Environmental Audits: a management tool to achive in environmental certification – 1992

Artigo publicado e apresentado no Congresso ABES – 1992

Autores: Cristina Knapp, Michel Epelbaum e Jair Rosa Claudio

ABSTRACT

The environmental certification of products and of environmental management systems is becoming a reality among countries member of the E. C. (European Community) in order to guarantee Good Environmental Practices in products life cycle. One of the means for obtaining this environmental certification is the implementation of an Environmental Management System together with an Audit Cycle Programme in order to promote continuous improvements in the environmental performance of industrial activities. The article discusses the environmental management systems implementation procedures and “The Eco Management and Audi t Scheme” Regulation and, the auditing procedures to achieve an effective environmental management system. Finally it discusses the approaches of environmental audits in large Multinational Corporation operating worldwide and the approach of
environmental audits in Brazil’s legislation.

INTRODUCTION

The managerial mind in the environmental field began to change as a result of an accident in Bhopal, India, where a leakage of a toxic gas took the lives of over 2.000 people. That gave rise to a discussion on the company’s responsibilities in the country where their sites were settled. The compliance to local legislation and requirements was not enough, regardless of the legal requirements. Today, such policies are sometimes more restrictive than local requirements. Such procedure has allowed companies to standardize the environmental practices on their sites.
From the accident involving ship Exxon Valdez in Alaska, where a leakage of oil of gigantic proportions occurred, the discussion has reached broader dimensions. Having polices and internal guidelines in which only systems of environmental protection within the physical limits of the site were verified was not enough; it was also necessary to include external practices, such as materials transportation, raw materials and waste disposal, among others. Those practices have also been
incorporated into the environmental polices of industries.
New concepts and theories on management are being incorporated, such as the theory of quality. And, either as a result of the market’s pressure, or of a growing awareness that the productive sector should be responsible for environmental protection and man’s health, new concepts in environmental management have arisen, gradually incorporating it into the managerial strategy and production costs.
Owing to this, innumerable corporations in a wide range of fields and countries have developed their own policies and established guidelines and programmes on environmental protection.

