A company sub-lets some of its buildings in its site boundary to other smaller businesses. When doing its ‘aspects and significance impacts assessment’ does the company need to consider the activity of these small business units? What evidence of control of them would a certification body be looking for? How much impact does the activity of these peripheral companies have on the company looking to gain a certification?
The company should indeed consider the activities of the smaller businesses to which it has sub-let buildings when assessing aspects and impacts. ISO 14001:2004 requires the company to consider the aspects that it can influence as well as those it can directly control.
Consequently, dependent on the operations being undertaken by the smaller businesses, such things as waste management and energy usage may be influenced, for example, contractually. Each shall contribute to the overall environmental impact of the company’s site.
Evidence of the controls that a certification body would be looking for could be documents such as the guidance and instructions issued by the company to the smaller businesses. Also the certification body would look to see how they address issues such as waste management. The provision of recycling skips would be a good indicator of how the company is attempting to positively influence the contribution of the smaller businesses’ to the overall environmental impact of the site.
Where the energy usage is being controlled by the company and on-charged to the smaller businesses, they could consider sourcing it from renewable green energy sources, fitting low-energy light bulbs and building management systems which would monitor and control the amount of energy being used in conjunction with natural light for each unit. The company could also consider fitting electricity meters for each of the units and then monitor and measure the electricity being used. If an upward trend is identified in one of the smaller businesses then this could be discussed with the tenants with a view to reducing the consumption by other energy saving measures.
In conclusion, an organization seeking third party certification for its environmental management system needs to demonstrate control over both its own direct impacts and also the indirect impacts of smaller businesses to which buildings on a shared site are sub-let. Failure to address those aspects of the smaller businesses which contribute to the overall environmental impact of the site (where an influence could be exerted) may be seen by the certification body as a failure in the environmental management system and could, therefore, prove a barrier to achieving certification.
By NICEIC
Trevor Nash is MD for certification at NICEIC. For more information visit www.niceic.org.uk
The ‘aspects and significant impacts assessment’ is a review of all activities, products and services controlled and influenced by the company including the activities of the small businesses.
The first part of the assessment considerswhether the company can exert control and influence. Although the degree of control of these independent businesses is likely to be limited, there will normally be some level of influence through the leaseor other contractual agreement. Having confirmed this, the assessment establishes what activities are being carried out and identifies relevant environmental aspects and impacts such as emissions, discharges, waste, nuisance, etc. For each identified environmental aspect, the company then determines whether the impact is significant.
It is only for those activities of the smaller businesses related to significant environmental aspects and impacts that the company should establish controls within the management system. If the company determines there are no significant environmental aspects and impacts related to the smaller businesses, there is no requirement to introduce environmental controls on the smaller businesses.
Finally, the level of impact of these peripheral enterprises on the company looking to gain certification will be based on the result of the 'aspects and impacts assessments' and the company's implementation of its procedures relevant to the small businesses. If the company concludes there are significant environmental aspects and impact related to the smaller businesses which it can influence then these should be controlled as defined in the management system.The certification body will look for evidence of effective implementation of these procedures. This is a requirement of the standard and thecompany would need to demonstrate conformance to their own procedures in order to begain certification.
By LRQA
Don Stanley is LRQA’s UK head of assessment. For more information visit www.lrqa.com
The response to this question relies very much on a number of factors. Firstly, do the sub-let buildings share the same water and sewage supply as the main business? If they do then the main company would need to take this into account in their ‘aspects and significance impacts assessment’.
There is then the location of the sub-let buildings and what is done in those buildings. If they are close to the main company and conduct operations that are medium to high risk then the company should be taking the sub lets into account. If they are some distance from the main company and are they carry out low to medium risk operations then it is probable that they should not be taken into account.
If they were to be taken into account then there would need to be evidence of planning consents and discharge consents to see what has been agreed with those sub-letting as far as environmental controls are concerned. There will also probably need to be periodic meetings and possibly inspections by the business sub-letting to ensure that their tenants are within the agreement.
By BSI
John Hele is a global product manager for BSI. For more information visit www.bsi-global.com
It depends on the way the organization defines its scope of certification and in line with the certification requirements. For the certification purposes the small business within the boundary will be regarded as separate legal entities and will not be included in the certificate.
If the organization is seeking to gain certification to cover the entire environment within where the small business are set-up and the activities of those small businesses that are likely to impact on the environment then, yes. In this instance they will need to demonstrate that they have considered all activities of the sub-let small businesses within their boundary when conducting the aspects and impacts assessments.
The organization must demonstrate through documentary evidence some of the key requirements of the standards that they:
- have a documented environmental management system in place that is capable of providing the support required to gain certification
- have identified all possible activities of theirs as well as of the small businesses
- have prioritised the aspects and impacts through an acceptable methodology for risk ranking and are tackling the most significant ones first
- have total control of those small businesses activities that can harm the environment. In that, they will need to provide documentary evidence of monitoring and measurements of controlled undesired outputs from those activities of the small business within the legal requirements. Monitoring instruments must have valid calibration documents
- have employees who perform the activities and carry out monitoring are adequately trained and are competent to perform their tasks and interpret the measurements and results taken
- are continuously monitoring the legal and other requirements that can impact on their activities and of the small business and are evaluating their compliance performance against those requirements
- are working closely with the tenants and ensure that there are no impacts on the surrounding environment due to their activities or of their tenants within the building or surrounding environment
- have a good communication system in place between themselves and the small business
By SAI Global
Alex Ezrakhovich is general manager at SAI Global Certification Services Pty Ltd. For more information visit www.sai-global.com
When implementing an environmental management system (EMS) to meet the requirements of ISO 14001, the company must consider environmental aspects that it can influence, as well as those it can directly control. In this scenario, sub-letting buildings within its site boundary for use by other businesses would be considered an activity over which influence could be exerted, and so should be included within the assessment of aspects and significant impacts. That is, given that the company has defined the scope of its EMS to include all buildings within its site boundary.
Assuming aspects relating to the activities of the tenants in the sub-let buildings are significant (as only significant aspects have to be taken into account within the EMS), an auditor seeking evidence of control may wish to look at the tenancy agreement between the company and the occupant businesses on its land. This would usually specify the tenant’s responsibilities and could contain, for example, environmental obligations such as waste management arrangements or permit conditions for water discharges to sewers or watercourses. It would be from this that influence over environmental aspects could originate. The company would need to provide evidence to demonstrate how the conditions of the tenancy agreement are being met, particularly where legislative requirements are applicable.
Further evidence of control could include monitoring and measurement, operational control and emergency preparedness procedures that, if necessary, may need to extend to the activities of the tenant businesses.
In terms of the impact on gaining certification – as with the activities, products or services of any organization – the company will be expected to have identified its environmental aspects, and for those it has deemed significant, demonstrated systematic management of them within its EMS. Provided satisfactory evidence can be provided of control and continual improvement that is commensurate with the environmental risk of those activities, then certification would be recommended.
By BM TRADA
Susan Morton is UK certification officer for BM TRADA Certification. For more information visit www.bmtrada.com
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