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RAP SPIDERWEB COLOUR PRINTERS LIMITED
APPENDIX I : Photographic evidence
APPENDIX II : RAP Spiderweb Environmental Policy
1.0 EXECUTIVE SUMMARY
The senior management of RAP Spiderweb have demonstrated a strong commitment towards achieving environmental improvement. This is supported by their intention to seek accreditation to the international environmental management standard, ISO 14001.
This review aims to facilitate the development of an environmental management system at RAP Spiderweb. It provides a comprehensive overview of the current position of the business with regard to the management of environmental issues, the requirements of ISO 14001 and current environmental legislation.
The main environmental aspects/impacts of the site are associated with their main business purpose: printing.
RAP Spiderweb currently employs***** full time staff and ****part time staff in order to meet the needs of continuous 24 hour / 7 day production. The commitment and enthusiasm for the development of an effective management system expressed by staff interviewed was very encouraging.
There was a question of compliance with environmental legislation identified during the site review, and several issues of general housekeeping needing attention. (details of which are contained within the body of this report).
2.0 REVIEW DETAILS
The objective of the review is to provide direction towards improved environmental performance. As such, this review should not be viewed as a technical compliance audit, but as a broad overview of the organisations current standing with regard to the management of environmental issues. A more in depth review (of each aspect identified within this report) will be required to determine the full scope of environmental improvements required.
The following Initial Environmental Review site visit was conducted on the 17th January 2008 by Nancy Thompson and Dr Charlie Clutterbuck of Environmental Practice at Work Co Ltd and Craig Johnston of RAP Spiderweb, followed by off-site research.
This review aims to facilitate the development of an EMS at RAP Spiderweb by providing a comprehensive overview of the company's current position with regard to the management of environmental issues. The review also relates RAP Spiderweb's performance with the mandatory requirements of current environmental legislation. The review focused upon the following key areas:
- Environmental Management.
- Environmental aspects of RAP Spiderweb's activities.
- Legislation and regulatory compliance, controls, existing policies, standards, regulations and codes of practice.
2.1 REVIEW METHODOLOGY
The preparatory environmental review was conducted by means of:
- A site inspection of premises and activities.
- Collation of existing reports and quantifiable data relating to RAP Spiderweb activities.
- Verification of existing environmental management procedures.
- Interviews with key personnel.
- The establishment of photographic evidence.
- Off-site research.
3.0 COMPANY PROFILE
RAP Spiderweb, Clowes Street, Hollinwood, Oldham, Greater Manchester. OL9 7LY Tel: 0161 947 3700 www.rapspiderweb.com
The business has an annual turnover of £xxxx. The business is unionised, members belonging to (insert union name) and the style of management is open and consultative.
Who owns it
how long in business
who are your major clients / main products
RAP Spiderweb is a collaboration of two successful print companies, with over fifty years combined experience, merging to become one of the leading providers of print for the not-for-profit sector. During the past two decades both companies embraced the technological revolution that swept the print industry. As one company RAP Spiderweb intends to carry on that investment in a way which will help to mitigate their environmental impacts whilst ensuring clients receive the best service possible.
Example of clients: Chew on This (pdf) - Food Magazine, published by Food Commission (printed by RAP Spiderweb on recycled paper)
RAP Spiderweb portfolio
3.1 LOCATION AND SITE HISTORY
| RAP Spiderweb is located in Oldham, Greater Manchester, OS REF: 390750,402750, on a purpose built industrial estate.
The premises are situated on the M60 orbital motorway at Junction 22, ideally placed to deliver quickly and efficiently throughout the UK.
The site was previously used for xxxxx.
Surface water drains feed into the River xxxxxx, running north-south to the west of the premises. A nature reserve is located to the south.
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Describe building - what it is made of, how many floors, age
(eg steel and brick construction, single storey, xxxx sq metres constructed in 1965 etc..)
A limited number of car parking spaces are located in the rear yard.
anything else? eg An electricity sub-station is located in the rear yard? or other outside constructions/landmarks that should be considered?
The building is heated by gas and or elctricity?
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RAP Spiderweb intend to include the whole of the Oldham premises, and all activities, in their environmental management system.
4.0 ENVIRONMENTAL MANAGEMENT
RAP Spiderweb currently has no specific environmental management programme or procedures.
4.1 EXISTING MANAGEMENT SYSTEMS
Do you have the quality management standard BS EN 1S0 9001?
