Artigo publicado e apresentado no Congresso ABES \u2013 1992<\/p>\n
The environmental certification of products and of environmental management systems is <\/i>becoming a reality among countries member of\u00a0the E. C. (European Community) in order to guarantee Good Environmental Practices in products life cycle. One of the means for obtaining\u00a0this environmental certification is <\/i>the implementation of an Environmental Management System together with an Audit Cycle Programme in\u00a0order to promote continuous improvements in the environmental performance of industrial activities.\u00a0The article discusses the environmental management systems implementation procedures and “The Eco Management and Audi t Scheme”\u00a0Regulation and, the auditing procedures to achieve an effective environmental management system.\u00a0Finally it discusses the approaches of environmental audits in large Multinational Corporation operating worldwide and the approach of
\nenvironmental audits in Brazil’s legislation.<\/p>\nINTRODUCTION<\/h1>\n
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\u00a0took 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\u00a0settled. The compliance to local legislation and requirements was not enough, regardless of the legal requirements. Today, such policies are\u00a0sometimes more restrictive than local requirements. Such procedure has allowed companies to standardize the environmental practices on\u00a0their sites.
\nFrom the accident involving ship Exxon Valdez in Alaska, where a leakage of oil of gigantic proportions occurred, the\u00a0discussion has reached broader dimensions. Having polices and internal guidelines in which only systems of environmental\u00a0protection within the physical limits of the site were verified was not enough; it was also necessary to include external\u00a0practices, such as materials transportation, raw materials and waste disposal, among others. Those practices have also been
\nincorporated into the environmental polices of industries.
\nNew concepts and theories on management are being incorporated, such as the theory of quality. And, either as a result of\u00a0the market\u2019s pressure, or of a growing awareness that the productive sector should be responsible for environmental\u00a0protection and man\u2019s health, new concepts in environmental management have arisen, gradually incorporating it into the\u00a0managerial strategy and production costs.
\nOwing to this, innumerable corporations in a wide range of fields and countries have developed their own policies and established guidelines\u00a0and programmes on environmental protection.<\/p>\n
The E.C. has been establishing environmental certification system for products, services and environmental management systems.
\nThe initiative has already exceed the boarders of the E.C. as noticed by the discussions for an ECO-LOGO for tropical timber products. This
\ndiscussion affects mainly African, Asian, and South American Countries.
\nThis certification schemes aims at showing that a product, service or system are distinguished from others.
\nEnvironmental certification means the voluntary granting of labels by a private or public body in order to informe consumers and thereby
\npromote consumer products which are determined to be environmentaly more friendly than others functionally and competitively similar.
\nThis certification process has to be in compliance with a given reference.
\nThis reference can be characterized by:
\n– A collection of requisitions issued as guidelines by an international institution (e.g. \u201cthe commission of the European Communities\u201d).
\n– A collection of codes and legislations adopted by a national public body.
\n– A collection of quality standards established by the company itself.
\nThe certification can be voluntary or officially required.
\nThe official certification is normally associated with a consumer’s and public health’s quality assurance. This certification is established by
\nnational or supranationals bodies as the CEC guidelines. Guidelines for medicines, food and drinks or any product that represents hazard to
\nhuman helth are already known to the public.
\nThe voluntary certification adopted as a reference a collection of the quality standards already accepted by competitors of a given sector. Although
\nvoluntary, in order to be accepted the system has to adjust itself to certain regulations criteria as the EN 45011, an European
\nStandard which establishes minima requirements for independent accredited certification bodies on behalf of EC.
\nThe certification schemes are voluntary in their majority. The original certification schemes are described below:
\nGreen Seal: Private system currently in discussion in the D.S.\u00c0. It intends to use environmental criteria based on the entire life
\ncycle of each product.
\nGreen Cross: U.S.A.’s private system. The manufactures do a voluntary environmental assessment of its products and packaging.
\nEco Mark: Japan’s non official products and service’s labeling programme.
\nBlue Angel: Germany’s 15 years old labelling scheme. It is been used as a basis for other countries efforts including the Eco Label programme.
\nEnvironmental Choice: Canadian official labelling programme. It is based on the Blue Angel Scheme.
\nWhite Swann: Nordic countries’ products environmental labeling programmes.
\nThe Blue Angel Scheme is considered as one of the most adequated and accredited scheme. The label is issued after being examined and assessed by
\nthe German Federal Environmental Agency (FEA).
