. It is consistent with the overall goals of the company

19. It is supported and put into practice by management

20. It takes the needs of day-to-day operations into account

and opens up possibilities as opposed to being a constraint

Total

Maximum no. of points possible (100%) = 150 points

Score obtained ( %) = points

2.1.4.7 Environmental Policy (sample structure)

An environmental policy is a unique document for each organization. The following example is

intended to illustrate and provide ideas for writing an environmental policy that suits the companys

commitment to environmental issues.

Company Xs Environmental Policy

Company X is committed to a clean, healthy environment. We will provide our customers with safe,

reliable and responsive utility service in an environmentally sensitive and responsible manner. We

believe that sound environmental policy contributes to our competitive strength and benefits our

customers, shareholders, and employees by contributing to the overall well-being and economic

health of the communities we serve.

We will:

Comply fully with the letter and spirit of environmental laws and regulations, and strive to

secure fundamental reforms that will improve their environmental effectiveness and reduce the

cost of compliance.

Consider environmental factors and the full acquisition, use and disposal costs when making

planning, purchasing and operating decisions.

Provide appropriate environmental training for all staff.

Monitor our environmental performance regularly through rigorous evaluations.


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Reuse and recycle whenever possible.

Use environmentally preferred materials.

Work cooperatively with others to further common environmental objectives.

Statement of Corporate Environmental Policy

Company X is committed to the continual improvement of its Environmental Management System

(EMS), which includes waste minimization, pollution prevention and compliance with all relevant

federal, state, and local environmental legislation and regulations. The company will meet or

exceed the environmental requirements of other organizations to which Company X subscribes. To

sustain this commitment, the requirements of the Environmental Management System described in

our EMS Action Plan apply to all activities, equipment, material and employees.

The companys Environmental Task Group is the companys EMS Management Representative,

with the responsibility and authority to plan, enforce, and maintain the companys Environmental

Management System. The Environmental Task Group, with the assistance of the Environmental

Action Group and Audit Team, will propose annual targets and objectives to be approved by the

Management Review Board.

The EMS Environmental Task Group may delegate some of this authority downward through the

organization in order to effectively implement the system.

Signed,

President and CEO

(date)


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2.1.4.8 Example: Stora Enso Oyjs environmental and social responsibility policy

source: www.storaenso.com -> sustainability -> EMAS statements

2.1.5 Environmental ProgramThe organisations environmental program is created based on the significant environmental

aspects that were found in the environmental review. It consists of general environmental objectives

and detailed targets related to the objectives. A good environmental target is measurable/it can be

evaluated somehow. One has to be able to verify the realization of the targets in practise so that the

management, personnel and external interest groups can be informed.

The creation of the environmental programme is often done by the environmental team of the

organisation together with persons responsible for planning and resourcing and it is approved by

the management of the organisation. The aim is that the personnel always has a possibility to give

their suggestions to the programme. This can be done for example by having a common planning

and idea event, where the environmental team presents the prioritised environmental aspects to the

personnel.

2.1.6 Documentation, instructions and guidelinesDocumentation such as written instructions and guidelines are essential part of communication.

One clear problem with EMS is that it is usually built from top to bottom and it can produce a lot of


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documentation that does not match very well to the needs of individual workers if they have not

been involved in the planning of the system. This leads to a problem that the system requires the

worker to execute procedures that may be felt irrelevant from the workers point of view. This is not

very motivating.

The documentation related to the environmental management system consists usually of four parts:

Introduction and description of the most important procedures: a description of the organisation

and its activities, the environmental policy and principles, and the main responsibilities and

practices related to the environmental management

Environmental program

Instructions and guidelines

Reference material: it consists of various documents related to the environmental management

system such as minutes of meetings, audit reports, measuring data, permits and agreements,

corrective actions.

When an organisation starts to plan the documentation of its environmental management system, it

should consider, what things really need to be documented and in what way. Too many documents

can prove to be more of disadvantage than of advantage, if personnel sees the whole

environmental file overburdening. It might be useful to split documentation into applicable parts so

that different personnel groups get only the information they need (e.g. emergency instructions are

distributed to everybody and specific work instructions are distributed only to those whose work

relates to them).