ENVIRONMENTAL CERTIFICATION

The E.C. has been establishing environmental certification system for products, services and environmental management systems.
The initiative has already exceed the boarders of the E.C. as noticed by the discussions for an ECO-LOGO for tropical timber products. This
discussion affects mainly African, Asian, and South American Countries.
This certification schemes aims at showing that a product, service or system are distinguished from others.
Environmental certification means the voluntary granting of labels by a private or public body in order to informe consumers and thereby
promote consumer products which are determined to be environmentaly more friendly than others functionally and competitively similar.
This certification process has to be in compliance with a given reference.
This reference can be characterized by:
– A collection of requisitions issued as guidelines by an international institution (e.g. “the commission of the European Communities”).
– A collection of codes and legislations adopted by a national public body.
– A collection of quality standards established by the company itself.
The certification can be voluntary or officially required.
The official certification is normally associated with a consumer’s and public health’s quality assurance. This certification is established by
national or supranationals bodies as the CEC guidelines. Guidelines for medicines, food and drinks or any product that represents hazard to
human helth are already known to the public.
The voluntary certification adopted as a reference a collection of the quality standards already accepted by competitors of a given sector. Although
voluntary, in order to be accepted the system has to adjust itself to certain regulations criteria as the EN 45011, an European
Standard which establishes minima requirements for independent accredited certification bodies on behalf of EC.
The certification schemes are voluntary in their majority. The original certification schemes are described below:
Green Seal: Private system currently in discussion in the D.S.À. It intends to use environmental criteria based on the entire life
cycle of each product.
Green Cross: U.S.A.’s private system. The manufactures do a voluntary environmental assessment of its products and packaging.
Eco Mark: Japan’s non official products and service’s labeling programme.
Blue Angel: Germany’s 15 years old labelling scheme. It is been used as a basis for other countries efforts including the Eco Label programme.
Environmental Choice: Canadian official labelling programme. It is based on the Blue Angel Scheme.
White Swann: Nordic countries’ products environmental labeling programmes.
The Blue Angel Scheme is considered as one of the most adequated and accredited scheme. The label is issued after being examined and assessed by
the German Federal Environmental Agency (FEA).
The sponsor of the labelling proposal is the manufacturer. The FEA reviews the proposal investigating the accuracy of the information and the claimed
environmental benefits. Each proposal and its review is examined by cientists, consumers protection bodies, industry representatives and
environmentalists. The whole process lasts years before the label is awarded.
The Blue Angel is only issued to products that:
– When compared to others are functionally similar;
– During alI production phases (including rational use of raw materiaIs) it is guaranteed the non agression to the environment.
– Are distinguished from their similar by the high leveI of non agression to the environment.
The German product labelling experience has been the basis for the majority of the schemes mentioned as well as to the Comission of the European
Community, established by the EEC Regulation nº 880/90.
ECO LABEL
The European Community system for the award of an environmental label to products, named ECO LABEL aims at:
Guarantee a minimum of environmental impacts in the whole product life cycle (including raw materials, production and final disposal).
Inform the consumers about the environmental impacts caused by a given product.
Products or semi-products imported by E.C. and subjected to an environmental labelling should follow the same criteria to those products
produced within the E. C. To check this, suppliers have to send an environmental analysis to their European importers. Those
sites are subject to an environmental audit to confirm the information sent.
The Commission of the European Community will set the analysis criteria. The Eco Label application has to be in products category.
Each application shall be accompanyed to a global product assessment since extraction/production of raw materials until packaging,
distribution and final disposal (cradle to crave principle).
Figure 1 shows an indicative matrix proposed by the EEC 880/92 Regulation. This matrix relates the environmental fields with the product
life cycle.
FIG. 1 – INDICATIVE ASSESSMENT CYCLE

The Eco Label will only be awarded to products categories which have their life cycle according to the E.C. standards for health, safety and
environment. In case the local and national legislation requirements are stricter than the E.C. guidelines they have to become incorporated
in the Eco Label award criteria.
It is possible to notice that the Eco Label scheme always refers to production issues, therefore i t is essential to have an adequate
environmental management system implemented.
According to this point af view the EC 1s a150 establishing voluntary Environmental Management criteria which adopt the Environmental Audit as a
management tool in order to achieve the “The Eco Management and Audit Scheme” Regulation 90a15.
THE ECO MANAGEMENT AND AUDIT SCHEME
In March 1993 the E.C.Council adopted a Regulation that will permit companies to participate in an “Eco Management and audit scheme”.
The scheme refers to the voluntary participation by companies performing industrial activities and will allow them to use the
European Eco-logo, or statement af participation for a given site in come lance with the E. C. Regulations. The regulations expected to come into force in
September 1994.
The scheme proposes environmental audits in order to promote continuous improvements in the environmental performance of industrial activities and the
provision of information on environmental performance to the public.
The statement of participation may not be used to advertise products, on the products themselves or on their packaging, although companies may use it to
advertise their participation in the scheme.
Assessment or audit of all significant environmental issues relevant to the activities concerned has to be carr1ed out by an accredited verifier by a competent
body of each Member state.
An environmental statement shall be designed for the public following the initial environmental review with a summary of figures on: pollutants emissions,
waste generation, raw materials, energy and water consumption, noise and other significant environmental aspects of the site.
In order to register a site in the scheme the company must:
Carry out an initial environmental review. Namely, an initial comprehensive analysis of the environmental performance issues, impacts an performance
related to activities on the site.
Adopt an environmental policy in the company as well as a programme, objectives and an environmental management system which must comply with all
relevant national and E.C. legislation. The company also needs to commit itself to the continuous improvement of its environmental performance.
Carry out an internal environmental audit covering the following issues:
– Assessment, control and reduction of the impact of the activities concerned on the various sectors of the environment.
– Energy management, savings and choice.
– Management of raw materials, savings, choice and transportation; water management and savings.
– Waste avoidance, recycling, reuse, transportation and disposal.
– Evaluation, control and reduction of noise both within and outside the site.
– Selection of new production processes and changes to production processes.
– Product planning (design, packaging, transportation, use and disposal).
– Environmental performance and practice of contractors, subcontractors and suppliers.
– Prevention and limitation of environmental accidents.
– Cont.ingency procedures in environmental accidents.
– Staff information and training on environmental issues.
– External information on environmental issues
Introduce, in the light of the results of, that review, an environmental programme for the site and an environmental management system
applicable to alI activities on the site. The environmental programme will be aimed at achieving the commitments contained in the
company’s environmental policy.
Set objectives at the highest appropriate management leveI and revise the environmental programme in order to achieve those
objectives on the site.
· Prepare an environmental statement to each site.
Have the environmental policy, programme and management system, review or audi t procedure and environmental statement
examined to verify that they meet the reIevant requirements of the Regulation.
Forward the validated environmental statement to the competent Body of the Member state where the site is located and disseminate it
to the pubIic in that state after registration of the site in questiono
The Eco management and audit scheme is a procedure guide to companies to achieve an efficient environmental performance.
A tool to achieve the requirements of the Eco Management and Audi t Scheme is to implement an environmental management system which
could be based on the BS 7750 (British Standard Specification for Environmental Management Systems).
Matrix 2 – shows the Iinks between the Eco Management and Audit Scheme and the BS 7750.
The E.C. Commission will probably propose an Environmental Management System based upon the British Standard BS 7750 (Specification
for Environmental Management Systems). This standard is certainly based upon the concepts described in the ISO series 9000 – QuaIity
Assurance Systems. An European Standard (E. N.) for Envirorimental Management System is expected to be developed and will probably
be founded on the BS 7750.
The requirements and elements established by the BS 7750 for an Environmental Management System are shown on figure 3 and
described as follows:

