An environmental management system (EMS) for a car manufacturing plant.

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Introducing an EMS policy for a car manufacturing plant

Copyright of LabSearch (a working title of Dr Malcolm Sutherland), 2013

Introducing an EMS policy for

a car manufacturing plant

Malcolm Alexander Sutherland

Matriculation no. 0204783

Submitted on 9th January 2003 in partial fulfilment of the requirements of the MSc.module (WW531) in Environmental Management

REVISED MAY 2013





CONTENTS

Executive Summary

1: Processes Occurring within a Car Manufacturing Plant, which are ofEnvironmental Significance

1.1: Constructing a Car - a Simplified Description1.2: Hazardous Materials, Wastes and Emissions from the Car Manufacturing Plant

2: Reasons for adopting an Environmental Management Strategy

2.1: Legislation

2.2: EMS Schemes2.3: How an EMS can Benefit the Company

3: Developing and Environmental Management Strategy

3.1: The General Layout of an EMS Stategy3.2: Environmental Risk

4: Analysing Hazards at the Car Manufacturing Plant

4.1: Categorising Activities in Terms of their Environmental Risk4.2: Discussion on the Findings in Appendix 1

5: Producing an Environmental Policy Statement

References

Appendix 1 (Table of 20 environmental impacts)

Appendix 2 (Pollution from a car Manufacturing Plant – the Issues)





EXECUTIVE SUMMARY

Introducing an environmental management strategy (EMS) at a car manufacturing plant,can work to the benefit of the plant and the car company alike. Several major car

companies, including Renault, Toyota, Vauxhall and Suzuki, are developing such

programs for tackling the environmental impacts of their manufacturing plants.

The environmental threats posed by manufacturing plants, include:

(1) air emissions of carbon dioxide and monoxide (CO2, CO), sulphurous and nitrous

oxides, and particulates;

(2) effluent discharges, which contain hydrocarbons and heavy metals;

(3) the use of asbestos, which is carcinogenic;

(4) waste production, a substantial proportion of which is classed as hazardous waste;and,

(5) high energy and water consumption, which contributes to air pollution.

Several of these issues are addressed by EU and UK legislation, and an EMS can be usedto measure their significance, and address them sensibly. It will help the company to

develop a sensible environmentally positive operation, and will raise possible

opportunities for the plant, including cleaner technologies, which could preserve, or even

increase its profitability. Ultimately, the EMS will improve the image of the car

company and its manufacturing operations, which will guarantee and encourage futureinvestment in the company, and equip it for changes m environmental legislation in

advance.

There are 2 main EMS programmes - the ISO standards, and EMAS. Several car

companies have achieved one or both of these certificates. Both these certificates declare

that a company is fully committed to tackling its environmental problems, although theISO standards have their weaknesses, and the EMAS system could expose the company

to litigation. The ISO standard is recommended, as it is an internationally recognised and

more carefully thought-out programme, under which the company is obliged to try and

improve its environmental standards, but the results can still be kept confidential.

The EMS will undoubtedly lead to increased expenditure, although there are ways of

counteracting this, through adopting new technologies, recycling initiatives, andenergy/waste-reduction strategies, all of which can reduce costs from electricity

comsumption and raw materials purchasing- Although the public does not take a strong

interest in the environmental aspects of car production, manufacturing plants arevulnerable to litigation, and so developing an EMS will help to improve the reputation of

the plant, especially if governing legislation becomes more stringent in the future





CHAPTER 1: Processes occurring within a car manufacturing plant,

which are of environmental significance

1.1: CONSTRUCTING A CAR - a simplified description

1:1:1 General Process

Over 9000 parts may be used in the construction of the modem automobile, but raw

materials are also produced in a manufacturing plant. The general process of fitting a cartogether, involves 6 stages (Vauxhall, 2002):

1:1:2 The Press Shop

Coils and sheets of car body pressings are manufactured in this unit. Steel is imported to

the plant, where it is cut, compressed and Sifted with the assistance of robotic cranes.

1:1:3 Sub-Assembly

The main components of the car body are welded together; this process is mainly robotic,

and manual labour is restricled lo placing the components in the right order.