Instructions and guidelines

Clear and sufficient instructions have to be drawn up to ensure common ways to act and to divide

responsibilities for various tasks. Instructions are needed especially for those activities in which

everybody must act in the same way. For example, sorting of waste can fail, if everybody sorts in a

different way. In emergency situations it is necessary that all act according to clear and precise

guidelines. When creating instructions is good to remember people that are not part of the

organisations own personnel (guests, suppliers etc.): how are they informed about common

procedures?

Instructions and guidelines must be easily available and preferably in clear sight in all premises

where they are needed. In addition, all instructions and guidelines should be collected in one place,

for example in the environmental management file or electrical database, to ensure their control

and up-dating as well as enabling taking new copies when needed.

Visibility and placing of the environmental instructions is important: a short sentence describing

when to switch off the lights on doors is better than a long written instruction in an environmental

management manual. Instructions can be made visually functional.


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It is good to remember that the instructions should help the personnel and not burden them. Fewer

good guidelines are better than a huge amount of instructions that nobody follows. In many cases,

the way to do things is less important than the desired outcome.

2.1.7 Internal auditThe EMS audit is a systematic, routine and documented process that must be carried out by an

independent auditor (personnel from within the organisation and/or external persons) who takes a

critical assessment on how the environmental management system is working. Almost everyone in

an organisation will be part of an internal audit.

The auditor makes an audit plan and the personnel is informed about it. This is important because

this way everyone gets an idea of the purpose of the audit and its goals and its benefits to the

organisation and for everyone (how can I use it in improving my own job).

It is essential to go through the steps and methods of the audit, the participation of personnel in the

audit and the way the information is processed together. In this stage the right spirit of the audit is

underlined: the needs of improvement are not seen as mistakes but as possibilities!

The auditor makes a report of the audit and gives it to the organisations top management. A good

way to work is that the auditor presents the results to the whole organisation and then it is

discussed. Transferring ideas and information inside the organisation and solving problems

together are the keys of the development. It is important to recognize and spread good practises

that can be useful to everyone. An organisation should find time for these kind of discussions and

record the issues that have adduced.

2.1.8 Environmental statement2.1.8.1 What is an environmental statement?

Upon organisations first EMAS registration it will produce an environmental report (EMAS refers to

this as an environmental statement). It is a way for an organisation to communicate about the

results of environmental work and the continual improvement of it (environmental successes,

problems and objectives). It can also be used to:

motivate employees to get actively involved in environmental protection measures

document environmental activities and performance

reinforce commitment to the on-going implementation of environmental management

monitor success and

aid planning

The most important thing with the statement and its publication is that it gives information about

organisations environmental work to the interest groups openly and clearly.


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Example (Barricalla of Collegno landfill/Italy): As a landfill of hazardous waste we were very

badly viewed by the local community. The publication of our EMAS environmental statement has

notably improved our relationship with them.

2.1.8.2 What does EMAS require

The minimum requirements for the information in the environmental statement are:

(a) a clear and unambiguous description of the organisation registering under EMAS and a

summary of its activities, products and services and its relationship to any parent organisations as

appropriate;

(b) the environmental policy and a brief description of the environmental management system of the

organisation;

(c) a description of all the significant direct and indirect environmental aspects which result in

significant environmental impacts of the organisation and an explanation of the nature of the

impacts as related to these aspects

(d) a description of the environmental objectives and targets in relation to the significant

environmental aspects and impacts;

(e) a summary of the data available on the performance of the organisation against its

environmental objectives and targets with respect to its significant environmental impacts. The

summary may include figures on pollutant emissions, waste generation, consumption of rawmaterial, energy and water, noise as well as other aspects. The data should allow for year-by-year

comparison to assess the development of the environmental performance of the organisation;

(f) other factors regarding environmental performance including performance against legal

provisions with respect to their significant environmental impacts;

(g) the name and accreditation number of the environmental verifier and the date of validation.

