(BAT) Reference Document for the Production of Chlor-alkali ...

Chapter 4
While both standardised systems (EN ISO 14001:2004 and EMAS) and non-standardised
systems apply in principle to organisations, this document takes a narrower approach, not
including all activities of an organisation e.g. with regard to their products and services, due to
the fact that the Directive only regulates installations/plants.
An EMS can contain the following components:
1. commitment of management, including senior management;
2. definition of an environmental policy that includes the continuous improvement of the
installation by the management;
3. planning and establishing the necessary procedures, objectives and targets, in conjunction
with financial planning and investment;
4. implementation of procedures paying particular attention to:
(a) structure and responsibility;
(b) training, awareness and competence;
(c) communication;
(d) employee involvement;
(e) documentation;
(f) efficient process control;
(g) maintenance programmes;
(h) emergency preparedness and response;
(i) safeguarding compliance with environmental legislation;
5. checking performance and taking corrective action paying particular attention to:
(a) monitoring and measurement (see also the Reference Document on the General
Principles of Monitoring) [ 70, COM 2003 ];
(b) corrective and preventive action;
(c) maintenance of records;
(d) independent (where practicable) internal and external auditing in order to determine
whether or not the EMS conforms to planned arrangements and has been properly
implemented and maintained;
6. review of the EMS and its continuing suitability, adequacy and effectiveness by senior
management;
7. preparation of a regular environmental statement;
8. validation by a certification body or an external EMS verifier;
9. consideration for the environmental impacts from the eventual decommissioning of the
installation at the stage of designing a new plant, and throughout its operating life;
10. following the development of cleaner technologies;
11. application of sectoral benchmarking on a regular basis.
Achieved environmental benefits
An EMS promotes and supports the continuous improvement of the environmental performance
of the installation. If the installation already has a good overall environmental performance, an
EMS helps the operator to maintain the high performance level.
Environmental performance and operational data
{Please TWG provide information on performance improvements of chlor-alkali plants due to
the implementation of an EMS.}
WORKING DRAFT IN PROGRESS
Cross-media effects
None reported. The systematic analysis of the initial environmental impacts and scope for
improvements in the context of the EMS sets the basis for assessing the best solutions for all
environmental media.
Technical considerations relevant to applicability
The components described above can typically be applied to all installations within the scope of
this document. The scope (e.g. level of detail) and nature of the EMS (e.g. standardised or
184 December 2011 TB/EIPPCB/CAK_Draft_1