TBR believes that continuous improvement in environmental management is an essential element within its overall business plan – minimising waste, consumption of resources and pollution goes hand in hand with high productivity and quality standards. This policy therefore applies to, and will be integrated with, all business activities, products and services with the potential to adversely affect the environment on a local or global scale.
We recognise and accept our legal duty of care toward the environment and are committed not only to complying with our legal duties and with other requirements to which we subscribe but to exceed these requirements where reasonably practicable.
Energy generation and consumption is a major contributor to the production of greenhouse gases and global warming and a significant cost to the business. We commit to actively managing our use of energy, reducing consumption and continuously improving efficiency wherever possible. We will also seek to minimise our direct and indirect consumption of other natural resources, particularly those obtained from non-renewable or non-sustainable reserves.
We will seek to identify all processes that generate waste – whether from the inefficient use of resources or the production of by-products, emissions or effluent discharges – and will seek to avoid pollution by eliminating, minimising or reusing waste products wherever reasonably practicable or, where this cannot be achieved, identifying and taking advantage of opportunities for recycling and waste recovery.
The basis of our environmental management system will be an ongoing review of business activities and the identification of aspects of our work that could have an impact upon the environment. This will be followed by the implementation of proactive steps to eliminate, minimise or manage them so that adverse environmental effects are at a minimum.
To enable us to measure our environmental performance, we will establish and monitor suitable objectives and targets that will promote continuous improvement year on year in our environmental performance.
The scope of the Environmental Management System extends to all products and services of the company.
Included within this definition, and in addition to planned operating conditions, are non-routine activities and foreseeable emergency situations
The environmental management system will also apply to those aspects of the activities of suppliers and service providers over which we have, or could have, an influence and the environmental performance of our business partners.
1. Environmental Aspects
The identification of those aspects (environmental aspects) of our activities, products and services that could have an impact upon the environment will be fundamental to our environmental management system. This policy will apply to those aspects over which we have control or can exert influence and will also apply to new developments, new or modified activities, products and services. Details of all environmental aspects will be recorded in the Register of Environmental Aspects.
Having identified our environmental aspects, we will assess those that have the potential to have a significant impact upon the environment (‘significant aspects’) and it is these aspects that will be taken into account in establishing, implementing and maintaining this environmental management system.
2. Legal and other requirements
The initial identification of legal requirements applicable to the business’ environmental aspects is the responsibility of the System Manager. Regular reviews of legal requirements relevant to the business will be carried out on a 6 monthly basis or when changes are made to business activities. The results of legal compliance reviews will be reviewed by top management during regular Management Review meetings.
3. Objectives, Targets and Programmes
In order to achieve continuous improvements in the performance of the environmental management system, objectives and targets associated with significant environmental aspects will be set by the Management Board and reviewed on a regular basis at the Management Review meeting. Objectives and Targets will be managed in accordance with Environmental Procedure EP3 (Objectives & Targets).
4. Competence, Training and Awareness
Induction training for all new employees will include the importance of conformity with the environmental policy and procedures. This will include information about significant environmental aspects and potential impacts associated with their work, and how their personal performance contributes toward protecting or polluting the environment.
Specific tasks or locations which could cause a significant environmental impact are listed in the Register of Significant Environmental Aspects. The company is committed to ensuring that all persons employed either directly or under a temporary contract, in carrying out tasks with the potential to have a significant environmental impact are competent on the basis of appropriate education, training or experience.
The competence of prospective contractors to comply with the terms of this policy will be verified as a part of the tender process, with contractor performance being monitored throughout the life of the contract.
In order to ensure that skills remain relevant, training records will be maintained and managed on an ongoing basis with refresher training being delivered, where required, at appropriate intervals.
In order for the environmental management system to function effectively, and to ensure that it responds proactively to business needs, it is essential that effective lines of communication exist between the various levels and functions of the organisation.
6. Control of Document
Where documents are used as part of the environmental management system, it is essential that they are effectively controlled to ensure that they are fit for purpose, that the correct version is available at the point of use, and is periodically reviewed to ensure that the document continues to meet requirements. In order to achieve this, all documents will be managed in accordance with Standard Procedure QP1 (Document Control).
7. Operational Control
The practical effectiveness of the environmental management system depends on processes and procedures associated with the significant environmental aspects, and those contributing to our environmental objectives and targets are carried out under planned conditions. Where deviation from planned conditions could lead to a failure of the aims and objectives of the environmental management system, procedures will be documented along with critical operating conditions that must be maintained.
Where goods or services supplied by external partners are associated with the control of significant environmental aspects, requirements will be communicated to them by the Aspect Sponsor.
8. Emergency Preparedness and Response
It is essential that operational control extends to foreseeable emergency situations. Risk assessments associated with the significant environmental aspects will be carried out to identify and assess the risks associated with the onset of emergency situations, and to plan effective controls to either eliminate the risk or respond effectively to them. Emergency response procedures will be prepared as required, in accordance with Environmental Procedure EP4 (Emergency Preparedness & Response).
Where emergency response procedures are put in place, they will be reviewed annually by the Aspect Sponsor or after actual emergency events, and tested at regular intervals to ensure effectiveness.
To ensure that processes associated with significant environmental aspects are being carried out within specified operating limits, suitable monitoring and measurements will be carried out on a regular basis, with the results being recorded in a suitable form. Documentation setting out the required operating conditions will be made available to those responsible for ensuring that compliance is maintained, along with appropriate calibrated equipment to enable them to take accurate measurements.
The results of monitoring and measuring will be reviewed on an ongoing basis, so that effective action can be taken to address deviations before hazardous situations develop. The results of monitoring and measurement will be formally evaluated against legal compliance or other standards, to which the business subscribes on an ongoing basis, by the Aspect Sponsor. A record of the findings of these formal reviews will be made and retained by the Aspect Sponsor.
10. Nonconformity, Corrective Action and Preventative Action
Processes and procedures associated with significant environmental aspects will include details of actions to be taken, to ensure that where deviations from planned operating conditions are detected, effective action can be taken to deal with the non-conformity to correct it or mitigate the environmental impact.
Nonconformities, Corrective actions and preventative actions will be dealt with in accordance with Standard Procedure QP4 (Nonconformities, Corrective and Preventative Actions).
11. Control of Records
Records required as part of our compliance with statutory obligations, or other standards to which the company subscribes, will be made and retained in accordance with Standard Procedure QP2 (Control of Records).
12. Internal Audit
Internal audits of the environmental management system are essential to the business, as they enable us to verify that planned actions are being implemented in the workplace. Audits will be carried out by Competent Internal Auditors. Internal Audits will be planned, carried out and managed in accordance with Standard Procedure QP3 (Internal Audit).
13. Management Review
The effectiveness of the environmental management system will be reviewed on a regular basis to ensure that it continues to be suitable, adequate and effective in managing the impact that the business has upon the environment. The management review process will be managed in accordance with Standard Procedure QP7 (Management Review).