Environmental Management System (EMS) Annual Management Review Paper Sponsored by Kevin Ingram, Executive Director of Finance and Corporate Services 4 February 2014 1. Issue ISO14001 accreditation requires the Executive Team to review NRW s EMS and make decisions about its appropriateness, adequacy and success on a regular basis. This paper is the required annual review and structured to aid Executive Team make risk-based decisions, targeting their involvement and for NRW to meet the ISO14001 standard requirements in the future. Recommendations for Executive Team are at Section 4 (page 5). 2. Summary In March 2013, Executive Team determined that NRW should aim to be re-certified to ISO14001 standard following the expiration of the transitional accreditation for the legacy bodies (March 2014). Whilst substantial progress has been made, risks associated with re-certification and uncertainties around our current performance data remain and the Corporate Dashboard Measure for EMS remains amber. Internal and external EMS audits identified 59 nonconformities in accordance with the ISO14001 standard (annex 1). 40 of these were breaches of environmental legislation. Most of the others were procedural. In accordance with EMS control procedures, prompt corrective action was taken to close off these nonconformities. Consolidation of the EMS documentation and collation of NRW baseline data is on target for completion in January.The full suite of EMS documents are now available on the NRW Document Management System (DMS). The 9 month performance data for NRW has been collated, indicative data shows the benefit of the accommodation strategy although lease car mileage is up 4% with train travel drastically reduced. There will be a further EMS paper regarding current performance and proposing 2014/15 objectives and targets before the end of March for Executive Team approval. EMS Management Review 4 February 2014 1 of 9
Annex 2 is a new Environmental Policy Statement for discussion and sign off by Executive Team. A key next step for NRW is to embed EMS into the culture of the organisation and the day job of all our staff. This includes NRW Leaders reviewing their risks, performance and compliance regularly and to engage staff appropriately and proportionally with EMS. The EMS Implementation Team (EMS IT) is using tools such as Yammer as well as new EMS inductions and awareness training and workshops with Directorate Leadership Teams to help embed EMS throughout NRW. Environmental Performance How are we doing? 2.1 Objectives and Targets OT1301 Objective: Target: Progress To provide a single Achieve ISO14001 We are on track to achieve integrated Environmental registration by ISO14001 registration; we are Management System March 2014 aiming to schedule external audits (EMS) for Natural for March 2014 Resources Wales (NRW). OT1302 To have a single external verification body to certify our ISO14001 registration. Appoint a single ISO14001 certification body by December 2013 We are expecting to be able to announce the appointment of our external verification body shortly. OT1303 OT1304 Ensure NRW comply with environmental legislation and maintain existing environmental performance and standards Establish a baseline year for NRW environmental and carbon monitoring and reporting Establish and complete an internal audit programme Monitor and report NRW utilities, business travel, water and waste and their equivalent carbon emissions An internal EMS audit programme has been implemented. The audits check we are meeting the standard of the ISO14001 certification and complying with relevant environmental legislation. (See Section 2.4 below.) NRW utilities, business travel, water and waste and their equivalent carbon emissions has been monitored and included in the draft 6 month sustainability report. EMS Management Review 4 February 2014 Page 2 of 9
