Safety at Work 6 E Part 18 potx

The environment at large 995 methods even though the least damaging environmental choice was their original proposal. One lesson of this event is that companies need to consider the whole life cycle of their products and processes, including their end-of-life treatment or disposal, rather than leaving this as an afterthought. 5.5.5 Ethical investing and green procurement Concepts such as ethical investments are likely to be low on the agenda of senior management but in recent years there has been a flurry of proposals, strategies, suggestions etc. that their investments should be linked with responsible or ethical funds. The aims of these are, in theory, to loan money or invest only in activities that are ethical. Non-ethical activities typically include the use of child labour in emerging countries, poor health and safety records or a history of environmental problems. The Co-operative Bank is perhaps the best known large UK institution that claims to embrace ethical investing. According to their policy 3 they only put money into projects and companies that meet certain socially responsible criteria. It is difficult to predict whether this is going to be the usual approach in the future, or whether it is just appeasing Greenpeace and Friends of the Earth. Even if ethical investing does increase in the future, it may continue only if the world economy remains healthy. In periods of recession when companies and even governments are faced with economic survival, it will be tempting to simply maximise profits and only meet legislative requirements. In 2001 the FTSE4Good 4 index was launched internationally with the aim of showing potential investors the most ethical companies based on a range of criteria. There have been some criticisms of the basis of the index and the presence or absence of certain companies. The criteria used to compare companies on the index include: ᭹ working towards environmental sustainability; ᭹ developing positive relationships with stakeholders; ᭹ upholding and supporting universal human rights. However limited the uptake at present, this is clearly a political initiative that is unlikely to disappear. Their Internet site is being updated regularly and extended to cover different parts of the world. Many claims have been made that government purchasing depart- ments should buy ‘green’ products or services under the concept ‘Green Procurement’. This attempts to encourage industry and service providers to consider the overall environmental impact of their products, processes, activities etc. over their complete life cycle, i.e. the ‘cradle to grave’ concept or Life Cycle Assessment. In theory the benefit to organisations following this approach is that they will have preferential treatment when tendering for government contracts. However, government departments have to operate within financial constraints that can predispose orders being placed with those who undercut prices rather than those with ‘Green Products’. 996 Safety at Work Life Cycle Assessment and Design for Environment principles are still comparatively new concepts and can have widely variable and unpre- dictable outcomes. In the competitive real world, few companies can produce sufficient ‘environmentally-friendly’ products at a cost that would sell in sufficient numbers to make them profitable or sustainable. Even so, there are proposals in the European Union (EU) to bring the principles of Life Cycle Assessment and Design for Environment in for a range of products. These proposals are currently being resisted by industry as unworkable, although political trade-offs are likely to result in some controlling legislation before 2010. Responsible companies are beginning to incorporate these principles in their research into new products. However, the incorporation of green issues into product design is only practised if there is a potential market advantage. In manufacturing operations protecting the environment is often a win/win situation bringing reduced costs through reduced waste, using less raw materials and reduced energy demand. Many attempts have been made to persuade industry to adopt the recognised environmental management systems of ISO 14000 and the Eco Management Audit Scheme (EMAS) as a means of enhancing environmental performance. This topic is dealt with in section 5.5.10. 5.5.6 Increasing environmental legislation, controls and public reporting Compared with health and safety legislation, effective environmental controls are a relatively recent innovation. Most environmental legislation has appeared over the past 30 years and although it seems to increase each year, the focus appears to be changing. The trend is shifting from monitoring and controlling at point sources of emissions and releases towards reducing impacts at source by making changes to processes. This doesn’t mean that controlling emissions will be abandoned. Recently the EU adopted a Directive on Environmental Liability 5 that deals with identifying those responsible for damaging the environment and holding them accountable. With increasing accountability comes the need to report. There are already mandatory reporting requirements in many countries for certain regulated processes. For example, in the UK, a site that operates a