Environmental commitment: meaning a company’s decision to establish an environmental management system to all the relevant
environmental issues.
Preparatory environmental review: the company shall establish formal assessment procedures of the current management system in order
to indentify compliance with the environmental commitment assumed.
Environmental policy: the company will establish, document and inform the public of its environmental policy.
Organization and personnel: the organization shall define and document the responsibility, authority and interrelations of key personnel
involved in the environmental management system in all levels.
Environmental effects: the organization shall establish and maintain procedures to record the environmental effects pertaining to its
activities.
Objectives and targets: the organization shall establish and document the specific objectives an targets of the different aspects of its
environmental protection. It shall be consistent with the environmental policy.
Programmes: the organization shall establish specific programmes for achieving the objectives and targets. It shall include:
– designation of responsibles for its implementation.
– The means by which they are to be achieved.
Manual: The organization shall establish and maintain a manual or manuals to the programme implementation. In additian to dealing with
the normal activities of the organization, the manual shall cover abnormal operating conditions and incidents, accidents and potential
emergency situations.
Control: The organization shall document working instructions defining how to conduct the activity, either by the organization’s own
employees or by others acting on its behalf, such as contractors and suppliers, and monitor and contral relevant characteristics of the
process (e. g. effluent strearns and waste disposal). Procedures and responsibles shall also be established in order to verify the non
compliance.
Records: The organization shall establish and maintain a record system in order to demonstrate compliance with the requirements of the
environmental management system and to record the extent to which planned environmental objectives and targets have been met.
Follow up environmental audits:
The organization shall establish and maintain an audit programme which aims at:
– Verify compliance with existing Environmental Management system.
– verify if the Environmental Management system designed implemented was designed according to the organization’s needs, specifically in reference to its environmental policy.