2.1.8.3. Planning

Collect information and data already available, including:


Established or developing environmental management system (EMS)

Information on material and energy flows

Environmental programme and environmental objectives

External communication figures (open days, complaints answered, site visits, meetings with

neighbours and customers)

Results of audits conducted


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Take a look at environmental statements that already exist:

http://www.inem.org/new_toolkit/comm/environment/emas/toolkit/toolkit_21_3.htm

Whereas the residents living near a chemical plant have a great interest in information because ofthe danger of accidents, a clothing manufacturer is likely to assign more importance to its end

consumers. Therefore, it is important to establish which target groupsare important for your

organisation. The following groups should be considered:

Employees

Neighbours and local residents

Customers and consumers

Environmental and consumer associations

Suppliers

Shareholders, banks and insurance

Media and press companies

Competitors

Authorities

Schools and universities

Employees

An EMAS statement is normally a result of many years of internal work in the organisation,

involving many of the employees. The printed EMAS statement is, therefore, a reflection of all hard

work being carried out and is usually very much appreciated within the organisation. A well thought-

out structure of an EMAS statement clearly increases its usefulness and can, among other things,

provide important input to in-house environmental education

A transparent presentation of the current situation, the objectives and the measures planned is

particularly important if you wish to continue to involve your employees in an on-going process of

improvement. You can address your employees with various themes:

Present what has already been achieved, using past success to encourage future involvement.

Give information on existing problems and ask questions, to encourage input and suggestions

for possible solutions.

Report on exemplary actions of individual employees.

Pay attention to reports from working groups within the organisation, if their environmental

activities are relevant to your organisation.
http://www.inem.org/new_toolkit/comm/environment/emas/toolkit/toolkit_21_3.htmhttp://www.inem.org/new_toolkit/comm/environment/emas/toolkit/toolkit_21_3.htm


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Customers and consumers

Remember that over time your customers may develop their own environmental purchasing policy.

The provision of credible information on products, processes and on your company's socialbehaviour can be a decisive factor when placing orders.

Suppliers

Your statement can play an important role in communicating your wish for support from your

suppliers on technical and environmental initiatives.

Shareholders, banks and insurance companies

Successful environmental management not only protects the environment, but also secures your

company's future. A complete and honest statement makes it easier for shareholders, banks andinsurance companies to be confident about your organisation.

Authorities

Given the huge number of environmental laws and regulations, it can be assumed that neither the

regulatory authorities nor the employees in your organisation responsible for environmental

management are familiar with all of the environmental legislation relevant to your organisation. At

best, various authorities receive fragmented information, such as permit applications and emission

reports, from which no overall picture emerges. If, however, they receive an environmental

statement that provides them with an overview of your company's environmental performance, it will

be easier for them to develop an understanding for the difficulties that you face.

Neighbours and local residents

Your neighbours are generally aware of many of your company's activities, e.g. heavy traffic when

the shift changes. In addition to these obvious nuisances there are those which cannot be seen,

heard or smelt, such as the threat of accidents from hazardous goods storage. Your neighbours'

interests relate mainly to the types of emissions and the threat of accidents. Building up the

confidence of local residents in your organisation may be of advantage when applying for your next

permit, or enable you to anticipate and react early to local concerns.

Environmental and consumer associations

As environmental and consumer associations are mainly active on the regional or the local level,

they will generally have close connections with your local residents. You should, therefore be

prepared to listen to these associations and to provide honest and detailed information on your

environmental performance.


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Media and press

You will want to be portrayed positively by the press. Your environmental statement is an important

information source for media interested in your organisation, and it should provide this group withinformation of current interest. An update of known facts is less newsworthy than new data,

information on a new project, or new products.

Competitors

Your competitors will also be interested in reading your environmental statement. They will probably

try to find out which new product developments or manufacturing processes you favour and which

new customers you are addressing. Your competitors will not learn anything from the environmental

report that they do not already know.

Schools and universities

Up to now universities have been one of the greatest 'purchasers' of environmental statements. The

strong demand from universities and research institutes has already resulted in some companies

selling their environmental statements as so-called 'teaching and information material'.

2.1.8.4 Content

EMAS-regulation (EC) No 761/2001 requirements (annex III, point 3.2)

Reguirement (a):A clear and unambiguous description of the organisation and a summary of its

activities, products and services and its relationship to any parent organisations as appropriate.

The organisations activities, production or services should be presented in an overall but guiding

way. To help the reader to understand the surrounding in which the organisation operates and its

relative importance and effects on the environment it is advisable to give facts like turnover, number

of employees, geographical location etc. Annotated maps, photographs and diagrams are effective

in providing this information and may also be used to illustrate the organisations management

structure and relationship to other parts of the organisation.

If the organisation produces a large range of products, these may be combined into product groups.

Goods produced and services provided could be included at the organisations basic economic

data. When describing the products or the services that the organisation provides it has proved to

be useful to use flow-charts for the incoming flow of materials such as raw materials, components

and energy as well as outputs such as finished goods, by-products, pollution and waste.