Part A Process under the 1990 Environmental Protection Act has certain environmental data reporting obligations. In Ireland since the mid-1990s certain sites have Integrated Pollution Prevention Control Licences with extensive reporting obligations and this approach has been widely adopted across the European Union. Many large responsible organisations produce voluntary annual environmental reports as part of their public relations policy. Some are stand-alone environmental reports while others are integrated with a health and safety report and presented as part of the company’s Annual Report. There is pressure on government to put a legal obligation on companies above a certain size to publish an annual environmental report 6 . The environment at large 997 5.5.7 End-of-pipe control ‘End-of-pipe’ controls are those schemes aimed at ameliorating, at the point of emission, the worst effects of atmospheric pollution and were the basis of most of the early environmental legislation which concentrated on setting absolute emission limits in the pious hope that it would maintain the status quo. With hindsight this approach was flawed since, to reduce environmental damage emissions should be either eliminated or reduced to as low as is technically possible. An example is the setting of SOx emission limits on power stations. In the electricity industry, a generating station could only meet these limits by either reducing output or by putting scrubbers on the top of the emission stacks to absorb most of the SOx. Problems then arose when there was pressure to increase output resulting in exceeding the capacity of the scrubbers. In these circumstances end-of-pipe controls were no longer sufficient. Even if these moves were successful, there was little pressure to reduce the consumption of oil or coal and thus the environmental impact associated with their extraction. Another example is the reduction by incineration of organic solvents to carbon dioxide and water with the aim of preventing VOCs entering the atmosphere and creating smog. While smog may be eliminated at ground level more carbon dioxide would be released to the atmosphere and add to the Global Warming problem. This represents a partial environmental gain at best. The problem relates to setting limits that are absolute and are not linked to production levels. Hence, a site could reduce its emissions, discharges or waste per unit of production yet still exceed its legal limits because its overall production had to be increased in an effort to remain more profitable in a highly competitive world. Controls that set fixed absolute limits do not lead to a culture embracing continuous improvement. If new technologies became available, the BATNEEC principle (best available technology not entailing excessive cost) needs to be applied when setting revised emission limits. It is important that economic factors are considered when setting environmental limits. Unfortunately, with the setting of absolute emission levels there is no real incentive for a company to reduce impacts as far as possible because there is no reward based on a sliding scale. On the contrary, the pressure is to maintain operations at a level that just meets legal requirements. Ed Gallagher (former Chief Executive of the UK Environmental Agency) lamented on many occasions that some companies are only motivated to operate the ‘CATNAP’ principle (cheapest available technology neatly avoiding prosecution)! This attitude of industry is not surprising when there is no obvious economic incentive to continuously reduce environmental impacts. The issue of a statutory notice will only halt operations until emissions can be brought down to agreed levels but will not result in any ongoing improvements. If bringing emissions down to set levels results in the operation no longer being viable it poses the dilemma of closing down local businesses and putting local people out of work. Emission limits also require recording to ensure that they are not being breached. 998 Safety at Work Responsible site owners will monitor and record their levels of emission to ensure they are operating within the agreed limits with enforcers visiting premises only to check or validate the data. The costs of monitoring are an on-cost on the product. 5.5.8 Polluter pays Legislative arrangements vary from setting absolute limits to introducing charges linked to the amount of environmental impact caused by emissions. This latter arrangement is cost-based and gives a financial incentive to companies to reduce their impacts on the environment. Examples are the Water Industries Act 1991 7 and the Water Resources Act 1991 8 . The former relates to discharges to sewers of trade effluent where the concern is to control the quality of the discharge to ensure it can be accommodated by the sewage treatment works. It is enforced by the water utility companies who make a charge depending on the type, content and quantity of the discharge. This gives an incentive to companies to improve the quality of their discharges. The water utility companies decide which sites require consents and also have some control on deciding what parameters to apply. Criteria in these consents can be influenced by the limits imposed by the Environment Agency on the water utility company