Have you developed an effective system for the management of health and safety issues. The system encompasses a manual containing the health and safety policy, safety management issues and various procedures relating to safe operations and emergency response plans. All staff have easy access to copies of this manual. Staff are regularly updated with safety matters arising through xxxxxxx(meetings/emails?). Overall responsibility for health and safety issues lies with xxxxxxx.
Do you have any of these or anything similar for your sector= any sort of Charter Mark; IIP kite mark; Equal opportunities statement/policy; other?
(may or may-not be able to include this statement!) The structure and systematic framework of the quality monitoring and safety management systems will mirror many of the requirements of the proposed EMS. It would be prudent therefore, to integrate existing management systems for quality and safety with the EMS where there is an overlap. This will avoid unnecessary duplication between the systems. The systems will remain independent of each other, but will be designed to allow RAP Spiderweb to fully integrate the systems in the future.
4.2 GENERAL REQUIREMENTS OF ENVIRONMENTAL MANAGEMENT SYSTEMS
The environmental management standard ISO 14001 will enable RAP Spiderweb to formulate a systematic approach to tackling environmental performance, whilst identifying tangible financial savings. RAP Spiderweb will be required to establish and maintain an EMS. The principle aim of which is to facilitate compliance with the aims and objectives of an established environmental policy, and provide the means for demonstrating that compliance with the standard has been reached.
RAP Spiderweb will produce full system documentation, this will include environmental procedures. Once the EMS has been developed the associated procedures will be implemented and incorporated into the daily activities of RAP Spiderweb. After a reasonable amount of internal auditing, including at least one review of the environmental policy, RAP Spiderweb should be ready to submit their EMS for external certification assessment.
4.3 COMMITMENT
The pro-active approach adopted by senior management towards the development of an EMS is encouraging from the initial findings of this review, it clearly appears that a high level of commitment has been assigned to the programme. This is essential as the implementation of the EMS will require a considerable amount of management time.
RAP Spiderweb's senior management have demonstrated this commitment by formally outlining intentions in their policy statement.
4.4. ENVIRONMENTAL POLICY
RAP Spiderweb is developing an ambitious and robust environmental policy, this will be subject to modification at various stages to reflect the significant aspects and other requirements of ISO 14001 as the EMS progresses. The policy will act as the public statement committing RAP Spiderweb to an understanding of its environmental effects and achieving continual improvement through the setting of objectives and targets.
In order to meet the requirements of ISO 14001 the environmental policy will reflect the significant environmental concerns of RAP Spiderweb's activities. All aspects of their activities will have some impact upon the environment, not all of these will be considered as significant. The policy will recognise this and reflect the major issues identified through a more detailed assessment of RAP Spiderweb's environmental aspects, impacts and relevant environmental legislation. These will include the issues outlined in this review.
Once developed, the policy statement will be communicated internally and externally. It may prove suitable to display the policy on the website and in the Oldham office reception area. All employees will be made aware of the policy and it should also be made available to interested parties on request.
see draft policy in Appendix II
4.5 COMMUNICATION
To satisfy the requirements of ISO 14001 RAP Spiderweb needs to establish and maintain procedures to report internally and externally on its EMS.
In order to:
- demonstrate management commitment to environmental improvements;
- respond to concerns and questions about RAP Spiderweb's activities, products and services;
- raise awareness of RAP Spiderweb's policies, objectives, targets and programmes;
- inform internal and external interested parties about their EMS and performance as appropriate.
At present RAP Spiderweb does not have a formal procedure for dealing with environmental communication.
How do you answer queeries now?
To disseminate information internally, effective communication procedures should be developed between all functions of the business. Communication should be a two way activity in comparison to transmission, which is a one way instructional activity. Whilst it is acceptable to impart general environmental information, more specific systems issues, such as environmental policy, objectives and targets, should ideally be communicated to encourage active participation and discussion. This may identify how they can be achieved and possibly enhanced.
RAP Spiderweb currently uses team briefings, notice boards, e-mail and hard copy notices to communicate information relating to health and safety, quality and general business issues. These methods should be evaluated to determine the most effective methods of communicating issues relating to the EMS.
Provision of appropriate information through an effective communication system will serve to motivate staff and encourage understanding of the significance of the EMS and awareness of their own roles in respect of the policy and objectives.
RAP Spiderweb can choose whether or not to develop pro-active external communication procedures. ISO 14001 requires established and maintained procedures for receiving, documenting and responding to relevant communication from external interested parties.