\nThe sponsor of the labelling proposal is the manufacturer. The FEA reviews the proposal investigating the accuracy of the information and the claimed
\nenvironmental benefits. Each proposal and its review is examined by cientists, consumers protection bodies, industry representatives and
\nenvironmentalists. The whole process lasts years before the label is awarded.
\nThe Blue Angel is only issued to products that:
\n– When compared to others are functionally similar;
\n– During alI production phases (including rational use of raw materiaIs) it is guaranteed the non agression to the environment.
\n– Are distinguished from their similar by the high leveI of non agression to the environment.
\nThe German product labelling experience has been the basis for the majority of the schemes mentioned as well as to the Comission of the European
\nCommunity, established by the EEC Regulation n\u00ba 880\/90.
\nECO LABEL
\nThe European Community system for the award of an environmental label to products, named ECO LABEL aims at:
\nGuarantee a minimum of environmental impacts in the whole product life cycle (including raw materials, production and final disposal).
\nInform the consumers about the environmental impacts caused by a given product.
\nProducts or semi-products imported by E.C. and subjected to an environmental labelling should follow the same criteria to those products
\nproduced within the E. C. To check this, suppliers have to send an environmental analysis to their European importers. Those
\nsites are subject to an environmental audit to confirm the information sent.
\nThe Commission of the European Community will set the analysis criteria. The Eco Label application has to be in products category.
\nEach application shall be accompanyed to a global product assessment since extraction\/production of raw materials until packaging,
\ndistribution and final disposal (cradle to crave principle).
\nFigure 1 shows an indicative matrix proposed by the EEC 880\/92 Regulation. This matrix relates the environmental fields with the product
\nlife cycle.
\nFIG. 1 – INDICATIVE ASSESSMENT CYCLE<\/p>\n
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
\nenvironment. In case the local and national legislation requirements are stricter than the E.C. guidelines they have to become incorporated
\nin the Eco Label award criteria.
\nIt is possible to notice that the Eco Label scheme always refers to production issues, therefore i t is essential to have an adequate
\nenvironmental management system implemented.
\nAccording to this point af view the EC 1s a150 establishing voluntary Environmental Management criteria which adopt the Environmental Audit as a
\nmanagement tool in order to achieve the “The Eco Management and Audit Scheme” Regulation 90a15.
\nTHE ECO MANAGEMENT AND AUDIT SCHEME
\nIn March 1993 the E.C.Council adopted a Regulation that will permit companies to participate in an “Eco Management and audit scheme”.
\nThe scheme refers to the voluntary participation by companies performing industrial activities and will allow them to use the
\nEuropean 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
\nSeptember 1994.
\nThe scheme proposes environmental audits in order to promote continuous improvements in the environmental performance of industrial activities and the
\nprovision of information on environmental performance to the public.
\nThe statement of participation may not be used to advertise products, on the products themselves or on their packaging, although companies may use it to
\nadvertise their participation in the scheme.
\nAssessment or audit of all significant environmental issues relevant to the activities concerned has to be carr1ed out by an accredited verifier by a competent
\nbody of each Member state.
\nAn environmental statement shall be designed for the public following the initial environmental review with a summary of figures on: pollutants emissions,
\nwaste generation, raw materials, energy and water consumption, noise and other significant environmental aspects of the site.
\nIn order to register a site in the scheme the company must:
\nCarry out an initial environmental review. Namely, an initial comprehensive analysis of the environmental performance issues, impacts an performance
\nrelated to activities on the site.
\nAdopt an environmental policy in the company as well as a programme, objectives and an environmental management system which must comply with all
\nrelevant national and E.C. legislation. The company also needs to commit itself to the continuous improvement of its environmental performance.
\nCarry out an internal environmental audit covering the following issues:
\n– Assessment, control and reduction of the impact of the activities concerned on the various sectors of the environment.
\n– Energy management, savings and choice.
\n– Management of raw materials, savings, choice and transportation; water management and savings.
\n– Waste avoidance, recycling, reuse, transportation and disposal.
\n– Evaluation, control and reduction of noise both within and outside the site.
\n– Selection of new production processes and changes to production processes.
\n– Product planning (design, packaging, transportation, use and disposal).
\n– Environmental performance and practice of contractors, subcontractors and suppliers.
\n– Prevention and limitation of environmental accidents.
