Southwest Environmental Limited

EPR + EMS - Necessary?

It is evident that EPR requires an Environmental Management System such as EMAS or BS8555 (Acorn or otherwise), the Under Generic Conditions of the Permit the General Management Section of a Permit States:

“in accordance with a written management system that identifies and minimises risks of pollution, including those arising from operations, maintenance, accidents, incidents, non-conformances [, closure] and those drawn to the attention of the operator as a result of complaints”

And what  does a an EMS require;

“The organization shall establish, document, implement, maintain and continually improve an environmental management system in accordance with the requirements of this International Standard and determine how it will fulfil these requirements.”[xxiii]

It would appear that there is a lot of overlap. EPR is a environmental management system in its self, there are many similarities between EPR and EMS; 

·         Helps Provide Insight in the Best Environmental Practice

·         Sets Performance Base Lines and Reviews

·         Documentation provide literature for plant operators

·         Reduces Environmental Risk

·         Creates a Holistic Attitude to Environmental Factors

And some differences:

·         EPR is compulsory if you are a permitted activity

·         There are no auditing costs associated with EPR

·         There are fines / prosecutions for non compliance with EPR

·         EPR is not pan European like 14001 and EMAS (although it does stem from IPPC Directive)

·         EPR will not win a company “green kudos” like EMS because it is compulsory

But it can be said that in fact in many ways that EPR replaces EMS, in term of functionality of an industry. It can be said that the “Continued Improvement” element of EMS, is one up from EPR, again demonstrating a company’s ethos.

Companies will keep EMS because of image, if you are doing extra (EMS) then you are in charge, you are a pioneer, you want to participate. However, EPR is a kick up the butt for all of the flagging industries, who up to now have been slow on the uptake.

In many ways you could compare EPR and EMS with safety features in cars, some companies have made Safety paramount over the last 30 years (Volvo, Saab) but is only now with Euro ENCAP ratings etc the likes of Fiat / SEAT  have pulled their socks up.