Introducing an EMS policy for a car manufacturing plant

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

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

Introducing an EMS policy for a car manufacturing plant

CONTENTS
Executive Summary 1: Processes Occurring within a Car Manufacturing Plant, which are of Environmental Significance
1.1: Constructing a Car - a Simplified Description 1.2: Hazardous Materials, Wastes and Emissions from the Car Manufacturing Plant

2: Reasons for adopting an Environmental Management Strategy

2.1: Legislation 2.2: EMS Schemes 2.3: How an EMS can Benefit the Company

3: Developing and Environmental Management Strategy

3.1: The General Layout of an EMS Stategy 3.2: Environmental Risk

4: Analysing Hazards at the Car Manufacturing Plant

4.1: Categorising Activities in Terms of their Environmental Risk 4.2: Discussion on the Findings in Appendix 1

5: Producing an Environmental Policy Statement References Appendix 1 Appendix 2

(Table of 20 environmental impacts)

(Pollution from a car Manufacturing Plant the Issues)

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

Introducing an EMS policy for a car manufacturing plant

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 used to 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 future investment 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 the ISO 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, and energy/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 are vulnerable 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

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

Introducing an EMS policy for a car manufacturing plant

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 car together, 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.

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

Introducing an EMS policy for a car manufacturing plant

II: Primer spray Vauxhall cars are treated within a chromate rinse several times, in order to "even-out" the Zn(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 a mixture 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 175C in the Vauxhall Plant), in order for the paint to solidify. Another anti-corrosion treatment is performed at the end, whereby the car is sprayed 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.)

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

Introducing an EMS policy for a car manufacturing plant

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 damage resulting 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 to consider 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 enormous quantities 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 rain formation, 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 of VOCs (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

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

Introducing an EMS policy for a car manufacturing plant

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 is toxic 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 plant needs 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 and zinc), 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 be toxic 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 oil sludges. 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 will vary 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).

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

Introducing an EMS policy for a car manufacturing plant

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 Water Resources 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 factors such as stack height, and me transport of pollutants (www.aeat.com, 2002). VOCs, being a complex mixture of hydrocarbons, are also addressed under this legislationCompounds 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, such as 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 be allocated 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 newlymanufactured vehicles to be recycled (DTI, 2000). As described, this tax is specifically designed to encourage companies to produce less waste (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

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

Introducing an EMS policy for a car manufacturing plant

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 (TiO2), 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 the ISO 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.
Copyright of LabSearch (a working title of Dr Malcolm Sutherland), 2013

Introducing an EMS policy for a car manufacturing plant

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 environmental information. 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 approach taken, in developing the audit system (Sheldon, 1997; Krause et al, 2001). If audits are conducted properly and taken seriously, they can be highly advantageous to companies, 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 led to 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 be criticised 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, and rubber 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.

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

Introducing an EMS policy for a car manufacturing plant

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

Replacing potentially hazardous substances Alternative materials are available on The market. For example, Renault have replaced their 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). Electrodeposition 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 their environmental 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 its financial 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

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

Introducing an EMS policy for a car manufacturing plant

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 to its 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, especially chemical, food, transport and utilities (Scottish Natural Heritage, 1996). Although issues of compliance are raised within the EMS program, the actual compliance

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

Introducing an EMS policy for a car manufacturing plant

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 failures or 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

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

Introducing an EMS policy for a car manufacturing plant

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 be sustainable, 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 the context 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 base his/her convincing argument on a wide range of information, which is gathered in various ways (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 strategy should not interfere with profit, but should hopefully maintain or even improve this.

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

Introducing an EMS policy for a car manufacturing plant

3:1:2: Planning The scope and detail within the audit of die manufacturing plant, will vary, depending on how 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 intense the audit needs to be. The level of knowledge amongst stakeholders, and their influence on 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, along with 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 within respectable 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 used in 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 issues and 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

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

Introducing an EMS policy for a car manufacturing plant

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 and waste water; (iv) material handling procedures; (v) hazardous materials management; (vi) oil-containing equipment; (vii) asbestos (which is still used in car pedals); (viii) waste management 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:

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

Introducing an EMS policy for a car manufacturing plant

Figure 4: methodology for assessing environmental effects

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

Introducing an EMS policy for a car manufacturing plant

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, appropriate 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 taking action on me environmental impacts of their production activities.