1:1:4 Body Building

The sub-assemblies (e.g. doors, roofs, bonnets) of the cars are now assembled to form the

complete car structure. There is intense welding involved, which generates high

temperatures, and continuous water pumping through the system is required to keep the

operations from over-heating.

1:1:5 Paint Shop

This phase involves more than spraying metallic paint onto the assembled car surface;

there are 4 stages to this (over-page):

I: Car Body anti-corrosion treatment

The underlying metal surface must be cleaned, first by hand, and then through 4

degreasing and phosphate dips. Zinc phosphate can be used here as an anti-corrosion

agent, and for polishing the metal framework.





II: Primer spray

Vauxhall cars are treated within a chromate rinse several times, in order to "even-out" theZn(SO4); deposits underneath. Throughout both the dipping and chromate rinsing

processes, pure water is used, which will contribute to wastewater effluent.

III: Coloured paint electroplating

Electro-deposition of polymers onto the car (for anti-corrosion purposes) involves the use

of water-based paints at the Ellesmere plant, whereby the car body is immersed in amixture of primer and pure water. After a series of water-rinses, the car is literally baked

in a furnace chamber, in order for the primer to solidify on the car structure. It is then

allowed to cool, is sanded down, and then sprayed with the PVC "finish", using

automated sprayers, or by some manual workers. Next the paint is applied. This is not a physical spraying process, but instead involves a complex array of electrically charged

spray guns, whereby the paint is electrically attracted onto the car.

IV: Wash and waxing protection coat addition

Afterwards the car is baked (at 175°C in the Vauxhall Plant), in order for the paint to

solidify. Another anti-corrosion treatment is performed at the end, whereby the car issprayed with anti-corrosion waxes.

1:1:6: Trim Shop

Small (electrical) systems and components, along with control panels, steering wheels,

seats, lights, mirrors, etc., are connected onto the car by manual workers in this phase of

car production.

1:1:7: Final Assembly and Inspection

Major components, such as the engine, wheels, brakes, and suspension fittings, are placed

into the car. The exhaust and catalytic converter systems are also added onto the vehicle.

Petrol, oil, chemicals (e.g. coolant) and water is provided, and the car is then test-driven, before it is allowed onto the market.

(The process of assembling a car may vary from this description, which is based almost

entirely on the Vauxhall Ellesmere Plant process.)





1.2: HAZARDOUS MATERIALS, WASTES AND EMISSIONS FROM THE CAR

MAUFACTURING PLANT

1:2:1: What are the issues?

Although the greatest concerns are raised by car usage, the environmental damageresulting from car manufacture is also significant in comparison. (Nieuwenhaus et al ,1994)

The manufacturing processes and effluent are not the only issues. The company needs toconsider a wide range of aspects, which are not all confined to local-scale environmental

impacts (Thoresen, 1999):

1:2:2: Air Emissions

The energy consumption of modem car manufacturing plants requires enormousquantities of fossil fuels, through electrical power supply, and for heating furnaces,

paints, etc. The combined activities of the Ellemere and Luton plants for Vauxhall,

produced over 236 tonnes of CO2, 10 tonnes of SO2, and 136 tonnes of NOx emissions,all in 1997 alone (DTI, 2000).

The heat generation results in the production of flue gases, including SOx and NOx

emissions, as well as particulates. The production of these gases leads to acid rainformation, which damages aquatic ecosystems, soils, and corrodes buildings. VOCs may

contain hydrocarbons which are directly toxic, and both VOCs and nitrous oxides (NOX)also lead to ozone formation, which is caustic to lung tissue. One important source ofVOCs (Volatile Organic Compounds) is from the car-painting process. This process is

said to account for 12% of all hydrocarbon emissions in France (Giddings et al, 1992;

Hamson, 2001, Renault, 2002).

The production of CFCs and other ozone-depleting chemicals (such as Halon) are being

tackled in manufacturing plants, and have recently been eliminated at the Vauxhall





Ellesmere plant (Vauxhall, 2002). These inevitably contribute to the weakening of the

ozone layer, leading to UV light penetration through the atmosphere, leading to increased

risks of skin cancer. Carbon monoxide is another product of plant emissions, which istoxic to human health, even at small concentrations.

