Approved OMV-EP Guideline – EMS

OMV-EP Guideline

Environmental Management
Systems

HSEQ-HQ-06-15-00

Prepared by: Date: 25 January 2010

Julian Roberts
E&P Environmental Manager

Approved by: Date: 25 January 2010

Rod Ritchie
Head E&P-HSEQ, Vienna

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 Approved OMV-EP Guideline – EMS

Table of Contents

1 Scope and Application ................................................................................................. 3

1.1 Scope ...................................................................................................................... 3
1.2 Application ............................................................................................................... 3
1.3 Effective Date .......................................................................................................... 3
2 Cross- References....................................................................................................... 3
3 Roles and Responsibilities........................................................................................... 4
3.1 Management............................................................................................................ 4
3.2 HSEQ Group............................................................................................................ 4
4 Definitions.................................................................................................................... 4
5 Guideline ..................................................................................................................... 5
5.1 EMS Background..................................................................................................... 5
5.2 Elements of an Environmental Management System ............................................... 6

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1 Scope and Application
1.1 Scope
The OMV E&P Environmental Standard (HSEQ-HQ-06-06-02) requires all E&P activities to
be managed in accordance with an Environmental Management System (EMS), consistent
with ISO 14001 or other similar internationally recognised standard.

The purpose of this guideline is to provide guidance on the preparation and implementation
of an EMS. The guideline follows the requirements set down in ISO 14001 but the scope
and extent of an EMS should be scaled to the requirements of the specific application to
which it relates.

1.2 Application
This guideline applies to OMV Exploration & Production GmbH, all its controlled
subsidiaries and OMV Australia Pty Limited (together “OMV EP Group”). “Controlled”
means the ownership directly or indirectly of more than fifty percent (50%) of the shares or
the rights of voting authority in a company, partnership or legal entity. Where OMV is
neither the operator nor holds the majority shareholding, OMV will seek to have this, or
similar, standards adopted for all operations.

1.3 Effective Date

The Guideline is effective with the approval date.

2 Cross- References
OMV Corporate Environmental Management Directive HSE 003
Environmental Standard HSEQ-HQ-06-06-02
EP Guideline – Management of Environmental Impacts During HSEQ-HQ-04-07-00
Projects
EP Guideline - Guidelines for HSEQ in projects HSEQ-HQ-04-01-01
HSEQ Management System Manual HSEQ-HQ-00-01-02
HSEQ System Audits HSEQ-HQ-12-01-00
EP Procedures for the Estimation of Emissions and Discharges HSEQ-HQ-06-13-00
Environmental Management Systems – Specifications with ISO 14001
guidance for use
Environmental Management Systems –General guidelines on ISO 14004
principles, systems and supporting techniques
Environmental Management - Environmental Assessment of ISO 14015
Sites and Organisations
Guidelines for Quality and Environmental Management Systems ISO 19011
Auditing

Integrated Management System Reference Manual IMS

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3 Roles and Responsibilities
3.1 Management
It is the responsibility of line managers to ensure that sites and projects are managed
according to the E&P Environmental Standard and the OMV Corporate Environmental
Management Directive. This guideline will assist line managers and venture staff with the
implementation of requirements relating to the development of an environmental
management system.

3.2 HSEQ Group

The HSEQ Group is responsible for supporting the line managers and their staff in the
implementation of this guideline. In doing so, the HSEQ group will provide technical advice
and assistance required to enable E&P activities to be undertaken while giving effect to these
requirements.

4 Definitions
Environment1
The surroundings in which an organisation operates including air, water, land, natural
resources, flora, fauna, humans and their interrelation.

Environmental Aspect
An element of an organizations activities, products or services that can interact with the
environment.

Environmental Impact
Any change in the environment resulting from the organisations environmental aspects,
both positive and negative.

Environmental Management System (EMS)

A structured framework for managing an organisation's environmental aspects (activities)
and implementing its environmental policy.

Some organisations have adopted the framework specified in national or international

standards, which set out the requirements of an EMS, and have had their systems
externally assessed and certified against these, others have developed their EMS in a more
informal way.

ISO 14001
A structured framework for identifying, evaluating, managing and improving an
organisation’s environmental performance.

Organisation
A company, corporation, firm, enterprise, authority or institution, or part or combination
thereof, whether incorporated or not, public or private, that has its own functions and
administration”.

1
EN ISO 14001:2004

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5 Guideline
5.1 EMS Background
Although a number of different standards exist, all EMS standards follow the typical PLAN –
DO – CHECK – ACT cycle – Figure 1 below. ISO 14001 is the most widely used standard
for Environmental Management Systems (EMS), and is one of a broad range of
environmental management standards in the ISO 14000 series.