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

Introducing an EMS policy for a car manufacturing plant

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 the use 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 grouped together 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 severity measurements (shown over-page). The matrix tables are not me only method of recording and comparing impacts and activities, 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 the environmental aspects (Lee, 1989).

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

Introducing an EMS policy for a car manufacturing plant

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

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

Introducing an EMS policy for a car manufacturing plant

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 not concerned, 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), is given 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 questionmarked. Column C - Global Environmental Impacts Air emissions including VOCs and CC>2 contribute to worldwide environmental effects such 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 the quantities 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 environmental issues, 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:

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

Introducing an EMS policy for a car manufacturing plant

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 refuse collection. Through the EMS program, future ratings tables will be more informative, and the ranking 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. A scale between 0 and 100 is a common method, which allows managers to make more informed decisions.

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

Introducing an EMS policy for a car manufacturing plant

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 is mainly 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 and targets; 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 the Document 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 (Figures 5, 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 towards improving 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 overpage, which will be available to the public. Modifications to this will need to be made, once the EMS program becomes active.

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

Introducing an EMS policy for a car manufacturing plant

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

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

Introducing an EMS policy for a car manufacturing plant

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 bestavailable technology. Improve the quality of waste-water effluent using better treatment methods, and reduce the overall wastewater production where possible. Identify sources of hazardous 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 company, 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)

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

Introducing an EMS policy for a car manufacturing plant

REFERENCES
Best Practise Guidelines Integrating Sustainable Development into the Automotive Supply Chain. Pages 3,25. Society of Motor Manufacturers and Traders Ltd., 2002. Clark, D. EMS from Above. Journal of Industrial Environmental Management 2000, p12. C.E.C. Study on the Technical and Economic Aspects of Measures to Reduce Water Pollution Caused by Discharges from the Industrial Sectors Involved in the Surface Treatment of Metal Final Report. 1.6.3.: Composition of the Effluents, pl6. Commission of the European Communities, 1992. Department of Trade and Industry (DTt). The Environmental Impacts of Motor Manufacturing and Disposal of End of Life Vehicles: Moving towards Sustainability. Pages 2-13. Crown Copyright 2000. Environmental Resources Management, 1996. Environmental Audit and Assessment: Concept, Measures, Practices and Initiatives. 5.7: Audit Verification, p68. Scottish Natural Heritage Review No.46. Giddings, T.J., Marlowe, I.T., Richardson, S.J,, MacDonald, E.K., Okeke, 0. Reduction of Volatile Organic Compound Emissions from Industrial Coaling of Metallic Surfaces using Carbon-Based Materials. Pages 3.5, 10.1. 1991 Commission des Communautes Europeennes (CEC). Harrison, R.M Pollution: Causes, Effects and Control (4 Ed.). Ch.5: Sewage and Sewage Sludge Treatment, ppll5-116. Ch.7: Air Pollution: Sources, Concentrations and Measurements, ppl84185, 190. Ch.13: Control of Pollutant Emissions from Road Traffic, pp330-331. 2001 The Royal Society of Chemistry. Kraus, D.V., Kraus, J.L. Limiting Exposure to Collateral Liability Associated with ISO 14001 EMS Audits. Journal of Corporate Environmental Strategy, Vol. 8, No.3 (2001), pp242-247. Lee, N. Environmental Assessment: a Training Guide. Ch 7: Impact Significance, Decisionmaking and Project Impementation, pp113-119, 132-133. 1989 University of Manchester (EIA Centre, Dept of Plannning and Landscape) McDonagh, P., Prothero, A. Green Management: A Reader. Ch.10: Constructing the Green Manager, pl85, Ch-12: Environmental Assessment, Auditing, and Information Systems, pp204206, 2i9-226. Ch.i3- A Model Protocol and International Standards for Environmental Audit, pp230-235, 240-248. Ch.24: "Greening" the Marketing Mix: a Review of the Literature, and an Agenda for Future Research, p417. Copyright 1997 Dryden Press Ltd. Nieuwenhius, P., Wells, P. Motor Vehicles in the Environment: Principles and Practise. Ch.l: Introduction, ppl-19. 1994 John Wiley & Sons Ltd Pritchard, P. Environmental Risk Management. Ch.3: Property-related Environmental Risks, pl7. Ch-5: Risk Management Integration, p56. Copyright 2000 Earthscan Publications Ltd.