\n– Cont.ingency procedures in environmental accidents.
\n– Staff information and training on environmental issues.
\n– External information on environmental issues
\nIntroduce, in the light of the results of, that review, an environmental programme for the site and an environmental management system
\napplicable to alI activities on the site. The environmental programme will be aimed at achieving the commitments contained in the
\ncompany’s environmental policy.
\nSet objectives at the highest appropriate management leveI and revise the environmental programme in order to achieve those
\nobjectives on the site.
\n\u00b7 Prepare an environmental statement to each site.
\nHave the environmental policy, programme and management system, review or audi t procedure and environmental statement
\nexamined to verify that they meet the reIevant requirements of the Regulation.
\nForward the validated environmental statement to the competent Body of the Member state where the site is located and disseminate it
\nto the pubIic in that state after registration of the site in questiono
\nThe Eco management and audit scheme is a procedure guide to companies to achieve an efficient environmental performance.
\nA tool to achieve the requirements of the Eco Management and Audi t Scheme is to implement an environmental management system which
\ncould be based on the BS 7750 (British Standard Specification for Environmental Management Systems).
\nMatrix 2 – shows the Iinks between the Eco Management and Audit Scheme and the BS 7750.
\nThe E.C. Commission will probably propose an Environmental Management System based upon the British Standard BS 7750 (Specification
\nfor Environmental Management Systems). This standard is certainly based upon the concepts described in the ISO series 9000 – QuaIity
\nAssurance Systems. An European Standard (E. N.) for Envirorimental Management System is expected to be developed and will probably
\nbe founded on the BS 7750.
\nThe requirements and elements established by the BS 7750 for an Environmental Management System are shown on figure 3 and
\ndescribed as follows:<\/p>\n
Environmental commitment: meaning a company\u2019s decision to establish an environmental management system to all the relevant
\nenvironmental issues.
\nPreparatory environmental review: the company shall establish formal assessment procedures of the current management system in order
\nto indentify compliance with the environmental commitment assumed.
\nEnvironmental policy: the company will establish, document and inform the public of its environmental policy.
\nOrganization and personnel: the organization shall define and document the responsibility, authority and interrelations of key personnel
\ninvolved in the environmental management system in all levels.
\nEnvironmental effects: the organization shall establish and maintain procedures to record the environmental effects pertaining to its
\nactivities.
\nObjectives and targets: the organization shall establish and document the specific objectives an targets of the different aspects of its
\nenvironmental protection. It shall be consistent with the environmental policy.
\nProgrammes: the organization shall establish specific programmes for achieving the objectives and targets. It shall include:
\n– designation of responsibles for its implementation.
\n– The means by which they are to be achieved.
\nManual: The organization shall establish and maintain a manual or manuals to the programme implementation. In additian to dealing with
\nthe normal activities of the organization, the manual shall cover abnormal operating conditions and incidents, accidents and potential
\nemergency situations.
\nControl: <\/i>The organization shall document working instructions defining how to conduct the activity, either by the organization’s own
\nemployees or by others acting on its behalf, such as contractors and suppliers, and monitor and contral relevant characteristics of the
\nprocess (e. g. effluent strearns and waste disposal). Procedures and responsibles shall also be established in order to verify the non
\ncompliance.
\nRecords: <\/i>The organization shall establish and maintain a record system in order to demonstrate compliance with the requirements of the
\nenvironmental management system and to record the extent to which planned environmental objectives and targets have been met.
\nFollow up environmental audits:<\/i>
\nThe organization shall establish and maintain an audit programme which aims at:
\n– Verify compliance with existing Environmental Management system.
\n– verify if the Environmental Management system designed implemented was designed according to the organization’s needs, specifically in\u00a0reference to its environmental policy.<\/p>\n
Both the “Eco Management and Audit Scheme” and the “BS 7750″ requirements make it very clear that Environmental Audits are essential
\nfor the implementation of an environmental management system by companies performing industrial activities.
\nENVIRONMENTAL AUDITS
\nEnvironmental audits shall be understood as a management tool comprising a systematic, documented, periodic and objetive evaluation of
\nthe existing Environmental Management System, including not only the organizational structure but also the existing pollution control
\nequipments. The environmental audits are performed with the aim at helping to safeguard the environment by facilitating management
\ncontrol of environmental practices which would include meeting regulatory requirements.
