Measuring the effectiveness of Environmental Management Systems

Measuring the effectiveness of 

Environmental Management Systems 

Phase 1: Desktop Report, June 2009

THIS PAGE IS INTENTIONALLY LEFT BLANK

www.ni-environment.gov.uk 

Measuring the Effectiveness of Environmental Management Systems: Phase 1 



Phase 1: Desktop Report, June 2009 

Background to the Project 

1


Background to the Project 

DoE Environment and Heritage Service (now Northern Ireland Environment 

Agency, NIEA) commissioned ‘An Evaluation into the Effectiveness of 

Environmental Management Systems’ as part of the ‘Better Regulation’ 

agenda, which ‘includes assessing aspects of a risk based approach to 

regulation, a more integrated approach to enforcement and improving 

awareness of obligations and best practice’ (EHS Tender Brief). 

The main aims of the study are to measure the effectiveness of EMS and 

analogous systems implemented by NI businesses in: 

1. Having a demonstrable impact on the level of legislative compliance, 

2. Improving an organisations environmental performance / reducing its 

environmental impacts. 

This study has been undertaken on behalf of NIEA by White Young Green 

in two distinct phases. The first is the completion of research and a desk 

top study into the types of management system, certification process and 

uptake from an international, national and local perspective. The desk top 

review has also collated research information relating to the effectiveness 

of Environmental Management Systems (EMS) undertaken within the last 

decade. The second phase is data analysis and interpretation from 1000 

Northern Ireland organisations in June 2008 (subject to a separate report). 

Background to Environmental Management Systems 

Environmental Management Systems are a systematic, planned approach 

to the management of environmental issues at an organisation and should 

be adopted as part of the overall company management structure. They 

are based on a Plan-Do-Check-Act methodology that aspires to continual 

improvement. There are a number of differing types of EMS. These can be 

summarised as : 

• 

• 

• 

• 

EMAS (Eco-Management and Audit Scheme) 

BS EN ISO 14001 (International standard) 

BS8555 : 2003 & the Acorn Scheme (Phased approach) 

Green Dragon (Arena Network) (phased approach) 

EMS is a risk management tool and all EMS standards have a similar 

framework and can be applied to any public or private sector organisations. 

EMAS is often viewed as the most stringent management system, as there is 

an explicit requirement for legal compliance and reporting of this status to 

the Regulator. All other systems require identification of legislation relevant 

to an organisations activities, products and services and a commitment 

to assess the level of compliance against the identified legislation. Whilst 

blatant non-compliance with legislation will result in a company incurring 

penalties with respect to any management systems certification body audit 

(e.g. a category 1 noncompliance), refusal or removal of certification is rare. 

Generally, companies reporting non-compliances with legislation, within 

their EMS, are encouraged to develop a detailed Action Plan to address the 

noncompliant issues. Certification bodies provide recognition of the EMS 

against the standards noted above (e.g. EMAS, ISO 14001 etc). In addition, all 

EMS standards require organisations to commit to continual improvement 

2 

Management Review 

Checking 


Continual improvement 

Environmental Policy 

Planning 

Implementation 

and 

operation


and evidence of this commitment is usually found in the setting of 

environmental objectives, targets, management plans or environmental 

performance indicators. Certification bodies are regulated by a strict code 

administered by the United Kingdom Accreditation Service (UKAS) in the UK, 

BS EN ISO/IEC 17021:2006. This code ensures consistency of the assessment 

process. There has been an amount of ‘bad press’ associated with EMS and 

legal compliance in recent years and UKAS and the accreditation bodies 

have been working hard to provide some clarification on the issue of the 

association between EMS and legal compliance (paper EA – 7/04 seeks to add 

clarification to the certification bodies as regards auditing legal compliance 

as part of ISO 14001:2004). 

The Drivers & Uptake 

There are a number of drivers for organisations wishing to develop and 

implement EMS, above and beyond legislative compliance or performance 

improvements. A key driver for organisations operating in England and Wales 

are the ‘Opra’ requirements relating to risk screening of activities and the 

relative proportion of effort applied to regulating organisations. In regulating 

through ‘Opra’ Environment Agency (England & Wales) demonstrates 

a policy commitment that for those organisations regulated under the 

“Environmental Permitting” Regulations an effective EMS is important in 

managing the risks associated with and delivering permit requirements. ISO 

14001 is the most favoured ‘type’ of management system to be implemented 

within organisations in the UK, with over 6000 registrations (at the end of 

2006). 

EMS ‘drivers’ 

• Legal compliance 

• Improved environmental performance 

• Cost savings 

• Customer / client pressure 

• Supply chain management 

• Enhanced PR 

• Environmental Risk Management 

EMS in Northern Ireland 


Northern Ireland business and industry has been served by a range of EMS 

support mechanisms over the last 15 years. These have been : 

• IRTU (now Invest NI) Environmental Audit Support Scheme grant 

• IRTU Environmental Management Support Scheme grant 

• Invest NI Building Blocks to a Better Business – pilot programme for 11 

no. manufacturing companies 

• The STEM Programme – cross border programme involving 

implementation of BS8555 for up to 240 businesses and 11 no. district 

councils 

• Easy Access (BS8555 for construction companies) 

• BiTES - Belfast City Council (Green Dragon through Arena Network) for 9 

organisations in the Belfast CC area 

• Coleraine BC (Green Dragon through Arena Network) 

3


Whilst research and evaluation of the above programmes has been on 

an ad-hoc basis, there have been some positive outcomes in relation to 

specific projects accumulating environmental improvements and indicating 

compliance with environmental legislation. This compares to less than 400 

registrations to the EMAS standard within the same period. There is evidence 

that levels of ISO 14001 uptake are stabilising in the UK, however significant 

growth in uptake in all standards have been seen in Spain and Italy. 

To conclude : 

Whilst desk top analysis of research would indicate strong evidence that EMS 

has a positive outcome in terms of improved environmental performance, 

the research is inconclusive in terms of legislative compliance. There is also 

not enough evidence to support the measurement of the effectiveness of the 

EMS in terms of its’ type (e.g. EMAS, ISO 14001 etc), particularly in relation to 

the collation of data in a local setting. 

The findings indicate the need for the detailed study into 1000 Northern 

Ireland organisations* and an evaluation of the data for organisations with 

accredited EMS, non accredited EMS and no systems in place. Validation of 

that data against regulator and certification body records would also be a 

valuable exercise. 

* This research has been carried out in conjunction with this desk top study. 

EMS Research 

The last decade has seen a plethora of research studies into EMS with 

a number considering their effectiveness in relation to compliance and 

improvements. These are summarised below: 

International 

Findings 

National 

Findings 

Northern Irish 

Findings 

4 

Survey Indicative of legal 

compliance? 

EMAS Ever 

Remas 

MEPI and follow up study 

ISO 14001 - a National Study in Austria 

SME-enviroment Survey 2007 

EMS and company Performance 

STEM 

BITES 

EASS 

Building Blocks 


Indicative of improved 

Environmental Performance?


Contents 


1 Introduction 8 

2 What is an Environmental Management System 10 

2.1 History of EMS 11 

2.2 Types of EMS 12 

2.3 Accreditation 22 

2.4 Certification 26 

2.5 Management Systems and Legal Compliance 37 

3 Drivers to Implementation of an EMS 40 

3.1 Overview of legislation and policy 40 

3.1.1 Formulation of Legislation 40 

3.1.2 NI Legislation 40 

3.1.3 Enforcement in Northern Ireland 40 

3.2 Procurement Policy and Promotion of EMS 43 

3.2.1 Central Procurement Directorate 45 

3.2.2 Other Local Procurement Drivers 46 

3.2.3 Compliance Drivers in England and Wales 48 

3.2.4 ‘Other’ Drivers for Implementing an EMS 51 

4 Uptake of EMS 54 

4.1 The International Scene 54 

4.2 Europe 55 

4.3 UK Wide 57 

4.4 Northern Ireland 57 

4.4.1 Invest NI 57 

4.4.1.1 Support Schemes 57 

4.4.1.2 Building Blocks 60 

4.4.2 STEM 61 

4.4.3 BITES 68 

4.4.4 Easy Access 68 

4.4.5 Green Dragon – Coleraine Borough Council 69 

4.4.6 Arena Network Survey 69 

5


5 Research Studies 71 

5.1 SME-nvironment Survey (NetRegs) 71 

5.2 Ever – Evaluation of EMAS and Eco-label for their revision 73 

5.3 EMS and Company Performance 74 

5.4 REMAS 75 

5.5 MEPI 79 

5.6 ISO 14001 – Experiences, Effects and Future Challenges: 

a National Study in Austria 80 

5.7 USA National Database 81 

5.8 Urban Government Review in Japan 82 

6 Conclusion 83 

7 Recommendations 87 

6 


References 88 

Appendix 1 Chapter 1 Key Targets Northern Ireland Sustainability Strategy 

Appendix 2 Chapter 6 Key Targets Northern Ireland Sustainability Strategy 

Appendix 3 Implementation of EMAS outside EU List of Figures 

Appendix 4 NI PPC Permits 

Appendix 5 NIEA Organisational Structure 

Figure 1 Key elements of legal compliance in an EMS 

Figure 2 Regulatory value of an EMS 

Figure 3 ISO14001:2004 EMS 

Figure 4 EMAS EMS 

Figure 5 BS8555:2003 EMS 

Figure 6 Green Dragon EMS 

Figure 7 EMAS Registration process 

Figure 8 ISO14001:2004 Assessment process 

Figure 9 Evolution of EMAS organisations





Phase 1: Desktop Report, June 2009 

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Introduction 

In March 2008, Environment and Heritage Service (now NIEA) published 

“Better Regulation for a Better Environment”. This position statement defines 

the principles of streamlining the regulation process for organisations. “Many 

of the businesses in Northern Ireland are not subject to direct regulation 

by EHS [NIEA] but are nonetheless required to comply with environmental 

legislation. The differing scales and activities covered by our regulations 

demand that we adopt a smarter range of tools and approaches to suit the 

nature and risk of an organisation” and this falls within the overall aim of 

working “closely with those we regulate to raise awareness of obligations 

and good practice, to simplify compliance and engagement with our 

regulatory teams and to reward those organisations who actively identify 

and manage their risks to the environment”. As part of this strategy, a 

commitment is made to “assess effectiveness of Environmental Management 

Systems (EMS) as a measure of environmental performance and compliance”. 

WYG successfully tendered to the EHS, now re-branded Northern Ireland 

Environment Agency (NIEA), to undertake this study on its behalf. The main 

aims of the study are: 

1. To evaluate the effectiveness of an EMS in improving an organisations legal 

compliance and, 

2. To evaluate the effectiveness of an EMS in improving an organisations 

environmental performance. 

The study is in two distinct phases, the first is ‘desk based’ and concentrates 

on analysis of existing data and studies relating to the implementation of 

an Environmental Management System on a world wide scale. The results of 

this ‘desk based’ research are presented in this report. The second element 

of the study involves a large scale survey of NI businesses and public sector 

organisations to capture evidence of legal compliance and environmental 

performance of organisations with, and without, EMS’s. Full data analysis and 

verification is enclosed within “Report 2”. 

Running in parallel to this study, Scotland & Northern Ireland Forum for 

Environmental Research (SNIFFER) are currently conducting report and 

survey UKCC19 - entitled “Better Regulation – Rethinking the Approach for 

SMEs. 

SNIFFER has looked at how best regulatory bodies should target their 

resources in the future, and finds that SMEs are neglected at present, while 

“resources currently go to firms with the most resources to self regulate”. 

The findings are also likely to suggest that SMEs would be best suited by a 

supportive command and control framework of regulation, since their limited 

resources mean they are less able to meet the requirements of regulated selfregulation. 

Methodology of firm categorisation enables SMEs and large firms to be 

divided into four separate categories related to size, and capacity for, or 

efficacy of, self regulation. Since SNIFFER seem to be advocating a trend 

towards allowing larger companies to exercise a greater degree of selfregulation, 

and that a greater proportion of resources to be focused on SMEs, 

it could be seen as a logical step that these larger, more environmentally 

proactive companies should be encouraged to implement, and have 

certified, EMS in place to allow this shift of regulatory resources – which has 

8 

www.ni-environment.gov.uk



been witnessed in terms of the encouragement on those firms appraised 

by the Environment Agency (England & Wales) under Opra to implement 

certified EMS. 

Since the “Better Regulation” programme is actively considering the shift 

towards a more risk based system of regulation – and were this to be the 

case, then it is of great importance to know whether there is empirical 

evidence that an EMS can reduce the risk associated with a particular 

organisation. It is the aim of this project and report to establish statistically 

robust data to be able to support or discount the hypothesis that an EMS 

improves an organisations compliance with applicable environmental 

legislation, and / or its’ environmental performance. This is in line with the 

Environment Minister Sammy Wilson’s vision of a new Agency that will 

“help business implement improved environmental management systems” 

(keynote speech 1st July 2008). 

In detail, this project has involved: 

1) A desktop survey and review of existing data and literature relating to 

development and implementation of EMS internationally, regionally and 

locally. The aim of this is to develop an understanding of the trends seen by 

those companies that have developed formal EMS to the various different 

standards including, but not limited to: EMAS; ISO 14001 and BS8555. 

2) Survey of 1,000 Northern organisations throughout Northern Ireland, 

including public and private, SMEs and large organisations. 

3) Data Evaluation, statistical analysis and verification of information 

gathered through the survey and questionnaires 

4) Preparation of an Interim and Final report and recommendations to 

the NIEA regarding the potential role of EMS within the Department of 

Environments programme for Better Regulation. 

EMS Evaluation 

Project Overview 

Desk Top 

Research 

Interim ‘Desk 

Top’ Report 

Final Report with 

Recommendations 

Data Collection 

Data Analysis & 

Review 

9


2.0 What is an Environmental Management System? 

The British Standards Institute have defined an EMS as “part of the overall 

management system that includes organisational structure, planning 

activities, responsibilities, practices, procedures, processes and resources 

for developing, implementing, achieving, reviewing and maintaining the 

environmental policy” (BS8555; 2003). It can be seen as a risk management 

tool also – since the standards to which organisations are assessed are not 

prescriptive, they provide the framework within which an organisation must 

identify it’s own potential impacts upon the environment, and seek to control 

these as well as to identify opportunities to reduce the associated risks. An 

EMS can be considered to follow the Deming cycle of “Plan – Do – Check – 

Act” 

Plan 

The role of an EMS is in delivering the commitments within an environmental 

policy. The policy should commit an organisation to legal compliance and 

continual improvement (BS8555 – phase 1, Stage 3; ISO 14001:2004 – clause 

4.2). The organisation should then identify all applicable environmental 

aspects that may create an environmental impact and also all relevant 

environmental legislation. Compliance with legislation must also be 

demonstrated in order to meet the requirements of BS8555 – Phase 2 

Stage 1-5; ISO 14001;2004 – clause 4.3.2 and 4.5.2. While in relation to 

Environmental performance, the organisation will have made a commitment 

to continually improve, and should set out Objectives and Targets and a 

programme to achieve these (BS8555 – Phase 3 Stage 3-7; ISO 14001:2004 

– clause 4.3.3). The objectives and targets provide the organisation with 

an improvement plan specifically tailored to ensure improvements in 

environmental performance related to it’s environmental aspects (BS8555 – 

Phase 3 Stage 1; ISO 14001:2004 - 4.3.1) associated with the range of activities 

it carries out, the product(s) manufactured or the service(s) provided. 

Do 

Control measures and procedures are intrinsic to the successful 

implementation and maintenance of an EMS, whether this is related to 

Training (BS8555 – Phase 1 Stage 6 and Phase 4 Stage 2; ISO 14001:2004 – 

4.4.2), Operational Control (BS8555 – Phase 3 Stage 6; ISO 14001:2004 – 4.4.6), 

or Emergency Preparedness and response (BS8555 – Phase 4 Stage 5; ISO 

14001:2004 – 4.4.7). Most organisations will have a clearly defined, written set 

of procedures that will outline what needs to be done to ensure compliance 

with the EMS. 

Check 

The success of implementation should be reviewed within the management 

system through a programme of Internal Audits (BS8555 – Phase 5 Stage 

1; ISO 14001:2004 – 4.5.5) and identification of corrective and preventive 

actions to deal with identified non-conformances (BS8555 – Phase 5 Stage 

2: ISO 14001:2004 – 4.5.3). Conformance of an organisation against the 

procedures will be evaluated during the audit process. Compliance with 

legislation will also be checked during auditing as a number of Operational 

10 



Procedures are drafted to ensure legal compliance of the activity as a 

minimum. 

Act 

The results of the “checking” stage of the process should be used to inform 

Management of areas of progress, or problems within the system as part of 

Management Review (BS8555 – Phase 5 Stage 3: ISO 14001:2004 – 4.6). This 

management review process should, in turn, then be used to re-address the 

issues of Environmental Policy, the organisations environmental aspects 

& impacts, legal compliance and objectives and targets. The continually 

improving organisation will then be able to adjust to any changes that may 

have occurred and set objectives and targets for forthcoming years. 

According to a study conducted by Business in the Community 

(Environmental Index Report 2006) an EMS helps an organisation to improve 

its environmental performance. Common requirements of an EMS (such 

as a policy, objectives, targets, training and reporting) demonstrate a 

commitment to incorporating environmental issues into key practices with 

the resultant benefits of: 

• 

• 

• 

• 

• 

improved risk management 

reduced liability costs 

increased competitive advantage 

more employee involvement and 

improved public image (www.bitc.org.uk) 

These benefits are further support by findings from a NetRegs survey 

conducted in 2007 of small and medium sized enterprises (SMEs) across the 

UK (including Northern Ireland) to reveal their attitudes and behaviours. 

In relation to benefits in addressing environmental issues, the three main 

business benefits of addressing environmental issues were: 

• 

• 

• 


Reduced risk of prosecution (81% strongly agree / agree); 

Creates good relations with customers (67% strongly agree / agree); and 

Reduces operating costs (66% strongly agree / agree) 

2.1 History of Environmental Management Systems 

The World’s first formal EMS developed by the British Standards Institute (BSI) 

was BS7750, first published in March 1992. The standard was based on a two 

year pilot implementation programme with 230 implementing organisations 

and was then modified on the basis of feedback, with the publication of 

this modified standard in January 1994 (Starkey, 1998). At the same time as 

the development of BS7750, the European Commission was setting out it’s 

proposal for an eco-audit scheme, after some initial proposals and changes 

the Commission published what has become known as the Eco-Management 

and Audit Scheme (EMAS), this was adopted by the Council of Ministers on 

June 29th 1993, and became open to company participation in April 1995 

(Starkey, 1998). 

The development of ISO14001 came about because of the need for improved 

environmental performance expressed at the United Nations Conference 

11


on Environment and Development (UNCED) in Rio de Janeiro in 1992. The 

International Organisation for Standardization (ISO) was charged with 

creating an internationally recognised environmental management system 

(Bansal and Bogner, 2002). ISO14001 was developed in under three years, 

much quicker than it usually takes to develop an international standard 

mainly because it relied heavily on the content of BS7750 as a framework 

(Schaltegger et al., 2003). The Comité Europé de Normalisation (CEN) realised 

that some companies would prefer to meet the EMS requirements of an 

equivalent standard to EMAS meaning that it had to adopt ISO14001 as a 

European standard, which meant that equivalent national standards had 

to be withdrawn, and as a result BS7750, that had influenced ISO14001 so 

much, was withdrawn by March 1997 (Starkey, 1998). 

This led to two EMS standards being available to organisations in European 

countries, the international standard ISO14001 and the European EMAS 

scheme. The EMAS regulation was revised in April 2001 and based on ISO 

14001, one of the principle benefits of this meant it made it easier for ISO 

14001 certified organisations to progress to what is considered the more 

rigorous EMAS regulation (LRQA, 2004). 

BS8555 was launched after an initial pilot programme called Project Acorn. 

Through Project Acorn, the Acorn Method for implementation of an EMS 

was run between October 2001 and March 2003, supported by British 

Standards Institution and White Young Green Consultants (Sheldon, 2003) 

Funded in the main by the UK Department of Trade and Industry (DTI), and 

supported by the UK Department of Environment, Food and Rural Affairs 

(DEFRA). On the completion of Project Acorn the Acorn Method was 

withdrawn and the new British Standard BS8555, the phased approach to the 

implementation of an Environmental Management System, was published in 

April 2003 (The Acorn Trust, 2003). 

2.2 Types of Environmental Management Systems 

There are now five main recognised standards in relation to environmental 

management. The five main standards are: 

• 

• 

• 

• 

• 

ISO 14001:2004 International Standard for Environmental Management. 

Eco-Management and Audit Scheme (EMAS). 

IEMA - Acorn Scheme 

BS8555:2003 Environmental Management Systems. 

Green Dragon (Arena Network). 

The first four can be subject to UKAS accredited certification and Green 

Dragon can be subject to UKAS accredited inspection. 

ISO 14001:2004 International Standard for Environmental Management 

ISO, the International Standards Organisation, has developed a series 

of voluntary standards and guidelines in the field of environmental 

management which collectively are known as the EN ISO 14000 series. 

Developed under ISO Technical Committee 207, the 14000 series of standards 

addresses many aspects of environmental management including the 

following: 

12 



• 

• 

• 

• 

Environmental Management Systems – requirements with guidance for 

use (ISO 14001 : 2004) 

Environmental Management Systems – General Guidelines on principles, 

systems and support techniques (ISO 14004: 2004) 

Environmental Management Systems – Draft Guidelines for a staged 

implementation of an environmental management system, including 

the use of environmental performance evaluation (ISO 14005) – due for 

publication in September 2010. 

Environmental Performance Evaluation (ISO 14031:1999) 

Within this series, “EN ISO 14001 environmental management systems — 

specifications with guidance for use” is the only certifiable standard, the 

remainder being supportive guidelines. The aims of EN ISO 14001 are to 

promote environmental protection in light of socio-economic concerns. 

Clause No Clause Title Clause No Clause Title 

4.1 General Requirements 4.4 

4.4.1 

4.4.2 

4.4.3 

4.4.4 

4.4.5 

4.4.6 

4.4.7 

4.2 Environmental Policy 4.5 

4.5.1 

4.5.2 

4.5.3 

4.5.4 

4.5.5 

4.3 

4.3.1 

4.3.2 

4.3.3 

Planning 

Environmental Aspects 

Legal & Other 

Requirements 

Objectives, Targets & 

Programmes 


Implementation & 

Operation 

Resources, roles, 

responsibility & authority 

Competence, training & 

awareness 

Communication 

Documentation 

Control of Documents 

Operational Controls 

Emergency Preparedness & 

Response 

Checking 

Monitoring and 

measurement 

Evaluation of Compliance 

Nonconformity, corrective 

action and preventive 

action 

Control of Records 

Internal Audit 

4.6 Management Review 

13


An effective environmental management system based on ISO14001 

provides an organisation with a defined structure to allow them to more 

confidently and effectively manage environmental issues by: 

• 

• 

• 

• 

• 

Establishing a policy and awareness that good environmental 

performance is a strategic objective of the organisation. 