4.6 RESPONSIBILITY & RESOURCES
Strategic management of the environment resides with Craig Johnston. (position?) Craig will need to develop a team who will take joint responsibility for some of the different parts of the EMS. The office manager, Diane XXXx will become responsible for xxxxxxxx
The team will need to meet regularly to discuss a broad range of issues relating to RAP Spider's environmental performance and will set motions for improvement. To ensure that the EMS is effectively managed and co-ordinated, Craig Johnston will take on the role of Environmental Manager. Ideally he should be supported and guided by the team who will act both in an advisory and implementation capacity. This team should be comprised of representatives from key activities across the business.
Environmental issues arising from the team meetings should be integrated into current board meetings, such as those covering quality, finance or business strategy. This will ensure that the policy and the EMS is subject to regular top management review.
The environmental manager, Craig, will have defined authority and responsibility for ensuring that the requirements of the standard are implemented and maintained. Craig will be responsible for the reporting of the progress of the EMS to the team for review and improvement.
The workload involved in implementing and maintaining an EMS can be considerable, it would be wise for RAP Spider to carefully select individuals to to be part of the team providing assistance to the environmental manager. Machine operators and shift supervisors are those with the greatest knowledge of particular activities and with the associated problems and pitfalls.
During the implementation project, specific tasks will involve the writing of procedures, manuals and various forms of documentation. Other tasks will involve activities such as waste management, supplier appraisal and purchasing. Members of the team should be chosen and given responsibilities according to their skills.
RAP Spiderweb will also be required under ISO 14001 to define and document the responsibility, authority and interactions of all key personnel who manage, perform and verify activities having a significant effect, actual or potential, upon the environment. The responsibilities should be effectively communicated to facilitate effective environmental management. As part of the EMS all employees having a key input into the system should have their environmental responsibilities documented.
Resources must also be provided to enable the system to be fully implemented and maintained. This will involve the provision of time, technology, finance and personnel. At this stage it would appear that full commitment has been given in terms of personnel for the overall management of the EMS.
4.7 ENVIRONMENTAL TRAINING, AWARENESS AND COMPETENCE
All employees will be involved in some way with the EMS, whether they will be involved in developing, reviewing or simply complying with it. They should therefore have some knowledge of its requirements relating to their job roles and activities and how they can contribute to the attainment of the environmental policy, objectives and targets.
Environmental training and awareness can have many benefits. Following training, staff are more likely to come up with useful ideas which can be translated into action. In addition many breaches of legislation are caused by human error. Development of an effective training programme will enable such incidents to be avoided or the impacts of incidents minimised.
To attain ISO 14001 registration RAP Spiderweb will need to identify the training needs of all personnel whose jobs have a significant impact upon the environment. This will evolve throughout the implementation activity (ie as significant aspects and impacts are identified and responsibility for their control assigned). Employees at each level of the organisation will need to be aware of:
- The importance of conformance with the environmental policy, procedures and the requirements of the management system.
- The significant environmental impacts, actual or potential, of their activities and the environmental benefits of improved personal performance.
- Their roles and responsibilities in achieving conformance with the policy and procedures and with the requirements of the EMS, including emergency preparedness and response requirements.
- The potential consequences of departure from specified procedures.
Persons who perform tasks which have significant effect upon, or potential to significantly affect, the environment should be competent on the basis of appropriate education, training or expertise. All employees will require different elements and levels of training. This can be determined by adopting a training needs analysis activity. RAP Spiderweb has not yet conducted a formal review of the environmental training needs of its employees. The company will also be required to provide environmental induction for all new staff and may wish to incorporate this with existing training methods. In addition the environment team members may require more thorough training with regard to specific system requirement issues. Within the context of the EMS. Procedures for identifying training needs and conducting environmental training will need to be established. As the EMS develops, training needs will be regularly assessed. All training will be recorded.
Once training needs have been identified, records should be kept as evidence for ISO 14001. Feedback and follow up to any training will also be required in order to assess any increased awareness and skills following the training activity.
5.0 ENVIRONMENTAL ASPECTS
The ISO 14001 standard defines an environmental aspect as an element of an organisation's activities, products or services that can interact with the environment. Environmental aspects will be those which impact upon the mediums of air, land and water, including the use of resources and the causes of nuisance.
The environment is defined as the surroundings in which a business operates, including air, water, land, natural resources, flora, fauna, humans and their interrelation. An environmental impact is defined as any change in the environment, whether adverse or wholly or partially beneficial resulting from the organisation's products, activities or services.
