Last reviewed 8 April 2019
The Eco-Management and Audit Scheme (EMAS) was developed by the European Commission to help organisations evaluate, report and improve their environment performance. Paul Clarke reports.
Europe and the Environment
With the exception of problems involving the free movement of workers, the argument most frequently used against the EU during the fractious Brexit debate has been that it undermines national sovereignty and tries to bind the Member States into an ever-more integrated, supra-national unit.
The European Commission has always responded with reference to “subsidiarity”. This bit of EU jargon basically means that, while decisions should be taken as closely as possible to the local level, action should be pursued at EU level where it is possible to achieve more than individual countries acting independently. The best example of where this concept has most value, the Commission argues, is the environment — given that problems such as air and water pollution, global warming and waste disposal do not respect national borders.
In the Single European Act (SEA), the first major revision of the 1957 Treaty of Rome and the document that eventually led to the foundation of the single market in 1992, it clearly spelled out its policy in this regard: “(Europe) shall take action relating to the environment to the extent to which the objectives can be attained better at that level than at the level of the individual Member States.”
Putting subsidiarity into practice
Three distinct strands can be identified when it comes to the EU taking action to ensure that all its members are playing to the same rules, with the first and most obvious being legislation. In the 27 years since the SEA gave it a legal foundation to adopt laws in this area, it has produced dozens of environmental directives with pollution and waste alone seeing legislation on landfill, integrated pollution prevention and control (IPPC), batteries, hazardous waste (and its import and export), packaging, electrical waste and industrial emissions. Other significant legal advances include work on habitats, greenhouse gas emissions, environmental impact assessments and endangered species.
The second significant way that the EU (and particularly the European Commission) has shaped environmental matters at a supranational level is through the series of multi-annual Environment Action Programmes of which the seventh runs to 2020 (from 2014) under the general title Living Well, Within the Limits of Our Planet. This is seen as a key contributor to the EU’s target of being able to say by 2050: “Our prosperity and healthy environment stem from an innovative, circular economy where nothing is wasted and where natural resources are managed sustainably, and biodiversity is protected, valued and restored in ways that enhance our society's resilience.”
The least obvious of the three strands is the one on which this article will concentrate. With the first two focusing on action at the European level, this concerns the attempt by the Commission to ensure that subsidiarity works both ways — so that decisions that can better be accomplished at a regional or local level are taken there and the widest possible involvement in environmental management is ensured. Set out in EC Regulation 1221/2009, it concerns the voluntary participation by organisations in the EMAS Regulation.
What is EMAS?
From the beginning, the Commission made the case that excellence in environmental performance offers a strong business advantage, which is why environmental management systems are used worldwide by companies and organisations of all sizes and types. “With EMAS,” it advised businesses, “you find answers to three of today’s key management challenges which organisations of all types face: resource efficiency; climate change: and corporate social responsibility”. Furthermore, it continued, EMAS strengthens an organisation’s ability to cope with risks and to identify opportunities by implementing systematic environmental management processes and structures.
Given the distinctive features of EMAS — such as environmental disclosure through the environmental statement or the application of Key Performance Indicators (KPIs) — organisations are helped to successfully navigate through complex sustainability challenges.
How does EMAS work?
As is often the case with EU legislation, the practical details are contained in the seven annexes to the relevant regulation. These cover the following.
The environmental review (the first step of an EMAS registration is to identify all significant environmental impacts through a review).
Environmental management system requirements and additional issues which must be addressed by organisations implementing EMAS.
An internal environmental audit.
Use of the EMAS logo.
Information requirements for registration.
The environmental verifier’s declaration on verification and validation activities.
Several of these annexes were expanded in 2017 by EU Regulation 2017/1505 and an amended version of the full text published. Most recently, in December 2018, Annex 4 on Environmental Reporting was updated by EU Regulation 2018/2026. This takes account of improvements identified in the light of experience gained in the operation of EMAS.
The 10-step approach to EMAS is summarised in this PLAN-DO-CHECK-ACT infographic…
Setting the standard
Both EMAS and ISO 14001 have the common objective of providing good environmental management. Since the revision of the annexes of the EMAS Regulation, it is easier for an organisation already complying with an environmental management system such as ISO 14001 to step up to EMAS. And the Commission makes it clear that it is indeed a step up. While the ISO 14001:2015 environmental management system requirements are an integral part of EMAS, the Commission argues that the EU initiative is the more credible and robust environmental management instrument available. By contrast with ISO 14001, for example, EMAS provides registered organisations with the following six performance indicators.
EMAS also offers:
stricter requirements for the measurement and evaluation of environmental performance against objectives and targets, and the continuous improvement of that environmental performance
registration by a public authority after verification by an accredited/licensed environmental verifier (which leads to improved access to public contracts)
compliance with environmental legislation, leading to reduced risk of fines and ensured by government supervision
strong employee involvement and greater team-building capacity.