Focusing on the prevention of waste and pollution and on continual 

improvement of environmental performance. 

Systematic analysis, planning, control and monitoring of all activities that 

may affect environmental performance. 

Assisting companies to more effectively meet legislative and regulatory 

requirements. 

Demonstrating to regulators, stakeholders and other interested third 

parties that a formal environmental management system is operational 

and effective (www.nsai.ie). 

The main rationale for the creation of ISO14001 was that its world wide 

acceptance should facilitate international trade by harmonising otherwise 

diffuse environmental management standards and by providing an 

internationally accepted blueprint for sustainable development, pollution 

prevention and compliance assurance (Delmas Magali A., 2002). 

Management Review 

Checking 

Figure 3 ISO14001:2004 

14 

Continual improvement 


Planning 

Implementation 

and 

operation 




ISO 14001 is very similar to EMAS but at the time of registration, 

Environmental regulators are consulted to make sure that they are satisfied 

that organisations have “identified and know the implications [to the 

organisation] of all environmental legislation and that their system is capable 

of meeting these on an ongoing basis”. , it can take a more prescriptive 

approach to environmental management issues. The ISO 14000 standards, 

by contrast, rely on voluntary acceptance by all interested parties, and 

therefore must maintain a balance between the needs and expectations of 

each of these parties. (www.europa.eu). 

Eco-Management and Audit Scheme (EMAS) 

The EU Eco-Management and Audit Scheme, known as EMAS, is a voluntary 

market based instrument designed to encourage better environmental 

performance from all types of organisation. EMAS is completely compatible 

with the international standard for environmental management systems, ISO 

14001, but goes further in its requirements for performance improvement, 

employee involvement, legal compliance and communication with 

stakeholders. Uniquely EMAS requires organisations to produce an 

independently verified report about their performance (www.emas.org.uk). 

EMAS is a direct response to some of the key principles in the European 

Union’s Environmental Action Programmes and the challenge of sustainable 

development. Behind EMAS stands the concept of broadening the range 

of policy instruments and promoting an approach of shared responsibility 

in environmental protection. EMAS was first adopted by the European 

Environment Council on 29th June 1993 and became open to industrial 

participation from April 1995 onwards. EMAS was revised in 2001, and 

eligibility widened to include all sectors of public and private economic 

activity (DEFRA). 

The EMAS Regulation applies to all 27 EU Member States, and the 3 

European Economic Area States (Iceland, Norway and Liechtenstein) – all 

candidate countries (e.g. Turkey, Croatia and the Former Yugoslav Republic 

of Macedonia) are obliged to implement the scheme in preparation for their 

accession to the EU. 

Some international companies operating sites outside of the EU / EEA, have 

opted to pursue EMAS registration. However, since these countries are not 

members of the EU / EEA, their registrations do not hold the same legal 

status; in this instance they are referred to as “quasi-registrations” – currently 

these “quasi-registrations” exist in countries such as Brazil, Switzerland, China 

and the USA. 

15


Figure 4 EMAS 

Source of Diagram : ‘EMAS: A Practical Guide’, ISBN : 0-946655-81-2 

Institute of Environmental Management and Assessment (IEMA) Acorn 

Scheme 

“Acorn” is the name of a project with a main objective to help British SMEs 

improve their environmental performance through a five-level approach to 

the implementation of an environmental management system (EMS) in line 

with ISO 14001, and a sixth level that facilitated external certification to ISO 

14001 and / or registration to EMAS. 

Once the project was completed a “not for profit” organisation, the Acorn 

Trust, was founded in order to develop a standard based on the project’s 

methodology (www.europa.eu). 

The IEMA Acorn Scheme, an officially recognised EMS standard, offers 

accredited recognition for organisations evaluating and improving their 

environmental performance through the phased implementation of an 

environmental management system (EMS). Acorn focuses on environmental 

improvements that are linked to business competitiveness and is flexible 

so that all types of organisation, whatever their size, can participate. Acorn 

offers a unique feature whereby organisations can engage environmental 

performance indicator (EPI) reporting within the procurement process in 

accordance with ISO 14031. This compliments the ‘one size fits all’ aspects 

of ISO14001 & EMAS and provides the opportunity to set environmental 

requirements in supplier contracts and monitor operational/product 

performance – a strength acknowledged by the Government in a recent 

EMS position statement published by DEFRA. A system of independent 

inspection is central to providing recognition that an organisation has 

met the achievement criteria of a particular Acorn phase and continues to 

improve its environmental performance (www.iema.org). 

16 



BS 8555:2003 Environmental Management Systems 


Work on Project Acorn led to recognition by the British Standards Institute 

(BSI) of the phased approach to development of an EMS and the benefits 

for small to medium sized enterprises (SMEs). As with Acorn, the standard, 

BS8555:2003, sets out a six phase implementation programme, to work 

towards a formal EMS that can be certified to BS EN ISO 14001 or the EU Eco- 

Management and Audit Scheme (EMAS) at Phase 6. Each phase is broken 

into a number of specific stages, with guidance and process planning 

spreadsheet available to organisations to assist their development. Progress 

can be acknowledged against the standard, with certification at any of the 

six phases, allowing SMEs greater control and freedom over the project plan. 

After full certification to ISO 14001, at phase 6, the second most popular 

certification for SMEs is at Phase 3. This allows for actual cost, compliance and 

environmental benefits to be realised before detailed written procedures are 

required. Although principally aimed at SMEs, the guidance can be used by 

any organisation, regardless of size, the nature of their business undertaken 

or their location (Environmental Management Systems Fact Sheet No. 4). 

The Six Phases of BS8555: 

1. Commitment & establishing the baseline 

2. Identifying & ensuring compliance with legal and other requirements 

3. Developing objectives, targets & programmes 

4. Implementation and operation of the EMS 

5. Checking, audit & management review 

6. Certification to either ISO 14001 or EMAS 

The International Standards Organisation (ISO) is currently reviewing the 

incorporation of BS8555:2003 into the international ‘family’ of standards. 

ISO 14005 “Guidelines for the staged implementation of an environmental 

management system, including the use of environmental performance 

evaluation” is currently in development with a proposed publication date of 

September 2010. 

17


18 


Figure 5 BS8555:2003 - Overview of the phased implementation of an environmental management system.


Figure 6 Green Dragon 

Green Dragon 


Green Dragon was developed by ARENA Network and Groundwork Wales 

with support from the Welsh Assembly Government, Environment Agency 

Wales, Welsh Local Authorities and the European Regional Development 

Fund. Funding for the project was provided from a mix of Welsh Assembly, 

private companies and also several high profile multinationals funded the 

pilot scheme. There are 971 organisations from a variety of sectors and 

across a broad range of size that have already made the commitment to the 

implementation of Green Dragon to date. 

The Green Dragon Standard offers an environmental management system 

relevant to the specific needs of any organisation, large or small in the UK or 

Republic of Ireland. Green Dragon is a stepped approach aimed at simplifying 

the approach to implementation of environmental management systems 

(www.greendragonems.com). 

The standard is made up of five steps each incorporating the key elements 

of Planning, Taking Action, Checking Progress and Reviewing Achievements 

to realise continual environmental improvement. Some organisations may 

progress through each of the steps until they reach level 5. However, an 

organisation can enter the process at a suitable level and can remain at 

whichever level is most appropriate. 

Organisations achieving Green Dragon feature on a register of certified 

companies. The register is a resource – similar to that maintained by IEMA of 

organisations registered under EMAS and the Acorn scheme – which enables 

quick validation of an organisations claim to hold valid certification 

In-Brief 

There are five main recognised standards or schemes in relation to 

environmental management. 

• 

• 

• 

• 

• 

The Five Steps 

1 2 3 4 5 

Commitment to 

Environmental 

Management 

Understanding 


Responsibilities 

Managing 


Impacts 

ISO 14001 International Standard for Environmental Management. 

Eco-Management and Audit Scheme (EMAS). 

IEMA Acorn Scheme 

BS8555:2003 Environmental Management Systems (developed as direct 

result of Project Acorn and adopted as a British Standard). 

Green Dragon (Arena Network). 


Management 

Programme 

Continual 


Improvement 

19


Summary Table: Comparative Analysis of the main standards For the purposes of this analysis BS8555 and Acorn are taken together 

20 

EMAS ISO14001 BS8555 : 2003 / IEMA Acorn Scheme Green Dragon 

Step 1 Commitment to 

environmental management 

Responsibility 

Environmental Review 


Environmental Monitoring 

Improvement Plan 

Environmental Policy Environmental Policy Phase 1 Commitment and 

Establishing the baseline 

Stage 1 Gaining Top Mgt Commitment 

Stage 2 Baseline Assessment 

Stage 3 Developing draft 

environmental policy 

Stage 4 Developing environmental 

indicators 

Stage 5 Developing draft 

environmental management system 

implementation plan 

Audit 

Step 2 Understanding environmental 

responsibilities 

Phase 2 Identifying and ensuring 

legal and other requirements 

Environmental Review Planning 

Register of legal & ‘other’ requirements 

Managing legal requirements – 

emergency preparedness 

Communication and competence 

Environmental records 

Stage 1 Identify Legal Requirements 

Stage 2 Identify ‘other’ requirements 

Stage 3 Checking compliance 

Stage 4 Ongoing compliance 

Stage 5 Developing compliance 

indicators 

Environmental aspects 

Legal & other requirements 

Objectives targets and programmes 

Audit 

Step 3 Managing environmental 

impacts 

Environmental Programme Implementation and operation 

Register of environmental aspects 

Evaluation & control of environmental 

aspects 

Pollution prevention plan 

Objectives and targets 

Monitoring environmental 

performance 

Carbon data collection 

Environmental statement 

External communication 

Roles, resources, responsibility and 

authority 

Competence, training and awareness 

Communication 

Documentation 

Control of documents 

Operational Control 

Emergency preparedness and 

response 


Phase 3 Developing objectives, 

targets and programmes 

Stage 1 Evaluation of environmental 

aspects and impacts 

Stage 2 Finalizing the environmental 

policy 

Stage 3 Developing objectives and 

targets 

Stage 4 Establishing indicators 

for environmental performance 

evaluation 

Stage 5 Developing the environmental 

management programme 

Stage 6 Developing operational 

control procedures 

Stage 7 Launch environmental policy; 

objectives; targets and indicators 

Audit


EMAS ISO14001 BS8555 : 2003 / IEMA Acorn Green Dragon 

Step 4 Environmental management 

Programme 

Phase 4 Implementation and 

operation of the environmental 

management system 

Environmental Management 

System 

Training 

Environmental manual 

Control of documents 

System procedures 

System monitoring 

Carbon data collection 

Step 5 Continual environmental 

Stage 1 Finalise management 

structure and responsibilities 

Stage 2 Training, awareness and 

competence, plans and records 

Stage 3 Establishing and maintaining 

formal communication 

Stage 4 Documentation and record 

keeping 

Stage 5 Reviewing and testing 

emergency preparedness and 

response 

Stage 6 Developing indicators of the 

environmental management system 

Audit 

Phase 5 Checking, audit and review 

Environmental Audit Cycle Checking 

improvement 

Internal audit programme 

Management review 

Addressing sustainability 

Supply chain 

Reducing greenhouse gas emissions 

Environmental report 

Stage 1 Establishing audit 

programmes 

Stage 2 Correcting non conformances 

and taking preventive action 

Stage 3 Management review 

Stage 4 Improving environmental 

performance 

Stage 5 Improving the environmental 

management system 

Monitoring and measurement 

Evaluation of compliance 

Nonconformity; corrective action and 

preventive action 

Control of records 

Internal audit 


Audit 

Environmental Statement Management review Phase 6 Environmental management 

system acknowledgement: 

Preparing for EMAS Registration or 

Preparing for ISO14001 Assessment 

Validation (independent 

validation of the environmental 

statement, and therefore of 

environmental performance) 

21


2.3 Accreditation 

The UK Picture 

In the UK, the United Kingdom Accreditation Service (UKAS) performs 

the accreditation function for ISO 14001:2004 certification bodies, EMAS 

verifiers and IEMA Acorn inspection bodies. Accreditation criteria and 

guidance is developed at an international level by organisations such as the 

International Accreditation Forum (IAF) and accreditation bodies are required 

to comply with BS EN ISO/IEC 17011:2004 “Conformity assessment – General 

requirements for accreditation bodies accrediting conformity assessment 

bodies”. Certification assessments are carried out according to international 

standards and guidelines, such as EA 7/02 (IAF, 2003). It is of particular note 

within the context of Northern Ireland that the Irish National Accreditation 

Board operates as the UKAS equivalent in the Republic of Ireland: they, along 

with UKAS co-operate with one another and European wide accreditation 

bodies ensuring that a multilateral agreement applies to the recognition of 

accredited certificates. 

The Accreditation Process: 

22 

Certification Body 

Auditors 

Accreditation Body 

BS EN ISO/IEC 17011: 2004 

CERTIFICATION BODIES (CAB) 

BS EN ISO/IEC 17021:2006 


Auditors 

United Kingdom 

Accreditation 

Service (UKAS) 


Auditors 


Auditors 



While in order to accredit conformity assessment bodies (CABs), the 

Accreditation body e.g. UKAS, must meet the requisite standards (detailed 

above) – the CABs (or Certification Bodies {CBs}) must in turn comply with an 

international standard - BS EN ISO/IEC 17021:2006 “Conformity assessment 

- Requirements for bodies providing audit and certification of management 

systems”. To apply for accreditations to certify organisations, the CAB must 

seek approval from UKAS (in the UK) to conduct the certification to the 

defined ‘scope’. Individual auditors working on behalf of the CAB must also 

have the competence to carry out this certification and they will also be 

subject to individual approvals by UKAS. 

UKAS accreditation underpins the validity of testing, inspection, calibration 

and certification activities including those relating to: air, soil and water 

quality, the development of renewable energy sources, environmental 

management systems and energy efficiency. UKAS is the sole national 

accreditation body recognised by UK Government to assess, against 

internationally agreed standards. 

Accreditation on an International Scale 

In most developed economies there are bodies similar to the United 

Kingdom Accreditation Service. Were these to operate only national 

accreditation systems, barriers to trade would be accentuated. Instead, 

however, they have set up international accreditation infrastructures to 

facilitate the acceptance of goods for import and export across international 

borders. In order that these can work, the national accreditation bodies 

agree the elements of mutually acceptable international accreditation 

systems, develop the necessary technical detail for these to have integrity, 

and operate peer evaluation so as to confirm the basis for acceptance of 

accredited results worldwide (www.ukas.com). 

UKAS is a member of three international accreditation organisations: 

• 

• 

• 


International Laboratory Accreditation Cooperation (ILAC) 

International Accreditation Forum (IAF) 

European cooperation for Accreditation (EA) 

UKAS represents the UK Government in these international organisations 

and, generally through these, negotiates mutual recognition arrangements 

with other overseas accreditation bodies. The international functions are 

undertaken on behalf of Government and are supported by the Department 

of Trade and Industry. The international recognition of UKAS as a signatory 

to multilateral agreements enables government to use accredited bodies to 

meet its obligations under world trading agreements such as those deriving 

from EU Directives and the World Trade Organisation’s Agreement on 

Technical Barriers to Trade. 

EA-7/04: Legal Compliance as a part of Accredited ISO 14001: 2004 

certification. 

The European Co-operation for Accreditation (EA) is the European Network 

of nationally recognised accreditation bodies operating within the European 

region. Including organisations such as UKAS and INAB - all members must 

be able to demonstrate compliance with the applicable standards, and are 

23


subject to peer review. 

EA-7/04 was produced by a working group within the EA with the purpose 

to “provide useful information on the relationship between an organisation’s 

accredited Environmental Management System (EMS) certification according 

to ISO 14001:2004 and that organisation’s degree of compliance with 

applicable environmental requirements” (EA, 2007). The document provides 

a summary of the areas within the system and of the auditing process 

(internal and external) which should serve to ensure and demonstrate 

compliance with applicable environmental legislation. 

The main purpose of EA-7/04 is to provide clarification over the issue 

of whether the implementation and maintenance of an EMS enhances 

environmental performance, and therefore can lead to a relaxation in 

regulatory oversight, by focusing on the issue of legal compliance. As such, it 

has become the benchmark tool regarding legal compliance for certification 

bodies which via accreditation through UKAS, fall under its remit. 

EA-7/04 defines legal compliance as “full implementation of applicable 

environmental legislation. Compliance occurs when requirements are met 

and desired changes are achieved” (IMPEL, 1992); and goes on to state that 

legal compliance “with respect to the interface between the organisation 

and the environmental regulators can be understood as the situation 

when no reactive enforcement actions are made or can be expected by the 

organisation” (EA, 2007). 

The issue remains, however, as to what extent certification of an EMS can 

and does demonstrate legal compliance, and the European Co-operation 

for Accreditation assert that while “certification of an EMS against the 

requirements of ISO 14001:2004 is not a guarantee of compliance” they add 

that “neither is any other means of control, including…legal compliance 

inspections, {but} it is a proven and efficient tool to achieve and maintain 

such legal compliance” (EA, 2007)). 

EA-7/04 specifically states that “any organization failing to demonstrate their 

initial or ongoing commitment to legal compliance…shall not be certified or 

continued to be certified… [and] deliberate or consistent non-compliance 

shall be considered a serious failure to support the policy commitment to 

achieving legal compliance and should preclude certification or cause an 

existing ISO 14001 certificate to be suspended or withdrawn” (EA, 2007) 

The issue regarding whether the system ensures compliance is further 

complicated by the assertion that it is not the role of certification body 

auditors to make a direct evaluation of legal compliance, but it is the role 

of the organisation, and a function of the EMS to be able to demonstrate 

compliance status. 

Within the section on “Compliance Criteria for the Certification decision”, 

there are three important clauses: 

1) “The organisation should be able to demonstrate that it has achieved 

compliance with environmental legal requirements through it’s own 

evaluation of compliance prior to the certification body granting 

certification” 

24 



2) “Where the organisation may not be in legal compliance, they should 

be able to demonstrate a documented agreement with the environmental 

regulator on a plan to achieve full compliance. The successful 

implementation of this plan should be considered as a priority within the 

management system” 

3) “Exceptionally the certification body may still grant certification but shall 

seek objective evidence to confirm that the EMS is capable of achieving 

the required compliance once the above documented agreement is fully 

implemented” 

In summary, this document has become the benchmark assessment tool 

with respect to legal compliance for both certification bodies as well as 

for the Accreditation body (e.g. UKAS). The document stresses throughout 

that assessors are not inspectors of the environmental regulator, and should 

not provide statements or declarations of legal compliance, but that they 

verify the evaluation of legal compliance and that whilst ISO 14001 cannot be 

an absolute and continuous guarantee of legal compliance, neither can any 

legal scheme. The EMS provides a framework whereby compliance can be 

assessed and achieved consistently, and provides the support for continual 

improvement of the organisations environmental performance. 

Confidence in Accreditation 


UKAS sought to bolster confidence in UKAS-accredited EMS via a review 

of the EMS accreditation processes. The assessment process is conducted 

in a more robust and challenging manner, scrutinising the assessment 

methodologies of EMS certification bodies in greater detail. The transition 

from the current accreditation standard ISO / IEC Guide 66:1999(E) to a new 

International Standard ISO / IEC 17021:2006 (see pgs. 36-37) in tandem with 

EA-7/04 places greater emphasis on the impartiality of the certification 

process and the competence of all certification body personnel, managers, 

administrators and auditors. Certification bodies face significant work to 

demonstrate to UKAS that their processes meet the requirements of the 

standard by the transition deadline of 15 September 2008. UKAS has 

recognised that the ability to provide feedback plays an important role in 

maintaining confidence in the integrity of EMS. Consequently, each UKASaccredited 

certification body is required to have a complaints procedure and 

make this information available to its clients. Additionally, EMS certification 

holders can make customer feedback to UKAS directly and these matters 

are managed with strict confidentiality. The International Standard ISO 

14001:2004 and the EMAS Regulation (EC No 761 / 2001) are also under 

revision, which presents an ideal opportunity to direct the purpose of the 

standards. UKAS has a clear voice in the revision process through its roles 

on the relevant British Standards Institution Committee and the Forum 

of Accreditation Bodies established by the European Commission. Other 

avenues for UKAS to influence the development of accreditation guidance 

include involvement in the European Cooperation for Accreditation and 

the International Accreditation Forum. The UKAS EMSAC (Environmental 

Management Systems Advisory Committee) provides one of the main 

opportunities for engagement in EMS accreditation. UKAS also continues to 

work closely with IEMA, Defra and the regulators, such as the Environment 

Agency and the Scottish Environment Protection Agency, to enhance the 

value of accreditation at a government level. 

25


2.4 Certification of EMS’s 

“Defra believes that a robust and effective EMS should be externally audited 

to a recognised international or national standard by a Certification Body 

accredited by the United Kingdom Accreditation Service (UKAS)” (Defra 

Positioning Statement April 2008), with the view that accredited third 

party certification is important to realise many of the benefits of an EMS. 

Companies with an accredited certified EMS are given greater recognition 

by the Environment Agency under Integrated Pollution and Prevention 

Control (IPPC) and some other regulatory regimes. Accredited certification 

means that organisations can demonstrate to shareholders, regulators 

and the public that their system has been audited, in the same way as are 

their financial accounts, by those with appropriate professional skills, and 

knowledge. The information provided by a certified system is often seen as 

being more credible and reliable. 

The Scottish Environmental Protection Agency in their position statement 

has stated support for EMS and believes that they can “benefit the 

company and the environment and assist companies in understanding how 

environmental law applies to their site, products and operations”. However, 

at the time of publication (prior to remas) they were unconvinced that 

EMS had a sufficiently positive impact upon: permit compliance, frequency 

of incidents, and numbers of public complaints. They stated that if, as a 

regulator, they were to consider provision of financial incentives (such as 

available via the Environment Agency’s Opra scheme) they would have to be 

provided with “a clear case to the contrary” (SEPA, 2004) 

Certification is the process by which an organisation’s system (e.g. its EMS) 

is assessed for its conformity to the requirements of a standard (e.g. ISO 

14001:2004). Certification Bodies (CBs) may be accredited to perform such 

assessments where they meet the criteria in ISO/IEC Guide 66 (ISO, 2003) or 

ISO/IEC 17021:2006 (from September 2008). 

Accreditation bodies check on a regular basis via surveillance at the CB’s 

offices, witnessed assessments at their client’s sites and other activities that 

certification bodies are capable of providing accredited certification. Similar 

processes are operated to accredit environmental verifiers to carry out 

verification under EMAS, including the validation of EMAS environmental 

statements, and IEMA Acorn inspection bodies. 

Accredited CBs are bound by the requirements under which they operate 

to maintain confidentiality. They must have arrangements to safeguard 

the confidentiality of the information they obtain in the course of their 

certification activities, including on-site audits. CBs cannot disclose 

information to a third-party about the organisation that has been certified 

without the written consent of that organisation. If there are circumstances 

where the law requires information to be disclosed, then the CB must inform 

the organisation beforehand of the information that they have been required 

to provide. 