itself. Monitoring data have to be obtained, available and checked periodically at locations chosen by the water utility company. The Water Resources Act 1991 relates to water abstraction and to discharges to controlled waters. It is administered by the Environment Agency who apply stricter standards than those required under the Water Services Act since the discharges are to natural water courses that have no means of treatment. Usually the water utility companies have consents from the Environmental Agency to discharge their treated effluent into controlled waters. Charges paid by the polluter are based on the ‘Mogden Formula’ 9 which allows for suspended solids, concentration of certain components such as ammonia, BOD (biological oxygen demand) and/or COD (chemical oxygen demand), and volume discharged. There are also ‘standing charges’ which vary among the Water Service Companies. The actual charge finally levied increases with the amount of polluting material discharged and requiring treatment. The output from the treatment works is a water stream that is usually discharged directly to controlled waters and a solid residue that may be spread on land, treated as solid waste for landfill disposal or burnt in an incinerator. A Landfill Tax was introduced in the UK in the mid-1990s in the attempt to encourage industry to reduce the amount of waste disposed of by landfill burial. Reports suggested that landfill costs in the UK were far too low and did not reflect the true cost of this treatment method. Other countries such as The Netherlands had already banned landfill disposals. By imposing a tax based on the weight and related to the hazardous properties of the wastes, the intent was to encourage producers of waste to reduce the amounts. This tax is a direct charge on a company’s profits The environment at large 999 but the revenue from this tax can be ploughed back into environmental improvement projects by providing grants to worthy causes. Critics of this tax fall into two camps which claim, either that it is too low to make any difference on industry’s practices of sending wastes to landfill or that it is too high and so leads to an increase in ‘fly-tipping’ that actually has a far more harmful impact on the environment. Whatever the issues of landfill taxes, the problem is that many countries simply have less and less landfill space for burying their wastes. The logical solution seems to be to generate less waste in the first place. 5.5.9 Producer or shared responsibility During the 1990s environmental laws were introduced into the European Union that made those responsible for generating the adverse environ- mental impacts also responsible for their treatment and control. Thus there is or soon will be legislation on packaging waste, tyres, batteries, end-of-life vehicles and electronic products, placed on the supplier of the product. However, there is a major problem with this approach because the key question becomes who is or who are the producer(s)? Is it just one person or company that makes a product or provides a service? Do distributors have a responsibility? Furthermore, do the general public or the consumers and customers have an element of responsibility? It can be argued that they contribute to any environmental damage by wanting the products and/or services thereby creating the demand for the producer to meet. In Europe much of the ‘Producer Responsibility’ legislation is focused on the role of industry. An alternative approach could be to consider shared responsibility where all those involved in the manu- facture, supply and use of products have some role to play which should relate to their part in producing the waste. There is an example of a shared approach in the UK. The Producer Responsibility Obligations (Packaging Waste) Regulations 1997 10 requires each player to carry a certain percentage of the cost of collecting and recycling the wastes. Companies have to obtain Packaging Recovery Notes (PRNs) to cover their obligated packaging wastes. However, companies having a turnover less than £2 million or handling less than 50 tonnes of packaging per year are exempt. It is interesting that of all the European Union Member States only the UK has this ‘shared’ approach. A possible explanation is that it has proved quite complex to implement even though the format was agreed by a cross-section of UK industry. The complexity arises because of the attempt to include all parties in sharing the costs and prevent ‘free riders’. The problem faced in Europe is to achieve an equitable balance between all the contributors within a complex legal system. The lawmakers, to justify the introduction of legislation, use the term ‘Producer Responsibility’. Without really involving all types of pro- ducers, the responsibility normally focuses on industry. This approach, however, tends to go beyond controlling traditional environmental impacts and is starting to impinge on product design via Design for Environment principles. There are some attempts in Europe to bring in 1000 Safety at Work legislation that would control the actual design of products but these go beyond current legislative requirements and, arguably, beyond what the customer wants 11 . 