1:2:3: Water Pollution

The cooling process, pins the vats used tor dips, require large quantities of water. Again,

with reference to the Ellemere Vauxhall Plant, over 1,440 megalitres are used each year,

even when most water is recycled on-site (DTI, 2000). The wastewater from the plantneeds to be treated on-site, before the effluent is discharged into the sewers; the Water

Resources Act (1991) provides guidelines for this procedure, and will be discussed later.

Hydrocarbons and heavy metals (including cadmium, chromium, copper, lead, nickel andzinc), as well as suspended solids (SS) and a chemical oxygen demand (COD), will exist

within the effluent. Hydrocarbons consist of a complex mixture of non- toxic and

carcinogenic organic compounds. Heavy metals, in particular lead and nickel, may betoxic to both aquatic life and human health. SS and COD inputs can asphyxiate aquatic

ecosystems, by removing oxygen from the water, and reducing photosynthesis (among

other effects). (Harrison, 2001; DTI, 2000; Vauxhall, 2002.)

1:2:4: Solid Wastes

Solid wastes include (1) scrap metal, including cuttings and defects; (2) effluent oilsludges. There may be other defect and residual component materials, such as plastics,

foams, paper, cardboard, rubber, glass, and oils. The motor industry produces around

5% of all industrial waste, and several solutions for recycling both cars and waste

materials are being researched and adopted (Renault, 2002; Vauxhall, 2002).

From the Ellesmere Plant alone, around 5900 tonnes of waste are produced, of which

over 1000 tonnes (-17%) are classed as special (hazardous) waste. These quantities willvary between plants, but the proportion of waste being hazardous is significant (DTI,

2000).

1:2:5: Asbestos

The Control of Asbestos at Work (1987) regulations, require alternative materials to this

dangerous fibrous material (Porteous, 1996). In the environmental reports by Renault,Volvo, Ford, Toyota, Vauxhall, Suzuki, and the automotive sector in Pakistan (see

References), asbestos is not mentioned. In the UK, all asbestos being used or imported is

now illegal, under the 1999 Asbestos (Prohibitions) Regulations Act, so this is not an

issue for the manufacturing plant (Kazen-Allen, 2000).





CHAPTER 2: Reasons for adopting an Environmental Management

Strategy

2:1: LEGISLATION

2:1:1: Introduction

At present in the UK, companies are under no obligation to attain any EMS certification.

The EC directives behind environmental management, programmes within companies,have often been received with antipathy from the UK/mainly from industry as a whole

(through the CBI) (Wathem, 1988).

However, environmental policies from the EU have also been enforced. The WaterResources Act 1991, Air Quality standards, and the Landfill Directive have been adopted

in the UK, and companies are being forced to respond quickly to the legislation

mentioned here.

2:1:2: Air Emission Standards

The National Air Quality Standards were adopted by the UK government in 2000, which

contain prescribed limits for concentrations of pollutants in air, including CO (carbon

monoxide), NOx, SOx, and particulate matter. Regulatory authorities also prescribe legal

limits for stack emissions from the manufacturing plant, which is determined by factorssuch as stack height, and me transport of pollutants (www.aeat.com, 2002). VOCs, being

a complex mixture of hydrocarbons, are also addressed under this legislation-

Compounds such as benzene and butadiene are monitored by the UK Hydrocarbon Network (Harrison, 2001).

2:1:3: Water Effluent Quality Standards

The Water Resources Act 1991 requires industries to apply for a consent license for

discharging effluent into the sewers. The standards expected, are determined by the

regulatory authorities, and, as with air emissions, are based on several parameters, suchas the capacity of the STW plant to treat this effluent.

2:1:4: Waste Disposal and the Landfill Directive

This issue is being brought before the waste producers, through the Landfill EC

Directive, whereby the polluter (in this case, the car company) pays for waste to beallocated to landfill. The charges for waste collection are steadily rising each year (SEPA,2002). Furthermore, the European End-of-Life Directive will require 85% of all newly-

manufactured vehicles to be recycled (DTI, 2000).