26 



There are different types of audits that are required within an EMS and that 

usually make up an organisations audit programme. These are a combination 

of: 

• 

• 

• 

1st Party - An audit performed within an organisation by the 

organisation’s own auditing resource. Also referred to as an internal 

audit. 

2nd Party - Audits of contractors/suppliers undertaken by or on behalf 

of a purchasing organisation. This may include the assessment of 

companies or divisions supplying goods or services to others within the 

same group. 

3rd Party - Audits of organisations undertaken by an independent 

certification body or registrar or similar third party organisation. 

Purpose of certification 

Third-party certification assessment provides an independent appraisal of 

a management system. The assessment is designed to determine whether 

or not an organisation satisfies the requirements of the relevant clauses of 

the standard. It will involve preparation, a review of documentation, on-site 

audit and a consideration of audit reports. It also includes other activities 

such as a site tour and staff interviews at all levels within an organisation. 

On completion of an assessment, a CB should have sufficient information 

to enable a decision on the grant of certification to be made. An important 

element of the certification and verification process is that, in addition to 

evaluating whether the system elements have been implemented, the 

assessor will determine whether the organisation is capable of running the 

system and improving it in the future. As such, the award of an accredited 

ISO 14001:2004 certificate or EMAS registration indicates an organisation’s 

ongoing commitment to legal compliance and gives some indication of its 

capability to comply in the future. The certification and verification process 

will also determine the extent to which the organisation has set objectives 

and targets, instigated improvement programmes, and how well they 

are linked to its legal compliance and performance improvement policy 

commitments. The IEMA Acorn Scheme uses accredited inspection, rather 

than accredited certification, for determining whether an organisation has 

met the scheme’s requirements. The reason for this is that the certification 

standards used by accreditation bodies can only be used for assessing 

organisations that have a fully implemented and functioning system; 

organisations using the IEMA Acorn Scheme will not have all the system 

elements implemented in the earlier phases, hence the use of inspection 

standards. 

EMAS Registration 

(www.iema.net) 


The route to EMAS begins with a document review normally conducted 

on site to meet accreditation requirements for ISO 14001, and an on-site 

verification audit and validation of the environmental statement. The 

process is illustrated in Figure 7. As a first step, the verifier ensures that an 

EMS has been implemented according to the requirements of Annex 1 of 

the EMAS Regulation. The process of verification of the EMAS management 

system is essentially similar to that for ISO 14001:2004 as described above 

except for the additional environmental statement, although there is also 

additional emphasis on legal compliance and environmental performance 

27


improvement (www.iema.net). 

Statement validation: when the requirements of the EMAS Regulation have 

been adequately addressed by the organisation, the verifier checks the 

accuracy and adequacy of the statement and, once satisfied, confirms (or 

‘validates’) it by signing and dating each page and counter-signing the final 

page of the statement. The statement is then forwarded to the verification 

body along with the report. Importantly, the verifier shall not validate the 

environmental statement if during the verification process he/she finds 

through spot-checks that the organisation is not in legal compliance. 

Statement amended by verifier: when the requirements in the EMAS 

Regulation have not been fully addressed by the organisation, the verifier 

issues corrective actions or nonconformities and the organisation then 

amends the environmental statement as necessary. The verifier agrees a 

timescale for the revised statement to be forwarded for validation once the 

changes have been made. 

Statement reviewed: the statement will be reviewed by the verification 

body and the original signed statement is returned to the organisation. 

The organisation can then apply for EMAS registration with the appropriate 

competent body by completing the application form and enclosing 

the appropriate fee. The competent body in the U.K. is the Institute of 

Environmental Management and Assessment. The organisation should also 

forward a copy of the final printed version of the environmental statement to 

the verification body. 

Verification frequency: following EMAS registration, the verifier ensures that 

all elements required to maintain EMAS registration are verified in a period 

not exceeding 36 months. This is usually through a surveillance programme 

of a visit every 12 months in the 36 month period. In addition, any updated 

information on the environmental statement is validated at intervals not 

exceeding 12 months. In smaller organisations, the verification may take 

place in one visit, at a frequency to be agreed between the verifier and the 

organisation. Even so, the whole system must be verified at least every 36 

months. Deviations from the frequency with which updates are performed 

can be made in certain circumstances. 

28 


Figure 7 EMAS registration process 

Source: IEMA Vol 6 Legal Compliance


ISO14001 Certification 

(www.iema.net) 

Certification assessment is conducted in two stages (in accordance with ISO / 

IEC 17021:2006): 

Stage 1 audit: the purpose is to check that the requirements of the standard 

are adequately addressed by the organisation’s EMS. Stage 1 also assesses 

the extent to which the EMS has been implemented and applied in order to 

determine a suitable time frame for the organisation to move towards the 

stage 2 audit. The assessment programme for the stage 2 audit is also agreed 

at this stage. With reference to legal compliance, the stage 1 audit should 

ensure that the: 

• 

• 

• 

• 

EMS is designed to meet the environmental policy – the policy should 

include a commitment to comply with applicable legal requirements and 

other requirements relating to its environmental aspects; 

organisation has appropriate environmental permits in place, e.g. 

discharge consents and process licences, relevant to its activities, 

products and services; 

organisation has identified all applicable legal requirements relevant 

to its activities, products and services within the scope of its EMS and 

determined how the legal requirements apply to its environmental 

aspects; and 

an overview has been carried out of applicable regulations (including 

licences and permits) and any agreements with regulators, (such as the 

Environment Agency or the local authority), that the organisation may 

have. 

The assessor also informs the organisation of any additional information that 

will be required for inspection at the stage 2 audit, such as: 

• 

• 

licence and permit requirements; and 

records, including records of incidents, breaches of regulation or 

legislation and relevant correspondence with regulators and relevant 

authorities – and any other information on which the organisation based 

its assessment of compliance with regulatory requirements. 

Stage 2 audit: the objective of the stage 2 audit is to ensure that the 

requirements of the standard are being met in practice. This stage of the 

assessment focuses on many issues. Key issues are control, monitoring and 

improvement to ensure compliance with legal and other requirements. An 

assessor examines matters relating to legal compliance in detail, including 

ensuring that the organisation has established, implemented and is 

maintaining a procedure for periodically evaluating its compliance with 

legislation. The assessor will inspect the results of the periodic evaluation of 

legal compliance. The Stage 2 assessment has a standard format consisting 

of: 

• 

• 


an opening meeting at which the assessor confirms the scope of the 

registration and the audit programme – this will relate to the scope of the 

EMS which the organisation is required to define and document under 

clause 4.1; 

the assessment itself including a tour of the premises, interviews with 

29


• 

staff at all levels, examination of documentary evidence and observation 

of tasks being carried out – it is at this stage that any deviation from 

procedures or the requirements of the standard is noted by the assessor 

– these ‘non conformances’ are discussed with the organisation which is 

given an opportunity to challenge or agree to them; and 

a closing meeting, during which the assessor presents a report on the 

assessment and summarises the agreed non-conformities. Depending 

upon the nature of the non-conformities, the assessor recommends 

either certification or non-certification. 

Certification: the assessor’s report is forwarded to the CB with a 

recommendation regarding certification. The report will be reviewed and if 

approved a certificate will be issued. 

Regular surveillance: an EMS is, or should be, dynamic and regular 

surveillance visits are undertaken to ensure continued conformance with 

the standard and to confirm continual improvement in the performance 

generated by the EMS. With respect to legal compliance, the surveillance 

audit ensures the functioning of procedures for the periodic evaluation and 

review of compliance with applicable legal requirements. CBs carry out a reassessment 

of the entire EMS over a three-year period, ensuring that all the 

elements of the system are audited. 

Enquiry 

Application 

Stage 1 audit 

Stage 2 audit 

Certi�cation 

recommended 

Surveillance 

Figure 8 ISO14001 Assessment Process 

Source: IEMA Vol 6 Legal Compliance 

30 

Certi�cation not 

recommended 

Reassessment 



BS8555 Certification 

The BS8555 implementation process has been designed as a series of 

iterative cycles or phases. There are six phases in all with a number of stepby-step 

actions or “stages” within each phase. The first five phases relate to 

implementation of an environmental management system. At the end of 

each phase and prior to embarking on the next, organisations can consider 

an internal audit to satisfy themselves that the stages are complete, and 

that the associated guidance has been considered and, where appropriate, 

implemented. A sixth phase is included for those organisations that wish 

to achieve accredited certification to BS EN ISO 14001 and/or that decide 

to pursue external reporting on their environmental performance and/or 

registration under the EMAS scheme. 

Green Dragon Certification (Arena Network) 

The standard made up of five steps incorporates the key elements of 

Planning, Taking Action, Checking Progress and Reviewing Achievements to 

realise continual environmental improvement. 

Some organisations progress through each of the steps until they reach 

Step 5, a certificate is issued at each of the 5 steps and upon achieving all 5 

steps. Organisations are re-audited annually to ensure the standard is being 

maintained and those achieving Step 5 may also be successful in achieving 

ISO 14001 or EMAS. 

Role of Assessors and auditors 

An assessor conducts a visit as part of the initial certification process. 

Subsequent periodic surveillance and re-assessment visits are made to verify 

the continuing conformity of the organisation’s EMS to the standard and that 

the EMS has been properly implemented and maintained and that continual 

improvement is evident. An assessor checks that the requirements of the 

ISO 14001:2004 or EMAS standard have been met. The assessment focuses 

on the resources committed to satisfying these requirements to ensure that 

they are being applied in a manner which benefits the environment, the 

organisation and the local community in which the organisation operates. 

This is accomplished through close examination of the factors that give 

rise to ongoing environmental performance improvement. It assists the 

organisation in meeting regulatory requirements and delivering reductions 

in its environmental impacts, thus improving environmental performance 

as a whole. Assessors play a key role in ensuring that certified EMS’s are 

delivering meaningful results. This requires them to meet comprehensive 

competence criteria. 

Competence of assessors and auditors 

The competence requirements for assessors are laid down in the 

accreditation criteria of CBs offering certification of EMS’s. In addition, 

minimum criteria are prescribed in ISO 19011 (ISO, 2002). The qualification 

criteria for EMS auditors cover: 

• 

• 

• 

personal attributes; 

the ability to apply knowledge and skills; 

audit principles, procedures and techniques; 


31


• 

• 

• 

• 

• 

• 

management systems knowledge; 

organisational situations such as organisational size and structure; 

applicable laws, regulations and other such requirements; 

environmental management methods and techniques; 

environmental science and technology; and 

technical and environmental aspects of operations. 

An assessor should have knowledge of environmental management systems, 

environmental terminology, pollution abatement and control techniques 

and the type of organisation being audited – this includes knowledge of 

the sector and issues such as the size and complexity of the organisation. 

In addition, an assessor should have a sufficiently detailed knowledge of 

environmental laws and regulations to know whether an organisation 

has correctly identified all its applicable legal requirements related to its 

environmental aspects. Inspectors involved in the IEMA Acorn Scheme 

require the same competencies as those already outlined, but with additional 

training given in order ensure consistency of interpretation when judging 

degrees of EMS development against the guidance in BS 8555. 

Auditors may gain certification to the International Register of Certified 

Auditors (IRCA) or other recognised national schemes such as the IEMA 

Register of Auditors. These registers provide programmes of Continuing 

Professional Development and recognition for the competence of auditors 

across environment, quality and health and safety auditing roles. 

In-Brief 

• 

• 

• 

• 

• 

• 

• 

• 

32 

Certification is the process by which an organisation’s system (e.g. its 

EMS) is assessed for its conformity to the requirement of a standard (e.g. 

ISO 14001:2004). 

Certification to any environmental standard will require : 

- A detailed understanding of legal requirements and a commitment 

to comply 

- Evidence of continual improvement in environmental issues 

Certification Bodies (CBs) may be accredited to perform such 

assessments where they meet the criteria in ISO/IEC Guide 66 (ISO, 2003) 

or ISO / IEC 17021:2006 (from September 2006) . 

1st, 2nd and 3rd party audits will make up an organisations audit 

programme. 

Third-party certification assessment provides an independent appraisal 

of a management system. 

An assessor conducts a visit as part of the initial certification process. 

Subsequent periodic surveillance and re-assessment visits are made 

to verify the continuing conformity of the organisation’s EMS to the 

standard and that the EMS has been properly implemented and 

maintained. Continual improvement must be evident. 

Validation for EMAS can only take place when there is evidence of full 

legal compliance. 

The competence requirements for assessors are laid down in the 

accreditation criteria of CBs offering certification of EMS’s and auditors 

may be placed on international (IRCA) or national (IEMA) registers. 



EMS Certification: the ENDS Survey 2003 & 2006 

In December 2003, the ENDS Report published the results of an opinion 

survey conducted jointly with the Institute of Environmental Management 

and Assessment. It revealed widespread concern regarding the perceived 

integrity of certified EMS, with almost half of respondents believing that 

“certification bodies are not sufficiently competent” (ENDS, 2003), and 

67% believing that “EMSs provide the basis for achieving significant 

environmental performance improvement that otherwise would not have 

been achieved”. Following this survey, and speaking at the EMS national 

Forum later that month, the UKAS external affairs Director, Roger Brockway, 

stated “we have let things slide and I think certification bodies have let things 

slide, and we have to take some responsibility for that” (ENDS, 2003). 

Subsequently UKAS began a review to the system of accreditation in order 

to reassert the integrity of the certification process. In 2006, ENDS, along 

with IEMA, UKAS and the Environment Agency engaged in another survey 

to ascertain the opinions of professionals once again – with around 600 

respondents, participation was almost twice that of 2003. 

Interestingly, respondents views regarding the role of an EMS in enhancing 

environmental performance had changed relatively little, with 70% citing 

EMS as the basis for driving performance improvements – a 3% gain on 

2003, which while perhaps lower than one might expect, the report does 

suggest that few if any other voluntary tools could provide such assurance. 

With regards the question of legal compliance: over 90% believed that the 

implementation of an EMS leads to better identification of legislative noncompliance. 

Key findings are demonstrated below, and they demonstrate a belief among 

respondents that confidence in UKAS and certification bodies was growing, 

though it should be noted that organisations would be principally operating 

under the revised standard of ISO 14001:2004 at this point, and that to some 

extent this may have driven the confidence in the certification process also. 

The findings are outlined on the next page: 


33


Over 95% of respondents were of the belief that an EMS can/ 

will reduce risk – 64% stating that performance between 

different organisations is variable. 

85% of prospective purchasers said a supplier’s EMS would 

have some influence on their decision to buy but they would 

want additional evidence or product-specific criteria to be 

met. 

Over 70% feel that verifiers and certifiers spend an 

appropriate amount of time on-site. 

34 


Greater than 80% believe certifiers and verifiers check 

at least for documentary evidence that a full internal 

evaluation of compliance has been carried out. 

One-fifth felt that individual assessors within certifying/ 

verifying bodies do not provide consistent or comparable 

conclusions.


Three-quarters of respondents feel certifiers/verifiers spend 

an appropriate amount of time on assessments. 

Source: Ends, 2006 

Half of respondents feel that the credibility of accredited 

certified/verified EMSs has improved. 


A small majority said their confidence in UKAS has not 

grown in the last 12 months 

35


Since these surveys UKAS has undertaken an extensive review of its 

own accreditation processes based on stakeholder consultation. Greater 

attention was given to the assessment of auditor competence, the reporting 

of environmental performance and legal compliance and the role of the 

advisory committee within certification bodies. UKAS also increased 

its awareness campaign, promoting the benefits of UKAS-accredited 

certification to businesses across all industries. The most important 

acknowledgement of the benefits of accredited certification has been 

given through the work of the remas project. This three-year pan-European 

project provides evidence directly linking EMS with improved environmental 

performance, which in turn leads to improved regulatory performance. These 

findings effectively restored confidence in the integrity of UKAS-accredited 

EMS certification (see section 5.4 “remas”). 

In Brief 

• 

• 

• 

• 

• 

36 

An Accredited Certification Body is an organisation accredited by an 

authorising body such as UKAS (the United Kingdom Accreditation 

Service) to undertake third party assessment of management systems 

such as ISO14001 and to award and withdraw Certificates of registration 

to these standards. 

Accredited certification means that organisations can demonstrate 

to shareholders, regulators and the public that their system has been 

audited, in the same way as are their financial accounts, by those with 

appropriate professional skills, and knowledge. 

The British Government in its position statement believes accredited 

third party certification is important to realise many of the benefits of an 

EMS. 

In most developed economies there is a body similar to the United 

Kingdom Accreditation Service. 

In October 2006 a professional opinion survey involving more than 

600 environmental professionals revealed how effective they think 

environmental management systems (EMSs) really are. The survey was 

carried out jointly by ENDS, the Institute of Environmental Management 

and Assessment, the Environment Agency and UK Accreditation 

Service and concluded that whilst confidence in UKAS had not 

grown significantly in the 3 no. years since the previous survey, many 

respondents had increased confidence in the credibility of certification 

bodies and 97% believed that an EMS will reduce environmental risk. 



Environmental impact 

assessment 

(identify legal requirements) 

Risk assessment 

(assess legal compliance) 

Figure 1 Key Elements of legal compliance in an EMS 

Source: IEMA “Practioner” Vol 6, 2005 

2.5 Management Systems and Legal Compliance 

Continual management of environmental impacts requires a structured 

approach and EMS’s provide a way for an organisation to do this. Legal 

compliance (BS8555 – Phase 2 Stage 1-5; ISO 14001;2004 – 4.3.2 and 4.5.2) 

and good environmental performance are fundamental requirements of an 

EMS. A robust EMS should lead to improved environmental performance, 

including better and more consistent legal compliance. Regulators are 

supportive of accredited certification to ISO 14001:2004 as the basis for a 

systematic approach to managing environmental legal compliance 

(www.iema.net). 

of 

of 

Activities, products and 

services 

Environmental impacts 

Control measures to mitigate environmental impacts 

(achieve legal compliance) 


System and procedures - to operate and maintain control measures 

(manage legal compliance) 

37


Regulators may also support EMAS (which incorporates conformance to ISO 

14001) as a way for organisations to demonstrate their green credentials 

beyond ISO 14001:2004 accredited certification. A company registered to 

EMAS must comply with legislation, and assurance must be sought from 

the environmental regulator. EMAS also places additional emphases on 

environmental performance and public environmental reporting. The 

regulatory approach at any site will always be informed by the observed 

standards of environmental protection and management, including permit 

breaches, incidents and complaints from the public. When regulators carry 

out assessments of compliance, information from an EMS may be used 

to demonstrate (i.e. give assurance) that an organisation is or has been in 

compliance. EMS records provide an objective means for the regulator to 

make such appraisals and may provide evidence for an audit trail. 

Figure 2 Regulatory value of an EMS 

Source: IEMA “Practioner” Vol 6, 2005 

38 



Source: IEMA “Practioner” Vol 6, 2005. 


Regulators have been previously concerned at the lack of consistency 

in approach between certification bodies during assessments with not 

enough attention paid to compliance with legislation. IEMA also states that 

regulators have expectations of accredited certification these are detailed 

below: 

Assurance that legal compliance is being effectively managed, 

regulators expect: 

• certification assessments to provide assurance that organisations 

are conforming to the standard’s key requirements concerning 

legal compliance (ISO 14001 : 2004, clauses 4.3.2, Legal and Other 

Requirements and 4.5.2, Evaluation of Compliance); 

• a greater emphasis on identifying and correcting legal non-compliances, 

as well as detecting and correcting non-conformances with the standard; 

• better communication and information exchange, particularly with 

regard to the identification and notification (to regulators) of noncompliances 

found or reported during a certification assessment; 

• greater transparency in the circumstances and process for suspension or 

withdrawal of certification, including dealing with complaints from third 

parties; and 

• that organisations that have regular legal non-compliances (due to 

management failures) would not retain their ISO 14001 certificates, or 

EMAS registrations, 

Competencies and training of certification assessors: regulators expect: 

• assessors and assessment teams to be selected according to relevant 

environmental and legal competencies and experience related to the 

organisation being assessed; and 

• all UKAS accredited certification bodies to have access to and use 

the same criteria for selecting assessors. It should be stressed that 

accredited certification bodies are required to use auditors who meet the 

requirements of ISO 19011 (ISO, 2002). 

39


3.0 Drivers to the Implementation of an EMS 

3.1 Overview of Legislation & Policy 

3.1.1 Formulation of Legislation 

Environmental legislation is changing all the time. Much of it originating from 

the European Union, but there is a great deal of national regulation as well. 

Most legal requirements fall into one of the following categories: 

• 

• 

• 

• 

• 

• 

EU Regulations - Binding on all Member States in their entirety and 

directly applicable in law. Normally used for detailed and specific issues. 

EU Directives - These must be transferred into the national law of each 

Member State. 

EU Decisions - Binding in their entirety, they may be addressed to a 

government, a private enterprise or an individual. 

Acts of Parliament - Laws generated by the UK. They will include laws 

derived from EC Directives. 

Regulations - Enabled by Acts of Parliament and made by Ministers. 

These are made by government ministers under rights, powers and 

duties which stem from Acts. 

Orders - Give the force of law to enabling actions of Ministers. 

3.1.2 Northern Ireland Legislation 

Within Northern Ireland, the Planning and Environmental Policy Group 

(PEPG) is the key department within the Department of the Environment 

(DoE), responsible for policy and legislation relating to environmental issues. 

It has set out a number of objectives which among others, include: 

• 

• 

• 

Develop Integrated and effective environmental policies and legislation 

Ensure the timely and effective transposition of EU Environmental 

Legislation 

Promote sustainable development within Northern Ireland 

Working alongside devolved institutions in Wales and Scotland as well as 

other Northern Irish Agencies – particularly the NI Environment Agency, DoE 

PEPG has responsibilities covering issues as diverse as Waste, Climate Change, 

Biodiversity, Contaminated land and protection of Water Bodies. 

3.1.3 Enforcement of Legislation in Northern Ireland 

(see Appendix 5) 

The main authority responsible for enforcing environmental legislation 

in Northern Ireland is the Northern Ireland Environment Agency. NIEA 

incorporates four directorates, three of which administer and enforce diverse 

sub-sectors of legislation. The four directorates are as follows: 

Environmental Protection: 

• Water Management Unit 

• Land and Resource Management Unit 

• Industrial Pollution and Radiochemical Inspectorate 

• Drinking Water Inspectorate 

• Strategy Unit 

40 



Built Heritage: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Protecting Historic Buildings 

Protecting Historic Monuments 

Recording Built Heritage 

Corporate Services: 

Learning and Development 

Finance 

Co-ordination Unit 

Information Technology 

Corporate Communication 

Freedom of Information 

Natural Heritage: 

• 

• 

• 

• 

• 

Conservation Science 

Conservation Designations and Protection 

Countryside and Coast 

Regional Operations 

Biodiversity 

Three of the key units responsible for regulation of NI organisations are as 

follows: 

The Water Management Unit has responsibility for “the protection of the 

aquatic environment”. It carries out a variety of activities including: 

1) Monitoring water quality 

2) Controlling effluent discharges 

3) Taking action to combat or minimise the effects of pollution. 

