MANAGEMENT & PROTECTION SYSTEMS

QUALITY ENVIRONMENTAL AND SAFETY : ISO 9001 - ISO 14001 - EMAS - ISO 45001
INFORMATION TECHNOLOGY: ISO 27001 - ISO 20000 - ISO 22301

 

 

 
 

Organizations operating in multiple sites

 

 

Under the EMAS Regulation, participants can continue to register individual sites or their parts or combinations as "organization".
In both cases, all participants must demonstrate a continuous improvement in the performance of their aspects and significant environmental impacts, in harmony with their policy, their program and their targets.
Participants who register multiple sites such as unique organization must be able to possibly justify the reasons why the improvement of environmental performance is not evident in each of their sites.
In addition to clarifying and justifying the selection of a site or a combination of sites, the organizations that requesting registration with EMAS, in the public or private sector, must also be ready to specify and justify to their shareholders their intentions regarding sites not yet registered.

 

With identical or similar products or services
To obtain a "registration number", the organization must be able to demonstrate to the verifier the consistent application of its management procedures and environmental policy on all sites. Organizations that fall into this category are often characterized by common management procedures for their operations on different sites, such as a common environmental management manual.
Because of this, it may be possible to reduce in-depth verification on individual sites if the organization can demonstrate full control of all its sites.

 

If the activities on the site have similar environmental aspects and impacts, are subject to a similar environmental management system and operate within the same structures as branches, offices or workshops, it becomes possible to check some of the various sites on a selective basis. The examples must be selected to ensure that the verifier has a representative and comprehensive understanding of the organization's environmental performance and can verify the reliability of the data and local responsibility.
Good practices must be followed in the selection of the techniques of sampling and verifiers must take into account the following factors in the choice of sites to be included in the verification program:
- environmental policy and program;
- complexity of the environmental management system (EMS), meaning of aspects and direct and indirect environmental impacts and potential interaction with sensitive environments;
- maturity of the EMS system on the site;
- views of interested parties (complaints, public interest in a site);
- distribution of the organization's personnel to the sites;
- any turn-based service;
- precedents in the field of environmental problems;
- results of previous internal audits and audits.

 

All sites must be covered over a period of verification cycles. In the first verification and in each subsequent verification cycle, the site must be included in the verification program.
Organizations and verifiers must bear in mind that if there are significant environmental impacts associated with distinct geographical areas, all sites must be verified < br> individually and the related environmental data associated with significant environmental impacts must be indicated in the environmental declaration, in accordance with the principles of "local responsibility".

A site must be verified individually if:
- the size, scale and nature of the activities / operations on the site have been recognized as significant;
- internal audits and management analyzes have shown the need for corrective actions,

- substantial changes occurred in the environmental management system or in operations on the site after the last verification;
- or if the site is significantly different from the other sites of the organization at the level of:
      - dimensions and operational practices;
      - direct and indirect environmental aspects / impacts (type and importance);
      - sensitivity of its environments;
      - applicable legal requirements;
      - structure of the local EMS and / or local management system;
      - size, scale and nature of activities / operations on the site.

 

With different products or services
In these cases it is not possible for the verifier to use sampling techniques as the operating procedures and impacts on each site are different. It is up to the organization to decide if it intends to register each site separately or if it wants to register its sites under a common registration number.
Regardless of whether an organization intends to proceed with one or more separate registrations for each site, you must keep in mind numerous aspects, including:
a) the need to analyze the environmental aspects and impacts associated with all the different locations;
b) the respective management control;
c) the existence of an environmental policy and programs that take into account the principle of local responsibility. In this case all sites must be individually verified and the related environmental data must be reported separately in the environmental statement.

 

Also in this case, an organization that intends to register some or all of its sites under a common registration number must bear in mind the risk of losing the common registration in case of violation on a single site (location).
A company can initially register individual sites and then unify them under a single registration number as an organization.

 

 

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