To meet the requirements of ISO 14001 RAP Spiderweb must establish and maintain procedures for identifying, examining and evaluating its environmental aspects over which it can reasonably be expected to have an influence. It should then determine those activities which have a significant impact upon the environment. Both direct and indirect aspects of its activities, products and services should be assessed.
The identification of environmental aspects is an essential element in the development of an effective EMS. A logical ranking method will need to be applied to each aspect identified to determine its environmental significance. Environmental, financial and technical factors will all need to be considered. These factors may promote or hinder action from being taken. Aspects deemed to be environmentally significant should be considered during the setting of objectives and targets and form part of RAP Spiderweb's environmental improvement programme.
Several environmental aspects have been identified within the following section of this report, which should be incorporated within a more detailed assessment of environmental aspects and ranking of significance. This section therefore aims to give an indication of the apparent significance of RAP Spiderweb's main environmental aspects.
5.1 MATERIALS
Craig - this is where i need a lot of input from you
Paper, card,
Ink etc Chemicals
Specialist Materials
A wide variety of chemicals are used in the printing and finnishing activities. please confirm CoSHH regulations are in place and bunded stores available for storage. . The spill response kit is stored xxxxxx making its immediate and effective use realistic. Solvents are recycled by xxx????. The bunded stores is well maintained and carries relevant notices (please confirm). Other areas where there is use of specialist and hazardous materials should be checked for regulatory compliance.
Aluminium sheeting for plate-making ......
5.2 BUSINESS ACTIVITIES: OVERVIEW
DESIGN
xxxxx
PREPRESS
xxxxx
PRINTING
Running on a 24-hour shift, RAP Spiderweb need reliable machinery. At one end of the print room is a five-colour B2 Heidelberg Speedmaster SM74, with coating unit on line. At the other a four-colour B2 Heidelberg Speedmaster SM74 perfector. Both presses are sheet fed and fully computerised. With the help of a time served operator they are capable of producing anything from an A6 postcard to a B2 poster. The five colour press prints five colours and seal on-line. While the four colour perfector can print either four colours one side or two colours on both sides simultaneously ie two back two.
Heidelberg machinery was chosen for reliability and as environmentally sound products. Link to Heidelberg Products overview
Heidelberg has pledged to support its customers at all stages of the print activity. Heidelberg solutions help users of their machinery to responsibly manage resources, such as energy, water and air. Heidelberg also provide advice on the most important products required for printing: ink and paper. By selecting suitable machines and methods, it is possible to design the print activity in an highly environmental-friendly way, whilst also cutting down on costs. Link to Heidelberg environmental protection.
FINISHING
RAP Spiderweb finishing department is capable of producing multi-paged publications using Stahl folders and Muller Martini stitch and trim machine. The folding machines can be adapted to fold leaflets and flyers in a variety of formats.
Finishing activities include: guillotining, punching, stitching, scoring, collating.
There are several specialist finishing activities not carried out in-house: lamination, perfect binding, wiro-binding, cutting and creasing. These operations are contracted out to quality trade finishers. (see 5.7 Suppliers and Contractors)
MAILING SERVICE
This facility is available to clients who need their printed items mailing out. Eg newsletter, magazine, conference flyer. RAP Spiderweb offers mailing service using envelopes with or without windows, pre-printed or not, or customised polywrap with a carrier sheet. Labels can be supplied by the client or printed from databases.
5.3 WATER
Water is used for both domestic purposes and during the printing activity.Regulatory and environmental pressures have increased the cost burden associated with consumption and disposal of large volumes of water. This pattern is likely to continue. It makes financial sense therefore to minimise consumption of this resource.
All water used by RAP Spider comes from (North West Water /United Utilities?) direct mains supply.
Do you store water anywhere?
The majority of hot water is provided by xxxx eg (a central boiler supply heated by gas).
need a bit about water used in activities
RAP Spiderweb is keen to take steps towards reducing water consumption. Water consumption is metered, annually/ quarterly / monthly (which) readings are taken, sewerage costs are also monitored.
bar charts - consumption / costs - any months showing significant increase + reasons why?
Measures can be taken to reduce water usage such as water limiting fittings and push taps. Measures to reduce consumption by modifying WCs could be taken. A review of water consumption and prompt action should be taken to mend any leaking taps and pipes. The following action points may be investigated as part of an overall water minimisation strategy :
- adopt low cost techniques to encourage staff awareness of things they can do to save water
- check for leakage in hidden pipes by identifying abnormal peaks in water use - this would require monthly monitoring
- encourage staff to report visible leaks
- install infra-red activated flush control devices to urinals
- use cistern volume control adjusters to restrict the quantity of water used for each flush
- install duel-flushing mechanisms to toilets
- install flow restrictors on taps
- do you already have any of the above?