The Land and Resource Management Unit is responsible for the 

implementation of waste management policy. “Towards Resource 

Management” (NI’s current waste management strategy) reinforces the 

proposed activity as enshrined within the “Framework for waste prevention 

in Northern Ireland” to “encourage the implementation of Environmental 

Management Systems…”, stating that EMS’s “provide a systematic way of 

managing the environmental concerns of a business addressing immediate 

and long term impacts of all practices within an organisation”. The remit of 

LRM includes among others: 

1) Waste Management Licensing 

2) Control and Management of Hazardous Waste 

3) Development of guidance for contaminated land 

4) Management of land quality database 


The Industrial Pollution and Radiochemical Inspectorate is the unit 

responsible for the regulation of operators in Northern Ireland which fall 

under Part A and Part B of the Integrated Pollution Prevention and Control 

Regulations and with responsibility relating to the controlled keeping, use 

and disposal of radioactive waste. Those operators which would fall under 

41


only Part C of these regulations are regulated by the local District Council. 

The system of Integrated Pollution Prevention and Control (IPPC) applies an 

integrated environmental approach to the regulation of certain industrial 

activities. This means that emissions to air, water (including discharges 

to sewer) and land, plus a range of other environmental effects, must 

be considered together. It also means that the enforcing authority must 

set permit conditions so as to achieve a high level of protection for the 

environment as a whole. These conditions are based on the use of the ‘Best 

Available Techniques’ (BAT), which balances the costs to the operator against 

the benefits to the environment. IPPC aims to prevent emissions and waste 

production and where that is not practicable, reduce them to acceptable 

levels. IPPC also takes the integrated approach beyond the initial task of 

permitting, through to the restoration of sites when industrial activities 

cease. 

In order to ensure a high level of environmental protection, effective 

management systems are considered useful tools. Under IPPC, some 

operators will apply environmental management systems at their 

installations, certified to standards such as EMAS, ISO 14001:2004, BS8555 

and Green Dragon, while a number of permitted organisations have informal 

(un-certified) management systems in place. 

Across Northern Ireland, 82 Permits have already been determined for Part A 

and B processes, with a further 209 Permits pending. A full list of these can 

be seen in Appendix 4. 

Along with the responsibilities of District Councils in regulating the impacts 

on the environment, NI Water Ltd holds some responsibility, particularly in 

the area of Trade Effluent Discharges. Since the 1st April 2007, NI Water took 

over from the Department of Regional Development’s Water Service. While 

still 100% Government owned, NI Water Ltd has now lost Crown Immunity. 

This has been important in ensuring the NI Water increases the quality of 

it’s own effluent discharges, whilst increasing the importance placed on the 

quality and quantity of effluent it will receive from domestic and commercial 

/ industrial premises. 

To date there is no reliable NI specific information on the level of compliance 

with legislation of companies with or without Environmental Management 

Systems. The next phase of this project for NIEA will provide data surrounding 

this compliance evaluation issue. 

42 



3.2 Procurement Policy in Northern Ireland 

Northern Ireland Sustainable Development Strategy – First Steps 

towards Sustainability 

(www.ofmdfmni.gov.uk) 

‘First Steps’ is the first ever sustainable development strategy for Northern 

Ireland, published in May 2006 the strategy presents the opportunity to 

achieve a better balance between social, environmental and economic 

progress. 

One of the visions of the strategy is a vision of Northern Ireland as a one 

planet economy. (reference Northern Limits) The priority is to reduce 

dramatically the amount of resources consumed and, just as important, 

the amount wasted and to get much more from the resources used in 

production. Three strategic objectives on sustainable consumption and 

production have been chosen for the strategy. 

• 

• 

• 

To become more resource efficient; 

To make the Northern Ireland public sector a UK regional leader in 

sustainable procurement 

To minimise the unsustainable impacts of consumption 

The government will meet the objectives by: 

• 

• 

• 

• 

• 

• 

• 

• 

• 


Communicating and promoting the one-planet living concept and 

regularly updating the ecological footprint for Northern Ireland to 

illustrate impact and to measure progress. 

Promoting the wider use of Environmental Management Systems (EMS) 

and the uptake of environmental reporting such as the annual survey of 

the largest Northern Ireland companies. 

Significantly reducing leakage of mains water and developing campaigns 

to encourage reductions in the demand for consumption of potable 

water. 

Pursuing sustainable development objectives through purchasing and 

expenditure decisions and make Northern Ireland a regional leader in 

sustainable public procurement. 

Developing a database to monitor the implementation of existing 

guidance on integrating environmental, social and economic 

considerations into procurement decisions. 

Working with the Food Standards Agency and other partners to promote 

healthy eating. 

Introducing across the Northern Ireland Civil Service a wide-ranging 

programme known as Workplace 2010 which aims to make better use of 

space and reduce energy consumption. 

Implementing a rolling plan to require public sector office 

43

• 

• 


• 

accommodation to achieve a BREEAM rating of at least “very good”. 

Environmental Management Systems (EMS) will reinforce the progress 

made. 

Promoting the Travelwise initiative to achieve a modal shift in terms of 

how staff travel to and from work. 

3.2.1 Central Procurement Directorate 

(www.cpdni.gov.uk) 

Governance can be defined as the process of decision making and 

implementation. Central Government is one key component of good 

governance. Sustainable development has profound implications for 

governance. A society committed to sustainable development will be 

characterised by a system of governance that focuses on mainstreaming and 

balancing social, economic and environmental progress. 

There are two strategic objectives on governance in the Northern Ireland 

sustainability strategy: 

To mainstream sustainable development across Government; 

To strengthen the network of accountability for governance for 

sustainable development 

The key targets and important steps from Chapter 6 of the sustainability 

strategy are outlined in appendix 2 

The public procurement policy for Northern Ireland was agreed in 2002 

by the Northern Ireland assembly outlining key governing principles and 

the implication of those principles. One implication is that the Executive’s 

economic, social and environmental strategies and initiatives should be more 

closely integrated into procurement policy. 

Construction can affect communities and businesses and can make heavy 

demands on limited natural resources. When planned successfully it can 

also lead to positive outcomes. The Government recognises this and is 

committed to addressing these issues in order to achieve the delivery of 

sustainable development in Northern Ireland. The CPD Policy Framework 

for the Procurement of Public Sector Construction Projects (June 2005) is 

testament to this commitment with a 5 point plan outlining procurement 

strategy. Point 2 embraces ‘Excellence’ with the OGC ‘Achieving Excellence 

Procurement Guide 11: Sustainability’ identified as the mechanism for 

delivering sustainable development. The suite of guides set out the processes 

by which public sector clients can procure and deliver construction projects 

that best promote sustainable development while still achieving optimum 

whole life value for money. 

Whilst ‘Procurement Guide 11: Sustainability’ covers in some detail the 

sustainable development issues that should be considered at each key 

decision making stage – from preparing the initial business case, to operating 

and decommissioning the completed facility, it does not fully reference the 

benefits of the implementation of an Environmental Management System 

and the reader could therefore deem that sustainability and EMS were 

44 



entirely separate entities. 

Point 5 of the CPD Policy Framework outlines the implementation plan for 

construction sustainability ‘Sustainability Action Plan’ with a deadline date 

of March 2006. The requirement for all public sector construction projects 

to have a BREEAM (or equivalent) rating of ‘excellent’ for new build and 

‘very good’ for refurbishment projects, is a commitment by March 2006 and 

evidence of this has been seen in public sector tenders since this date. EMS as 

a requirement, is again not mentioned in the Sustainability Action Plan. 

A large proportion of construction and construction supply companies in 

Northern Ireland do however have a fully certified EMS. Recent QPA figures 

cite that 49 no. quarrying (and associated road contractor) companies are 

accredited to ISO 14001. This could be due largely to the stringent quality 

and health and safety systems requirements imposed by DRD Roads Service 

for tendering contractors. The Highways Agency National Sector Schemes 

has a minimum need for an accredited ISO 9001 (Quality Management 

System). Many contractors have used this as an opportunity to integrate 

systems with ISO 14001 and the health and safety specification OHSAS 

18001, or Northern Ireland specific Safe-T-Cert standard (administered by 

Construction Employers Federation). In addition, the Aggregates Levy Credit 

Scheme requires all quarry operators to undergo a detailed Environmental 

Audit process to enable them to pay a significantly reduced aggregate tax. 

The DoE and HMCE have stipulated that this audit must be carried out by 

an IEMA accredited Environmental Auditor to a strict protocol covering 

104 environmental issues, with a section on Environmental Management 

Systems. There is however, no specific requirement for quarry operators to 

implement EMS and in the second round of Audits (in 2008) Improvement 

Notices issued by DoE under the scheme have yet to stipulate any 

conditions relating to the implementation or accreditation of Environmental 

Management Systems. 

At present the government procurement regime focus appears to be on 

sustainability rather than on EMS. The evidence based credits of BREEAM 

and its’ civil engineering equivalent (CEEQUAL) lend themselves well to 

organisations with formal or informal environmental management systems 

yet, these do not seem to have been recognised by procurement bodies in a 

strategic manner. The DRD Roads Service pre-qualification questionnaire for 

‘Term Contract for Road Markings 2009’ Question C2.4 “Has your organisation 

a third party certified Environmental Management System? If yes, provide 

a copy of the certificate and a third party audit report of your system. If no, 

provide a concise overview of any internal management system that your 

organisation has” is typical of recent invitations. This one environmental 

question however will be judged amongst 21 no. very specific health and 

safety questions. 

Sustainable Operations on the Government Estate 


Action plans have already been produced by a number of government 

agencies in order to support the Governments Sustainable Development 

Strategy. These aim to intertwine the CPD policy as detailed above along 

with sustainably managing the Governments estate in order to encourage 

each body the department sponsors, to among other aspects, lead by 

example in publicly demonstrating commitment to sustainable development 

45


in the way they run their estates. 

Objectives and targets are set in relation to waste; water; energy; estate; 

travel; and procurement. There is also a commitment within the “Estate” 

section of some of the departments’ plans, to “identify and commence a pilot 

Environmental Management System (ISO 14001) on minimum of one site by 

October 2006”. This demonstrates the increased importance placed upon 

EMS in not only managing the impact of government Departments, but also 

of the need to display that the “greening Government” agenda is actually in 

process. 

The Northern Ireland Environment Agency was the first agency of 

the Department of the Environment to receive certification for their 

environmental management system to ISO 14001. Speaking after 

certification in June 2005, the then Chief Executive of the EHS, Richard Rogers 

commented that the system would give staff “an effective way to control and 

minimise their impact on the environment”, and continued on to express his 

delight that the agency “is taking a lead in attaining systems and standards 

that will not only help the environment, but also save public money”. 

3.2.2 Other local (NI) procurement drivers 

Despite the sustainability focus from CPD outlined above, other public 

sector procurement initiatives give examples of EMS at the heart of the 

procurement process. 

One of the leaders in this field is Belfast City Council – 

Belfast City Council has implemented management systems ‘by Department’ 

over the last 5 years. Individual heads of Department have made 

independent decisions relating to management systems development. 

The procurement unit led the way with an integrated management system 

that included ISO 14001 and ISO 9001. This has subsequently been a 

significant driver for companies (particularly in the greater Belfast area) 

that are providing goods and services to Belfast City Council, to prove their 

environmental credentials. All tenders issued by Belfast City Council now 

include an “Environmental Management Questionnaire” with a list of eight 

questions. These are as follows: 

1) Does your organisation have a named officer responsible for 

Environmental Management? 

If ‘yes’, please state the name, position and qualifications of that person: 

2) Does your organisation have an Environmental Policy? 

If ‘yes’, please enclose a copy 

3) Does your organisation have in place an Environmental Management 

System? 

If ‘yes’, do you have any objection to this being inspected? 

4) Does your organisation hold either of the following accreditation’s? 

EMAS 

ISO14001 

5) Has your organisation compiled a register of Environmental Regulations 

and Legislation relating to your business operations? 

46 




6) Has your organisation compiled an Environmental Effects Register? 


7) Do you have an Environmental Action Plan in place to reduce your adverse 

impact on the Environment? 


8) Please identify (on a separate sheet) the environmental impact in the 

provision of your supply/service. 

Belfast City Council Events Unit and Fleet Management Unit have also 

implemented integrated management systems that meet the requirements 

of ISO 14001, ISO 9001 (quality) and OHSAS 18001(health and safety) and 

Project Management Unit has embarked upon development of procedures in 

readiness of certification. 

Constructionline 


Constructionline is “the UK’s register of local and national construction and 

construction-related suppliers pre-qualified to work for public and private 

sector buyers. It is owned for the department for Business, Enterprise 

and Regulatory Reform (formerly the DTI) and supported by the Office of 

Government Commerce and the Department of Communities and Local 

Government. Its aim is to provide efficiency savings to public and private 

sector procurers and the construction industry as a whole by streamlining 

procedures” (Constructionline Registration Criteria, 2008). 

It follows current Public Procurement criteria, and aims to reduce the 

administrative burden on buyers and suppliers alike since the relevant 

information is submitted and then revised annually; thus reducing time 

spent preparing tender submissions. It is of note that there is a specific set 

of criteria encompassed within an “environmental questionnaire” which was 

developed alongside ‘Constructing Excellence’. Answers must be provided, 

and where relevant, supporting documentation should be submitted. 

This also demonstrates the growing role of environmental issues within the 

public procurement process. It is becoming clear that the Public Sector is 

quickly beginning to understand the importance of environmental issues, 

and the role they can play in championing value for money throughout the 

whole life of the project, however, the role of EMS specifically within the 

procurement process is still unclear. 

47


3.2.3 Compliance Drivers – EA approach to Opra in 

England and Wales 

Environmental Permitting Regulations “Operational Risk 

Appraisal” (Opra for EPR) (England and Wales) 

(www.environment-agency.gov.uk) 

The Environment Agency has sought to streamline the Regulation process 

for organisations in England and Wales – culminating in the absorption of 

the Pollution Prevention and Control Regulations within the “Environmental 

Permitting Regulations”. An important tool within this approach has been 

the “Opra” methodology which has been amended and revised frequently 

since it’s inception. The latest revision occurred in line with the 

The Opra scheme is a risk screening methodology that builds on the 

principles developed by the Environment Agency’s EP Opra scheme, which 

it supersedes. Its role is to provide a common tool with which to undertake 

risk assessments of organisations and to target appropriate regulatory 

resources. Operator Performance and Risk Assessment (Opra) in turn evolved 

from schemes developed separately for Integrated Pollution Control (Opra 

for IPC) and Waste Management Licensing (Opra for Waste). The new scheme 

assesses both the environmental hazards of an operation and the operator’s 

performance using information from operators, checked by the Environment 

Agency. 

Opra is a risk-screening tool used to regulate operators under the 

Environmental Permitting (England and Wales) Regulations 2007 (“EPR”). It 

allows the EA to identify and score the following elements of an activity: 

• 

• 

• 

• 

what the activity is; 

where it is being carried out; 

how competent the operator of the activity is; 

how well the operator complies with the conditions in the permit; in 

order to risk evaluate the activity being conducted by that operator at 

that location. 

EA use the resulting risk profile to decide how much effort they need in order 

to regulate a facility, based on a range of factors related to their risk, such as 

where they’re located and what their performance has been like in the past. 

This information is then used to decide the charges each operator needs to 

pay. 

Opra is one step towards the EA’s goal of developing a common approach to 

regulation across a range of regulatory regimes. EA want to: 

• 

• 

• 

make regulation more effective and efficient 

make the process easier for both industry and regulators 

target their resources at activities that pose the greatest risks to the 

environment. 

Each attribute is scored to produce a ‘band’ value (A to E) where ‘A’ equates to 

low risk and good performance and ‘E’ high risk and poor performance. The 

scores for each attribute are added to generate the overall Opra risk profile (A 

to E). The information from each Opra assessment is used in two ways: 

48 



• 

• 

in planning compliance assessments; and 

in determining application and annual subsistence charges – using the 

principle that lower risk requires less Agency regulatory effort and hence 

lower fees are charged to the operator. 

Opra attributes 


The risk assessment is based on the five attributes set out below. 

• complexity: the complexity of the activities and processes operated and 

regulated; 

• emissions: permitted to all environmental media – air, water and land; 

• location: proximity to and sensitivity of environmental receptors; 

• operator performance: the extent and effectiveness of the operator’s 

environmental management system – covering compliance history, 

operation and maintenance, competence and training, emergency 

planning, performance evaluation and external reporting; and 

• compliance rating: compliance with permit conditions, driven by 

the number and significance of permit breaches, classified using 

the Compliance Classification Scheme (CCS). The principle of which 

is to “evaluate non-compliance in accordance with the potential 

environmental effect and rate the non-compliance accordingly” (EA). 

They are rated from CCS Category 1 (potentially major environmental 

effect) through to CCS Category 4 (no potential environmental effect). 

Operator performance (management systems) attribute 

Operator performance consists of an assessment of the operator’s ability, 

preparedness and commitment to meet permit conditions and other 

regulatory requirements. This takes into account the management systems in 

place. EA call this OP1. It also considers previous formal enforcement action 

taken by regulatory bodies at the site. EA call this OP2. While OP3 is the 

Compliance rating attribute and is based upon any non-compliances noted 

and scored using CCS. 

EA’s position statement outlines the policy that effective management 

systems are important to managing the risk associated with an activity and to 

delivering permit requirements. Operators are responsible for managing their 

facility’s impacts and for ensuring compliance with permit conditions. EA 

also believe that the absence of an effective and documented environmental 

management system (EMS) indicates a need for an increased level of 

regulatory oversight. The management systems in place and the regulatory 

enforcement history determine the operator performance (management 

systems) attribute. 

49


This attribute takes into account the following factors: 

• 

Presence or absence of management systems or recognised procedures 

covering areas such as: 

- Operations and maintenance 

- Competence and training 

- Emergency planning 

- Auditing, monitoring, reporting and evaluation. 

• 

Enforcement history at the regulated facility. 

Management systems 

EA’s position statement (Version 2 – January 2005) says: 

“The Agency strongly encourages the implementation and use of robust 

EMS’s. A robust EMS should lead to improved environmental performance, 

including better and more consistent legal compliance. We fully support 

EMAS (which incorporates ISO 14001) and recognise its additional emphases 

on legal compliance, environmental performance and public environmental 

reporting.” 

The detailed requirements for a management system are proportional to 

the risks the system seeks to manage. The presence of accredited certified 

management systems will be taken into account when determining risk 

profiles. Greater weight will be given to certified systems such as EMAS and 

ISO 14001, but other robust and auditable environmental management 

systems (EMS) will be taken into account. These systems provide EA with 

insight into commitment to comply with the permit whether EA are present 

or not. 

The amount of credit given by the Environment Agency reflects the reduced 

effort in determining permit applications due to information generated by 

the EMS, and the potential for reduced compliance assessment effort. Of 

the points available within the Operator Performance Section of Opra, 

the percentages achievable directly through certification to different EMS 

standards are as follows: 

- 40% for EMAS certification 

- 30% for ISO 14001:2004 certification 

- 24% for certification to a published standard subject to external verification 

(e.g. BS8555 or Green Dragon) 

- Up to 24% for an extensive uncertified EMS which produces a public 

statement 

While these are directly achievable due to the EMS in place, the remaining 

60% of credits are likely to be more achievable if an EMS is in place since they 

are predominantly related to procedures: for instance 

- Operations and Maintenance 

- Competence and training 

- Emergency Planning 

50 



The final section of the Operator Performance section can apply a weighting 

of up to negative 40% based on the organisations enforcement history.- 

which considers aspects such as enforcement actions, prohibitions and 

convictions brought not just by the Environment Agency, but also by the 

Health and Safety Executive (HSE) if relevant to the COMAH Regulations, and 

Local Authorities. 

3.2.4 “Other” Compliance Drivers 

Supply Chain Management: 

The importance of market forces in the implementation of Environmental 

Management Systems should not be underestimated. The implementation 

of an EMS can be driven down the supply chain by operators with high 

public visibility; i.e. a company with a large supplier base may decide that 

that the next logical step for their own continued improvement is to ensure 

that it’s suppliers conform to an environmental management standard, 

thereby re-enforcing the company’s claims to be strong environmental 

stewards. The Ford Motor Company in October 1999 detailed a requirement 

that all suppliers with manufacturing facilities were to certify at least one 

manufacturing facility to ISO 14001 by the end of 2001 and all facilities by the 

1st July 2003. At the time, Ford was operating 140 Manufacturing facilities in 

26 countries around the world. Therefore those companies supplying parts 

were under pressure to certify Environmental Management Systems or lose 

high profile, high value, business. 

Customer Perception: 

Often it is felt that improvements in environmental performance can prove 

a useful marketing tool. Sir Stuart Rose, the Chief Executive of Marks and 

Spencer has said that “in the longer-term, a successful business also has to 

be an environmentally and socially sustainable business too” (Marks and 

Spencer, 2008). Marks and Spencer introduced their “Plan A ‘eco plan’ ” in 

January 2007, and fifteen months into its implementation, energy and waste 

costs had been reduced, but also “industry surveys such as the Chatsworth 

FTSE 100 Green Survey and the Covalence Ethical Ranking show how Plan A 

is having a positive effect on how people regard Marks & Spencer – retaining 

the loyalty of existing customers and winning us new business” (Marks and 

Spencer, 2008). 

Therefore, the development of certified EMSs by NI companies could lead to 

improved corporate image among customers and the public, as well as the 

regulators. 

Improved Environmental Performance 


Examples of improved environmental performance through the 

implementation of EMS can be seen in case studies published by Envirowise 

(a government funded organisation aimed at assisting business with resource 

efficiency and waste minimisation). These case studies include: 

1) Dairy Produce Packers Ltd. located in Coleraine, Northern Ireland, decided 

to undertake a waste audit in the run-up to the certification of their EMS, 

with the intention of producing a waste minimisation strategy. The results 

51


of the implementation of the strategy greatly improved the environmental 

performance of the company – for instance: waste disposed to landfill 

reduced by 140 tonnes per annum; water use fell by 14,000 m3 per annum; 

and greatly improved the ratio of materials such as wooden pallets that 

were re-used and cardboard recycled. As well as this reduction in terms 

of environmental impact, the company made cost savings of an estimated 

£46,000 per annum. Alan McMinn, the Factory General Manager summed up 

the improvements made – “the company, in promoting a culture of reduce, 

re-use and recycle, has attained its waste minimisation goals and reaped the 

financial rewards”. 

2) Based in Beith in Ayrshire, McKechnie Plastic Components appointed 

an environmental co-ordinator, in response to customer requirements, to 

develop a certified EMS. “The cost savings that could be achieved through 

simple environmental improvements and reducing waste surprised the 

company and more than paid for the co-ordinator’s salary”. Cost savings have 

been estimated at over £93,000 per annum, while environmental benefits 

include 40 less tonnes of waste to landfill per year, and reductions in new 

packaging and the generation of scrap. 