The final section of this article will examine the advantages of this final claim (which is not a requirement of ISO 14001).
What about the workers?
Having brought environmental management down to the level of the individual organisation, can EMAS actually take the subsidiarity principle as far as involvement by individual employees? The amended annexes referred to above certainly make it clear that the process of implementation of EMAS should include involving the organisation’s workers as this increases job satisfaction and knowledge of environmental issues. The various regulations accordingly call for active involvement of employees and their appropriate training.
“Employee involvement” in this context should be understood as including both direct employee participation and the provision of information to employees and their representatives. This requires an employee participation scheme at all levels as well as management regularly providing appropriate feedback to employees.
The 2017 Regulation states: “Employees or their representatives shall be involved in the process aimed at continually improve the organisation's environmental performance” through:
involvement in the initial environmental review
the establishment and implementation of an environmental management and audit system improving environmental performance
environmental committees or work groups gathering information and ensuring the participation of environmental officer/management representatives along with employees and their representatives
joint working groups for the environmental action programme and environmental auditing
the preparation of the environmental statements.
Organisations should also take steps to ensure that their suppliers and contractors comply with their environmental policy. As the UK-based Institute of Environmental Management & Assessment (IEMA) states, implementing environmental improvement programmes should involve workers at all levels of the organisation — from top-level management to those working in administration or on production lines. “Not only does this help to ensure the success of an organisation’s environmental initiatives,” it argues, “it also acts as a valuable teambuilding exercise for employees.”
Appropriate forms of participation such as the use of suggestion books, project-based works or environmental committees can be used to improve the level of employee engagement with EMAS. The Commission offers as an example the UK Environment Agency, which urged its staff to think up ways to reduce its carbon footprint. Employees then came up with the idea of using methanol fuel cells to power the agency's fish counting equipment. Since the batteries no longer need to be changed so frequently, this saved 1.5 tonnes of carbon dioxide (CO2) per year per fuel cell, totalling more than 50 tonnes of CO2 every year. The cells paid for themselves within six months, while the agency saves travel costs related to the replacement of batteries.
“The ideas and experience of your staff can help you identify areas for improvement,” the Commission pointed out. “They usually know best what the workflow is, where weaknesses occur, and which solutions are the most practical. Sometimes (as in the UK example above) these ideas lead to innovations that save both resources and money.”
Keeping it green
One approach to employee involvement is through the use of Green Teams. As with all aspects of EMAS, this should be voluntary and should seek to involve a broad cross-section of the organisation, focusing on people with a good knowledge of its operations, a willingness to learn and a commitment to continual improvement. To fulfil their role effectively, the members of the team must be given the authority to pursue implementation of the EMAS process and must be able to propose new ways of working that benefit the environment, the company and its people. One of the first and core activities of the Green Team can be performing the environmental review that will help identify the company’s current level of environmental performance.
The team could also prepare a simple, anonymous environmental survey to assess employees’ behaviours regarding different environmental topics (waste management, energy, mobility, internal communication, etc), as well as their willingness to adopt more sustainable behaviours. Suggestions that come from the staff, the Commission notes, may, once implemented, be more suitable for the reality of the company, and hence find greater acceptance among staff, than top-down decisions coming from the management.
Under the new requirements of the EMAS Regulation, roles and responsibilities need to be clearly defined and communicated. Online tools have been developed to support the implementation of EMAS, together with an instruction manual. Tool 3 allows responsibilities to be assigned when starting EMAS through the Responsible, Accountable, Consulted, Inform, Support (RACIS) Matrix. It is estimated that this exercise can be done in a Green Team workshop in around an hour and a half, with small groups of three to four people each working on one part of the matrix.
The European Trade Union Confederation (ETUC) has put forward more ideas on worker involvement in its Green Workplaces guide for union representatives. In the UK, the TUC argues that union involvement will strengthen an environmental management system and can form an important part of the evidence employers use to gain accreditation. It has produced a similar guide to that published by its European colleagues (Go Green at Work). This recommends a joint union-management committee to provide the necessary oversight, structure, and mechanism for staff involvement.
Whistle while you work
Since the revision of its annexes, EMAS has invited organisations to identify the interested parties that are relevant to the environmental management system. It requires organisations to list these parties’ relevant needs and expectations and to identify which of these it expects or wants to fulfil. Employees clearly fall into this category, which means that organisations have to assess their staff’s environmental performance expectations.
If they are directly involved in the definition and implementation of measures, their needs are more likely to be satisfied. In its assessment of employee involvement in EMAS, the Commission also suggests that it represents an easy way to boost happiness at work. People gain a stronger feeling of belonging to the company, higher job satisfaction and a higher level of motivation, it suggests, and environmental education actions (such as awareness-raising and training) give employees new motivation and feed their personal development. With a nod to the bottom line, it points out that happier and more committed employees can reduce absenteeism and tend to be more productive.