As described, this tax is specifically designed to encourage companies to produce lesswaste (the tax is rising by £1 each year, and at present stands at £12/tonne - it will reach

£14/tonne in April 2004) (SEPA, 2002). This applies to mixed wastes (inert and





hazardous). Around 20% of wastes from car manufacturing plants are classified as

"Special" (hazardous), and almost 6000 tonnes originate from the Vauxhall plant alone

(DTI, 2000).

Hazardous Waste

Under the EU Hazardous Waste Directive, special wastes include titanium oxide (TiO 2),oil sludges, and batteries, all of which are produced within the manufacturing plant

(Council Directive 91/689/EEC). TiO2 is a common pigment used in car paints – this may

form up to 25% of the materials used (www.wcdinc.com).

2:2: EMS SCHEMES

2:2:1: The ISO 14000 objectives (Sheldon, 1997)

The ISO guides on developing an EMS are numerous. The ISO 9000L5eries precede theISO 14000 series, although participating companies tend to select either of these. The

founding principle of the ISO 14001 EMS philosophy is that an audit system must be a

continuing cycle, in which problems are identified, solutions are proposed, then put into

practise, and finally reviewed (Figure 1):

Figure 1: the ISO 14001 continual assessment model

2:2:2: The EMAS objectives (Official Journal of the European Communities, 2002)

This recommendation is given under EC Directive No.761/2001, and again follows

similar principles to the ISO and BSI requirements:

• companies must develop an environmental strategy;

• companies must evaluate and continually improve on their environmental record;• the public must have the right to access company environmental records; and,

• employees must gain an awareness of the potential environmental effects of their jobs.





2:3: HOW AN E.M.S. CAN BENEFIT THE COMPANY

2:3:1: Are these E.M.S. programmes worth the effort?

The type of EMS program will have its advantages and problems. For example, the

EMAS scheme requires a company to allow the public to access its environmentalinformation. Meanwhile, criticism is falling on the ISO standards, which are knowingly being taken advantage of by those at management level, who only see it as a means of

improving company image, and who simply produce an environmental statement, but

make little effort to take the process seriously (Claris, 2000).

However, the EMAS structure is not withou! its problems either. Its verification process

often uncovers the company's non-compliance problems, and its EMS programme has

been found to be expensive and bureaucratic. The main problem lies in the approachtaken, in developing the audit system (Sheldon, 1997; Krause et al , 2001).

If audits are conducted properly and taken seriously, they can be highly advantageous tocompanies, especially heavy industries, which are still viewed as an environmental threat

in general.

The EMAS system is a well thought-out structure for developing an EMS, and it has ledto increased investment for many participating businesses. As with all EMS programmes,

it helps the company to establish environmental standards, in advance of those being

imposed upon the company by new EC/UK laws. Companies are less likely to becriticised or prosecuted by regulatory authorities such as SEPA or the EA, as they will

play a role within the EMS programme. The ISO standard is recognised worldwide

(Sheldon, 1997).

2:3:2: Making savings through reduction and recycling schemes

Reducing energy costs

The potential recycling opportunities with materials being processed in the manufacturing

plant are not limited to the cars themselves, which contain many useful metal, plastic, andrubber components (along with many other substances). The waste exiting the

manufacturing plants, including oils, cardboard, and paper, may be incinerated, and can

help reduce fossil fuel demands. The Renault Cleon plant incinerates its oil sludge,

generating over 7500 tonnes of steam (equivalent to 500M tonnes of oil) per annum,using the system shown in Figure 2. Incineration is not a popular option in the UK

however, mainly because this produces flue gases and particulates.





Figure 2: the Renault Cleon factory example (Renault, 2002)

Replacing potentially hazardous substances

Alternative materials are available on The market. For example, Renault have replacedtheir VOC-producing paints with water-based equivalents at their Flins plant, and are

investigating the possibility of recycling their plastic car bumpers at the Dreux plant,

allowing for a 20% decrease in purchasing new bumpers (Renault, 2002). Electro-deposition can rely on water-based paints, with no other modifications being made to the

paint shop process (CEC, 1992.)