Other local companies noted for successfully implementing and running 

certified EMS include: 

3) Michelin – which chose to implement ISO 14001:2004 in order to “improve 

the impact of site activity on the environment…The requirements imposed 

by this standard are incorporated into the EMS with the following two 

objectives: 

- to lessen the impact of the Group’s activities on the environment 

- reduce the environmental risks linked to this activity 

Specific targets have been set in relation to reducing energy consumption, 

reducing in-process waste, controlling liquid waste and to limit gaseous 

emissions, particularly of Volatile Organic Compounds (VOCs). In relation to 

VOCs, Michelin announce that they have achieved a 54% reduction in solvent 

use and therefore in VOC emissions based upon the 1992 reference level and 

have since targeted reductions of 75%. 

4) LaFarge Cement, based in Cookstown operates an EMS certified to EMAS. 

Objectives have been set for emissions, which are subsequently monitored 

and publicly reported. One of the key emissions monitored and targeted is 

Carbon dioxide (kgs) per tonne of cement (PCE). In 1999, for every tonne of 

cement produced, the Cookstown works was emitting 1014 kgs of CO2. By 

2005, this had been reduced to 833kgs per tonne PCE – a reduction of over 

17%. LaFarge continues to monitor and target these emissions as well as to 

produce Biodiversity action plans, and has targeted reductions in the annual 

tonnage of waste disposed of to landfill. 

5) GPS Colour Graphics, Belfast – the first Carbon Neutral printing company 

in Northern Ireland. The company was awarded Irish Environmental Printer 

of the Year status in 2005 and again in 2006 for initiatives including the 

implementation of their ISO 14001 certified EMS. Whilst reducing their 

carbon footprint, GPS Colour Graphics also benefited from reducing waste by 

14%, improved efficiency – the introduction of a CtP Platemaker has reduced 

chemical usage at the site by 50% within the first year. The management 

team also expound the virtues of the system for encouraging positive 

52 



engagement with their 57 no. staff. Business has not suffered at GPS since 

the implementation of the EMS and Carbon Neutral status. Derek Bell, MD 

states “We have worked hard and fortunately successfully at maintaining our 

high standards whilst our business experienced significant growth over the 

last few years. In 2005 GPS increased in size in terms of sheets printed to 54 

million compared with 32.8 million in 2003”. 

(source Irish Printer, February 2007) 

In-Brief 

• 

• 

• 

• 


There are a number of ‘drivers’ for an organisation implementing an EMS 

- Legal compliance 

- Procurement (particularly government procurement strategy 

- Supply Chain Pressures 

- Enhanced public image and PR 

- Improved environmental efficiencies and cost savings 

Government procurement strategy relates to EMS in an ad hoc manner 

on a tender by tender basis. As yet, procurement strategy does not 

provide structured guidance for the public sector bodies on how to 

assess or evaluate organisations with a management system against 

those that do not. 

First Steps is the first ever sustainable development strategy for Northern 

Ireland, the strategy presents the opportunity to achieve a better balance 

between social, environmental and economic progress. It also makes the 

commitment to promote the wider use of EMS as well as the uptake in 

the Arena Survey (see section 4.4.6) 

The Opra scheme is a risk screening methodology which builds on the 

principles developed by the Environment Agency’s EP Opra scheme, 

which it supersedes. With points available for the implementation of 

certified EMS in particular EMAS and ISO 14001:2004, in the knowledge 

that the methodology is “linked to fees and charges levied on IPPCregulated 

sites so having an EMS can result in lower costs” (Defra Position 

statement on EMS, 2008) 

53


4.0 Uptake of EMS 

4.1 The International Scene 

Up to the end of December 2006, at least 129,199 ISO 14001:2004 certificates 

had been issued in 140 countries and economies. The 2006 total represents 

an increase of 18, 037 (+16 %) over 2005, when the total was 111, 162 in 138 

countries and economies. 

Service providers accounted for 27 % of all ISO 14001:2004 certificates issued 

up to the end of 2006. 

From The ISO Survey of Certifications 

54 



4.2 Europe 

ISO14001 

EMAS 

There are currently 6,205 sites in 4,138 EMAS registered organisations 


55


High uptake rates in Spain and Italy can be explained as over the last years, 

legislation has been put in place in Italy with allowances for 

• 

• 

• 

• 

• 

• 

• 

a higher score for EMAS registered organisations concerning permits for 

use of water; 

an EMAS registration replaces application for renewal for permits for 

waste management activities; 

longer life of permits – 8 years instead of the usual 5 years; 

Reductions in some regions taxes for EMAS registered organisations; 

Reductions in fees for inspection; 

and in Spain exemptions from inspections for EMAS registered 

companies; 

Regional governments give financial support to new EMAS registered 

companies every year. 

Ref: “The firm, Environmental Management and Environmental Measures: 

lessons from a Survey of European Manufacturing Firms”. – N. Johnstone, P. 

Scapecchi, B. Ytterhus and R. Wolf in Journal of Environmental Planning and 

Management; vol. 47, N° 5. 685-707, September 2004. 

Source: Europa: http://ec.europa.eu/environment/emas/about/participate/ 

sites_en.htm 

Figure 9 Evolution of organisations and sites 

Quarterly Data 13/3/2008 

7000 

6000 

5000 

4000 

3000 

2000 

1000 

0 

Organisations in the 

EU and EEA 

(Europa. www.europa.eu) 

56 

EMAS STATISTICS 

EVOLUTION OF ORGANISATIONS AND SITES 

Quarterly Data 

13/3/2008 

5223 

3908 

3935 

3910 

3762 

3912 3855 

3797 

3770 

3755 3718 

3652 

3417 

3576 

3498 

3532 

3325 

3966 

3244 

3796 

3067 3093 3195 

3842 

3063 

2876 

3055 

3416 3605 

2775 

3259 

3110 3041 

3116 

2686 

3072 

3148 

2531 

2316 

2140 

1269 

5435 

4800 

4628 4655 

5914 

5671 

5743 

5066 

4093 4137 

3901 4050 

4253 

4178 

3930 

5956 

Organisations 

(before the 

correction) 

Sites 

1. 

2. 

3. 

4. 

5. 

To facilitate comparisons, the previously reported figures are kept on the graph. 

The Commission started to collect the number of sites in addition to number of organisations in 

March 2004 to provide a more accurate picture of EMAS development. 

Germany reported a significant number of corrections in March 2004. 

Germany and Spain reported corrections in June 2005. 

The UK corrected their number of sites in December 2005. 

31/12/97 31/03/99 30/09/99 31/03/00 30/09/00 31/03/01 30/09/01 31/03/02 30/09/02 31/03/03 30/09/03 31/03/04 30/09/04 31/03/05 30/09/05 31/03/06 30/09/06 31/03/07 29/02/08 

31.09.2007 



Corrections were undertaken in order to accurately ascertain the numbers 

of organisations which had implemented EMAS, and how many sites were 

incorporated within the organisations system. Interesting to note is the 

slow down which occurred during this period of corrections, but that 

subsequently, while the number of organisations implementing EMAS has 

developed at a relatively steady rate, the number of sites has grown much 

more rapidly. This could suggest that for those organisations which have 

implemented EMAS – clear benefits have been seen in the sites covered, and 

this has been extended to other sites within the groups. 

4.3 UK Wide 

ISO14001 

UK organisations have made rapid progress in implementing EMS’s over the 

last few years. Globally, the UK is now ranked 6th amongst countries with the 

highest number of ISO 14001 certificates (as of the end of 2007 there were 

over 6,000 UKAS accredited certifications to ISO 14001 in the UK) 

UKAS have details of 52 certification bodies which are accredited to certify 

EMS to ISO 14001, however, only 40 of these are recorded as having 

issued UKAS accredited certificates to organisations operating in the 

United Kingdom. It should also be noted that certification bodies must be 

approved under the various European Co-operation for Accreditation Scope 

References, and even then it may be ‘full’ or ‘limited’ accreditation. 

In 2006, over 100 ISO 14001:2004 certificates were withdrawn from 

organisations within the UK (around 1.5%). The figures though are provided 

as “a rough indicator” (ISO, 2007) as not all certification bodies provide 

information relating to withdrawn certificates. Unfortunately no explanation 

is provided for why these were withdrawn – whether through noncompliances 

or company withdrawal from the system etc. 

4.4 The Situation in Northern Ireland 

4.4.1 Invest NI Support 

The Technical and Sustainable Development Unit at Invest NI is aimed at 

helping business to solve technical energy and environmental problems. 

This remit is served through the support of organisations such as Carbon 

Trust, NISP (National Industrial Symbiosis Programme) and Envirowise but 

also through the development of training packages, grant aid and loans for 

delivery by the Invest NI Sustainable Development team. A number of the 

initiatives detailed below will have been delivered by IRTU (pre-Invest NI). 

4.4.1.1 Support Scheme Grants 


The Environmental Audit Support Scheme (EASS) provided financial 

assistance to businesses conducting environmental audits. The scheme 

offered 66.67% grant towards the cost of up to 15 consultancy days and 

reasonable expenses, subject to a maximum grant of £5,000. It had the 

overall aim of assisting industry in taking its first step towards improving 

environmental performance, with the objective of encouraging “industrial 

and commercial enterprises…to commission environmental audits…with a 

57


view to formulating and implementing environmental policy.” 

Within the audit, detailed on-site examinations were carried out of 

environmental activities by an independent consultant selected by the 

business: a wide range of potential impacts were covered: with the aim of 

helping businesses create a baseline of environmental performance and 

highlight areas of weakness. 

First launched in November 1993, circa 560 businesses were assisted; with an 

approx. Invest NI spend of £420,000, 95% of which went towards consultancy 

costs - circa 80 audits per annum. A follow up evaluation with 49 businesses 

which received support revealed the following information. 

Factors Influencing an Audit: 

The 49 respondents were surveyed on which of the following factors 

influenced their decision to undertake the audit: 

Influencing Factor Number of responses % of respondents 

Compliance with legislation 30 61% 

Customer influence/demand 8 16% 

Availability of grant 8 16% 

Previous Environmental Concern 9 18% 

Reduce Operating Costs 3 6% 

PR Opportunity 10 20% 

Other 6 14% 

Total 74 

*Does not add to 100% as some respondents gave more than one response 

The vast majority undertook the audit to determine compliance with 

legislation (61%), while the “other” section is stated by Invest NI to represent 

those wishing to achieve ISO accreditation. One fifth of respondents felt 

it was a valuable PR tool, and a further 16% undertook it due to customer 

influence / demand. 

Respondents were then asked to identify the potential environmental 

impacts that their business was seeking to address through the audit. 

Of these, four impacts (waste management 65%, EMS 29%, Energy Efficiency 

26%, and Elimination of waste, recycling and recovery 24%) show a trend 

towards the areas of legal compliance and cost reduction. Perhaps surprising 

is that only 8% of respondents cited pollution abatement as an impact 

requiring addressed, but this may suggest that companies that are more 

proactive regarding environmental audits and management systems pose 

less of a risk to the environment – due to an already heightened awareness of 

environmental issues. 

58 



Implementation of Recommendations: 

Respondents were asked to outline the key recommendations, and to what 

extent they had implemented them: 

Of the 47 that were implementing, or had implemented, the suggestions, 

98% felt their business’ environmental performance had improved, and they 

were subsequently asked to comment on the benefits. At the time of survey: 

• Two businesses had achieved ISO 14001 following completion of the 

programme; 

• One business achieved ISO 9000 accreditation; 

• A number of businesses confirmed that it gave them a greater 

understanding of environmental recycling issues; and 

• A number of businesses confirmed that their costs and waste had 

reduced 

Summary 


Throughout this survey, there are two prevalent themes: firstly, compliance 

with legislation; and secondly, cost reduction through improved efficiency. 

There is no doubt that the availability of EASS meant that many businesses 

went through the formal audit process that otherwise may not (85% 

claim financial support was a key factor in their decision to undertake an 

Audit) – but that virtually all felt this had led to an improvement in their 

environmental performance (98% of those implementing recommendations). 

A third of whom went on to make further investments, and almost half of 

all respondents were now setting quantifiable targets for environmental 

improvement. 

Invest NI had also sponsored the “Environmental Management System 

Support Scheme (EMSS)”. This scheme operated for a shorter duration than 

the Environmental Audit Support Scheme and provided up to 75% grant on 

consultancy and certification fees for businesses seeking to implement an 

EMS to a recognised standard. A large number of companies participating 

in the EASS will have gone on to avail of the EMSS to assist with the 

achievement of ISO 14001 accreditation. While this scheme has now ceased, 

unfortunately, Invest NI were unable to provide information on analysis 

undertaken under the EASS programme. 

59


4.4.1.2 Building Blocks 

Launched in September 2003, funded by Invest NI and delivered by White 

Young Green, this Pilot Programme was designed to help companies achieve 

certification to BS8555 – the phased approach to implementation. Through a 

series of workshops, and designated consultancy days, the 11 companies that 

were selected to participate all went on to have their systems certified by an 

accredited body to Phase 3 of BS8555. Nine of these companies continued 

through the later Phases of the Standard, and at the time the evaluation of 

the Programme was undertaken (May 2005), six of these had been certified 

to ISO 14001. 

The evaluation of this Pilot Programme included making contact with all of 

the eleven companies which participated in the programme – focusing on: 

Drivers for undertaking the Programme; Perceived benefits of undertaking 

the Programme; and Realised Benefits of undertaking the Programme. 

Drivers for Application: 

1) 68% due to the availability of funding. 

2) 58% to improve legislative compliance. 

3) 34% due to customer influence / demands. 

Perceived Benefits: 

1) 86% thought they would see an improvement in environmental 

performance. 

2) 46% felt they would benefit from improved liability control. 

3) 38% thought they would see financial benefits. 

If improved environmental performance was sought, the organisations were 

asked to detail how they hoped this would manifest itself: 

1) 100% hoped to improve waste disposal routes. 

2) 90% expected reduced energy consumption. 

3) 80% were targeting a reduction in the waste generated. 

Realisation of perceived benefits: 

Organisations were to allocate responses on a scale of 1 -4, where 1 equalled 

‘not a lot’ and 4 equated to ‘a lot’. By combining the scores 3 and 4 (i.e. the 

positive responses), the top three were as follows: 

1) 100% felt they had improved liability control. 

2) Just over 80% believed they had improved their environmental 

performance. 

3) Just over 50% felt they had improved their public image. 

Improved Liability Control: 

The organisations reported a greater awareness of environmental legislation 

applicable to their activities; and felt more able to demonstrate compliance 

60 



through the measures the EMS had initiated such as a register of legal and 

other requirements; demonstration of control measures in place to maintain 

compliance and collation of supporting evidence (e.g. Waste Transfer Notes, 

and Licenses of waste contractors) 

Improved Environmental Performance: 

The organisations had initiated a wide range of different measures, 

depending on the nature of the industry, but improvements cited by the 

participants included: installation of oil / water separators to improve 

storm water discharge; improved waste segregation and recycling; and 

improved bunding; through to the recruitment of personnel dedicated to 

environmental issues. 

Improved Public Image: 

While only around half of respondents felt they had improved their public 

image, all received publicity through their engagement in the scheme and 

successful completion up to Phase 3 of BS8555, while others reported that 

it enabled them to set an example to sister companies, as well as promoting 

a positive image with customers, the public, and demonstrating “green” 

commitment to the supply chain. 

4.4.2 STEM 

The STEM (Sustainable Together through Environmental Management) 

Project was established in 2004 to run until June 2008. Funded by the EU 

INTERREG IIIA programme for Ireland / Northern Ireland, nine participating 

councils and Southern Group Environmental Health Committee. It had three 

key objectives: 

• 

• 

• 


Deliver ISO 14001 to the nine councils and SGEHC 

Assist 270 businesses (within the council areas) to achieve accreditation 

to BS8555 (phase 3) 

Offer project management support to businesses that have achieved 

BS8555 and are willing to commit extra resources in order to attain ISO 

14001 

STEM was designed to assist the local authorities in meeting their targets 

and to demonstrate the commitment of public bodies to environmental 

improvement, and also for those SMEs that sought to reduce their 

environmental impact though EMS, but may not have had the resources to 

do so, STEM was able to provide a service that could otherwise have been 

very costly. 

For councils, the key objective was to achieve joint certification to ISO 

14001:2004 for a minimum of 3 services in each of the 9 councils and SGEHC 

– it was exceeded in 2007 when a number of councils completed certification 

of their civic buildings and therefore the services within. The below table 

demonstrates the councils and certified services / facilities. 

61


Council Env. Health Technical/ Leisure services Civic Building Grounds 

Maintenance 

Ards Borough Council 

Armagh City and District Council 

Banbridge District Council 

Craigavon Borough Council Oxford Island Site 

Down District Council 

Dungannon and South Tyrone 

Council 

Newry and Mourne District Council 

SGEHC 

Monaghan County Council 

Louth County Council 

Water Services Roads Services Civic Building Environment Section 

When asked about the motivating factor for businesses to participate in 

STEM, the qualitative information available suggests a range of factors. The 

free advice and guidance was obviously attractive for those SMEs that were 

already considering the implementation of an EMS; and the usual crop of 

responses relating to desires to reduce costs and improve efficiencies, as 

a marketing tool or due to supply chain pressure were present. There was 

also an interesting story relating to legislative requirements – for many 

EMS represent the best available technique to monitor and demonstrate 

legal compliance, though for some others, legislation was seen as a barrier 

to implementation, based on the cost to comply but also regarding the 

potential of becoming “visible” to the regulator and therefore leaving 

themselves open to prosecution. In terms of businesses, the below table 

shows the breakdown of total participants in the scheme and associated 

employee numbers: 

NI ROI Total 

Business Participants 253 63 316 

Employees 5306 2070 7376 

A further split shows the recruitment of businesses from both sides of the 

border and by business sector. 

62 



Northern Ireland Businesses by Sector 

Business Sector Number of 

businesses 

Construction 45 872 

Engineering 18 354 

Food and Drink 29 1085 

Garage/Repair 6 67 

Horticulture 10 110 

Hotel/Tourism 11 474 

Manufacturing 37 1070 

Quarry 18 433 

Recycling 12 83 

Services 44 338 

Transport 5 81 

Wholesale /Retail 18 339 

Total 253 5306 

Number of 

employees 


ROI Businesses by Sector 

Business Sector Number of 

businesses 

Construction 8 194 

Engineering 6 109 

Food and Drink 11 461 

Garage/Repair 0 0 

Horticulture 2 95 

Hotel/Tourism 6 403 

Manufacturing 10 427 

Quarry 2 80 

Recycling 1 60 

Services 10 120 

Transport 2 32 

Wholesale /Retail 5 89 

Total 63 2070 


employees 

63


STEMs second key objective was to assist 270 businesses to achieve 

accreditation to BS8555 (phase 3): the programme fell slightly short of this 

target – due to drop out rates. Below is the data relating to total businesses 

accredited to BS8555 throughout the life of the project. 

Business Sector Number of businesses 

Construction 43 

Engineering 17 

Food and Drink 26 

Garage/Repair 4 

Horticulture 4 

Hotel/Tourism 12 

Manufacturing 33 

Quarry 18 

Recycling 11 

Services 42 

Transport 4 

Wholesale/Retail 19 

Total 233 

The graph on the next page depicts the amount of business participants that 

received accreditation, plotted against total business participants and the 

associated percentage. 

In total, almost three-quarters of participants in the scheme (233 businesses) 

were successfully certified to BS8555 (phase 3) – and 11 of these went on to 

become certified to ISO 14001 (3% of total participants). 

64 




The STEM project demonstrates that there is demand among NI Businesses 

for support in the implementation of EMS – and that the reasons for 

participation range from desire for improvements in environmental 

performance through to legal compliance and customer demand. The 

twenty-five percent drop out rate could suggest that for some SMEs it was 

felt that benefits could be derived without a certified EMS 

Further information relating to the rates of re-certification for the above 

companies is slightly more limited since due to the nature, and timing, of 

the re-inspection process, some organisations have yet to receive their 

first surveillance audit. Therefore information is only available for those 

companies certified by the end of December 2006, and have subsequently 

undergone the surveillance process by the end of December 2007. 

65


In total, only 47% of those certified prior to end December 2006 were 

successfully re-audited. This could demonstrate that upon certification, and 

therefore the end of STEMs involvement, SMEs were unwilling to dedicate 

the necessary resources to maintain the system. If this figure were to be 

extrapolated for total businesses certified within the life of STEM, then only 

110 of the originally accredited participants can be expected to retain this 

after the original certification audit. It is possible therefore that an absence 

of any financial support to keep the EMS up to date has had a detrimental 

impact on the going registrations to BS8555: 2003 within the STEM project. 

Interestingly, as the graph below and table demonstrate, there is a definite 

trend regarding the likelihood of an organisations propensity to maintain 

the system when considered in relation to employee numbers: as employees 

numbers increased, so too did the proportion of successful re-audits. This 

would indicate that it is likely that there is a dedicated resource available 

within larger organisations to assist in the ongoing implementation process. 

66 



Percentage re-certified 

100.00% 

80.00% 

60.00% 

40.00% 

20.00% 

0.00% 


Employees 

Certified Re-certified Percentage 

1-10 36 12 33.33% 

11-50 48 21 43.75% 

51-100 19 13 68.42% 

101-150 2 2 100.00% 

>150 1 1 100.00% 

Total 106 49 

Percentage of Companies Re-certified 

1-10 11-50 51-100 101-150 >150 

Employee Numbers 


Percentage 

67


4.4.3 Bites 

Business Improvements through Environmental Solutions (BITES) is a 

programme funded by Belfast City Council’s Economic Development Unit 

and “Better Belfast” – the Landfill Communities Fund Distribution programme 

which was administered by Bryson Charitable group on the behalf of Belfast 

City Council. The programme was developed by Belfast City Council, Arena 

and Queen’s University. The aim of BITES is to “help companies create an 

environmental management system which is tailor made for their own 

business. By doing this they will both improve their carbon footprint and 

make financial gains”. The programme has at this stage only been run once, 

(though recruitment is currently under way for the second programme) and 

six organisations (public and private sector) took part. The programme lasts 

for a year and comprises five modules: EMS; Resource and Efficiency; Energy; 

Water and; Purchasing and Transport. Throughout the programme, the 

organisations develop management systems in line with Green Dragon. 

Of the 6 organisations which participated, all successfully attained Level 

3 of the Green Dragon standard and most received Waste Awareness 

Certificates from CIWM and an IEMA Associate Certificate in Environmental 

Management. All organisations reported improvements in resource 

efficiency, and environmental performance, for instance; Patient and Client 

Support Services of “The Royal Hospitals” made savings of £22,000 through 

better waste recycling; and “ASG” (a marketing solutions company) diverted 

30 tonnes per annum of waste from landfill through improved recycling, 

as well as identifying and implementing a solution to a boiler which was 

running inefficiently – thereby improving their environmental performance 

as well as making cost savings of £300 per annum. Other companies also 

reported how changes implemented had reduced the potential of pollution 

incidents, and subsequently reducing risk of non-compliance with applicable 

environmental legislation. 