Both the “Eco Management and Audit Scheme” and the “BS 7750″ requirements make it very clear that Environmental Audits are essential
for the implementation of an environmental management system by companies performing industrial activities.
ENVIRONMENTAL AUDITS
Environmental audits shall be understood as a management tool comprising a systematic, documented, periodic and objetive evaluation of
the existing Environmental Management System, including not only the organizational structure but also the existing pollution control
equipments. The environmental audits are performed with the aim at helping to safeguard the environment by facilitating management
control of environmental practices which would include meeting regulatory requirements.
This definition is the same adopted by ICC – International Chamber of Commerce – an international institution which has been gathering and
discussing the Environmental audits methodologies implemented by a few international corporations.
Therefore, environmental audits will only be useful to the company if understood as an evaluation step for implementing or improving an
Environmental Management System. Environmental audit is the key element to the environmental management within companies as well as a financial
audit i5 in the administration management of the company.
The programmes adopted in those multinational corporations performing industrial activities follow the sequence bellow, with slight
variations:
The initiative appears in head offices for t.l1e purpose of standardizing their environmental policies in branches worldwide.
Environmental audits are programmed in some branches based in different countries and continents, either by the companies,
verifiers or by groups of environmental consultants hired by the head office.
The first series of audits is then accomplished with the purpose of revising the compliance with local environmental rules and legislation, the
environmental management system in the branches, and the performance of the pollution control equipments. In short, the first audits aim at
the diagnosis of the branches’ situation and the environmental programmes implemented by each site.
The main necessities of each site are listed based on that first round of audits. With those data in hands, the head office establishes its
policies and internal guidelines aiming at preserving its image worldwide, assuring appropriate performance of environmental protection
programmes in all coutries in which it operates.
The next step is the preparation of manuals on the Good Environmental Practices, which are disseminated to those in charge of the
environmental management in branches located in the several countries where the corporation operates. Usually, such guides are followed
by general guidelines and job schedules for implementation of measures on the control of pollution.
Such guidelines normally contemplate personnel training in environment, preparation of contingency and emergency plans in case of
accidents involving the environment, handling of raw materials byproducts and waste, air emissions and effluent discharge.
Once the recommendations are implemented, follow-up audits are effected. As a result of those audits, objective schemes are requested
and they should be sent in to the manager of each branch and to the head office of the corporation.
On principle, follow-up audits should not be seen as police supervision, but rather as an auxiliary tool to implement the head office’s
guidelines and improve the performance of environmental practices in the branch. Thus, it is essential that verifiers establish an atmosphere
of open communication and mutual confidence with those verified.
The period of time between follow-up audits may vary, and it obviously depends on the stage of the local programmes of environmental
protection detected during the first diagnosis audit and in the previous follow-up audit.
ENVIRONMENTAL AUDITS IN BRAZIL
In Brazil, states like Minas Gerais and Rio de Janeiro, and municipa1ities like Santos, in São Paulo, have already presented Bets obliging
environmental audits in factories and companies of high pollutant potential. In the state of Espirito Santo and in the federal Congress there are also
bills aiming at the regulation of environmental audits in the country. These legal diplomas see the environmental audit as an external tool to
control industrial pollution, occupational health and local environmental effects of companies or existing activities including, among
others:
Oil refineries, pipelines, gasoi1s, oil terminals and by=products.
Port facilities.
Processing facilities and final disposal of toxic and hazardous waste.
Power stations which generate electricity from thermal and radioactive springs.
Treatment plants and systems of final disposal of sewage.
Petrochemical industries and steel mills.
Chemical and metallurgic industries.
Pulp and paper mills.
Hospital waste.
Mining.
Tourism.