How some competitors are seeking improvements

Companies such as Renault, Suzuki, Toyota and Vauxhall, are seeking ways to use theirenvironmental strategies to improve their production methods and increase recycling,which is beneficial to their expenditure, as well as (heir image. Toyota conducts on-going

research into several projects, based on eliminating or reducing individual environmental

impacts (Ryding, 1992; Toyota, 2000). The Renault and Vauxhall are both setting

ambitious objectives, to cap all solid waste production being sent to landfill. This has itsfinancial benefits, as well as the reduction in indirect environmental effects (Vauxhall,

2002, Renault, 2002). The Society of Motor Manufacturers & Traders reported that one

manufacturing plant saved over £700,000 p.a. as a result of its EMS.

Reducing waste destined for landfill

An indirect environmental improvement is to use recycled materials from scrap cars.Suzuki converts these into useful secondary products (eg. defect car bumpers are used for

under-covers and fuel tank materials), and packaging of paints has been significantly

reduced by importing larger containers, producing a smaller waste volume (Suzuki,2000). Although the land-filling of used cars is not an issue directly associated with the

plant itself, this approach can improve the car company's overall financial record, with

less purchasing of raw materials and components. The use of recycled parts by the Ford





Motor Company has risen to 75% of their cars in Europe, and Toyota manufacturers in

the U.S. are concerned that the development of cleaner processes abroad may lead to a

new competitive threat from these companies seeking to "go green" (Toyota, 2002).

2:3:3: Improving the company image

The H.M.S. enables a company to communicate an environmentally positive message toits stakeholders. The stakeholders determine me financial stability of the company, thus

the E-M.S. program is a financial opportunity, rather than a set-back. The main

stakeholders are listed in Table 1 (Coopers & Lybrand Consultants, 1997):

Table 1: stakeholders being affected by an EMS strategy

2:3:4: A financially sensible programme

The financial benefits of undertaking a more environmentally positive approach are not to be under-estimated. Reporting corporate performance is a new field of marketing, and

environmental standards within a company are drawing the attention of city analysts. As

early as 1994, 65 of the FT Top-100 companies produced environmental reports;

reporting and auditing has become standard practise in many industrial sectors, especiallychemical, food, transport and utilities (Scottish Natural Heritage, 1996).

Although issues of compliance are raised within the EMS program, the actual compliance





investigation, and the EMS programs, will be kept separate. The EMS programme is

designed to evaluate the overall environmental performance of the company, and make

reasonable suggestions on improving standards. It is not designed to expose any failuresor negligence of the company. If these problems did exist, the EMS is a well-organised

program for addressing them (Kraus et al , 2001). There are 4 types of objective, which

result from the decision-making process:

• management objectives to continue monitoring of an impact (if it meets legal

requirements);

• improvement objectives (if the impact exceeds legal requirements);

• monitoring requirements (if an impact has not been fully investigated - this may be due

to financial or time restrictions); and,

• enhancement objectives (if an impact is found to be costly as well, and the process used

can be replaced by a cleaner technology, which also reduces expenditure) (Sheldon,1997).

An EMS program should not lead to financially exhausting solutions, but will vary

according to the company's spending capacity (Figure 3):

Figure 3: the environmental risk hierarchy





CHAPTER 3: Developing an Environmental Management

Strategy

3:1: THE GENERAL LAYOUT OF AN EMS STRATEGY

The EIA (Environmental Impact Assessment) is just one of 5 components in an EMS.The Environmental Manager must be aware, that developing a strategy must besustainable, not only for the environment. An EMS must provide environmental solutions

and strategies, which do not compromise the company's ability to compete in the market,

nor affect its public relations or working conditions (Figure 4):

Figure 3: factors of a balanced EMS strategy

3:1:1: Developing a policy

Relevant environmental policy must be identified, and correlated with the manufacturing

plant activities. This must be translated through company policy, which must also set thecontext of the EMS strategy Tins will involve the environmental manager bringing the

main environmental issues, with their challenges, threats and opportunities to the

attention of those at management level. The environmental manager is expected to basehis/her convincing argument on a wide range of information, which is gathered in variousways (McDonagh and Prothero, 1997):

• Questionnaires • Checklists

• Interviews

• Measurements/monitoring

• Direct observations

The arguments being presented to those at management level, will always take related

social and economic issues into account. In the long-term, the environmental strategyshould not interfere with profit, but should hopefully maintain or even improve this.