4.4.4 CEF Easy Access 

The Constructors Employers Federation (CEF), in partnership with CIRIA and 

White Young Green, provide an EMS training programme tailored to meet the 

needs of the Construction Sector. The programme is known as Easy Access. 

The programme follows the BS8555 methodology. Training is provided over 

the course of a 12-18 month period on each of the 6 phases of BS8555. 

Up to ten firms can be accredited at any of the six phases of Easy Access. 

However most use Easy Access to prepare them for ISO14001 the 

international Environmental Management standard. 

A key focus of the programme is compliance with environmental legislation. 

A full day training session is dedicated to helping companies identify and 

comply with environmental legislation. As environmental compliance is a 

minimum requirement for an EMS, the topic is also covered throughout the 

course of the programme, 

68 



4.4.5 Green Dragon 

Coleraine Borough Council was the first Council in NI to offer support to 

businesses to implement Green Dragon. In partnership with Arena Network 

and part funded by the EU Building Sustainable Prosperity Programme, it was 

able to provide the service to some local businesses free of charge. 

Approximately 40 organisations in NI have implemented EMS to the Green 

Dragon standard. Of these around 80% have been inspected to level 2, and 

the remaining 20% have undergone inspections at level 3. In the region 

of 90% of these organisations have received support through funded 

programmes including BITES and Coleraine Borough Council initiatives. 

4.4.6 Arena Network Survey 

Published in late September 2008, the 10th Annual Arena Network Survey 

represents the largest annual environmental survey in Northern Ireland. 250 

of NI’s largest organisations are invited to take part in the online survey which 

culminates in the publicly available document which ranks organisations into 

quintiles depending on their performance in the Survey. 

The Survey underwent a significant revision which was in recognition of the 

fact that as the performance of NI’s organisations improved Arena Network 

needed to “raise the bar” (Arena, 2008) This 10th Survey: 

- “places more emphasis on performance…less about policy and 

processes and more about delivering actual improvements on the 

ground” 

- New sections were added to cover areas such as compliance, 

advocacy and transport – requiring evidence for the first time in 

some areas 

- Verification also became a more rigid process, with 15% of 

participants subjected to an independent review. 

13 industry sectors were represented by 128 organisations – a fall on 

previous years, though this was expected due to the changes to the survey 

and rationalisation among the public sector participants. The overall score 

fell also, again attributable to the revised process – thus the results of this 

report are due to form a new baseline to facilitate future comparisons. 

However, though comparisons are made difficult, some of the results which 

were found prove interesting as stand alone issues: for instance; 

• 

• 

• 


98% of organisations have an environmental policy, the same percentage 

have also appointed a senior manager with environmental responsibility. 

97% have set environmental objectives and targets. Arena believes these 

to be the basic tenets of an EMS 

91% of participants claimed to have an EMS, or were developing one; 

and 49% of all businesses had a certified EMS in place 

The new questions relating to compliance addressed whether 

organisations had registers of applicable environmental legislation 

(4% had) – though there were no further questions relating to noncompliance 

/ prosecutions or enforcement actions. 

69


Due to the revision of the Survey, it is difficult to ascertain whether or not 

performance has improved across the organisations – this will become 

apparent as the Survey is undertaken again in subsequent years. Though the 

survey does not actively consider whether or not an EMS contributes to legal 

compliance and enhance environmental performance, it did ascertain that 

94% of organisations have a formal register of environmental legislation, and 

two-thirds of participants “engage with decision makers to influence policy or 

take an active stance to promote environmental practice” (Arena, 2008). 

In-Brief 

• 

• 

• 

• 

• 

70 

There have been large increases internationally in the uptake of 

accredited EMS 

In the UK, more than 6,070 certificates have been awarded to 

organisations with EMS to ISO 14001:2004, and 69 organisations 

(encompassing 366 sites) to EMAS. 

Northern Ireland Support Schemes have been very successful in 

terms of numbers of organisations applying, and where available, the 

analysis of these schemes have generally demonstrated benefits (both 

environmental and financial) for the organisations. 

However, analysis of the information available from STEM suggests 

that smaller businesses are less likely to maintain an EMS following 

withdrawal of the support structure. 

The revision of the Arena Survey and the subsequent results demonstrate 

the growing commitment of the leading NI organisations in towards 

environmental management systems with 98% having in place the basic 

tenets of an EMS and 49% of respondents operating certified EMS. 



5.0 Research into EMS 

The effectiveness of Environmental Management Systems has been long 

debated and there has been a significant body of research undertaken in 

recent years. Relevant research papers have been considered for this review 

and summarised in this chapter. Research relating to the effectiveness of EMS 

in relation to legislative compliance and improvements in environmental 

efficiencies have been closely regarded below. 

5.1 ”SME-nvironment Survey, 2007” 


In 2007, NetRegs Undertook the “SME-nvironment Survey” – the purpose was 

to examine progress and knowledge advancements since the similar surveys 

undertaken in 2003 and 2005. Including England, Scotland, Wales and NI, 

the survey is a useful tool in comparing SMEs across the UK with regards to 

perceived environmental performance. 

As the graph demonstrates – knowledge across all SMEs regarding their 

environmental impact was very low, with a UK average of 15% of businesses 

which thought their activities could cause environmental harm, this rose 

to an average of 49% when prompted with a list of harmful activities: 

“businesses in Northern Ireland were least likely to admit to undertaking 

any activities that were deemed to be harmful to the environment 

(44%)”(NetRegs, 2007). This demonstrates a lack of understanding at the 

vast majority of organisations as to the effects their activities can have on the 

environment. 

71


*Should be noted that multiple responses were accepted under the “Motivations” category. 

In Northern Ireland and England, businesses were the least likely to have 

taken actions to improve their environmental performance (46%). The 

main driver common for all regions was general environmental concern 

rather than to ensure legislative compliance. This is perhaps unsurprising 

when further questions probe the respondents awareness of environmental 

legislation – only 23% of NI businesses were able to name a piece of 

environmental legislation – 36% of those who could, cited the Packaging 

Waste Regulations. It is even less surprising then, that when questioned 

about the main business benefits of addressing environmental issues, 81% 

strongly agreed / agreed with “reduced risk of prosecution”. 

Environmental Policies and Management Systems: 

Businesses with between 50-249 employees were much more likely than 

those businesses with 9 or fewer members of staff to have an environmental 

policy in place: 71% compared to 28% respectively. Northern Irish businesses 

were the least likely to have an environmental policy in place (35%) when 

compared to the other regions (39% in England and Wales, and 43% in 

Scotland). 

The take-up rates of EMS throughout the UK was consistent, with around 

15% already having one in place, and a further 6% planning to introduce one 

in the future. 

72 



5.2 EVER – Evaluation of EMAS and Eco-label for their revision 

Carried out on behalf of the European Commission, and published in 

December 2005, the Ever Report aimed to provide recommendations for 

the revision of EMAS and the EU Eco-Label. With reference to EMAS, it 

specifically considered the impact of EMAS on environmental performance. 

Environmental performance was classified into four sub-sectors: 

- Absolute Improvement 

- Continuous Improvement 

- Relative Improvement 

- Target-led improvement 

Using three different methodological techniques, the authors considered 

“Quantitative Analysis of eco-efficiency and impact indicators”, 

“environmental management indicators” and “interview and survey 

data” to draw their conclusions. Despite the variety of methodologies, 

it was still found that “whether and to what extent EMAS improves the 

environmental performance of organisations is difficult to assess... This may 

appear surprising, given that the continual improvement of environmental 

performance is a key objective of the EMAS Regulation and given that EMAS 

organisations are required to publish environmental data” (EVER, 2005). It 

is their belief that the difficulty stems from issues regarding the definition of 

performance improvement, establishing cause/effect relationships and the 

availability of data. 

The findings in relation to the four improvement sub-categories are 

summarised below: 

EMAS and Absolute Improvement 

Based on interview results, the authors found that EMAS is “perceived to have 

a positive effect on environmental performance, especially in facility-related 

aspects such as waste, water and air pollution” but that other areas such as 

environmental regulation and “technical progress” have a greater impact on 

performance. 

EMAS and Continuous Improvement 

Again based on interview results, “the large majority of respondents (89%) 

hold the view that their EMS contributes to environmental improvement year 

on year”. 

EMAS and target-led Improvements 


Targets tended to be set “on the basis of economic and technical feasibility 

rather than public policy objectives”, and the targets tended to be qualitative 

rather than quantitative. Two-thirds of those surveyed believed they 

obtained their targets “often”, while just under a quarter said they “always” 

met theirs. 

73


EMAS and Relative Improvements 

Conducting a comparison between EMAS registered and non-EMAS 

registered organisations (of whom, 22.5% had no EMS); it was found that very 

little difference existed in perceptions about performance. In fact, the only 

area of questioning where there was divergence was in relation to targetsetting. 

EMAS organisations were less likely to consider public policy targets 

when setting their own objectives than non-EMAS organisations, but were 

twice as likely to “always achieve” their targets. 

Summary: 

The survey found that EMAS has a positive effect on environmental 

performance, and that for those that have adopted it, it is seen as a 

useful tool, however, it “is not one of the most important determinants of 

environmental performance and it appears not to be a strong autonomous 

driver for improvement”. 

It also suggests that ISO 14001:2004 is as strong as EMAS as regards 

facilitating and stimulating environmental performance improvement. 

5.3 Environmental Management Systems and Company Performance: 

Assessing the case for extending risk-based regulation. 

Prior to the issue of ISO 14001:2004 and looking exclusively at sites regulated 

under Industrial Pollution Control (rather than its successor IPPC – and 

subsequently Environmental Permitting - EP) in England and Wales, this 

study sought to examine the case for “regulatory relief” for those companies 

with formal, certified EMS’s. It also took place prior to the variety of changes 

to the Opra methodology which have subsequently seen it become ‘Opra’ – 

however, it produced some interesting findings pertinent to the questions 

posed by NIEA, in that the authors sought to answer many of the same 

questions such as the links between certified EMS and environmental 

performance and legislative compliance. 

The validity of the Opra scheme in England and Wales was considered along 

with it’s incentivisation of the uptake in EMS’s through reduced compliance 

assessment activities and with the potential to reduce regulatory monitoring 

where there is overlap between the outputs of an EMS and regulatory 

reporting requirements, i.e. to prevent the duplication of effort on behalf of 

the operator. 

EMS and Company Performance 

In order to assess whether sites with an EMS were associated with higher 

levels of Operator Performance, the sample was split into three groups: 

Sites without a certified EMS; Sites certified to ISO 14001; and sites certified 

to ISO 14001 and EMAS. Comparing the most recent Overall Performance 

Assessment (OPA) scores at the time of publication; it found that “mean OPA 

scores are significantly higher for sites with an externally validated EMS than 

for those without, and that EMAS registered sites score higher than sites 

certified only to ISO 14001. Differences were also noted with regards to the 

range of scores attained: with “fewer poor performers, as judged by fewer 

low scores and a higher concentration of high OPA scores, among the groups 

74 



with externally validated environmental management systems…having an 

EMS cuts off a ‘tail’ of poor performance” (Dahlstrom et al, 2003). However, 

further analysis demonstrated that five of the six questions that the OPA 

scores referenced at this point were related to “aspects of performance that 

a management system is intended to improve”, while for the one attribute 

related to “incidents, complaints and non compliance events” there was no 

significant difference between the three groups. This could support one 

of the findings of remas (see below) that a certified EMS could appear to 

raise levels of non-compliance events as the EMS increases awareness of the 

organisations compliance status. 

EMS and Continuous Improvement 

To analyse this, the study compared the first and last OPA scores for sites 

assessed more than once, and discounting those which occurred within 

twelve months of each other, leaving a sample of just over 400 sites. Of 

these, almost 40% experienced no change, 46.4% improved with the 

remainder deteriorating. “There were significant differences in the rate of 

improvement of OPA scores between the three groups. Sites with either ISO 

14001 or EMAS started from a higher baseline than those without…and… 

improved more rapidly”. 

EMS and Enforcement Action 

“From a regulatory perspective, legal compliance is a key aspect of 

environmental performance”…however, the available dataset to enable a 

comparison of the links between EMS and compliance was too small to allow 

accurate analysis of the links, thus fails to provide “evidence that sites with an 

externally validated EMS are more or less likely to be subject to enforcement 

action”. 

Summary: 

Sites with a certified EMS have higher levels of operator performance 

than those without, with EMAS registered sites out-performing those with 

ISO 14001. However, they “do not have a lower likelihood, as assessed by 

enforcement officers, of suffering from incidents, complaints and noncompliance 

events”. The context within which this study was undertaken 

should be noted, in that it pre-dated ISO 14001:2004, and was prior to the 

expansion in coverage of the PPC Regulations. 

5.4 REMAS 


remas was a three-year project designed to examine environmental 

management systems (EMS’s) currently in place in business and industry 

across EU Member States. remas aimed to demonstrate that companies and 

organisations that implement environmental management systems, such 

as EMAS and ISO 14001, show better environmental performance overall. 

The IEMA is one of the project partners, along with the Environment Agency, 

Scottish Environment Protection Agency and the Irish EPA. Unfortunately, 

DOE EHS were not part of the remas review and so opportunities to examine 

the effectiveness of EMS with a proportional representation of Northern 

Ireland companies were not utilised during this three year period. 

Businesses around the world are facing increasing demands for improvement 

75


in environment performance. They are exposed to greater pressures from 

customers, employees and competitors and are having to deal with a 

plethora of rapidly changing regulations and guidelines in their field. To 

deal with these pressures, many companies have chosen to implement 

environmental management systems (EMS) that essentially allow the 

environmental impact of a company or organisation to be more easily 

controlled. 

Implementing an EMS should improve a company’s environmental 

performance, but prior to the remas project there has been little data to back 

this up. remas commenced on 1 November 2002 and remas collected data 

from European sites until October 2005. remas sought data from sites with 

formal, informal and no EMS. remas used this information to demonstrate 

ways of avoiding duplication from the overlap of regulatory process work 

and EMS implementation. 

remas set out to achieve the following objectives: 

• 

• 

• 

• 

Demonstrate mechanisms to meet Article 10 of the Eco-Management 

and Audit Scheme (EMAS) (relates to the consideration of how to avoid 

unnecessary duplication of effort by both organisations and enforcement 

authorities) 

Demonstrate where EMAS improves performance and compliance with 

environmental regulation 

Demonstrate how effective implementation of EMAS improves 

environmental performance faster or further than command and control 

regulation 

Encourage uptake of the approach through dissemination with key 

European Community stakeholders 

remas findings 

The project used a bespoke mathematical model to interpret the 

relationships between the adoption of a particular type of EMS and the 

management activities or ‘behaviours’ a regulator expected on a good 

site, and then the subsequent impact of these on regulatory compliance 

performance and environmental performance. The latter metric was 

normalised to allow comparisons against raw materials and emissions 

benchmark levels defined as ‘best available techniques’ within the European 

Union’s Integrated Pollution Prevention and Control Directive. Whereas the 

benchmarks were known, the derivation of the model and comparisons 

techniques is groundbreaking with a number of ‘spin-off’ learning points 

established during the work which adds to the value of the project. 

The data gathered was subjected to a number of quality control audits, 

including site visits by the team and cross reference to local regulatory 

inspectors. The website used to gather data remains available as an 

additional project deliverable, and is translated into five languages. 

Data on various types of EMS were collected, but these were classified into 

five: 

1. Sites with no defined EMS approach 

2. Sites with an informal EMS but no third party auditing 

3. Sites that had achieved certification to ISO14001 using an accredited 

76 



certification body 

4. Sites within group (3) that had also taken the steps to reach EMAS but have 

not registered under the scheme 

5. Sites registered under EMAS. 

remas results - link between EMS and performance (based on data from 

320 sites in Europe) 

In summary the project measured the relationship between implementing 

different types of EMS and: 

• 

• 

• 

• 

• 

• 

The change in behaviours at a site, (defined as site environmental 

management activities) 

The impact of these on emission levels, (benchmarked against best 

available techniques) 

Compliance with legislation. 

Behaviours are measured against those expected on a well managed 

site as defined by IMPEL (European network of regulators). Collectively 

these are known as the remas criteria (“those elements of an EMS that 

are considered to be key to improving environmental performance and 

regulation”. 

Improved self knowledge of permit breaches (better detection usually 

means increased numbers of non-compliances) 

Compliance management (better management leads to reduction of 

non-compliance events). 

remas Summary Results 


• There is strong evidence that the adoption of an accredited certified 

EMS improves site environmental management activities. Overall 

environmental management is better under ISO14001 than under an 

informal system; which in turn is better than under no system at all. 

• There is evidence that overall site environmental management is better 

under EMAS than under ISO14001; driven largely by better performance 

in performance monitoring, documentation control and (self) reporting 

of environmental performance. 

• There is some evidence that improved site environmental management 

leads to lower average emission levels. However, the strength of the 

evidence differs significantly between receiving media, regions of Europe 

and sectors. 

• There is strong evidence that improved environmental management 

has an impact on the number of self recorded permit / licence 

breaches. The impact may be observed both as positive (i.e. reducing the 

number), or as negative (i.e. increasing the number), and varies between 

regions and sectors. 

• The mix of positive and negative impacts for the two compliance 

indicators demonstrates that improved site environmental management 

results both in a reduction of the rate at which “non-compliance” 

incidents (such as permit breaches) occur and in an improvement in the 

detection and reporting of incidents when they do occur. 

77


remas conclusion 

The remas project concludes that there is a relationship between EMS’s 

and performance driven through better site management activities. An 

interesting point to note is that the authors assert that high levels of noncompliance 

issues (for instance in respect of emission levels) may not be a 

bad thing, and suggest that “a comparison of whether a site has an EMS and 

whether these result in lower numbers of compliance, is too simplistic”. This 

is explained in terms of the below diagram: 

(remas, 2006) 

This illustrates that higher levels of non-compliance may occur under an 

EMS – not due to slipping management standards, but because of a greater 

awareness of non-compliance. “[O]ne of the better behaviours expected 

on a site is looking for non-compliance events and registering these where 

they occur…Clearly where the better behaviour identifies non-compliance 

events that were previously unknown, this may lead to an increase in the 

number” – this is not necessarily seen as a bad thing since identification of 

non-compliance is necessary in order to correct any issues, and remas seem 

to suggest that the implementation of a robust EMS can greatly contribute to 

a greater extent of self-regulation. 

78 




5.5 Measuring Environmental Performance in Industry (MEPI) 

It should be noted that whilst the MEP1 and subsequent studies carried out 

robust sampling methodologies and statistical analysis, the work related to 

the ‘old EMS standard ISO14001 : 1996’. This predicted the changes made to 

the 2004 standard. Furthermore the dataset is over ten years old and only 

covered two years past adoption of the 1996 standard. If a follow up survey 

was to be carried out, the quality and availability of information may have 

improved significantly, and facilitate the drawing of clear conclusions, as well 

as encompassing the changes made in the way that EMS are implemented 

and certified. 

Funded under the EC’s fourth framework research programme, the 

groundbreaking “measuring environmental performance in industry” (MEPI) 

project was coordinated by the Science Policy Research Unit (SPRU) at the 

University of Sussex (www.sussex.ac.uk). 

In cooperation with six other European research institutes, it set out to 

compare the economic and environmental performance of 280 companies 

and 430 production sites in six industrial sectors - electricity generation, 

pulp and paper, fertilisers, book and magazine printing, textile finishing 

and computer manufacture - across six countries: the UK, the Netherlands, 

Germany, Austria, Belgium and Italy – covering the years 1985, 1990 and 1994 

to 1998. 

A lack of reliable data due to the large proportion of overseas manufacture of 

components forced the re-searchers to drop computer manufacture from the 

results. 

Researchers extracted “technically sound” data from publicly available 

sources and fed these into core economic and environmental indicators for 

each sector and even sub-sector, where there were significant differences in 

the production technology used. 

The MEPI project aimed to answer several questions dogging policymakers, 

including whether several years of EC regulation have succeeded in 

narrowing differences between companies’ performance; whether large firms 

perform better than small ones; whether there is a link between economic 

and environmental performance; and whether environmental management 

systems have improved performance. 

On this last question, the report concludes: “Firms and sites with a certified 

environmental management system [ISO14001 or EMAS] did not appear 

to perform better than those without.” For example, it points out that 

fertiliser manufacturers with certified systems produced higher levels of NOx 

emissions than those without, although their discharges of nitrogen to water 

were lower. For the other four sectors, the researchers could not find any 

statistically significant results to demonstrate improved performance 

(www.endsreport.com). 

79


However, the survey finds as a key conclusion that the level of publicly 

available, robust information was insufficient to enable many conclusions 

to be firmly made, and that the lack of a clear link between companies with 

certified EMS and improved environmental performance could be down to: 

• 

• 

• 

A ‘lag effect’ in which companies with an EMS do not immediately 

experience an environmental performance improvement 

A ‘catching up effect’ in which companies which perceive themselves to 

be poor performers are those that seek to implement a system as a way 

of reaching the best practice frontier 

The requirement for ‘continuous improvement’ is interpreted weakly by 

verification agencies 

Additional research 

In a follow up research study published in March 2008 using the MEPI 

dataset, the authors (Hertin et al, 2008) found that while it is “not appropriate 

to conclude either that EMS are ineffective or that policy support for 

EMS should be withdrawn. Any conclusion about the link between EMS 

and environmental performance is necessarily preliminary…moreover 

EMS may have other benefits…regulatory certainty, internal or external 

communication or awareness raising that may justify policies encouraging 

their diffusion” Though, they further add “the weak link between EMS and 

performance is a matter of concern if EMS are envisaged as serving as a 

substitute for other policy instruments…it could be argued that there is 

currently no evidence to suggest that EMS have a consistent and significant 

positive impact on environmental performance. 

5.6 ISO 14001 – Experiences, Effects and Future Challenges: a 

National Study in Austria 

This study undertaken by Schylander and Martinuzzi sought to explore the 

perspectives of Austrian ISO 14001 organisations. It was identified that there 

were 501 ISO 14001 certified sites, with 297 environmental mangers (due 

to multiple site certifications). All were contacted, and 71 responses to the 

questionnaire were received. While the survey looked at issues including 

future tools to assess environmental performance, and the role of integrating 

management systems, it also considered the questions of legal compliance 

and environmental performance improvement. Using a Likert Scale, the 

organisations were asked “how important 10 different motives were for 

deciding to implement ISO 14001 …[and]…how well these expectations 

were fulfilled” (Schylander and Martinuzzi, 2007). 

Results of the survey are demonstrated in the below table, “where the 

left y-axis shows the differences between expected benefits and received 

benefits in order to investigate the ‘degree of happiness or frustration’ related 

to each motive; the values are expressed in terms of number of organisations. 

The right y-axis shows the averages of how the organisations assessed their 

expectations (4 = very high expectation) and perceived benefits (4 = very 

high benefits).” (Schylander and Martinuzzi, 2007) 

80 



Expectations and Perceived Benefits of ISO 14001 (Schylander and Martinuzzi, 2007) 

“The expectations regarding ensuring legal compliance…seemed to be 

fulfilled by the implementation, [as did] improvements in environmental 

performance, a systemization of environmental activities, and risk 

minimization” (Schylander and Martinuzzi, 2007). The survey also found 

that the largest environmental improvements were made within waste and 

recycling, and that “in-depth analyses show a high correlation between 

the awareness of environmental issues and improvements in energy 

consumption, waste and recycling” (Schylander and Martinuzzi, 2007). 