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

Introducing an EMS policy for a car manufacturing plant

Radojevic, M., Bashkin, V.N. Practical Environmental Analysis. Ch.5: Soil, Sediment, Sludge and Dust Analysis, pp359-366. 1998 The Royal Society of Chemistry. Renault, 2002. (Papers from the Student Environment Pack.) "Target - Zero Waste", pp12, 24-25. "Environmental Protection". De-pollution and recycling (The Cleon Example), pp(1/6)-(1/10), (M5/1) - (M5/3), (M6/2). "Recycling"; pp18-26. Review of the Literature and an Agenda for Future Research, p417. Copyright 1997 Harcourt Brace & Co. Ltd Ryding, S. Environmental Management Handbook. 5:5: Remedial Actions, pp414-416. 1992 IOS Press. Sheldon, C. ISO 14001 and Beyond: Environmental Management Systems in the Real World. Ch.l: An Introduction to the ISO 14000 Series, pp22-26. Ch.2: the Limits of ISO 14001 as an Instrument of Global Corporate Environmental Management, pp45-57. Ch.10: Training and Environmental Management Systems, ppl83-192. Ch.12: Targeting Sustainability: the Positive Application of ISO 14001, pp2! 1-212, Ch.13: from EMAS to SMAS: Charting the Course from Environmental Management to Sustainability, pp246. 1997 Green Leaf Publishing Suzuki, 2001. The 2000 Suzuki Environmental Report: "Smaller, Fewer, Lighter, Shorter, Neater"; pp17-18, 22-24 Thoresen, J. Environmental Performance Evaluation - a Tool for Industrial Improvement. Journal of Cleaner Production 7 (1999), pp365-370 Toyota, 1999. Countdown to Change. Work in Progress, 1999. Toyota, 2000. News and Awards: Toyota Announces Ambitious Environmental Action Guidelines for US North American Plants Vanxhall, 2001. Vauxhall and the environment: pp4-7, 10. How We Build a Car, pp5- 11. Volvo, 2002. Environmental Statement 2002 Volvo Cars Gent (Belgium); pp4-9. Wathem, P (editor). Environmental Impact Assessment: Theory and Practise. Ch, 11: The EIA Directive of the European Community, pl99-201. 1988 Wathem (and contributing authors). Biddies Ltd.

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

Introducing an EMS policy for a car manufacturing plant

WEBSITES
These were viewed back in late 2002, and are no longer available. Only the titles and authors/owners are listed.

A.A.A., 2001. Getting Rid of Automotive Wastes. Coopers & Lybrand Consultants, 1997. Environmental Reporting: Why Produce an Environmental Report? Environmental Management, Vol.2, No. 1 (1997) CFP, 2002. Cleaner Production Opportunities: Automotive Sector in Pakistan. Pages 1 - 9. Department for Environmental Quality, State of Virginia (USA), 2001. ISO 14001 Environmental Policy (4.2). Envirowise, 2002. Environmental Management Systems. How to Assess Significance of Environmental Effects. Environmental Management Systems: Getting Senior Management Commitment. European Environment Agency, 1998. Urban Waste Water Treatment Directive - Directive 9S/15/EEC Amending Directive 91/27 I/EEC European Environment Agency, 2001. Guide to the Approximation of European Legislation in the European Union. Part 2: Overview of FU Environmental Legislation; C: Waste Management. Ford, 2002. Environmental Management System Manual. Appendix B: Aspects, Objectives and Targets. Environmental Management System Development & Implementation. HM Customs & Excise, 2002. Landfill Tax. Jasch, C. The Use of Environmental Management Accounting (EMA) for Identifying Environmental Costs. The Journal of Cleaner Production (2003). Kazan-Alien, L. Asbestos Finally Banned in the United Kingdom. Metrohm UK. Chromium. National Park Service (USA). Envirofacts: Antifreeze/Coolant Waste Management. Hazardous Waste Management & Pollution Prevention Team, Washington D.C, Scottish Environmental Protection Agency, 2002- Safe Storage and Disposal of Used Oils: PPG8.

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

Introducing an EMS policy for a car manufacturing plant

APPENDIX 1

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

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

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

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

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