The presentation should clearly state if only part of the organisation is registered under EMAS so

that there is no confusion with regard to closely related parts of the organisation, both from a

geographical and managerial point of view.


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If the company has partially owned subsidiaries, joint ventures or out-sourced production, this

should be accounted for. The same applies for acquisitions, mergers and divestments during the

year.

Good practice:

maps and diagrams

annotated aerial photographs

flow diagrams

classification (i.e. the NACE code) of the organisation

name of contact person

Requirement (b):the environmental policy and a brief description of the environmental

management system of the organisation.

Include the environmental policy in the environmental statement. An organisational chart showing

responsibility for environmental issues may demonstrate how the environmental management

system (EMS) is implemented. A simple flow chart or diagram may also show links between the

policy, identification and evaluation of aspects, targets and objectives and auditing.

The inclusion of a foreword from company management will increase the credibility of your

statement. It should refer to your environmental policy and name the key elements and problems of

implementing environmental measures up to now. The foreword can also refer to the other pillars of

sustainable development, social and economy. Summarise the main tasks ahead. If your company

has received any environmental awards, don't forget to mention them.

Good ideas:

include the environmental policy, and possibly an introduction letter, signed by the management

(managing director, plant manager etc.)

include an organisational chart with contacts for the environmental representative

include a diagram showing the EMS structure

comment on any major changes in environmental policy or management system.

Requirement (c):a description of all the significant direct and indirect environmental aspects which

result in significant environmental impacts of the organisation and an explanation of the nature of

the impacts as related to these aspects

This part of the EMAS statement is probably the most interesting part to a large portion of the

readers and it attracts many for a more thorough study. The key issue is that the reader

understands the link between what the organisation does and the significant environmental impact

that can be caused.
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The organisation may describe how each of its significant environmental aspects impact on the

environment. Alternatively, the organisation may show different environmental media (such as air,water, flora and fauna) and describe which of its significant aspects impact on each. Input/output

diagrams, matrices and annotated pictograms are all useful ways of showing this information in a

concise form.

Readers would also very likely appreciate a description of environmental issues in a holistic life-

cycle perspective - from raw material aquisition, manufacturing, distribution, product use, recycling

and finally during waste handling.

In many cases it is important to make a distinction beteween direct and indirect environmental

effects. Direct effects are usually caused by own activities such as for instance process emissions

at the site of a company or energy consumption at the office as a part of an organisation. Indirect

effects are usually caused by activities carried out by others outside the organisation and thereby

not controlled to the same extent, such as for instance for raw materials and goods delivered by

sub-contractors, transportation services or during usage of products and services. In case of

significant environmental issues linked both to direct and indirect effects it may be worthwhile to

describe these separately under special headings.

Comment also on impacts due to accidents and environmental liabilities. Impacts associated with

past activities that may be translated into future liabilities might also be of importance.

In many cases it is sufficient to provide approximate figures of the information. Too detailed

information may distract many readers.

Requirement (d):a description of the environmental objectives and targets in relation to the

significant environmental aspects and impacts.

The organisations environmental programme with its objectives and targets will help the reader to

understand the organisations activities to improve its environmental performance. Relate objectives

and targets to significant environmental aspects and impacts. This can be presented in a table

which includes the time period by which the targets and objectives should be achieved. This may

be combined with the information required under point (c). Present targets and objectives so thatthey are specific, adequate and relevant, and wherever possible, measurable.


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Example

source: http://www.j-sainsbury.co.uk

Good ideas:

outline the rationale for setting objectives and targets with reference to precautionary methods, if

applicable

report on the designation of responsibility for reaching objectives and targets

indicate the costs of meeting the objectives and targets

relate to targets and objectives from previous reporting periods.

Requirement (e):a summary of the data available on the performance of the organisation against

its environmental objectives and targets with respect to its significant environmental impacts. The

summary may include figures on pollutant emissions, waste generation, consumption of raw

material, energy and water, noise as well as other aspects. The data should allow for year-by-year

comparison to assess the development of the environmental performance of the organisation.

The results of the environmental work, the environmental performance, of course makes up one of

the most importants parts of the EMAS statement. It enables comparisons to be made between

separate EMAS statements both in the same organisation and between different organisations.