5.7 USA National Database 


A national database on environmental management systems (NDEMS) 

has been set up with the aim of determining whether an EMS delivers 

environmental performance improvements (www.ndems.cas.unc.edu). 

The project is funded by the Environmental Protection Agency and a 

consortium of state governments interested in using ISO14001 and other 

systems to further their policy goals. Their primary purpose was to answer 

the question “What effects does the implementation of an EMS have on a 

facility’s environmental performance, regulatory compliance and economic 

performance?” 

So far, it has collected comprehensive baseline data on 50 public and private 

facilities, which describe their structure, past environmental performance, 

compliance history, and extent of public “outreach” efforts and the nature of 

the management system being used but no conclusive recommendations 

have been reached as the study is currently ongoing. 

81


5.8 Urban Government review of the use of EMS (Japan) 

(www.gdrc.org) 

Many cities in Japan are turning to the approach of developing an EMS 

with the goal of attaining certification to ISO14001. The establishment 

of an EMS is seen as a tool for creating the structures to integrate 

changed responsibilities for the urban government to plan and allocate 

the resources to implement and deliver services so that they address 

community priorities. The development of an EMS provides a number of 

general benefits. It creates structured management systems, from which 

a cycle of continuous improvement can be established. It brings the many 

environmental issues of concern expressed by the community into daytoday 

operations and development of long term work plans and programs 

of the urban government. It also improves the understanding amongst an 

urban government’s personnel of where operations interact with the natural 

environment and the role that various groups play in the delivery of urban 

services. 

The Japan studies have concluded that there are several internal and 

external benefits for urban governments if they seek ISO certification. While 

internal benefits ensure wider and deeper participation on the part of an 

urban government’s employees, it is the external benefits that form the key 

justification for an urban government seeking to obtain ISO certification. The 

view from Japan report states the external benefits of ISO certification as: 

• 

• 

• 

82 

With growing prioritization of the global and local environment, ISO 

14001 acquisition demonstrates a city’s ‘green face’ to its citizens and also 

helps in emphasizing the need for greater environmental action on the 

part of urban stakeholders at the local level. 

A city’s acquisition of ISO certification helps in serving as a model for 

other urban and regional governments to emulate and replicate. An 

urban government that has obtained ISO certification can, from a 

position of strength, promote replication of acquiring ISO Certification 

from other stakeholders in the city, particularly private sector businesses 

and industry, where a properly and 

strategically implemented EMS can have far-reaching and long-term 

impacts. It emphasizes the concept, ‘environmental-action-starts-athome’, 

where local and immediate actions at the grassroots have longterm 

global implications.” 



6.0 Conclusions 

The project as commissioned by the NI Environment Agency aims to address 

two key questions relating to the role of EMS and to guide future strategies 

in Northern Ireland as to whether a more risk-based policy of environmental 

regulation could be adopted. Generated by the needs of the “Better 

Regulation” programme this desktop review of existing studies forms one 

part of a process to address the questions of: 

• 

• 


How effective is an EMS in contributing to improvements in an 

organisations environmental performance; and 

How effective is an EMS as a measure of legal compliance. 

This desktop study has considered the history of environmental management 

systems, along with the most commonly implemented systems. Reviewing 

the different types of standards which are most prevalent: from what is seen 

as perhaps the most stringent, though Euro-centric (EMAS), to the most 

widely adopted standard internationally (ISO 14001:2004) through to those 

systems such as BS8555 and “Green Dragon” which implement EMS through 

staged approaches and are perhaps more suited to SMEs. 

The certification process for each of these types of EMS has also been 

considered, to ascertain how robust in nature certifications are. This 

evaluation found that while EMAS certifications undergo a more thorough 

process culminating in the production of a public statement and comments 

on the degree to which objectives and targets have been met, this may 

not be appropriate for all organisations due to the time and therefore cost 

implications that may occur. For most, ISO 14001:2004 is seen as sufficient to 

ensure a high level of environmental management, and in fact, the standard 

has become incorporated within EMAS to facilitate those companies that 

wish to be accredited to the EU approved scheme doing so. BS8555 is the 

most recent of the three standards and has been specifically designed 

with SMEs in mind. The staged approach to implementation provides a 

more obviously structured method of managing environmental impacts 

and also enables recognition of progress at each stage, which means the 

organisations which implement it, can do so to the level of their own 

requirement. Similar to Green Dragon in many ways, it differs in that it 

is audited by an accredited certification body sanctioned, and therefore 

endorsed, by UKAS. 

The accreditation process is also considered since while informal EMS are 

often encouraged, it is the view of DEFRA among others, that an EMS is 

demonstrated to be sufficiently robust if certified by a body accredited by 

UKAS. This allows for a greater degree of quality assurance and trust to be 

placed on an EMS since the certification body which awards the certificate, 

must also conform to an international standard (ISO 17021:2006). 

The current situation regarding the uptake of management systems on 

a worldwide and local scale has also been addressed through this desk 

study, along with the drivers to the implementation of an EMS. The UK 

has the third highest uptake of ISO 14001 in Europe (2006) with Spain and 

Italy ahead however, levels of uptake remained constant over the 2005 / 

06 period in comparison to high levels of growth over the same period in 

both Spain and Italy. Levels of uptake of EMAS in the UK are significantly 

83


lower than ISO 14001 (380 against 6000) with the UK coming 4th in the 

uptake tables behind Germany, Italy, Spain and Austria. There have been 

a number of local, Northern Ireland initiatives and programmes regarding 

environmental management systems over the last decade however, there 

is limited evaluation of data and no collation of overall statistics relating 

to improvements or compliance assistance. Northern Ireland businesses 

have been involved in some EMS key projects over the last 5 years including 

the introduction of BS8555 to Northern Ireland (Invest NI’s Building Blocks 

programme) and STEM, the expansion of BS8555 to business and local 

authorities in the border council areas. 

The Environment Agency in England and Wales has already asserted the view 

that effective environmental management systems aid risk management in 

permitting and have developed the Opra methodology for this purpose. 

In tandem with this EMS Evaluation research, the SNIFFER project has looked 

at how best regulatory bodies should target their resources in the future, 

finding that SMEs would be less able to respond to reflexive law instruments. 

This has been borne out through the work of the STEM project indicating 

significant ‘drop out’ rates when consultancy support is withdrawn from the 

SME companies. 

There have been a range of international and national independent studies 

into Environmental Management Systems and a number of key studies 

have been included within this desk top research. This review established 

to what extent the questions relating to performance improvements and 

legislative compliance have been addressed, and a summary of the findings. 

A summary table of the findings has been produced below which aims to 

address how they dealt with the two key questions under consideration. 

84 

Indicative of neutral role of EMS 

Indicative of positive role of EMS 

Indicative of negative role of EMS 



Indicative 

of improved 


Performance? 

Sufficient Coverage 

of environmental 

performance? 

Indicative 

of Legal 

Compliance? 

Survey Summary of Main Findings Sufficient 

Coverage 


Compliance? 

x 

Ever - EMAS The survey found that EMAS has a positive effect on environmental 

performance, and that for those that have adopted it, it is seen 

as a useful tool, however, it “is not one of the most important 

determinants of environmental performance and it appears not to 

be a strong autonomous driver for improvement”. 

remas The remas project concludes that there is a relationship between 

EMS’s and performance driven through better site management 

activities. An interesting point to note is that the authors assert 

that high levels of non-compliance issues (for instance in respect 

of emission levels) may not be a bad thing, and suggest that “a 

comparison of whether a site has an EMS and whether these result 

in lower numbers of compliance, is too simplistic”. 

While it is “not appropriate to conclude either that EMS are 

ineffective or that policy support for EMS should be withdrawn. 

Any conclusion about the link between EMS and environmental 

performance is necessarily preliminary…moreover EMS may 

have other benefits…regulatory certainty, internal or external 

communication or awareness raising that may justify policies 

encouraging their diffusion” Though, “it could be argued that there 

is currently no evidence to suggest that EMS have a consistent and 

MEPI and follow 

up study 

x 

significant positive impact on environmental performance.” 


“The expectations regarding ensuring legal compliance…seemed 

to be fulfilled by the implementation, [as did] improvements in 

environmental performance, a systemization of environmental 

activities, and risk minimization” (Schylander and Martinuzzi, 2007). 

The survey also found that the largest environmental improvements 

were made within waste and recycling, and that “in-depth analyses 

show a high correlation between the awareness of environmental 

issues and improvements in energy consumption, waste and 

ISO 14001 – 

Experiences, 

Effects 

and Future 

Challenges: a 

National Study 

in Austria 

recycling” (Schylander and Martinuzzi, 2007). 

Among SMEs there is a gap in understanding regarding the 

environmental impact of activities - principally due to the low 

SME-nvironment 

Survey 2007 

uptake of EMS among SMEs 

Sites with a certified EMS have higher levels of operator 

performance than those without, with EMAS registered sites outperforming 

those with ISO 14001. However, they “do not have a 

lower likelihood, as assessed by enforcement officers, of suffering 

from incidents, complaints and non-compliance events”. 

EMS and 

Company 

Performance 

International Findings National Findings 

85


Indicative 

of improved 


Performance? 

Sufficient Coverage 

of environmental 

performance? 

Indicative 


Compliance? 

Survey Summary of Main Findings Sufficient 

Coverage 


86 

Compliance? 

x 

x 

STEM The STEM project demonstrates that there is demand among NI 

Businesses for support in the implementation of EMS – and that 

the reasons for participation range from desire for improvements 

in environmental performance through to legal compliance 

and customer demand. Though the high drop out rates could 

undermine the effectiveness with regards to the benefits realised by 

businesses 

BITES All 6 companies involved reported and demonstrated 

improvements in environmental performance and legal compliance 

issues - principally in the areas of waste management. Thereby 

securing annual cost savings and reduced resource use. 

EASS Analysis of the scheme revealed two prevalent themes, both in 

terms of reasons for undertaking the audits, and in benefits derived 

- these related to improving legal compliance and cost savings 

through improved efficiencies. 

Building Blocks 100% of those that took part in the “Building Blocks” Programme felt 

they had improved liability control and 80% felt they had improved 

their environmental performance through the implementation of 

BS8555. 

Arena Survey There is no data relating to comparison in performance between 

the 49% of organisations with certified EMS compared to the51% 

without. This means that the Survey contributes little to the debate 

regarding the effectiveness of an EMS in addressing the questions of 

performance and compliance. 

The research summary indicates that in general, environmental management systems do provide environmental improvements (7 of the 11 no. research 

papers). Overall, the research is inconclusive regarding an EMS’s ability to provide improvements in legislative compliance with 4 of the 11 no. research 

papers highlighting this, however 3 of the papers did not include compliance within the evaluation criteria. Interestingly, 3 of the 4 local (Northern Ireland) 

studies suggest that an EMS has both a positive impact on environmental improvements and compliance with environmental legislation. 



7.0 Recommendations 


It is not been possible to fully ascertain the effectiveness in EMS in delivering 

environmental improvements and compliance with environmental legislation 

within a local context (Northern Ireland. A gap in the data is evident, since 

the Northern Ireland studies include figures that are very project specific, 

and tend towards being anecdotal evaluations. To date, there has not been a 

Northern Ireland wide survey or statistical analysis of data relating to EMS. In 

addition, the SME-nvironment Survey that was carried out sheds some light 

on the uptake of EMS in Northern Ireland, suggesting it to be around 15% of 

SMEs, but it also exposed huge areas of misunderstanding and knowledge 

gaps among SMEs regarding the environmental legislation relevant to them, 

and the impacts their activities can have on the environment. This is the 

only instance where some analysis was conducted comparing organisations 

with an EMS against those without, but this was done at a cursory level, and 

merely differentiated those who were deemed to be actively involved in 

addressing issues i.e. those which “have an EMS are planning to introduce 

one, have an environmental policy or have introduced a practical measure 

to address environmental harm” (SME-nvironment 2007) from those which 

had none of the above. It will therefore be necessary to carry out an in depth 

analysis of organisations within NI to enable a comparison of organisations 

with an EMS (of any type, formal or informal) to be compared to those with 

no EMS against environmental or compliance improvements. 

Further research has been commissioned alongside this desk top review to 

provide some additional verification and detail relating to EMS, compliance 

and environmental improvements in Northern Ireland business and public 

sector organisations. The basis of this research has been questionnaire survey 

of 1000 organisations in Northern Ireland, with statistical analysis of the 

results of the survey. In addition, it has become apparent that there is a need 

for validation of this research against factual statistics held by the Agency 

and also by the certification bodies operating in Northern Ireland. This data 

has been requested for use in the final report. 

NB. The results of this research and data analysis will be published under 

separate cover as part of this project, for NIEA. 

87


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New British Standard (BS 8555) and phased implementation of environmental management 

http://www.theacorntrust.org 

Arnold, R., and Whitford, A., (2006) 

Making Environmental Self-Regulation Mandatory in Global Environmental Politics 6:4, November 2006 

Bansal, P and C Bogner (2002): 

Deciding on ISO 14001: Economics, Institutions, and Context, Long Range Planning 

Business in the Community (2006): 

Environmental Index 2006 Report 

ww.bitc.org.uk 

Business in the Community (2006): 

Coleraine Green Dragon: Case Studies in Environmental Management 

www.colerainebc.gov.uk 

BS8555:2003: 

Environmental Management Systems Fact Sheet 4 www.pasa.nhs.uk/pasaweb/nhsprocurement/ 

sustainabledevelopment/environment/iso14001ems/BS85552003.htm 

British Standard (2003) 

BS 8555:2003, Environmental Management Systems – Guide to the phased implementation of an environmental 

management system including the use of environmental performance evaluation 

British Standard (2004) 

BS EN ISO 14001:2004 : Environmental Management Systems – Requirements with Guidance for Use 

British Standard (2006): 

BS EN ISO/IEC 17021:2006: Conformity assessment – Requirements for bodies providing audit and certification of 

management systems 

Dahlström, K., Howes, C., Leinster, P., and Skea, J.,(2003): 

Environmental Management Systems and Company Performance: Assessing the case for extending risk-based regulation; 

in Eur. Env. 13, 187–203 (2003) 

Department for Environment, Food and Rural Affairs (DEFRA) (2003): 

An Introductory Guide to EMAS: The Pinnacle of Environmental Management 

www.defra.gov.uk 

Department for Environment, Food and Rural Affairs (DEFRA) (2008): 

DEFRA Position Statement on Environmental Management Systems 

www.defra.gov.uk 

Delmas, Magali, A. (2002): 

Journal Article, Policy Scenes. Volume 35, Number 1, March 2002 

www.springerlink.com 

Eco-Mapping: 

http://www.ecomapping.com 

88 



Elliott, C (2001): 

A WWF perspective on ISO 14001 (ISO Management Systems) 

ENDS Report 347 (2003): 

EMS survey reveals widespread concerns over certification 

www.endsreport.com 


EMS credibility is at the ‘crossroads’ 



EMS auditors face increased scrutiny 


Envirocentre: 

www.envirocentre.ie 

Environment Agency (2008): 

Environmental Permitting Regulations Operational Risk Appraisal (Opra for EPR) 

www.environment-agency.gov.uk 

Environment Agency (2007): 

Analysis of final REMAS project datasheet 

www.remas.info 

Europa: 

http://europa.eu/ 

European co-operation for Accreditation (2007) 

EA-7/04 Legal Compliance as a part of Accredited ISO 14001:2004 certification 

www.ukas.com 

EVER (2005) 

Evaluation of EMAS and Eco-Label for their Revision, 

http://ec.europa.eu/environment/emas/index_en.htm 

Fresner, J (2004): 

Small and medium enterprises and experiences with environmental management 

Journal of Cleaner Production, 12(6), pages 545-547. 

Green Dragon: 

www.greendragonems.com 

Gunningham, N (2002) 

Regulating Small and Medium Sized Enterprises 

Journal of Environmental Law, 14(1), pages 3-32. 


Hertin, J., Berkhout, F., Wagner, M., and Tyteca, D., (2008): 

Are EMS environmentally effective? The link between environmental management systems and environmental 

performance in European companies; in, Journal of Environmental Planning and Management, 51:2 259-283 

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Hillary, R (2004): 

Environmental management systems and the smaller enterprise 

Journal of Cleaner Production, 12(6), pages 561-569. 

Hillary, R (1999): 

Evaluation of study reports on the barriers, opportunities and drivers for small and medium sized enterprises in the 

adoption of environmental management systems 

(Network for Environmental Management and Auditing. Paper submitted to UK Government. Department of Trade 

and Industry: Environment Directorate (5/10/99). London) 

Institute of Environmental Management and Assessment: 

www.iema.net/acorn. 

IEMA Practitioner, Vol 6, (2005): 

Managing compliance with environmental law: a good practice guide 

www.iema.org 

LRQA (2004): 

How can EMAS benefit my organization 

http://www.lrqa.co.uk 

LRQA (2005): 

IEMA Acorn Scheme 

http://www.lrqa.co.uk 

Marks and Spencer (2008) 

How we do Business Report 2008 

corporate.marksandspencer.com 

National Database on Environmental Management Systems and University of North Carolina at Chapel Hill (2003): 

Environmental Management Systems: Do they improve environmental performance. 

http://ndems.cas.unc.edu 

National Standards Authority of Ireland: 

www.nsai.ie. 

Northern Ireland Environment Agency (2008): 

EHS Better Regulation Programme: Better Regulation for a Better Environment 


NetRegs: 

www.netregs.gov.uk 

Office of Government Commerce (2005): 

Achieving Excellence in Construction, Procurement Guide 11 Sustainability 

www.ogc.gov.uk 

Roberts, H., and Robinson, G. (1998): 

ISO 14001 EMS Implementation Handbook 

Russomanno, G (2004): 

EMAS: SME’s specific barriers and needs 

90 



Schylander, E., and Martinuzzi, A., (2007): 

ISO 14001 – Experiences, Effects and Future Challenges: a national study in Austria. In; 

Business Strategy and the Environment 16, 113-147 

Schaltegger, S., Burritt, R., and Petersen, H., (2003): 

An Introduction to Corporate Environmental Management:- Striving for sustainability. 

Science and Technology Policy Research – University of Sussex (2000) 

Measuring Environmental Performance of Industry (MEPI) 

www.sussex.ac.uk 

Scotland and Northern Ireland Forum For Environmental Research (SNIFFER) (2009) 

UKCC20 - Targeted Risk Based Approaches to Compliance Assessment 

www.sniffer.org.uk 

Sheldon, C (2003): 

The Acorn Trust and BS8555 

http://www.groundwork.org.uk 

Sustainable Development Strategy for Northern Ireland (2006): 

First Steps Towards Sustainability 

www.ofmdfmni.gov.uk 

Starkey, R (1998): 

The Standardization of Environmental Management Systems: ISO 14001, ISO14004 and EMAS, in Corporate Environmental 

Management 1: Systems and Strategies 

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www.ukas.com 

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Cities, Environmental Management Systems and ISO 14001: A View from Japan 

http://www.gdrc.org 


Walley, L (2000): 

The environmental champion: making a start. Westfield: an SME success story in Small and Medium-Sized Enterprises and 

the Environment 

91


APPENDIX ONE : Chapter 1 : NI Sustainability Strategy Targets 

Chapter 1 – Sustainable Consumption and Production 

Strategic Objectives Key Targets Important Steps 

To become more 

resource efficient 

To make the Northern 

Ireland public sector 

a UK regional leader 

in sustainable 

procurement 

To minimise the 

unsustainable 

impacts of 

consumption 

92 

Northern Ireland 

economy will achieve 

85% resource 

efficiency by 2025 

Stabilise Northern 

Ireland ecological 

footprint by 2015 and 

reduce it thereafter 

By 2008 ensure that 

all public sector 

procurement is 

channelled through 

recognised Centres of 

Procurement Expertise 

(COPEs) 

By 2008 ensure that 

SD principles guide 

capital investment 

decisions on all 

major publicly 

funded building and 

infrastructure projects 

By 2008 produce 

a Sustainable 

Procurement Action 

Plan for Northern 

Ireland 

By 2008 produce 

Sustainable 

Consumption Action 

Plan for Northern 

Ireland 

By 2008 put in place 

measures which 

optimize the flexibility 

of retained and 

refurbished buildings 

Progressive reduction of quantities of biodegradable waste going to landfill 

and reduction of waste in general across all sectors 

Encourage and incentivise the business case for resource efficiency and waste 

minimization 

Promote materials recovery, re-use, and recycling through initiatives such as 

the Waste and Resources Action Plan (WRAP) 

Progressive reduction in leakage of mains water 

Develop training and guidance on sustainable procurement for all public 

sector purchasing officers 

Embed whole life costing into procurement decisions and policy 

Underpin the Investment Strategy for Northern Ireland with excellence in 

construction programmes that integrate SD principles 

Ensure that public sector housing and public properties are constructed or 

refurbished to maximise sustainability and flexibility of use 

Consider how the recommendations from Sustainable Procurement Task 

Force can be applied to Northern Ireland with particular reference to access 

for Small Medium Enterprises and Social Economy Enterprises 

Promote market Transformation initiatives and the work of WRAP 

Work with the Food Standards Agency and other partners to promote more 

sustainable food procurement in the public sector 

Consider how the recommendations from the Sustainable Consumption 

Roundtable can be applied to Northern Ireland 

Make it easier for consumers to make more reasonable, less damaging 

choices 

Implement Workplace 2010 on the Government estate 

SD action plans for each Government department 

Reduce demand for potable water 


Press for amendments to VAT rates for new versus refurbished buildings and 

support amendments to planning and building regulations


APPENDIX TWO : Chapter 6 : NI Sustainability Strategy Targets 

Chapter 6 : Governance and Sustainable Development 

Strategic Objectives Key Targets Important Steps 

To mainstream sustainable 

development across 

government 

Strengthen the network of 

accountability for governance 

for sustainable development 

By 2007 introduce a statutory duty on 

relevant public bodies to contribute to the 

achievement of sustainable development 

By 2007 ensure that all policy development 

actively considers sustainable development 

By 2007 link sustainable development 

objectives to the Priorities and Budgets and 

Comprehensive Spending Review Processes 

By 2007 ensure all Departments have a 

sustainable development Action Plan in place 

By 2009 ensure that community planning is 

implanted within the revised local authority 

By 2008 strengthen and modernise 

environmental regulation 

By 2006 finalise appropriate monitoring 

and reporting arrangements for 

sustainable development and establish an 

implementation role for the Ministerial – Led 

Group 

Agree the role of a sustainable development 

Forum by 2006 

Agree the way forward on the review of 

environmental governance in respect of 

sustainable development by summer 2007 

By 2009 build capacity to enable meaningful 

civic participation and identify participatory 

mechanism for decision making 


Embed sustainable development principles 

into the governance arrangements of new 

councils 

Develop a revised sustainable development 

input to OFMDFM Practical Guide to 

Policymaking 

Deliver a training programme focusing on 

sustainable development knowledge and 

skills across the NICS 

By 2007 develop and pilot the use of and 

Integrated Impact Assessment for use by all 

Government Departments 

By 2007 have in place a system of information 

provision, support and guidance on 

sustainable development for those involved 

in policy and decision-making 

By 2006 ensure that the principles and 

objectives of sustainable development have 

been incorporated into the Regional 

Development Strategy and planning 

legislation 

Determine how best to develop an 

appropriate audit/scrutiny role to ensure 

implementation of the objectives of the 

strategy 

Determine how best to utilise the role of the 

Sustainable Development Commission in 

Northern Ireland 

Ensure planning legislation and Planning 

Policy Statements are updated to reflect 

sustainable development principles and 

provide guidance on key areas 

Consider the outcomes of the review of 

environmental governance in respect of 

sustainable development by 2007 

93


APPENDIX THREE : Implementation of EMAS outside EU (List of Figures) 

Appendix 4 Implementation of EMAS outside the EU 

94 



APPENDIX FOUR: PPC Permits Northern Ireland 

Northern Irish PPC Permits – Determined and Pending 

PPC No. Site Operator Name Council Area Determined/Pending 

0143/01A Du Pont ( UK ) Ltd Derry CC Determined 

0163/01A Queen’s Isand Belfast CC Determined 

P0043/04A North West Galvanising 

Ltd. 