5.5.10 Environmental management system (EMS) and sustainable development Environmental management became topical in the mid-1990s as an addition to the suite of management quality systems. International Standards such as ISO 14001 12 and the predominantly European Eco Management Audit Scheme 13 became very popular and the number of accredited sites grew rapidly. Some companies such as IBM announced in 1997 a single registration for their worldwide operations 14 . Other companies like Eastman Kodak introduced a site-by-site programme over several years until all their manufacturing sites were registered 15 . There was some resistance at first to an imposed EMS as a result of experience with the ISO 9000 Quality Standards 16 which had, in some instances, become just a bureaucratic process. The benefit to a company of following another standard were not widely appreciated, however, the central concept of an EMS is that a company or site should identify the environmental impact of its operations by carrying out an ‘aspects and impacts analysis’. Subsequently it can rank these and thereby focus its management programmes on those areas having the highest adverse impact. Essential to achieving recognition under these schemes is that the whole assessment process is repeated periodically. A continuous improvement culture is thus generated. This emphasis on continuous improvement was missing from the early ISO 9000 Quality Standards. As companies began to introduce their EMS it became apparent that protecting the environment need not be seen as an add-on cost but rather as an opportunity to save money. For example reducing energy, using less fuel, water, raw materials, producing less waste and introducing vehicle route optimisation all lead to environmental protection and improved business performance. This is a win-win situation. Hence in some organisations it became relatively easy to convince senior managers of the benefits of having an EMS. Because of the similarity in the structure of quality and environmental management systems there was also a great opportunity to merge the two. Batts in his book 17 explains in practical terms how to implement an environment management system to meet the requirements of ISO 14001. Environmental management has moved on to embrace the concept of Sustainable Development. The 1987 World Commission on Environment/ Development under the guidance of Gro Harlem Brundtland (Prime Minister of Norway) made Sustainable Development the theme of its entire report called ‘Our Common Future’ 18 . It defined Sustainable Development as ‘development that meets the needs of the present generation without compromising the ability of future generations to meet their own needs’. In the UK in the mid-1990s the Department of Trade and Industry (DTI) modified the definition to ‘development which ensures a better quality of life for everyone, now and for generations to come’. The environment at large 1001 The basic concept of Sustainable Development is that the Earth does not have infinite resources of all the raw materials that are consumed by people around the world during their lives. However, it also recognises that economic success is also important and that in theory there is no reason why the human race cannot co-exist with its environment without damaging it irrevocably. Sustainable Development says there is nothing wrong with making money by economic activity as long as the well-being of the environment is a factor in that economic success. An obvious example is sustainable forests supplying wood and pulp where trees are continuously planted to replace those cut down. Finland for example plants three trees for every one cut. In fact it is not surprising that most of the ‘wealthy’ or developed countries around the world have good environmental records because they can afford to treat the environment with respect. There are of course some exceptions. The key is to move from situations where the Earth’s resources are plundered for a quick profit to one where the long-term effect of human activity on the planet is considered. Sustainable Development is at the centre of the 6th European Union Environmental Impact Strategy Action Plan as outlined in a keynote speech by Peter Johnston of the Information Society DG 19 . It notes that Sustainable Development does not really focus enough on end-products observing that the rapid development of global communications ‘short- ens the timetable for progress on sustainable development and offers a potential ‘win-win’ alternative to the traditional trade-off between growth and environmental sustainability’. The Action Plan demonstrates that real improvements can be made. It cites IBM as having achieved a 4% per year improvement in its use of energy corporately in its manufactur- ing sites. The report states that many of the improvements needed to reach Sustainable Development have come from the service sector. International conferences such as the ‘Rio+10’ conference in South Africa 20 seek solutions to these difficult issues. It is predominantly a challenge to the ‘rich nations’ that have not always been as responsible as they might have been. It has recently become apparent that certain European countries plus the USA tried to block environmental agree- ments at the 1972 Stockholm Conference for economic reasons 21 . Even today problems of balancing sustainable development issues remain and some countries will always place economic factors above environmental issues 22 . But it is not all bad news. Good examples can be found in global industries and small companies. The 2001 Queen’s Award for Sustainable Development recognises large companies such as Kodak Limited and smaller ones for their environmental responsibility 23 . 