Commission Implementing Decision (EU) 2017/2286Dangos y teitl llawn

PART 6 Organizational structure (roles and responsibilities), training and employee involvement

Corresponding EMAS requirement

1. The management shall ensure the availability of resources (including human resources) to ensure the good functioning of the system. Roles and responsibilities should be defined, documented and communicated (Annex II, A.4.1).

2. The top management shall appoint a specific management representative(s) who shall have defined roles, responsibilities and authority for ensuring the correct implementation and maintenance of the environmental management system and reporting to top management on the performance of that system (Annex II, A.4.1).

3. Training should be provided to employees to meet the EMS' needs (Article 1, Annex II, A.4.2)

4. Employees should be actively involved in the improvement of the organization's environmental performances. (Article 1, Annex II, A.4.2 and B.4).

1. Commitment of the management related to good implementation of the system and provision of necessary resources:

According to GIC 1946: ‘The enterprise must prepare an organisational chart or similar overview of the key roles in the organisation, such as the Eco-Lighthouse point of contact, the safety representative, chair of the working environment committee, HSE manager, head of procurement, and fire safety officer’.

According to Norwegian legislation, the top management is responsible for the management of the enterprise, comprising the HSE management and thus implicitly for the implementation of the environmental management system. If necessary resources are not provided, deficiencies would automatically appear at the next HSE- and Annual Climate and Environmental reports. These deficiencies will then be taken into account during the annual management review. This case could also create an obstacle for the next re-certification.

2. Specific representatives for the environmental management system:

One member of personnel is nominated environmental manager (Miljøfyrtårnansvarlig). This is not necessarily a full-time assignment, depending of the size of the organization. The environmental manager can be trained by the consultant at initial certification, or be taught by the previous manager. His/her tasks are:

• spokesman to the consultant (at the start of the process)

• spokesman to the certifier/verifier at initial certification and re-certification

• ensure compliance with the industry criteria

• train and motivate fellow employees.

• producing and submitting the annual Climate and Environmental report in the ELH web portal.

• discussing this report with the management at the ‘annual management review’ (ledelsens gjennomgang), as well as with the staff at staff meetings, disseminating the annual report in the organization, through intranet or other internal communication channels

• communicate particularly the organization's overarching environmental policy and the aims and goals for the coming year) as stated in the annual Climate and Environmental report to fellow employees

• contribute to improvement on a permanent basis.

ELH has implemented web-based training aimed at training the environmental manager (Miljøfyrtårnansvarlig) on how to complete the annual Climate and Environmental report, and specifically on how to achieve re-certification.

The ELH has specified an instruction for the environmental manager, as required in General Industry criterion 1947: ‘The enterprise must prepare written instructions for the employee responsible for Eco-Lighthouse implementation. The Environmental manager should involve, motivate and include the employees of the organization. ELH claims active employee involvement is a cornerstone of the ELH system’.

In larger organizations, additional staff can be involved through an environmental management group(1) (Miljøgruppe — EMG). The EMG can be integrated into the Health Environment and Safety (HSE) group which is legally compulsory for organizations with more than 50 employees.

3. Training:

Companies and organizations are bound by the General Industry Criterion (GIC) 1951: ‘The enterprise must have procedures in place for training employees in basic HSE and for informing them of changes. The training must include sound procedures pertaining to the external environment’.

The purpose is to ensure that employees possess sufficient knowledge and skills to perform their work in a proper manner and in accordance with HSE regulations. The scope of employee training will depend on the risks associated with the enterprise's activities. The main philosophy of the ELH is that the organization best knows itself and the competencies/needs of its own staff and therefore is its own best judge of which training is needed. The criterion is verified orally (by the certifier/verifier) by asking what procedures the enterprise has for training its employees and new recruits in HSE matters.

The key question is whether these trainings are oriented toward improving environmental performances, or only focused on procedural ELH items and HSE risk management. The HSE checklist used by ELH to assess whether ELH routines are known amongst the employees confirm that the scope of training goes beyond procedures and address key environmental areas such as waste management, energy efficiency or hazardous substance management.

4. Employee involvement:

To comply with EMAS requirements employees shall be involved in the process aimed at continually improving the organisation's environmental performance.

The appointment of an environmental group within the organisation and the active participation of employees in environmental activities is required(2). Employees are informed about the content of the Climate and Environmental report and shall also be specifically involved into processes contributing to environmental performance improvement such as waste separation. Different criteria (1953, 1962, 36) support continuous improvement through the use of an ‘idea bank’. These idea banks provided by the Eco-Lighthouse foundation contain different measures to improve performance in environmental areas such as transport, waste or energy in collaboration with the employees of the organisation.

Commission conclusion

The management is obliged by law to foresee the human resources for the correct functioning of HSE procedures and must — according to ELH rules — also appoint an ELH representative similarly to EMAS. The necessary resources to function properly shall therefore be made available to the responsible persons.

Organisations are also asked to train their employees in HSE competencies that include improvement of environmental performance and to involve employees in the implementation of the EMS and in environmental activities.

Based on these elements the Commission recognises that the part of ELH related to ‘Organizational structure, training and employee involvement:’complies with the corresponding EMAS requirements and can therefore be considered as equivalent.

(1)

Note that the HSE(Arbeidsmiljøutvalg) and the ELH (Miljøgruppe) group are different entities. The HES group is legally required when there are more than 50 employees. There is no compulsion to have an ELH group, but it is recommended by the ELH in organisations with more than a certain number of employees. Can be one and the same group, to ensure efficient organization and integration of ELH into existing management structures.

(2)

Eco-Lighthouse certification handbook 2016 — 3.2.4 Establishment and appointment of an environmental group/project group