All water is discharged to the main sewerage system. Some activities may produce substances which require specialist handling and treatment. The following areas should be investigated to ensure compliance with legislation and regulation:
- plate making
- printing
- xx
- xxx
Surface water drains feed into the River xxxx. These drains pose a potential pollution risk in the event of accidental spills. Plumbing for all sinks need to be checked for connections to foul sewer. RAP Spider should determine the outfall points of all drains on site and colour code indicating their destination.
Vehicle washing and cleaning should take place in designated and clearly marked areas, wash water should drain to the foul sewer.
Water consumption meter readings in cubic metres Note: 1 Cubic metre = 220 gallons, total annual consumption 1,789,920 gallons
E : Estimated reading as per North West Water invoices.
Total metered water consumption chargesxxxxxx
Sewerage chargesxxxxx
Total metered charges for 12 monthsxxxxx
Water consumption by month......
Total consumption xxx gallons costingxxxxx and incurring sewerage charges of xxxx (in addition to the water charges made as a rateable value by building?)
5.4 ENERGY
Cost control and energy reduction is a key concern for most businesses. It is now widely recognised that minimising energy use provides significant cost saving opportunities and can improve profitability. The consumption of energy also represents a significant environmental impact in terms of climate change/global warming caused as a result of energy generation.
RAP Spiderweb has taken a pro-active approach to energy management by inviting the Institute of Manufacturing, in August 2007, to conduct an energy audit. Their recommendations have enabled RAP Spiderweb to prioritise areas for improvement that could be encompassed within the objectives and targets of the EMS. (link to audit / recommendations)
The principle uses of energy are for press operating, finishing activities, heating, lighting and for computer equipment.
When replacing old for new lighting units RAP Spiderweb has actively sought to install energy efficient units and systems. eg xxx
Figures for electricity and gas usage by building were not/are available at the time of writing this review? (bar charts of consumption and costs?)
RAP Spiderweb does not have an energy policy or targets for consumption levels, however tariffs are reviewed regularly and invoices are checked against meter readings?
RAP Spiderweb could consider implementing the following no-cost or low-cost energy conservation techniques which could potentially realise financial savings of 10% or more:
5.5 WASTE: MANAGEMENT, DISPOSAL AND MINIMISATION
Increasingly stringent legislation has meant that producers of waste face greater legal and financial liabilities for any damage caused by their waste. Disposal costs as a result of landfill tax, compounds this fact. Businesses are therefore under greater pressure to control their waste and develop programmes to minimise waste production.
RAP Spiderweb produces a minimum of controlled and special wastes, which are covered under the Environmental Protection Act 1990 and the Special Waste Regulations 1996. As part of the environmental aspects/impacts assessment RAP Spiderweb should complete a detailed inventory of all wastes. Waste transfer notes and Duty of Care documentation are maintained. Special wastes are collected on request by xxxxxx and all regulatory procedures are adhered to. Relevant documentation was checked during the site visit and found to be in order. (please confirm this is all in order?)
RAP Spiderweb could investigate potential markets for paper and cardboard; however the mixes of paper waste are not readily seperated to allow for recycling (coated / non-coated sheet cuts). Recycling is already in place for the aluminium shheting used for print plates, these are collected by xxxxxx - documentation is in place.
RAP Spiderweb may also wish to evaluate the potential for reducing waste on a more strategic basis. Several opportunities exist which could be further explored through the adoption of a waste minimisation strategy. This would form part of the objectives and targets of the environmental improvement programme.
RAP Spiderweb currently uses xxxxx to collect and dispose of site waste. The following waste collection system is in place: (replace list below with your own containers)
1 x 14 cubic yard compactor emptied on request or weekly.
1 x 14 cubic yard enclosed skip emptied on request.
5 x 6m (8 cubic yard) F.E.L. containers emptied weekly.
The weekly cost to RAP Spiderweb (including Landfill Tax) is xxxxxxx Annual waste collection and disposal costs xxxxxx
Waste is collected on the shop floor in black refuse bags?.... and all staff who handle waste are aware of their responsibilities ????. who place the collected waste in the skips/bins?
No waste audit has been carried out and there are no waste streams in place.
what about waste chemical drums / ink containers / etc? hazardous and special wastes?