5.5.11 Corporate social responsibility Sustainable Development links environmental protection with economic prosperity and this link is being extended into Corporate Social Responsibility to include moral and ethical issues. This is sometimes called ‘triple bottom line reporting’ and means that more and more is 1002 Safety at Work expected of large organisations to conduct their business according to certain principles. This direction brings more accountability to report different performances against certain criteria. The European Commis- sion published a Green Paper ‘Promoting a European Framework for Corporate Social Responsibility’ 24 . Some forward thinking companies and organisations already consider Corporate Social Responsibility to be an investment for the future, rather than a cost, in the same way that protecting the environment can also be good business. The underlying principle of Corporate Social Responsibility outlined in the Green Paper is the ‘triple bottom line’ concept. The term ‘triple’ is used to merge economic, social and environmental issues into management strategies to create a better business. The European Commission believes that by adopting this strategy, businesses can contribute to the strategic European Union goal decided at the Lisbon Summit 25 . This goal is ‘to become the most competitive and dynamic knowledge-based economy in the world, capable of sustainable economic growth with more and better jobs and greater social cohesion’. It is hoped that the concept of Corporate Social Responsibility will lead business beyond conventional legal requirements to a greater responsibil- ity that matches the expectations and interests of their stakeholders. These stakeholders include employees, shareholders, suppliers, cus- tomers, local authorities, non governmental organisations, and local communities. Together they are providing the pressures that are shaping the political climate. The first steps along a tortuous road have been taken. The pace will increase with implications to all professionals who have a role to play in protecting the environment. References 1. Meadows, D., The Limits to Growth, Report to the Club of Rome and the United Nations Conference on the Human Environment, Stockholm (1972) 2. Fellenberg, G., The Chemistry of Pollution, J Wiley & Sons, New York (2000), ISBN 0471613916 3. The Co-operative Bank plc, Ethical Investment Policy, The Co-operative Bank plc, Skelmersdale (2001) 4. The Financial Times, Internet Site www.ftse4good.com, The Financial Times, London (2001) 5. European Union, White Paper COM92000/66, On Environmental Liability, EU, Luxembourg (2000). It can be downloaded from europa.eu.int/eur-lex/en 6. Meacher, M., UK Environment Minister reported in Industrial Environmental Management December (1998) 7. The Water Industries Act 1991, The Stationery Office, London (1991) 8. The Water Resources Act 1991, The Stationery Office, London (1991) 9. The British Photographic Association, The Mogden Formula: A Code of Practice for the Photoprocessing Industry for the Care of the Environment. The British Photographic Association now the Photo Imaging Council (PIC), Caterham (1997) 10. The Producer Responsibility Obligations (Packaging Waste) Regulations 1997, The Stationery Office, London (1997) 11. European Union, Proposal for a Draft Directive on the impact on the environment of electrical and electronic equipment (EEE), EU, Luxembourg (2000) 12. British Standards Institution, BS ISO 14001, Environmental Management Systems. Specifications for guidance for use, BSI, London (1996) The environment at large 1003 13. European Union, Regulation (EC) No: 761/2001, Allowing voluntary participation by organisations in a Community eco-management audit scheme (EMAS), published in the Official Journal L114 dated 24 April 2001, EU, Luxembourg (2001) 14. IBM, IBM and the Environment, Progress Report, IBM, New York (1997). See also www.ibm.com/ibm/environment 15. Eastman Kodak, Press Release: Kodak Reaches Goal: All 28 facilities worldwide now certified to ISO 14001, Eastman Kodak, Rochester, US (January 2002) 16. British Standards Institution, BS ISO 9000, Quality management systems. Fundamentals and Vocabulary, BSI, London (2000) 17. Batts, G., An Essential Guide to ISO 14001, Chandos Publishing, Oxford (1999), ISBN 1 902375 30 0 18. Brundtland, Gro Harlem, Our Common Future, World Commission on Environment and Development, Oxford University Press, Oxford (1987) 19. Johnston, P., h:/C1/Johnston/Speeches/Amsterdam IT for EH&S June 2001 (7–8 June 2001), The Knowledge Economy Can We Have Growth, More and Better Jobs and Sustainable Development? 