Environmental data in the forms of figures and numbers is not always instructive to the layman if

the data is not put into the right context. It is therefore important to relate the data given to e.g.

production volumes, due to the fact that a higher production volume in most cases result in

increased pollution even though there are improvements in the manufacturing processes.

Focus the statement on those aspects considered to be most essential from the environmental

point of view. Environmental performance should always be related to environmental objectives of

the organisation to facilitate for the reader to assess trends and development of the organisation in
http://www.j-sainsbury.co.uk/http://www.j-sainsbury.co.uk/


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question. Here, illustrative diagrams is very helpful to show the development. If reference values

from earlier statements 3-5 years back in time is included, this will further add to the readability of

the document.

Objectives and targets may not all be achieved within the intended time-frame, particularly if the

organisation sets itself challenging goals. If objectives and targets are not met, it is good practice to

include a note in the environmental statement explaining the reason why.

Good ideas:

use of performance indicators helps to increase clarity, transparency and comparability of the

information provided by an organisation

explain what action has been taken to achieve current performance levels

show performance against objectives and targets as well as against legal requirements and

national or sector environmental targets

explain the way the data have been acquired and processed

reproduce degree of fulfilment against targets and objectives from earlier environmental

statements to give a full picture of the organisations environmental performance

comment on why targets have not been achieved

comment if data are not available (no measurements carried out, no environmental permits or

limiting values to fulfil etc.).

Requirement (f):other factors regarding environmental performance including performance against

legal provisions with respect to their significant environmental impacts.

Where the organisation reports data on its environmental performance relating to significant

environmental impacts which are regulated, performance against the legal

level needs to be reported. Other information that the organisation may provide includes details of

investments to improve environmental performance, support to local environmental groups and

actions to promote dialogue with interested parties. Organisations may wish to consider reporting

on existing safety plans.

Good ideas:

product information

procurement policies

important decisions and investments

precautionary actions/environmental protection activities/preventive measures

complaints, public or community concerns

research and development


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incidents and breaches

budget.

Example Air emissions in relation to legal provisions

source: www.storaenso.com -> sustainability -> EMAS statements

Requirement (g):the name and accreditation number of the environmental verifier and the date of

validation.

Sample structure for environmental statement

A logical structure of the statement is essential. One way to approach the task of writing a well-

structured statement is to use to following sample structure for environmental statement.

A. General information on the company (sites, number of employees, etc.)

B. Environmental policy/environmental guidelines

Environmental guidelines

Foreword by management

Milestones in environmental protection and in the company

C. Organisation of environmental management/environmental management system

Overview/Organigram

Environmental management responsibilities

Employee information, training and involvement


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D. Overview of the most important environmental issues

Overview of material and energy flows

Relation of company activities to environmental issues and problems

Methodology: scope of data collection and evaluation criteria

E. Site and production related environmental issues

Material consumption

Energy consumption

Water consumption

Buildings, machinery, soil

Residual materials and waste

Atmospheric emissions, noise and odour pollution

Wastewater

Accidents and accident prevention

Transport

F. Products and services

Products or services sold

Product life-cycles

Product development

G. Overview of the environmental programme and main objectives

H. Influence of environmental management on profit

I. Dialogue with target groups

Previous contacts and activities with target groups

Questions and advice for target groups

Statements from external parties

J. Conclusion

Statement from the environmental verifier

Deadline for the next environmental statement

Responsibilities for writing the environmental statement

Explanation of important technical terms

Contact person, address, offer of additional information


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2.1.8.5 Key-elements and lay-out

Your statement should not be understood as a form of 'one-way communication', but as part of

a dialogue.

Success is heavily dependent on credibility.

Contents must be presented in a clear, easily understood manner.

If it is to remain interesting and have a media impact, not only in the year of publication but also

in following years, it is necessary to emphasise certain elements.

Check which are the most important environmental issues and impacts of your site or company

and focus your environmental statement on these issues.

Unnecessary overlaps, repetition and contradictions with other forms of environmental

communication by your company should be avoided.

An EMAS statement must be attractive reading to be able to compete with the vast amount of

environmental information currently available. This is not always accomplished by giving it a "fancy

format". A well structured but more simple statement may work equally well. Do not underestimate

the market value of a good EMAS statement. Using outside expertise may help to give good advise,

when preparing the first statement, on how to find a appropriate approach to a suitable lay-out of

the document.

