Manual on the Development of Cleaner Production Policies ... - Unido

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DEVELOPMENT OF CP POLICY MODULE 5: POLICY TOOLS AND INSTRUMENTS SLIDE: Integration of CP and ISO 14001/EMS • Decreased competition between CP and ISO 14001 consulting communities; • Mutual reinforcement: CP focuses on operational level, EMS on the management organization; • CP used as a tool to demonstrate continued environmental improvement; • Municipal CP programmes leading to EMS certification. In this slide, show that joint implementation of CP and environmental management systems is becoming a more common practice, and explain how the integration of the two concepts can benefit the company. Background In the early years of ISO 14001 and CP, the consulting communities most closely involved with each of the two concepts sometimes perceived each other—wrongly—as competitors. There is no reason to view CP and ISO 14001 as rival approaches, because in fact they are complementary. Several examples of the successful merging of the two concepts are now available, and experience shows that a CP programme can be an integral part of work to introduce an environmental management system. The rationale for the integration of the two concepts is that Cleaner Production focuses on the operational (plant floor) level, while an EMS system requires the development of a strong and formal management structure and procedures. CP can be used effectively to demonstrate the continued environmental improvement required under ISO 14001. CP is also likely to generate operational savings to the company, offsetting in part the cost of the EMS certification process. Conversely, a functioning EMS can help to keep a CP programme on track. There are a number of examples where CP projects and EMS certification were combined in municipal operations. The Czech Republic, for instance, has been pioneering work on the EU’s EMAS certification with a CP project. In Mexico, some municipal authorities are currently completing the certification process according to ISO 14001. EXAMPLE ISO 14001 implementation kit for local authorities In 2001, a consortium of four organizations, UNEP, Environment Canada, the International Federation of Consulting Engineers and ICLEI, developed a training package for local governments implementing EMS. The kit was based on ISO 14001:1996, and includes accompanying exercises, guidelines, resource kits and case descriptions. It can serve as a resource for trainers and municipal staff and acknowledges the activities undertaken by local governments towards sustainable development. Further information can be obtained from ICLEI at the e-mail address: training.centre@iclei-europe.org PAGE 122
DEVELOPMENT OF CP POLICY MODULE 5: POLICY TOOLS AND INSTRUMENTS SLIDE: CP in permitting, enforcement and financing support • Environmental permitting may include elements of CP; • Environmental inspectors could promote CP; • Implementation of CP programmes is mandatory in enforcement actions; • Financial assistance for environmental investments could require a prior CP assessment. This slide presents how CP and pollution prevention can be incorporated into the permitting process, enforcement actions and decisions on providing financial support to companies. The key message is that there already exist proven ways to make CP an integral part of regulatory mechanisms. Background Cleaner production has traditionally been considered a voluntary initiative, left to companies to adopt if they consider it appropriate. In contrast, obtaining environmental permitting and complying with the regulations are obligations that have to be met. However, enforcing regulations and complying with prescriptive laws are both costly to all parties involved. Consequently a number of countries have decided to make CP (or pollution prevention/source reduction) an integral part of the permitting process. Some of the strategies that have been used to promote CP and prevention in the permitting process include pre-permitting interviews and distribution of information, permit avoidance through CP, pollution prevention planning, or explicit pollution prevention permit conditions. CP in the permitting process As part of permitting, firms may be required to undergo Cleaner Production audits of their plants and to implement suggestions. In most cases, however, a CP review is a part of the process, and normally not an obligation to implement all potential measures identified. The following list contains possible approaches: (a) Permit application form includes questions that would help the authorities determine if CP potential exists in the applicant’s facility; (b) Permit application package includes a brochure on the benefits of CP and contact information of a CP technical assistance office; (c) A permit can be issued stipulating that a CP programme must be developed in the first year of operation, or even prescribe that companies must demonstrate that they have a waste minimization plan in place at the beginning of operations. Typically, companies are then required to submit annual progress reports; (d) Reduced record-keeping, inspections or permit fees are applied to companies that implement a CP programme; (e) Environmental fees and charges are set to encourage implementation of preventive techniques; (f) Some permits issued are based on an integrated analysis of processes rather than on environmental media specific impacts. PAGE 123
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