20. Rio-declaration signatory countries committed themselves, at the 19th Special Session of the United Nations’ General Assembly (1997), to draw up strategies for sustainable development for the 2002 World Summit on sustainable development 21. Hammer, M., Filthy rich, New Scientist, No: 2324, p. 7, 5 January 2002 22. EC Conference, Brussels 27&28/11/2001 accessible from http://www.socialresponsibility.be 23. UK Government, Queen’s Award for Enterprise: Sustainable Development, The Stationery Office, London accessible from www.queensawards.org.uk or www.dti.gov.uk 24. European Union, COM(2001) 366; Promoting a European framework for Corporate Social Responsibility, EU, Luxembourg (2001). This document is downloadable from http://europa.eu.int/eur-ex/en/com/availability/cpi_avail_year2001_351_400_en.html 25. European Union Member State Summit in Lisbon, Portugal (2000) [...]... enrolled nurse Society of Industrial Emergency Services Officers Skin (absorption of hazardous substances) Scottish Law Times The Supply of Machinery (Safety) Regulations 1992 Sound pressure level Sound reduction index State registered nurse The Safety Representatives and Safety Committee Regulations 1977 Statutory sick pay Sievert Safe working load Surveillance of work related respiratory diseases TEU... EN EP EPA ERA ESR EU eV EWA European inventory of existing commercial chemical substances Extremely low frequency European list of notified chemical substances Employment Medical Advisory Service, also (European) Eco-Management and Audit System European normalised standard European Parliament Environmental Protection Act 1990 Employment Rights Act 19 96 Essential safety requirement European Union Electronvolt... and Safety (Display Screen Equipment) Regulations 1992 Department of Social Services Department of Trade and Industry EA EAT ECJ EC EEA EEC EcoSoC EHRR Environment Agency Employment Appeals Tribunal European Courts of Justice European Community European Economic Association European Economic Community Economic and Social Committee European Human Rights Report DSE(R) List of abbreviations EINECS 1011 EN... the exchange of technical experiences, opinions and views Increasingly employers are demanding a high level of professional competence in their safety and health advisers, calling for them to hold recognised qualifications and have a wide range of technical expertise These are evidenced by Corporate Membership of the Institution for which proof of a satisfactory level of academic knowledge of the subject... Co- Predicted 4 hour sweat rate Pascal Portable appliance test Personal computer Polychlorinated biphenyl Pressure Equipment Regulations 1999 Preliminary hazard analysis Polymorphonuclear leukocyte Personal protective equipment Parts per million Pressure Systems Safety Regulations 2000 Polytetrafluoroethylene Permit to work The Provision and Use of Work Equipment Regulations 1992 Polyvinyl chloride QA... to Health Regulations 2002 Consumer Protection Act 1987 Cumulative trauma disorder Centre tapped to earth (of 110 V electrical supply) Chemical Weapons Convention DSS DTI Decibel ‘A’ weighted decibel Direct current Department of the Environment, Food and Rural Affairs Directorate General Deoxyribonucleic acid Dangerous occurrence Dangerous Substances and Explosive Atmospheres Regulations 2002 The Health... Radioactive Material by Rail Regulations 19 96, 872 Personal Protective Equipment at Work Regulations 1992 (PPER), 61 2, 842, 859 Petroleum (Consolidation) Act 1928, 61 , 62 , 63 , 810, 8 46 Petroleum Mixtures Order 1929, 8 46 Petroleum Spirit (Motor Vehicles etc.) Regulations 1929, 8 46 Pneumoconiosis etc (Workers Compensation) Act 1979, 143 Pollution Prevention and Control Regulations 2000 (PPC), 61 , 960 Power Press... magistrate Royal Society for the Prevention of Accidents Radiation protection adviser Respiratory protective equipment Radiation protection supervisor Risk rating Recommended retail price Repetitive strain injury s SAFed SC Sen Clause or section of an Act Safety Assessment Federation Sessions case (in Scotland) Sensitiser 1014 Appendices SEN SIESO Sk SLT SMSR SPL SRI SRN SRSC SSP Sv SWL SWORD State enrolled... subject reinforced by a number of years of practical experience in the field is required Recognised academic qualifications are an accredited degree in occupational safety and health or the Diploma Part 2 in Occupational Safety and Health issued by the National Examination Board in Occupational Safety and Health (NEBOSH) For those assisting highly qualified OSH professionals, or dealing with routine matters... (IOSH) is the leading professional body in the United Kingdom concerned with matters of workplace safety and health Its growth in recent years reflects the increasing importance attached by employers to safety and health for all at work and for those affected by work activities The Institution provides a focal point for practitioners in the setting of professional standards, their career development and . Sustainable Development the theme of its entire report called ‘Our Common Future’ 18 . It defined Sustainable Development as ‘development that meets the needs of the present generation without. treat the environment with respect. There are of course some exceptions. The key is to move from situations where the Earth’s resources are plundered for a quick profit to one where the long-term effect. the need to report. There are already mandatory reporting requirements in many countries for certain regulated processes. For example, in the UK, a site that operates a Part A Process under the