3:1:2: Planning

The scope and detail within the audit of die manufacturing plant, will vary, depending onhow successfully the plant is meeting legal standards, or what opportunities exist to

improve its operations, both the benefit of the company and the environment. The timing,

financial constraints, and level of existing knowledge, will also determine how intensethe audit needs to be. The level of knowledge amongst stakeholders, and their influenceon the company is also assessed.

People selected for the auditing team should not all originate from the car company,consultants and experts out with the company will also be involved, and their research

should be commissioned as soon as possible, in order for pertinent data to be collected, so

that the audit system is worthy of certification.

3:1:3: Implementation and Operation (E.I.A.)

This will involve similar information-gathering methods, to those listed in 3:1:1, alongwith the use of matrix sheets (discussed in the next chapter), data analyses, and staff

training- The scope of the data collection will be kept within context, such as monitoring

of air emissions, with limited sampling being conducted, and statistical sampling and

data-handling techniques being carried out. The sampling strategy will be kept withinrespectable spending costs.

3:1:4: Checking and Corrective Action

The findings from the data collected, will be evaluated. Issues raised in the evaluation,

include environmental regulation compliance, a description of environmental impacts,

their relative significance, and an assessment of alternative operations. The methods usedin me audit programme are also assessed, and the recommendations on both auditing and

the plant operations will be matched with reasonable company spending costs.

The result of this is that information on resource needs, predicted costs, and optimum

time periods for necessary environmental improvements, are carefully produced.

Management Review

A final audit report is produced, and presented before the company management team,

which will provide clear, understandable descriptions of the main environmental impacts,and the possible alternative processes, which will help to reduce these whilst the

manufacturing plant continues to be profitable. References, technical data and other

important references will be provided. In addition, a brief executive summary, which is

aimed at a non-technical audience, will be produced, which summarises the main issuesand possible solutions.

This will be produced as a first draft, and distributed amongst relevant employees,managers and external advisors, for their comments. For the EMAS certification, a public





document will also be produced. Management reviews are conducted on a regular basis

for the EMS conducted by Ford, and each focuses on main issues such as staff training

and auditing methods (McDonagh and Prothero, 1997; Ford, 2002).

3:2: ENVIRONMENTAL RISK

3:2:1: Factors used for assessing environmental risk

The most significant element of environmental risks posed by industrial plants, are the processes occurring within the site. One important aspect is the age of the site and its

infrastructure. Aspects of relevance to the car manufacturing plant are listed in Table 2:

Table 2: environmental risks of car manufacturing plants (Pritchard, 2000)

In addition, a wider range of environmental topics should be investigated within the

plant. These include: (i) regulatory compliance in general; (ii) air emissions; (iii) raw andwaste water; (iv) material handling procedures; (v) hazardous materials management; (vi)

oil-containing equipment; (vii) asbestos (which is still used in car pedals); (viii) wastemanagement and housekeeping; (ix) noise and vibrations; (x) cleaner technology

opportunities and ongoing initiatives; and, (xi) energy consumption (Pritchard, 2000).

A general process of assessing environmental effects is illustrated in Figure 4 over-page.

The prediction of environmental impacts will vary, depending on the type of aspect being

monitored. It is also a limited method at the start of an audit, and will become more

detailed and sensible as information is gathered. The objectives behind the assessment

must be clearly defined, and should therefore be fully supported by the management team(Lee, 1989; Ryding, 1992).

The management review of the risk assessment, should address the following aspects of

the audit methods used:





Figure 4: methodology for assessing environmental effects





• the way in which the problems have been defined and measured;

• the number and value of recommended alternatives;• the purpose behind the screening and ratings method;

• data, resource and information limitations affecting the audit report; and,

• a ppropriate decision-making processes (Lee, 1989).