\nThis definition is the same adopted by ICC – International Chamber of Commerce – an international institution which has been gathering and
\ndiscussing the Environmental audits methodologies implemented by a few international corporations.
\nTherefore, environmental audits will only be useful to the company if understood as an evaluation step for implementing or improving an
\nEnvironmental Management System. Environmental audit is the key element to the environmental management within companies as well as a financial
\naudit i5 in the administration management of the company.
\nThe programmes adopted in those multinational corporations performing industrial activities follow the sequence bellow, with slight
\nvariations:
\nThe initiative appears in head offices for t.l1e purpose of standardizing their environmental policies in branches worldwide.
\nEnvironmental audits are programmed in some branches based in different countries and continents, either by the companies,
\nverifiers or by groups of environmental consultants hired by the head office.
\nThe first series of audits is then accomplished with the purpose of revising the compliance with local environmental rules and legislation, the
\nenvironmental management system in the branches, and the performance of the pollution control equipments. In short, the first audits aim at
\nthe diagnosis of the branches’ situation and the environmental programmes implemented by each site.
\nThe main necessities of each site are listed based on that first round of audits. With those data in hands, the head office establishes its
\npolicies and internal guidelines aiming at preserving its image worldwide, assuring appropriate performance of environmental protection
\nprogrammes in all coutries in which it operates.
\nThe next step is the preparation of manuals on the Good Environmental Practices, which are disseminated to those in charge of the
\nenvironmental management in branches located in the several countries where the corporation operates. Usually, such guides are followed
\nby general guidelines and job schedules for implementation of measures on the control of pollution.
\nSuch guidelines normally contemplate personnel training in environment, preparation of contingency and emergency plans in case of
\naccidents involving the environment, handling of raw materials byproducts and waste, air emissions and effluent discharge.
\nOnce the recommendations are implemented, follow-up audits are effected. As a result of those audits, objective schemes are requested
\nand they should be sent in to the manager of each branch and to the head office of the corporation.
\nOn principle, follow-up audits should not be seen as police supervision, but rather as an auxiliary tool to implement the head office’s
\nguidelines and improve the performance of environmental practices in the branch. Thus, it is essential that verifiers establish an atmosphere
\nof open communication and mutual confidence with those verified.
\nThe period of time between follow-up audits may vary, and it obviously depends on the stage of the local programmes of environmental
\nprotection detected during the first diagnosis audit and in the previous follow-up audit.
\nENVIRONMENTAL AUDITS IN BRAZIL
\nIn Brazil, states like Minas Gerais and Rio de Janeiro, and municipa1ities like Santos, in S\u00e3o Paulo, have already presented Bets obliging
\nenvironmental audits in factories and companies of high pollutant potential. In the state of Espirito Santo and in the federal Congress there are also
\nbills aiming at the regulation of environmental audits in the country. These legal diplomas see the environmental audit as an external tool to
\ncontrol industrial pollution, occupational health and local environmental effects of companies or existing activities including, among
\nothers:
\nOil refineries, pipelines, gasoi1s, oil terminals and by=products.
\nPort facilities.
\nProcessing facilities and final disposal of toxic and hazardous waste.
\nPower stations which generate electricity from thermal and radioactive springs.
\nTreatment plants and systems of final disposal of sewage.
\nPetrochemical industries and steel mills.
\nChemical and metallurgic industries.
\nPulp and paper mills.
\nHospital waste.
\nMining.
\nTourism.
\nThe legislations establish that periodic environmental audits are compulsory and should take place in a period of time ranging from 1 to 5
\nyears. The results of the audits should also be at the public’s disposal.
\nWith regard to Federal Project 3160 and Act 780 – November 5, 1991 of the Municipality of Santos, the results should be published in
\nnewspapers disseminated to the region and all over the nation in order to inform the local population of the companies’ conditions
\nconcerning environmental protection.
\nIn 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
\none or more of its activities cumulatively suspended,
\nDeliberate omission or negligence on the part of the verifier will be penalized by means of a fine, loss of credentials and temporary or
\npermanent suspension of the professional activities, on an isolated or cumulative basis.
\nAccording to Act 780 – November, 5 1991 – the Municipality of Santos, omission of relevant information concerning the results of the audits
\nwill involve suspension of the verifier’s activities in the municipality for at least 5 years. Such fact should be reported to the respective
\nagencies of professional verifiers and to the office of the Attorney General of Justice.