Derry CC Determined 

P0044/04A Drumee Landfill Site Fermanagh DC Determined 

P0046/04A NK Coatings Ltd Newtownabbey BC Determined 

P0050/04A Silverwood Enterprise Ltd. Craigavon BC Determined 

P0051/04A Ultra Building Products Ltd Strabane DC Determined 

P0052/04A Lafarge Cement (Ireland) 

Ltd 

Cookstown DC Determined 

P0053/04A Quinn Glass Ltd Fermanagh DC Determined 

P0054/04A Gortmullan Cement Works Fermanagh DC Determined 

P0055/04A Calcast Ltd Derry CC Determined 

P0056/04A Montupet ( UK ) Ltd Lisburn BC Determined 

P0057/04A Michelin Tyre PLC Ballymena BC Determined 

P0058/04A Ryobi Aluminium Castings 

(UK) Ltd 

Carrickfergus BC Determined 

P0059/04A Sperrin Galvanisers Ltd. Magherafelt DC Determined 

P0060/04A Tyrone Brick Ltd Dungannon DC Determined 

P0061/04A Huhtamaki (Lurgan) Ltd. Craigavon BC Determined 

P0062/04A Kiel Pharma Ltd. Carrickfergus BC Determined 

P0063/04A S & B Production Limited Newtownabbey BC Determined 

P0064/05A Police Service of Northern 

Ireland 


Carrickfergus BC Determined 

P0065/05A Lisburn Proteins Lisburn BC Determined 

95


P0066/05A Ulster Farm By-Products Lisburn BC Determined 

P0067/05A Grampian Country Pork Ltd Cookstown DC Determined 

P0068/05A Omagh Meats Omagh DC Determined 

P0069/05A WD Meats Coleraine BC Determined 

P0071/05A O’Kane Poultry Ltd. Ballymena BC Determined 

P0072/05A Dunbia Dungannon DC Determined 

P0074/05A Stevenson and Company Ballymena BC Determined 

P0075/05A Foyle Meats/Proteins Derry CC Determined 

P0076/05A Linden Foods Ltd. Dungannon DC Determined 

P0077/05A Langford Processors Ltd. Antrim BC Determined 

P0078/05A ABP Lurgan Craigavon BC Determined 

P0079/05A ABP Newry Newry & Mourne DC Determined 

P0080/05A Moy Park Ltd. Dungannon DC Determined 

P0081/05A Belfast Sewage Sludge 

Incinerator Facility 

P0084/05A The Royal Group of 

Hospitals 

Belfast CC Determined 


P0086/05A Linergy Ltd Dungannon DC Determined 

P0087/05A Craigmore Landfill Site Coleraine BC Determined 

P0089/05A Dairy Produce Packers Ltd Coleraine BC Determined 

P0090/05A Cottonmount Landfill Newtownabbey BC Determined 

P0091/05A Glanbia Cheese Ltd Craigavon BC Determined 

P0092/05A Dale Farm Ltd (Dromona) Ballymena BC Determined 

P0093/05A Dale Farm Ltd 

(Pennybridge) 

P0094/05A Dale Farm Ltd 

(Dunmanbridge) 

Ballymena BC Determined 

Cookstown DC Determined 

P0095/05A TMC Dairies (NI) Ltd Strabane DC Determined 

96 



P0096/05A Armaghdown Creameries 

Ltd 

Banbridge DC Determined 

P0097/05A Scotts Feeds Ltd Omagh DC Determined 

P0098/05A Diageo Global Supply IBC 

Group 

Castlereagh CC Determined 

P0099/05A ABN Knockmore Lisburn BC Determined 

P0100/05A John Thompson and Sons 

Ltd 


P0101/05A G.E. McLarnon & Sons Ltd Antrim BC Determined 

P0102/05A United Feeds Limited Belfast CC Determined 

P0103/05A Moy Park Ltd Craigavon BC Determined 

P0104/05A Ballyrashane Co-op Coleraine BC Determined 

P0105/05A Coca Cola Bottlers (Ulster) 

Ltd 

P0107/05A Whitemountain Quarries 

Ltd 

Lisburn BC Determined 

Lisburn BC Determined 

P0108/05A ENVA (NI) Ltd Castlereagh CC Determined 

P0109/06A Biofuels Carryduff Castlereagh CC Determined 

P0110/06A Aughrim Landfill Ltd Lisburn BC Determined 

P0118/06A 3M (UK) PLC North Down Determined 

P0119/06A Almac Sciences Craigavon BC Determined 

P0120/06A Kilroot Power Ltd Carrickfergus BC Determined 

P0121/06A Ulster Carpet Mills Ltd Craigavon BC Determined 

P0123/06A Polypipe (Ulster) Ltd Craigavon BC Determined 

P0124/06A Tennants Textile Colours 

Limited 


P0125/06A Premier Power Ltd Larne BC Determined 

P0126/06A Coolkeeragh ESB Ltd. Derry CC Determined 

P0127/06A Langford Lodge 

Engineering 


Antrim BC Determined 

97


P0128/06A Clinty Chemicals Ltd Ballymena BC Determined 

P0129/06A Invista Textiles (UK) Limited Derry CC Determined 

P0130/06A Ulster Industrial Explosives Carrickfergus BC Determined 

P0131/06A Balcas Timber Ltd Fermanagh DC Determined 

P0132/06A Norbrook Laboratories Ltd Newry & Mourne DC Determined 

P0133/06A Norbrook Laboratories Ltd Newry & Mourne DC Determined 

P0134/06A Shorts Brothers PLC 

(Newtownards) 

Ards BC Determined 

P0135/06A Short Brothers PLC (Belfast) Belfast CC Determined 

P0137/06A Bio Fue Moyle BC Determined 

P0138/06A Spanboard Products Ltd Coleraine BC Determined 

P0139/06A Clinty Regen Ltd Belfast CC Determined 

P0140/06A Dalkia Utilities Service Plc Belfast CC Determined 

P0148/06A Craigahullier Landfill Site Coleraine BC Determined 

P0167/07A Antrim Area Hospital Antrim BC Determined 

P0001/03A Harland and Wolff Heavy 

Industries Ltd 

Belfast CC Pending 

P0082/05A P Clarke & Sons Ltd Fermanagh DC Pending 

P0143/06A Magheraglass Landfill Site Cookstown DC Pending 

P0145/06A Lisbane Landfill Site Armagh City & DC Pending 

P0151/06A Sales Corner Landfill Site Lisburn BC Pending 

P0152/06A Aughnagun Landfill Site Newry & Mourne DC Pending 

P0153/06A Ballymacombs Landfill Site Magherafelt DC Pending 

P0154/06A Drumanakelly Landfill Site Down DC Pending 

P0155/06A Kilroot Landfill Site Carrickfergus BC Pending 

P0156/06A Ballyduff Landfill Site Newtownabbey BC Pending 

P0158/07A The Old Mill - Drumaness Down DC Pending 

P0160/07A Clooney Road Landfill Site Derry CC Pending 

98 



P0161/07A Duncrue Street Belfast CC Pending 

P0162/07A Colinglen Road - Belfast Lisburn BC Pending 

P0178/07A 33 Greenogue Road Banbridge DC Pending 

P0179/07A Killough Road Industrial 

Estate 

Down DC Pending 

P0184/07A Tullyvar Landfill Site Dungannon DC Pending 

P0186/07A Duncrue Street - Belfast Belfast CC Pending 

P0187/07A Caulside Drive Antrim BC Pending 

P0235/07A Blue Circle Industries PLC 

t/a Lafarge Cement 

P0236/07A Ballyhome Road Landfill 

Site 

Cookstown DC Pending 

Coleraine BC Pending 

P0237/07A McParlands Landfill Newry & Mourne DC Pending 

P0238/07A Dunmurry WWTW Lisburn BC Pending 

P0239/07A Newtownbreda WWTW Belfast CC Pending 

P0240/07A Enniskillen WWTW Fermanagh DC Pending 

P0242/07A New Holland WWTW Lisburn BC Pending 

P0244/07A Omagh Sludge Treatment 

Plant 

P0245/07A Dupont Maydown Works 

Landfill Installation 

Omagh DC Pending 

Derry CC Pending 

P0246/07A Colinglen Road Landfill Lisburn BC Pending 

P0247/07A Rumbling Hole Landfill Site Lisburn BC Pending 

P0248/07A Ballynacor Sludge 

Dewatering Centre 

Craigavon BC Pending 

P0257/07A Mr D Robinson Derry CC Pending 

P0259/07A Blackmountain Phrase II/III 

Landfill Site 


Lisburn BC Pending 

P0260/07A Eastwood Envirowaste Belfast CC Pending 

P0277/07A Michael McAlary Strabane DC Pending 

99


P0278/07A Michael McAlary Derry CC Pending 

P0281/07A Ever Green Energy Biofuel Belfast CC Pending 

P0287/08A Coca Cola Bottlers (Ulster) 

Limited 

P0288/08A AES Kilroot Generating 

Limited 

P0289/08B Murphy’s Construction 

Materials Ltd. 

P0290/08B Whitemountain Quarries 

Ltd 


Carrickfergus BC Pending 

Limavady DC Pending 

N/A (Mobile) Pending 

PPC0002/08B Belfast Terminal Belfast CC Pending 

PPC0006/08B NuStar Terminals Limited Belfast CC Pending 

PPC0012/08B Calor Gas Northern Ireland 

Ltd 


PPC0013/08B M.P. Coleman Ltd. Cookstown DC Pending 

PPC0014/08B Lisbane Quarry Craigavon BC Pending 

PPC0014/08B Lisbane Quarry Craigavon BC Pending 

PPC0016/08B J Robinson & Sons Ltd Ballymena BC Pending 

PPC0017/08B Sounding Hill Quarry Magherafelt DC Pending 

PPC0018/08B Grange Limestone Mills Armagh City & DC Pending 

PPC0019/08B Charles Tennant & Co (NI) 

Ltd 


PPC0020/08B Cashel Quarry Castlereagh CC Pending 

PPC0021/08B Kilwaughter Chemical 

Company Ltd 

Larne BC Pending 

PPC0022/08B R J Mitten & Sons Fermanagh DC Pending 

PPC0023/08B R J Mitten & Sons Fermanagh DC Pending 

PPC0024/08B W & J Chambers Ltd Derry CC Pending 

PPC0025/08B James Stevenson (Quarries) 

Ltd 

PPC0026/08B Coote’s (Concrete 

Products) Ltd 

100 

Ballymena BC Pending 

Armagh City & DC Pending 



PPC0027/08B Northstone (NI) Ltd - 

Concrete Division 





Down DC Pending 

Banbridge DC Pending 

Castlereagh CC Pending 

PPC0031/08B Northstone (NI) Ltd Ballymena BC Pending 

PPC0032/08B Northstone (NI) Ltd Omagh DC Pending 

PPC0033/08B Northstone (NI) Ltd Coleraine BC Pending 

PPC0034/08B Northstone (NI) Ltd Cookstown DC Pending 

PPC0035/08B Northstone (NI) Ltd Magherafelt DC Pending 

PPC0036/08B Northstone (NI) Ltd Omagh DC Pending 

PPC0038/08B Northstone (NI) Ltd Ards BC Pending 

PPC0039/08B W J McCormick & Sons Ltd Down DC Pending 



Ballymena BC Pending 

PPC0041/08B Knockloughrim Quarry Magherafelt DC Pending 

PPC0042/08B Craigantlet Quarry North Down Pending 

PPC0043/08B Aughrim Quarry Lisburn BC Pending 

PPC0044/08B Clinty Quarry Ballymena BC Pending 

PPC0045/08B Glassdrummond Quarry Down DC Pending 

PPC0046/08B Mallusk Coating Plant Newtownabbey BC Pending 



Newtownabbey BC Pending 

PPC0048/08B Edentrillick Quarries Ltd Banbridge DC Pending 

PPC0049/08B Legavannon Quarry Limavady DC Pending 

PPC0050/08B Kennedy Concrete 

Products Ltd 



PPC0051/08B Budore Quarries Lisburn BC Pending 

PPC0052/08B Barrack Hill Quarries Ltd Dungannon DC Pending 

101


PPC0053/08B B McCaffrey & Sons Ltd Fermanagh DC Pending 

PPC0054/08B Craigall Quarry Coleraine BC Pending 

PPC0054/08B Craigall Quarry Coleraine BC Pending 

PPC0055/08B B Mullan & Sons 

(Contractors) Ltd 


PPC0056/08B ALT Quarry Newry & Mourne DC Pending 

PPC0058/08B Lagan Bitumen Ltd. Belfast CC Pending 

PPC0059/08B Moyard Properties Limited Newry & Mourne DC Pending 

PPC0060/08B James Boyd & Sons ( 

Carnmoney ) Ltd 

Newtownabbey BC Pending 

PPC0061/08B M W Johnston & Son Lisburn BC Pending 

PPC0062/08B Acheson & Glover Ltd Fermanagh DC Pending 

PPC0063/08B Crievehill Quarry Fermanagh DC Pending 

PPC0064/08B Douglas Acheson Ltd Armagh City & DC Pending 

PPC0065/08B Tynan Quarry Armagh City & DC Pending 

PPC0066/08B Armagh City Quarries Armagh City & DC Pending 

PPC0067/08B Ardverness Quarry Coleraine BC Pending 

PPC0068/08B Loughside Quarries Larne BC Pending 

PPC0069/08B John Finlay (Concrete 

Pipes) Ltd 

Armagh City & DC Pending 

PPC0070/08B Eden Quarry Limavady DC Pending 

PPC0071/08B Clady Quarry Armagh City & DC Pending 

PPC0072/08B Miskelly Bros Ltd Ards BC Pending 

PPC0073/08B Sean Quinn Group Ltd Fermanagh DC Pending 

PPC0074/08B Sean Quinn Group Ltd Fermanagh DC Pending 

PPC0075/08B P Clarke & Sons Ltd Fermanagh DC Pending 

PPC0077/08B Leod Quarry Newry & Mourne DC Pending 

PPC0078/08B T H Moore (Contracts) Ltd Newry & Mourne DC Pending 

PPC0080/08B Gibsons Bros Ltd Banbridge DC Pending 

102 



PPC0081/08B Portadown Quarry Craigavon BC Pending 

PPC0082/08B ICB Emulsions Ltd. Craigavon BC Pending 

PPC0083/08B Aughrim Quarry Newry & Mourne DC Pending 

PPC0085/08B Aughafad Quarry Strabane DC Pending 

PPC0086/08B Hightown Quarry Newtownabbey BC Pending 

PPC0089/08B Patrick Keenan Magherafelt DC Pending 


PPC0092/08B Bonds Glen Quarries Limavady DC Pending 

PPC0093/08B Patrick Keenan Magherafelt DC Pending 

PPC0094/08B Gortree Quarry Derry CC Pending 

PPC0095/08B Patrick Keenan Cookstown DC Pending 

PPC0097/08B Martin’s Quarry Down DC Pending 

PPC0098/08B Letterloan Quarry Coleraine BC Pending 

PPC0099/08B Castlereagh CC Pending 

PPC0100/08B Lisowen Quarry Down DC Pending 

PPC0101/08B Castlenavan Quarry Down DC Pending 

PPC0102/08B OMYA ( UK ) Ltd Larne BC Pending 

PPC0103/08B Corkey Quarry Ballymoney BC Pending 

PPC0104/08B Ballyboyland Quarry Ballymoney BC Pending 

PPC0106/08B Banbridge Quarry Complex Banbridge DC Pending 

PPC0107/08B Carrowdore Quarry Ards BC Pending 

PPC0108/08B Tullyraine Quarry Banbridge DC Pending 

PPC0109/08B Whitemountain Quarries 

Ltd 


Ltd 


Ltd 


Ltd 





Ards BC Pending 

103


PPC0114/08B Outlack Quarry Armagh City & DC Pending 

PPC0115/08B Tullyraine Quarries Ltd Banbridge DC Pending 

PPC0116/08B Loughran Rock Industries Armagh City & DC Pending 

PPC0117/08B WG Ballantine Strabane DC Pending 

PPC0118/08B Francis McCone & Sons Ltd Armagh City & DC Pending 

PPC0119/08B Carn Quarry Fermanagh DC Pending 

PPC0120/08B Dunaree Quarry Omagh DC Pending 

PPC0121/08B Drogan Quarry Fermanagh DC Pending 

PPC0122/08B M Leer Armagh City & DC Pending 

PPC0123/08B Glebe Quarry Armagh City & DC Pending 

PPC0123/08B John O’Hagan Newry & Mourne DC Pending 

PPC0124/08B Irish Asphalt Ltd Armagh City & DC Pending 

PPC0128/08B Mobile Crushing Unit N/A (Mobile) Pending 


Ltd 


PPC0133/08B Conway Bros Coleraine BC Pending 

PPC0135/08B FP McCann Ltd Newtownabbey BC Pending 

PPC0140/08B Technical Metals Ltd Ards BC Pending 

PPC0147/08B Tyrone Crystal Ltd Dungannon DC Pending 

PPC0152/08B G & G Ross (Mobile Stone 

Crushing ) 


PPC0155/08B Milburn Concrete Ltd. Cookstown DC Pending 

PPC0156/08B LSS Ltd. Derry CC Pending 

PPC0157/08B DCC Energy (NI) Ltd ( 

Flogas ) 


PPC0167/08B Deane Public Works Ltd N/A (Mobile) Pending 

PPC0168/08B DARD - Veterinary Science 

Division 


PPC0169/08B Roadmix Ltd N/A (Mobile) Pending 

104 



PPC0174/08B Patrick Megoran N/A (Mobile) Pending 

PPC0175/08B Boville - McMullan Ltd Antrim BC Pending 

PPC0177/08B Clady Quarries N/A (Mobile) Pending 

PPC0178/08B Cairnhill Quarry (Mobile 

Plant) 

PPC0179/08B McCaffrey Concrete 

Products Ltd 

Ards BC Pending 

Fermanagh DC Pending 

PPC0182/08B Eskra Quarry Omagh DC Pending 

PPC0183/08B HMG Powder Coatings Ltd Castlereagh CC Pending 

PPC0184/08B Dromalane Quarry Newry & Mourne DC Pending 

PPC0185/08B Rockmount Quarries/ 

Mobile Crusher 


PPC0187/08B Robert George McCullough N/A (Mobile) Pending 

PPC0188/08B Northstone (NI) Ltd N/A (Mobile) Pending 

PPC0189/08B Harold Graham Fermanagh DC Pending 

PPC0190/08B Stoneyford Concrete/ 

Flomix Ltd 


PPC0191/08B Crocknamolt Quarry Coleraine BC Pending 

PPC0194/08B Chris McCormick Contracts N/A (Mobile) Pending 

PPC0195/08B Toneymore Fermanagh DC Pending 


PPC0197/08B Swan Rock Quarries Newry & Mourne DC Pending 

PPC0198/08B McGeown International Ltd Newry & Mourne DC Pending 


PPC0200/08B B Mullan & Sons 

(Contractors) Ltd 


Limavady DC Pending 

PPC0201/08B Loughran Quarries Omagh DC Pending 

PPC0202/08B Eskrahoole Quarry Omagh DC Pending 

PPC0203/08B Stanley Bell & Sons N/A (Mobile) Pending 

PPC0205/08B Shaughan Quarries Ltd. Newry & Mourne DC Pending 

105


PPC0207/08B Portadown Quarry Craigavon BC Pending 

PPC0208/08B Patrick Keenan N/A (Mobile) Pending 

PPC0209/08B Castle Contracts Ltd N/A (Mobile) Pending 

PPC0210/08B Colton Quarries Ltd Fermanagh DC Pending 

PPC0211/08B MGR Crushing Ltd N/A (Mobile) Pending 

PPC0212/08B MAR Properties Ltd N/A (Mobile) Pending 

PPC0213/08B Fox Building and 

Engineering Ltd 


PPC0214/08B Omagh Minerals Ltd Omagh DC Pending 

PPC0215/08B C E Stevenson & Sons Down DC Pending 

PPC0216/08B CE Stevenson and Sons N/A (Mobile) Pending 

PPC0217/08B F.P. McCann Ltd N/A (Mobile) Pending 

PPC0219/08B King Brothers Armagh City & DC Pending 

PPC0220/08B Conexpo (NI) Ltd N/A (Mobile) Pending 

PPC0221/08B S. McConnell & Sons Ltd N/A (Mobile) Pending 

PPC0222/08B Gerry McManus Plant Hire 

Ltd 


PPC0223/08B G&G Ross N/A (Mobile) Pending 

PPC0224/08B DJ McAleese & Co. N/A (Mobile) Pending 

PPC0225/08B Martin’s Quarry (Mobile) N/A (Mobile) Pending 

PPC0226/08B P.T. McWillams N/A (Mobile) Pending 

PPC0228/08B Norman Emerson & Sons 

Ltd 

Craigavon BC Pending 

PPC0231/08B Geotech Construction Ltd Dungannon DC Pending 


Ltd 


PPC0233/08B Klargester Ireland Newry & Mourne DC Pending 

PPC0234/08B P.T. McWillams N/A (Mobile) Pending 


106 



APPENDIX FIVE: NIEA Organisational Structure 


107


108 


Northern Ireland Environment Agency 

Klondyke Building 

Cromac Avenue 

Gasworks Business Park 

Belfast BT7 2JA 

T. 0845 302 0008 


Printed on 100% post consumer waste 

Our aim is to protect, conserve and promote the 

natural and built environment for the benefit of 

present and future generations. 

ISBN No. 978-1-905127-81-8

Measuring the effectiveness of Environmental Management Systems

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