Too technical matters and environmental jargon must be avoided in order to be able to deliver an

easy understandable message to the reader. Too much data may do the same harm and make thetext difficult to digest. Technical information can preferably be summarised in tables or put in an

annex at the end of the document.

It is to recommend to use the EMAS logo in the statement, preferably on the front cover. The EMAS

logotype brings credibilty and status to the organisations environmental work. The logotype

distinguishes the EMAS statements from other types of environmental reports.

2.1.8.6 EMAS statement in relation to other environmental information

An organisation may be a part of a larger corporation, which annually publish an environmental

report covering information from all separate parts of the organisation. If this is the case, it is

important to harmonise the reporting structure so that information from separate EMAS-registered

parts can be added and, hence, directly used as inputs to the corporate environmental report.

Mandatory environmental reporting to authorities has quite another objective compared to EMAS

statements. The environmental report to the authorities addresses issues understandable to people

having environmental issues as their field of expertise. The EMAS statement, on the other hand,

should be fairly brief and written in a way meant to provide a heterogenous group of people with an

understandable overview of how the organisation influences the environment and how it manages


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its environmental work. If not carefully done, trying to combine the environmental report to

authorities and the EMAS statement into one document could result in too detailed and complicated

statements hardly understood by the public.

If parts of the EMAS statement is meant to be used in information campaigns or for advertisement it

is important to use a simple language that is non-deceptive and that clearly represent the

environmental properties of the activity, process, product or service under study.

2.1.8.7 Feedback and finalisation of the report

Once all information has been collected and a draft version prepared the statement should be given

to each member of the team established for developing the statement. The draft version should

also be given to different employees and people external to your company to get feedback on the

content and the comprehensibility of information. The feedback that has been gathered should beincorporated into your statement.

2.1.8.8 Verification

It is recommended that the organisation has the structure, including illustrations, of the statement

ready for discussion with the verifier at an early stage. According to the EMAS regulation, the

verifier shall approve the EMAS statement provided it is correct, enough detailed and fulfils the

requirements listed in the regulation. The verifier should sign every part of the original document

when approved.

The verifier will most likely provides the organisation with advise on how to improve the quality of

the report. This is a good reason for not finally setting the lay-out of the document, or even worse to

print it before it is approved by the verifier.

2.1.8.9 Dissemination

The EMAS statement is official, i.e., it should be easy available for anyone who has an interest in

receiving a copy. It is important to consider practical procedures for co-ordination and distribution of

the EMAS statement with the annual report of the organisation. We recommend to make use of

internet and other forms of modern media to make the information easily available and widely

spread.

Prepare yourself early, so that your environmental statement does not end up gathering dust on a

shelf. In the planning phase think about how the statement will be published and distributed and

how it can be used effectively in dialogue and co-operation with your target groups.

The following points should be considered:

How will your defined target groups obtain the publication?

o who needs a paper version,

o who needs only an electronic version


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o who just needs to be informed that the statement is available on your website?

Which internal and external persons, groups or organisations are responsible for the

publication and distribution of the statement?

How many paper versions should be published?

Who is responsible for dealing with enquiries about the environmental statement and how

much time can be given to this task?

The following are ways in which you can reach your target groups with a paper version:

Presentation and distribution at staff or department meetings and press conferences.

Mail to customers, suppliers, sector associations, chambers of commerce, etc.

Distribution at trade fairs.

Personal distribution through sales representatives or with business contacts.

Display in retail outlets, public buildings.

Presentation and distribution at local or regional environmental discussions with authorities

representatives, neighbours, neighbouring companies, etc.

Mail to residents and authorities.

The following are ways in which you can reach your target groups with an electronic version:

Email to customers, suppliers, sector associations, chambers of commerce, etc.

Make a link to the statement in your organisations website.

2.1.8.10 Follow-up

Do not forget to collect and evaluate feedback (questions, suggestions for improvements, criticism)

which the company receives in response to the statement. Environmental statements can be

included as part of an environmental learning process. Use this opportunity, continuously improve

and optimise your environmental statements.

Keep a written record of feedback. If you do not receive this feedback personally, collect it from the

people or departments who do, or organise a meeting with the relevant people a few months after

publication of the report to evaluate the reactions and impacts.

2.1.8.11 Simplified environmental statements

According to EMAS environmental statement must be published according to the organisations

audit cycle, i.e. at least once every three years. If the organisation doesnt conduct an

Training and Communication

Documents

Transcript of Training and Communication