5.6 SITE MANAGEMENT AND HOUSEKEEPING
Site management plays a part in the overall environmental performance of RAP Spiderweb and the image it presents to staff, clients and the local community. Good housekeeping should therefore form an integral part of the EMS.
External housekeeping
The external visual appearance of the site is generally good. Adequate parking is provided for staff at the rear of the premises. The visual impact of its surroundings is let down by the scrub land at the rear of the premises. Tree and shrub could be maintained or landscaped and adequate seating and litter bins provided for staff and visitors convenience. Potential for bird table and other conservation features. Pathways and road surfaces are well maintained, being relatively clean and litter free. External lighting is adequate ?/ non-existent? and is switched on / off at ?
Internal housekeeping
Few queeries here re storage and the area for plate making appeared to have containers of chemicals ' shoved' under a bench.... need another look around and chat re this
Marked floor areas around machinery and storage areas in line with H&S requirements, but incomplete. Height of heavy items stored possibly an issue re H&S?
5.7 SUPPLIERS AND CONTRACTORS
There is a need to take account of the environmental impact of suppliers and contractors for the purposes of the ISO 14001 standard. This asks businesses to identify both direct and indirect effects of their suppliers and contractors activities over which they can reasonably be expected to have influence.
Whilst it is accepted that the influence of RAP Spiderweb will be limited, the requirement to be exercising control over suppliers and sub-contractors should be in place. The EMS requires that contractors be made aware of relevant system requirements, the contractors should accept the site rules and their environmental responsibilities. This needs to be documented. RAP Spider have already set in motion a systematic survey of suppliers and contractors using a questionnaire
It is desirable to adapt a system whereby, if two companies demonstrate identical quality, capabilities, price and delivery, business should be directed towards the company able to demonstrate better environmental performance.
(do you use any contractors? )Contractors, include those persons employed by a third party to provide security guards, cleaning, vehicle and grounds maintenance. No environmental information has been collected about these contractors, their products, materials, activities or policies.
RAP Spiderweb has a central purchasing system ?? which will be able to ensure that only those suppliers who have been approved for the EMS purposes are used.
5.8 EMERGENCY RESPONSE SYSTEMS
Under emergency situations such as floods, severe fires, chemical spills or tank ruptures, significant damage can be done to the environment if adequate contingency plans are not in place. This should include written instructions on emergency and response systems specifically in respect of liquids described under the CoSHH regulations.
An emergency plan for occupational safety, and fire prevention has been implemented (?). The plan defines responsibility in the case of an emergency and the correct procedures to be followed. Operational responsibility lies with xxxxx. The plan should include procedures for fire, explosion, flood, collapse of building, roof or floor, power failure, bomb or terrorist threat and chemical spillage. The plan should include a list of relevant external contacts, Environment Agency and Water Bodies should also be listed.
5.9 TRANSPORT AND DELIVERIES
Vehicles owned - size / capacity / age / fuel / driver competence / environmental creds or not?
Miles travelled by Craig (and others) to meetings? Would it be possible to reduce with eg skype conferencing?
Over 85% of RAP Spiderweb clients are situated in and around the London area. Monday to Thursday our London-bound driver sets off around 3 am to be in the capital first thing in the morning. This conserves fuel by travelling during the night so avoiding congestion, and motorway access direct to London ensures residential areas are not disturbed by noise or air pollution.
Local and other deliveries are co-ordinated from the office in Oldham, Greater Manchester.
6.0 LEGISLATIVE REQUIREMENTS
Under ISO 14001 RAP Spiderweb is required to establish and maintain procedures to identify, have access to and understand all legal and other requirements to which it subscribes, directly attributable to the environmental aspects of its activities, products and services. RAP Spiderweb will need to develop a register of legislative requirements. This will provide a method of reviewing obligations for compliance and could be updated regularly mirroring changes in legislation.
There is a trend in environmental regulation towards placing a legal Duty of Care on organisations to manage and improve their environmental performance. European and UK Government policy has also moved towards the polluter pays principle. Fines and heavy remediation costs are potential consequences of legislative non-compliance. Failure to monitor and respond to forthcoming legislation may expose RAP Spiderweb to such liabilities. It is important, therefore, that RAP Spiderweb is aware of and understands current environmental legislation affecting its activities.
