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Environmental management, representation, and reporting

Integration of environmental management systems in line with DIN 14001 and EMAS

The environmental management system (EMS) is one part of the overarching management system and includes the organizational structure, responsibilities, behaviours, formal procedures, processes, and means for establishing and implementing environmental policy. The EMS includes recording and evaluating the effects of the company's activities on the environment and also the company's environmental policy, targets, and programs.

Representatives for immission control, water pollution control, hazardous incident prevention, and waste

The water pollution control representative advises the company owner or operator and employees in matters that may be significant for controlling water pollution. The representative's rights and duties are set down in legislation.

The representative for waste advises the plant owner or operator and employees in matters that may be significant for recycling management and waste management. The representative's rights and duties are set down in legislation.

The hazardous incident prevention representative advises the operator on all matters that may be significant for the safety of the plant.

The immission control representative is to be appointed when required under Germany's Federal Immission Control Act (BImSchG) based on the size and nature of the plant producing emissions and requiring approval.

Emissions declarations (11th German Federal Immission Control Ordinance, BImSchV)

According to the 11th BImSchV, the operator of a plant requiring approval has a duty to provide an emissions declaration every 4 years. This must state the emissions of air pollutants produced by the plant and the throughputs of substances contributing to the emissions.

Safety design concepts and safety reports and emergency plans in line with the German Federal Immission Control Ordinance, BImSchV

Plants in which hazardous substances are present in appreciable quantities are subject to the regulations of the Hazardous Incidents Ordinance (12th BImSchV). Depending on the quantities of substances present, the operators must also draw up a safety design concept, safety report, or emergency and hazard response plan.

In developing a concept for preventing hazardous incidents, the operator is made aware of his or her reporting duties to provide the necessary conditions for preventing hazardous incidents and limiting the effects thereof through a suitable organization.

The purpose of the safety report is to provide a written account of the implementation of the safety design concept, to identify risks of hazardous incidents, and to ensure the performance and reliability of subsystems and the existence of emergency plans.

The emergency and hazard response plan is a description of the type and sequence of measures to be taken to control a hazardous incident and to limit its effects, and the necessary technical and organizational means and structures required for this purpose. Operators in an industrial sector with extended obligations must demonstrate in the safety report that internal emergency plans are available.

Health and safety coordinator

The H&S coordinator should be involved right from the design phase of a building proposal. S/he should draw up the health and safety plan, or have said plan drawn up, and compile a document with the required information regarding health and safety, which document is to be taken into account during any later work on the structural installation.

In the context of executing a building project, the H&S coordinator oversees the implementation of the general principles of section 4 of the German Occupational Safety and Health Act (ArbSchG), adapts the health and safety plan to the needs of the particular case (or has it adapted), organizes cooperation between employers, and coordinates supervision of correct working practices by the employers.

PRTR reporting duties

Operators of factory equipment are required to submit a PRTR report if the following criteria are fulfilled:

  • at least one activity is carried out in accordance with annex I of the E-PRTR Regulation,
  • pollutant emissions exceed one or more of the thresholds set in annex II of the E-PRTR Regulation,
  • more than 2 tonnes of hazardous waste or 2,000 tonnes of non-hazardous waste are removed from the location each year.

The report is submitted in electronic format using BUBE-Online software.

Implementing the REACH Regulation

When the EU REACH Regulation came into effect, existing EU directives and national legislation (in Germany, ChemG, GefStoffV etc.) were expanded within the framework of European policy on chemicals.

The REACH Regulation requires the manufacturer/importer of chemical substances, as defined by the legislation, to stipulate the area of application and possible uses, to record detailed exposure scenarios, and to produce comprehensive substance dossiers.