3:2:2: Some indicators and targets used in EIA auditing by other car companies

The Toyota company has set out an environmental objective, to almost eliminate its

landfill contributions, reduce VOC emissions by 30%, and achieve marginal (15%)

reductions in water and energy consumption (Toyota, 2002). The Vauxhall group

provides a list of environmental indicators which it assesses in its manufacturing plants,including COi (carbon dioxide), VOCs, NOx and SOx emissions (Vauxhall, 2002).

Suzuki is focusing on reducing air and water pollution, along with waste and energy

consumption (Suzuki, 2000). Some car companies are therefore recognising, and takingaction on me environmental impacts of their production activities.





CHAPTER 4: Analysing hazards at the car manufacturing plant

4:1: CATEGORISING ACTIVITES IN TERMS OF THEIR ENVIRONMENTAL

RISK

4:1:1: Typical systems used

Developing a sensible environmental strategy requires more than identifying

environmental aspects; their significance also needs to be determined. This involves theuse of matrix tables, where each aspect of a company is given a rating. Two common

types of matrix sheets are given in the short examples below. These can address (1)

activities, and (2) materials/pollutants:

Some of me matrix table entries listed above, may be sub-categorised, or groupedtogether during the assessment. There will be far more aspects being addressed, than

those given in Figure 9. Columns A, B, C, D and E, (etc.), are me types of impact

associated with the activity or material. Within the columns, numbers are inserted, as a

measure of each impact. They could be YES/NO-based questions, or severitymeasurements (shown over-page).

The matrix tables are not me only method of recording and comparing impacts andactivities, as the matrix table does not consider the impact from, say, a combination of

sources or activities. The process of rating each impact requires the opinion and working

knowledge of relevant candidates being interviewed and invited to discuss theenvironmental aspects (Lee, 1989).





Determining the significance may be a difficult and noil-technical process as a result

However, it is not just me severity of me impact which affects its importance. Other

aspects include:

• probability of occurrence (where appropriate);

• duration of impact;• difficulty and potential costs in altering me impact/activity;

• concerns of interested parties (public, workers, share-holders, regulators); and,

• effect of impact on the public image of the company (Envirowise, 2002).

4:1:2: Twenty activities at a car manufacturing plant

These are listed in Appendix 1. The "N", "A", "D" and "I" columns are explained there.Appendix 2 describes the problems oflhc main environmental impacts in more detail.

Column A - legislation

This has already been described. Legislation covers all effluent and emissions, as well as

waste disposal. Surface drainage is also affected, as the Water Framework Directive





applies to diffuse sources, such as car park surface runoff. The CIMAH regulations also

apply to industries using or storing large quantities of hazardous chemicals (e.g. oil tanks)

(Harrison,2001).

Column B - Stakeholders

This is a complicated issue to address. While some people (especially customers) are notconcerned, the local community, or me regulators may be more apprehensive of some

activities. Any activity, which poses a risk to the local environment (e.g. landfill of

hazardous wastes, effluent discharge), or is a hazard to workers (e.g. ethylene glycol), isgiven a rating of 5. In reality, any environmental impact is of concern to the regulator; in

general, less "worrying" aspects given a (0) rating, although these are usually question-

marked.

Column C - Global Environmental Impacts

Air emissions including VOCs and CC>2 contribute to worldwide environmental effectssuch as ozone depletion and global warming. Effluent, particulates, solid wastes and

spillages will tend to have a local or regional impact.

Column D - Quantities

Oil, water, air emissions, most chemicals, and solid waste are gencraled in large

quantities from the plant itself. Oil spills are unlikely to occur often. No data for thequantities for office refuse, and accessory chemicals such as coolant, was found, and it

may not be wise to assume that these are insignificant, in comparison to those listed in

the first sentence.

Column E - Regularity of live occurrence

Nearly everything listed in the table is used or will occur on a regular basis. Waste production, air emissions, chemicals being used, and wastewater production, will occur

constantly.