A queery has arisen relating to the production capabilities of RAP Spiderweb:
If the facility has the capacity to consume more than 150kg per hour, or more than 200 tonnes per year, of organic solvents for printing, coating, degreasing, painting or cleaning, you may require a permit from your Environmental Regulator under Part A (A2 in England and Wales) of the Pollution Prevention and Control (PPC) regime.
In England, Scotland and Wales, a Part B permit is required to operate any activity for applying printing ink, paint or any other coating material to a substrate, or drying or curing after such application, where the activity may result in the release into the air of particulate matter or volatile organic compounds, and is likely to involve the use in any period of 12 months of:
(i) 20 tonnes or more of printing ink, paint or other coating material which is applied in solid form;
(ii) 20 tonnes or more of any metal coating which is sprayed on in molten form;
(iii) 25 tonnes or more of organic solvents in respect of any cold set web offset printing activity or any sheet fed offset litho printing activity; or
(iv) 5 tonnes or more of organic solvents in respect of any activity not mentioned in sub paragraph (iii)
(see http://www.netregs.gov.uk/netregs/sectors/273248/997634/1006156/?version=1&lang=_e)
6.1 LEGISLATIVE EXAMPLES
Legislation pertinent to the printing trade can be located on the Environment Agency website, NetRegs, under the relevant sector.
Water Resources Act 1991 Part III: Part III of the Act sets out provisions for the protection of controlled waters.
Section 85 (I) specifies that a person, knowingly permits or causes any poisons, toxins or polluting matter or any solid waste to enter any controlled water is causing an offence.
Water Industry Act 1991: Under the Water Industry Act 1991 (Section 118), effluent may not be discharged to public sewer without a discharge consent. Conditions of effluent quality and quantity are attached to the discharge consent issued by the sewerage undertaker. The consent lays down the permitted constituents, their amounts, flow and other parameters such as temperature and pH of the effluents.
Environmental Protection Act 1990: PART III - Statutory Nuisance (S 79-82): Local Authorities have the power to abate a statutory nuisance or to prevent one occurring. Statutory nuisance is defined in the Act as :
- Smoke emitted from premises so as to be prejudicial to health or a nuisance
- Fumes or gas emitted from premises so as to be prejudicial to health or a nuisance
- Any dust, steam, smell or other effluvia arising on industrial, trade or business premises and being prejudicial to health or a nuisance.
- Noise and Statutory Nuisance Act 1993
The Act extends the list of statutory nuisances contained in S79 of the Environmental Protection Act 1990. It now includes noise emitted from or caused by a vehicle, machinery or equipment in the street.
7.0 FUTURE WORK AND ACQUISITIONS
When planning future works opportunities arise to take into account environmental considerations. These include the construction of new buildings, or extension of existing ones, to maximise the use of energy through the choice of design and fabric of the construction. Investment should be made in choosing efficient lighting, heating, and other electrical components. Water usage considerations and inclusion of new technological and engineering innovations should be analysed.
All refurbishment or structural changes present opportunities for RAP Spiderweb to demonstrate commitment to environmental improvement. Lighting, heating, choice of materials, decorating and furnishings should all be chosen which offer, not only the most efficient, but also the environmentally sound alternatives available eg low emissivity double-glazing.
Contractors environmental statement and performance should be taken into account with the tendering procedure for these works.
APPENDIX II ENVIRONMENTAL POLICY STATEMENT
RAP Spiderweb Environmental Policy Statement
RAP Spiderweb is a supplier of full-colour print and associated services to the voluntary and not-for-profit sector. We provide the complete service from design through print to finishing and distribution from our print works in Oldham, Greater Manchester. This covers a wide variety of printed materials including multi-paged newsletters, magazines, annual reports, leaflets, folders and posters.
We are aware of the impacts our production activities have upon the environment and are committed to monitoring, assessing and changing, where feasible, our operations to reduce these impacts. Outlined in this environmental policy are the steps we are taking to enable us to develop our Environmental Management System.
This policy covers all aspects of our business: administration, studio, pre-press, printing, finishing, fulfilment, delivery, site and situation. We acknowledge the responsibility we have to ensure this policy is implemented and its aims and objectives are fully met. We will ensure our staff, suppliers and those contracted to dispose of our waste are aware of our policy and adhere to its principles.
Policy Aims:
- to demonstrate commitment to improve our environmental practices
- to reduce our negative environmental impacts
- to communicate our intention to develop an environmental management system in line with international standards
Environmental Objectives for 2008:
- Reduce all general waste generated throughout the print works and specific waste created from all production activities.
- Disposal of waste products: Establish a Chain of Custody for all waste collected from our site.