The legislations establish that periodic environmental audits are compulsory and should take place in a period of time ranging from 1 to 5
years. The results of the audits should also be at the public’s disposal.
With regard to Federal Project 3160 and Act 780 – November 5, 1991 of the Municipality of Santos, the results should be published in
newspapers disseminated to the region and all over the nation in order to inform the local population of the companies’ conditions
concerning environmental protection.
In case the audit fails to happen, the institution will be fined and/or will not be allowed to have its operative license renewed. It will also have
one or more of its activities cumulatively suspended,
Deliberate omission or negligence on the part of the verifier will be penalized by means of a fine, loss of credentials and temporary or
permanent suspension of the professional activities, on an isolated or cumulative basis.
According to Act 780 – November, 5 1991 – the Municipality of Santos, omission of relevant information concerning the results of the audits
will involve suspension of the verifier’s activities in the municipality for at least 5 years. Such fact should be reported to the respective
agencies of professional verifiers and to the office of the Attorney General of Justice.
By disregarding an audit, the defaulter may be liable to reimburse the Executive.
According to all acts and bills under discussion in the country, although environmental audits are compulsory, their costs should be at the
expense of those verified.
CONCLUSIONS
As we can see, the environmental audit concepts proposed in the CE and other transnational organization models for environmental
management systems are rather different from those found in the Brazilian legislation.
Whereas in international models the environmental audit is a corporate management tool that aims to achieve more efficiency in activities directed to environmental issues, the Brazilian legislation has made it into a control instrument and thus, a policing factor for companies.
The implementation of environmental audit systems as proposed by BS 7750 – “Specification for Environmental Management Systems” and by “The ECO Management and Audit Scheme” may be an important tool to adequate companies performing industrial activities to European criteria so that environmental certifications can be obtained.
However, a long way still has to be covered until a systematic standard of environmental certification of products recognized by different nations is consolidated. According to the well known course of Quality programmes based on the ISO 9000, which established an international standard of criteria of Quality, it is licit to assume that the environmental guarantee of a product will be more easily accepted if its production process is proved to follow an international environmental standard. An appropriate Environmental Management of productive
processes will be undoubtedly, a requirement. If worst comes to worst, it will facilitate the acquisition of an environmental certificate for products.
REFERENCES
– BRITISH STANDARD INSTITUTION – BS 7750 – “Specification for Environmental Management Systems”, 1992.
– Camara dos Deputados – projeto de lei nº 3160 de 1992 – Dispõe sobre a obrigatoriedade de realização de auditorias ambientais nas
instituições cujas atividades causem impacto ambiental.
– Commission of the European Communities (1993) – Proposal for a council regulation allowing participation in the industrial sector in a
community “Eco Management and audit Scheme”.
– DAY, I.J. (1993) – Gerenciamento ambiental e os modelos de auditoria ambiental – Seminário sobre Gerenciamento e Certificação
Ambiental.
– Estado do Espírito Santo – projeto de lei – 1992. Dispõe sobre a realização de auditorias ambientais e dá outras providências.
– Estado de Minas Gerais – Assembléia Legislativa, Lei nº 10627 de 16 de janeiro de 1991 – Dispõe sobre a realização de auditorias
ambientais e dá outras providências.
– Estado do Rio de Janeiro – Assembléia Legislativa, Lei n2 1898 de 26 de novembro de 1991 – Dispõe sobre a realização de auditorias
ambientais.
– ICC, International Chamber of Commerce (April 1991)- “Guide to effective Environmental Auditing” – Paris.
– JOURNAL OFFICIEL DES COMMUNAUTÉS EUROPÉENES (1992) – nº 199/1 Réglement (CEE) nº 880/92 Du Conseil –
Bruxelles, Mars.
– NEWSWEEK (1990), Cleaning up: Consumers want environmentally safe goods, and business 18 starting to stir, November 19 .
– OECD (1991), Environmental labelling in OECD Countries, Paris.
– Prefeitura Municipal de Santos – Lei nº 780 de 5 de novembro de 1991 – Dispõe sobre a realização de auditorias ambientais no município de Santos e dá
outras providências.
– REVISTA INMETRO (1992), O novo sistema brasileiro de Certificação, v. 1. n.1.
– UNEP – Technical reports series nº 2 – ENVIRONMENTAL AUDITING (10-11 January 1989) Report of a limited Nations Environment
Programme/Industry and environment workshop – Paris.