4:2: DISCUSSION OF THE FINDINGS IN APPENDIX 1

Since this is a theoretical study of car manufacturing and the associated environmentalissues, each of the ratings in columns A to E, is either 0 or 5, since information on the

quantities of chemicals used, and the nature of their storage and release into the

environment, will vary between plants. Not all the values estimated are certain,

especially as not all stakeholders may be interested in a particular environmental impact,and data on the quantities of chemical used or produced in a plant is not always available.

The ratings are listed in Table 3 over-page:





Table 3: environmental risk assessment ratings for various car manufacturing sites and activities

These ratings are very debatable. For example, TiO; is a toxic waste product, yet it is just

as "environmentally damaging" than refuse collection. Brake fluid and coolant contain

hazardous chemicals, which would harm both human health and the environment – yet

they are classed as being less environmentally significant than the trim shop, and refusecollection.

Through the EMS program, future ratings tables will be more informative, and theranking of environmental impacts will be more sensible than the above table. During an

EMS, the scale used will be both quantitative, and detailed- Instead of me YES/NO

approach, the significance of each impact under columns A to E, will be measured. Ascale between 0 and 100 is a common method, which allows managers to make more

informed decisions.





CHAPTER 5: Producing an Environmental Policy Statement

There is no standard format for a company environmental policy, although this is a

statement, which legitimizes the steps the company promises to undertake in its EMS

(McDonagh and Prothero, 1997).

The policy must have been agreed upon by those in senior management, and will

therefore reflect the nature, size and scope of the company (premises). The policy ismainly driven by legislation, and stakeholder values.

Standard requirements of the policy statement are:

• the company will seek to continually improve its environmental standards;

• it will develop alternative methods of production in order to reduce pollution, where

possible;

• it will implement a framework to set and review its environmental objectives andtargets;

• its ambition to comply with legislation;

• its activities will be properly documented, and self-regulated; and,• information can be made available to the public (EMAS only).

An executive manager must sign the statement, and the document must comply with theDocument Control ISO procedures. Once a draft is produced, it must be reviewed by

those at management level, who will decide if the statement addresses the scale of the

company, all relevant environmental laws, and can be understood by all employees.

Two example environmental policy statements are given over the next two pages (Figures5, 6).

An important feature, which has not been discussed at length in this report, is the need for

staff training. This will involve making the employees aware of the environmental issue

and policies in the workplace, or training them, in the event of new technologies or

procedures being established. This can help to consolidate their commitment towardsimproving the company's environmental standards, and it provides evidence for

regulators and the public, that the company is making these efforts.

A draft environmental policy statement for the car manufacturing plant is provided over-

page, which will be available to the public. Modifications to this will need to be made,once the EMS program becomes active.





Figure 5: Example environmental policy statement: Solid State Services PLC





Figure 6: example environmental policy statement: Capital & Regional PLC

Template EMS policy for a car manufacturing plant:

The ________ car manufacturing plant recognise that their activities have many (indirect environmental

impacts, including air emissions, water pollution and solid waste production.

The company is committed to developing an EMS (environmental management strategy), in which it seeks

to achieve the following targets and standards.

• Reduce VOC (volatile organic compound), acid rain-producing, and greenhouse gas emissions using best-

available technology.

• Improve the quality of waste-water effluent using better treatment methods, and reduce the overall

wastewater production where possible.

• Identify sources of hazar dous waste production, and find alternative means of processing these, or reduce

them at source, wherever possible.

• Identify non-hazardous alternatives which can replace the use of dangerous/environmentally harmful

chemicals or materials.

• Contribute towards a recycling policy for the car com pany, to reduce the number of used cars being sent

to landfill.

The company will develop an environmental program, in order for the company to meet current and future

environmental legislation. It is therefore committed to a continual process of environmental auditing,

improving environmental standards and auditing procedures, and will promote staff training and awareness,

through regular discussion meetings and instructions.

Signed

(Managing Director)





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APPENDIX 1

An environmental management system (EMS) for a car manufacturing plant.

Documents

Transcript of An environmental management system (EMS) for a car manufacturing plant.