- Manage solvent use: Reduce the emissions of volatile organic compounds (VOCs) and substitute where feasible with vegetable-based products.
- Reduce consumption: Reducing material and energy consumption in all departments.
- CO2 emissions: Measure and monitor the quantity of CO2 emissions we generate and develop plans to mitigate emissions.
- Energy: Implement the recommendations made by the Institute of Manufacturing Audit carried out in August 2007.
Management have demonstrated commitment to fulfil these objectives by providing resources, staff training, procurement of expert advice and investment to improve facilities.
This policy will provide a platform to enable us to strive towards achieving ISO 14001 environmental accreditation .
Management will review the policy on a monthly basis as our environmental programme progresses.
If you would like to know more about our environmental policy and discuss how we are progressing please contact:
Craig Johnston on 0161 947 3700.
KEY RECOMMENDATIONS
4.3 Commitment
Recommendation 1 Build upon the strong commitment of Management to engage all levels of staff.
Recommendation 2 Establish an Environmental Team to include representation from each function of the business.
4.4 Policy
Recommendation 3 Obtain Senior management/board commitment to this policy.
Recommendation 4 Communicate the policy externally and internally.
4.5 Communications
Recommendation 5 Evaluate the suitability of current communication mechanisms for the communication of environmental information.
Recommendation 6 Consider the development of external environmental communication procedures, including procedures to deal with incoming communications.
Recommendation 7 Include updates to ISO 14001 implementation in the RAP Spider magazine 'Print Talk' and on www.rapspiderweb.com
4.6 Responsibilities and Resources
Recommendation 8 Assign adequate resources for implementation of the EMS.
Recommendation 9 Include relevant environmental responsibilities in staff job descriptions and contracts.
4.7 Training
Recommendation 10 Evaluate mechanisms for the provision of environmental training.
Recommendation 11 Develop a suitable environmental training programme after assessing the training needs of all staff.
5.0 Aspects
Recommendation 12 Establish procedures for identifying, examining and evaluating the environmental aspects of RAP Spiderweb's activities.
Recommendation 13 Establish quantified environmental objectives and targets.
Recommendation 14 Seek research and development funding and grants for partnership projects with an environmental theme.
5.1 Materials; 5.2 activities
Recommendation 15 Audit to identify materials and activities that may impact on the environment.
Recommendation 16 Audit consumables used by administrative departments.
Recommendation 17 Check bunds on chemical store / chemical use areas.
Recommendation 18 Check all areas where chemicals / hazardous substances are in use for legislative compliance.
Recommendation 19 Evaluate the potential to replace environmentally hazardous materials with those viewed to be less damaging
5.3 Water
Recommendation 20 Identify taps, WCs and urinals which do not have water saving devices installed.
Recommendation 21 Check discharges to sewerage system in recommended areas.
Recommendation 22 Ensure a comprehensive drainage plan of all sites is available.
5.4 Energy
Recommendation 23 Implement recommendations of energy audit.
Recommendation 24 Evaluate the potential opportunities to improve energy efficiency across the site.
Recommendation 25 Energy efficiency to be taken into account when replacing equipment.
5.5 Waste: Management, disposal, minimisation
Recommendation 26 Carry out a waste audit.
Recommendation 27 Consider opportunities to reuse and recycle wastes.
Recommendation 28 Ensure all special and hazardous wastes are documented and disposed of appropriately
5.6 Site management and housekeeping
Recommendation 29 Site management: tidy up around the scrub at rear of car park
Recommendation 30 Internal Housekeeping: ensure all chemical containers are stored correctly and in bunds whilst in use
5.7 Suppliers and Contractors
Recommendation 31 Develop procedures to assess the environmental performance of all suppliers, contractors and sub-contractors.
Recommendation 32 Develop an official document regarding environmental rules for contractors.
Recommendation 33 Contractors environmental policies should be taken into account when tendering for work.
5.8 Emergency response
Recommendation 34 Integrate more detailed emergency procedures for all foreseeable environmental incidents within the existing plan.
6.0 Legislative requirements
Recommendation 35 Ensure RAP Spiderweb is meeting its legal obligations including the statutory requirements for the storage and disposal of controlled and special wastes.
Recommendation 36 Develop a register of legislation and a means of updating this.
Recommendation 37 Check excemption (or permit compliance) with Part B Pollution Prevention Control
7.0 Future work and acquisitions
Recommendation 38 New works and acquisitions to be carried out using materials and designs that have the least environmental impacts.
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