\nBy disregarding an audit, the defaulter may be liable to reimburse the Executive.
\nAccording to all acts and bills under discussion in the country, although environmental audits are compulsory, their costs should be at the
\nexpense of those verified.
\nCONCLUSIONS
\nAs we can see, the environmental audit concepts proposed in the CE and other transnational organization models for environmental
\nmanagement systems are rather different from those found in the Brazilian legislation.
\nWhereas in international models the environmental audit is a corporate management tool that aims to achieve more efficiency in activities\u00a0directed to environmental issues, the Brazilian legislation has made it into a control instrument and thus, a policing factor for companies.
\nThe implementation of environmental audit systems as proposed by BS 7750 \u2013 \u201cSpecification for Environmental Management Systems” and\u00a0by \u201cThe ECO Management and Audit Scheme” may be an important tool to adequate companies performing industrial activities to European\u00a0criteria so that environmental certifications can be obtained.
\nHowever, a long way still has to be covered until a systematic standard of environmental certification of products recognized by different\u00a0nations is consolidated. According to the well known course of Quality programmes based on the ISO 9000, which established an\u00a0international standard of criteria of Quality, it is licit to assume that the environmental guarantee of a product will be more easily accepted if\u00a0its production process is proved to follow an international environmental standard. An appropriate Environmental Management of productive
\nprocesses will be undoubtedly, a requirement. If worst comes to worst, it will facilitate the acquisition of an environmental certificate for\u00a0products.
\nREFERENCES
\n– BRITISH STANDARD INSTITUTION – BS 7750 – “Specification for Environmental Management Systems”, 1992.
\n– Camara dos Deputados – projeto de lei n\u00ba 3160 de 1992 – Disp\u00f5e sobre a obrigatoriedade de realiza\u00e7\u00e3o de auditorias ambientais nas
\ninstitui\u00e7\u00f5es cujas atividades causem impacto ambiental.
\n– Commission of the European Communities (1993) – Proposal for a council regulation allowing participation in the industrial sector in a
\ncommunity “Eco Management and audit Scheme”.
\n– DAY, I.J. (1993) – Gerenciamento ambiental e os modelos de auditoria ambiental – Semin\u00e1rio sobre Gerenciamento e Certifica\u00e7\u00e3o
\nAmbiental.
\n– Estado do Esp\u00edrito Santo – projeto de lei – 1992. Disp\u00f5e sobre a realiza\u00e7\u00e3o de auditorias ambientais e d\u00e1 outras provid\u00eancias.
\n– Estado de Minas Gerais – Assembl\u00e9ia Legislativa, Lei n\u00ba 10627 de 16 de janeiro de 1991 – Disp\u00f5e sobre a realiza\u00e7\u00e3o de auditorias
\nambientais e d\u00e1 outras provid\u00eancias.
\n– Estado do Rio de Janeiro – Assembl\u00e9ia Legislativa, Lei n2 1898 de 26 de novembro de 1991 – Disp\u00f5e sobre a realiza\u00e7\u00e3o de auditorias
\nambientais.
\n– ICC, International Chamber of Commerce (April 1991)- “Guide to effective Environmental Auditing” – Paris.
\n– JOURNAL OFFICIEL DES COMMUNAUT\u00c9S EUROP\u00c9ENES (1992) \u2013 n\u00ba 199\/1 R\u00e9glement (CEE) n\u00ba 880\/92 Du Conseil –
\nBruxelles, Mars.
\n– NEWSWEEK (1990), Cleaning up: Consumers want environmentally safe goods, and business 18 starting to stir, November 19 .
\n– OECD (1991), Environmental labelling in OECD Countries, Paris.
\n– Prefeitura Municipal de Santos \u2013 Lei n\u00ba 780 de 5 de novembro de 1991 – Disp\u00f5e sobre a realiza\u00e7\u00e3o de auditorias ambientais no munic\u00edpio de Santos e d\u00e1
\noutras provid\u00eancias.
\n– REVISTA INMETRO (1992), O novo sistema brasileiro de Certifica\u00e7\u00e3o, v. 1. n.1.
\n– UNEP – Technical reports series n\u00ba 2 – ENVIRONMENTAL AUDITING (10-11 January 1989) Report of a limited Nations Environment
\nProgramme\/Industry and environment workshop – Paris.<\/p>\n