2.2 Performance Component / tonnes CO2e 2012/13 2013/14 (Projected) Trend Status Buildings Electric 1966.4 1883.5 4% Green Buildings Gas 382.0 376.3 1% Green Buildings Heating Oil 54.3 42.9 21% Green Pool Fleet Fuel 2083.8 2053.1 1% Green Grey Fleet 233.9 224.9 4% Green Lease Fleet 693.3 724.1 4% Amber Hire Car 123.9 120.3 3% Green Train 129.2 107.1 17% Red Air Travel 10.9 5.0 54% Green EMS IT are in the process of apportionment these figures into the individual directorates for further review and action. These will be included in the future paper to set ongoing objectives and targets. 2.3 Pollution Incidents & Near Miss Reporting In the period 1 April 2013 to 31 December 2013 NRW has reported 24 environmental incidents and 1 near miss. Of the 24 environmental incidents, 20 were related to Operations (18 to Forest Operations), and four to National Services. The incident on the Afon Bidno (NIRS ref: 1168337, AIRS ref: CRMRY/231013) in October, at Drum Maen Hafren, did have the potential to have been a serious (Cat 2) pollution incident. The incident was not self reported. It was reported by the Wye Valley Trust. 2.4 Internal & External EMS Audits Audit Nonconformity Reports: In the period 1 April 2013 to 31 December 2013 51 internal and 10 external audits were completed. 59 nonconformities were raised of these 40 were breaches of environmental legislation. The breaches of legislation were due to waste documentation and transfers, nonconformity with discharge consent requirements and compliance with the F-Gas regulations. EMS Management Review 4 February 2014 Page 3 of 9
Corrective and Preventative Actions: The main actions arising out of audits can be summarised in the following groupings: Incorrect Waste transfer documentation EMS IT has designed and implemented well attended and received waste awareness workshops and developed consolidated NRW waste procedures. Waste exemption compliance These were mainly around septic tank maintenance procedures being followed. Now being taken forward via Integral s (facilities contractor) planned preventative maintenance system. F-gas engineer competence Centralised recording of F-gas qualifications for Integral s staff now in place. Discharge consent & Abstraction breaches new EMS procedures have been introduced to ensure future compliance with licenses 2.5 Risk Management Biosecurity, contractors, lease and grey fleet travel have been identified as high environmental risk in our aspects and impacts register. The risks are currently being managed by legacy procedures. There are a number of reviews and projects underway including the fleet review, procurement strategy development and control of contractors in buildings, once they have been completed we will identify measures to reduce the environmental risk further. 3. NRW s Environmental Awareness What are we telling our staff and what skills are we helping them develop? Embedding the EMS throughout NRW remains a real challenge for EMS IT as it is woven throughout all NRW s activities. Our key message is that EMS helps identify and manage our risks and impacts and reduces our costs, protects our reputation and the environment in Wales. Communications: Consistent, relevant and motivating communications is a big challenge going forward for EMS IT and NRW Leadership. We are taking both bottom up and top down approaches simultaneously. There is a new EMS Yammer group which has nearly 100 followers. We will be using this group to keep all EMS co-ordinators and leads up to date and for practical discussions about how we can improve our performance and solve any problems we have. We issued a bilingual EMS update bulletin to NRW EMS coordinators in November and it can be found it in the new Yammer Group. On the 11 th December, EMS IT engaged with the Finance Leadership Team (LT) through a presentation and discussion to help the LT understand how the NRW EMS will help deliver improved sustainability by providing insight into the tools it provides managers to achieve continuous improvement (without being onerous) and for them to take a little time to identify their team s priority actions. The plan is to engage with each Directorate LT in EMS Management Review 4 February 2014 Page 4 of 9
turn, with the objective that NRW leaders have the confidence and knowledge to lead on EMS with clarity over the messages to staff and a proportionate action plan for their team s risks and opportunities. Training: EMS IT designed and delivered 5 EMS & Waste Awareness workshops to over 100 staff. All were well received and plans are in place to repeat as required. We have designed a new EMS induction presentation and are already rolling this to new starters. 4. EMS Recommendations for Executive Team Achieving continuous improvement within NRW New Environmental Policy Statement: Recommendation: Annex 2 is a new Environmental Policy Statement for discussion and sign off by Executive Team. Embedding NRW s EMS: Recommendation: To agree that EMS IT discuss with the Operational Management Groups how to review and action EMS risks and impacts on a quarterly basis for each area. Reviews would include considering the following information for the Area with EMS IT supplying data and support: KPIs and Performance Compliance Staff awareness, engagement and Green Group activity Expanding our EMS: Executive Team to Note: EMS IT and Ops Services South (Peter Garson) are piloting a study of the gap between siviculture, harvesting and forestry civil engineering operations to determine the scale and cost of their inclusion in the scope of NRW s EMS in the future. Note that EMS plan a future Executive Team paper comparing the benefits and costs of including Forestry Operations within NRW s ISO14001 scope. Paper Prepared by: Jacqui Murray & Carl Wannop On behalf of the EMS Implementation Team EMS Management Review 4 February 2014 Page 5 of 9
ANNEX 1: Additional Information A: Types of Nonconformity Figure 1: B: Communications & Complaints 0 Complaints have been received in relation to the EMS 0 Freedom of Information (FOI) requests have been received in relation to the EMS 8 External communications were received relating to the EMS all were responded to within 1 week of receipt. These were in the main requests for the NRW Environmental policy statement and our ISO14001 certification. EMS Management Review 4 February 2014 6 of 9
C: NRW s Aspects & Impacts What are the significant environmental impacts to the organisation? REF. GROUP ACTIVITY RISK RANK AI23 Waste Waste to landfill D4 1 AI43 Operational Bio-security D4 2 AI02 Business Travel Leased (Capes) Fleet Travel C4 3 AI03 Business Travel Grey Fleet Travel C4 4 AI26 Waste Fly-tipped Waste C4 5 AI50 Contractors Control of Contractors C4 6 AI04 Business Travel Air Travel C3 7 AI25 Waste Hazardous Waste / WEEE / Chemicals C3 8 AI21 Estates Historic Land Contamination D2 9 AI31 Operational Oil & Fuel Storage (Bulk) D2 10 AI32 Operational Mobile Plant Use & Refuelling D2 11 AI35 Operational Site construction D2 12 AI36 Operational Flood defence construction D2 13 AI01 Business Travel Pool / Badge Fleet Travel B4 14 AI05 Business Travel Train Travel B4 15 AI06 Business Travel Other Ferry / Taxi / Bus / Underground B4 16 AI08 Buildings Office Equipment & Lighting B4 17 AI09 Buildings Heating B4 18 AI16 Estates Refurbishment & new build C2 19 AI19 Estates Buildings Cooling Air conditioning / F-Gas C2 20 AI33 Operational Sampling C2 21 AI45 Operational Tree Treatment - Electrodyne C2 22 AI28 Procurement Procurement of Goods & Services B3 23 AI37 Operational Riverbank Maintenance B3 24 AI14 Buildings Water Abstraction D1 25 AI38 Operational Managing Fish Farms D1 26 AI22 Estates Management of Tenants / Agreements B2 27 AI24 Waste Recycle B2 28 AI13 Buildings Discharge of Trade Effluent to Sewer C1 29 AI20 Estates Chemical & Fuel Storage C1 30 AI27 Emergency Pollution / Flood /Marine Incidents C1 31 AI29 Operational National Nature Reserves (NNR) C1 32 EMS Management Review 4 February 2014 Page 7 of 9
AI34 Operational Laboratory Management C1 33 AI44 Operational Deer Larders C1 34 AI46 Waterways Ocean Going Vessels C1 35 AI47 Waterways Reservoir, Dam & Embankment management C1 36 AI48 Waterways Shingle & Sand Recharge C1 37 AI49 Waterways Navigation and harbour management C1 38 AI11 Buildings Water use in buildings A3 39 AI17 Estates Buildings Maintenance A3 40 AI42 Operational Vehicle / Plant Cooling (F-Gas) A3 41 AI12 Buildings Discharge to Controlled Waters B1 42 AI30 Operational Use and Storage of Chemicals B1 43 AI39 Operational Electro- Fishing B1 44 AI40 Operational Water treatment (Fish farms) B1 45 AI41 Operational Vehicle Washing B1 46 AI18 Estates Grounds Maintenance A1 47 AI07 Business Travel Video/Audio conferencing / Bicycle / Walk A1 48 AI10 Buildings Grey water & rain water harvesting A1 49 AI15 Buildings Photovoltaic / Biomass / Hydro / Wind A1 50 EMS Management Review 4 February 2014 Page 8 of 9
ANNEX 2 - Environmental Policy Statement EMS Management Review 4 February 2014 Page 9 of 9