Figure 1: Typical PLAN-DO-CHECK-ACT Cycle

An EMS helps to ensure that the organisation’s overall environmental objectives, as set out
in its environmental policy, are implemented throughout the organisation and that
employees, contractors and suppliers know their roles and responsibilities in helping the
organisation to achieve them. A critical part of the EMS which, along with the policy, drives
the setting of the environmental objectives is the identification of the environmental aspects
and impacts (see the definition above).

Regular measurements, monitoring and auditing of the organisation’s environmental

performance and the system that is put in place to improve it, provide management with a
basis for evaluating the effectiveness of the EMS and making changes as appropriate. A
core principle of an EMS is that of continual improvement, thereby leading to better
environmental performance by the organisation on a sustained basis.

The various components of an EMS are presented in Figure 2 and are discussed in more
detail below.

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 Figure 2: Overview of Environmental System Process

5.2 Elements of an Environmental Management System

5.2.1 General requirements

Before the system design and implementation is undertaken the scope needs to be clearly
defined, so as to set the scene for all personnel etc. It should state what will be included
within the EMS, as the EMS grows and evolves so does the scope.

5.2.2 Environmental policy

Central to an EMS is the environmental policy. The environmental policy is a declaration of

the organisation’s overall aims and principles with respect to environmental protection. It
must include a commitment to pollution prevention, the continual improvement of
environmental performance of the organisation and to compliance with environmental, legal
and other requirements.

In addition to emphasising the environmental effects that are the most significant, the policy
should also be used to communicate aims and objectives to employees and other
interested stakeholders (Figure 3).

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 Figure 3: Example of an Environmental Policy from OMV UK

5.2.3 Identification and evaluation of environmental impacts

A key element of an EMS is the process of identifying and evaluating the organisation’s
impacts on the environment and the activities that cause them (environmental aspects).
This process enables an organisation to prioritise how to implement mitigation / control
methods for it’s environmental aspects (through its associated significance). In some
instances the greatest effort may not be applied to the aspect with the greatest
environmental harm as this may require large capital investment which may rule it out in the
short term. The method for identifying significant environmental aspects is set by the
organisation but it needs to take account of the legislative, regulatory and other
environmental requirements that affect the organisation. For each of these significant
environmental aspects, the EMS needs to provide assurance to management and others
who might have an interest (e.g. environmental regulators and customers), that there is a
method put in place for its effective management.

5.2.4 Environmental review

The environmental review is a systematic process to:

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 • determine all the organisations activities and how the significance for each will be
assessed;
• determine the impacts the organisation has on the environment for each activity;
• understand which activities cause the significant impacts;
• understand which activities are covered by environmental legislation and
regulations;
• understand the extent to which significant environmental aspects are being
controlled and whether effective controls are already in place; and
• identify where objectives and targets for environmental improvement and implement
additional operational controls as necessary can be devised.

An easy way to get started on the environmental review is to map out the boundaries of the
EMS and highlight areas where there are environmental considerations. These could
include greenhouse gas emission sources, hazardous substance storage facilities or waste
disposal facilities.

The EMS should address direct and indirect environmental aspects. The environmental
aspects will vary for each project and can include the following2:

• Atmospheric emissions (including greenhouse gas, venting, flaring and ozone

depleting substances);
• Wastewater / effluent discharges;
• Freshwater use and management;
• Use of resources, consumption of utilities;
• Energy use and energy-efficiency;
• Solid and liquid waste management;
• Noise and Light Generation;
• Biodiversity impacts
• Terrestrial and marine impacts and project footprint;
• Other accidents with environmental impact (e.g venting, flaring);
• Chemicals management (REACH for Europe); and
• Spills of oil and other hazardous substances – including likelihood and potential
consequences.

Consideration should be given to impacts caused during normal and abnormal operating
conditions (i.e. periods of maintenance and shutdown), and to significant environmental
impacts that could occur during emergencies. Once impacts have been identified, their
significance should be evaluated.

5.2.5 Assessment of significance

Assessing the significance of an environmental impact is one of the most difficult parts of
environmental management. The significance of an environmental impact can be assessed
through consideration of:

• size, nature, frequency, likelihood and duration of the environmental impact;

2
IFC Environmental, Health, and Safety Guidelines & OMV Environmental Standard

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 • the sensitivity of the receiving environment and the extent to which the impact is
reversible;
• the extent to which the impact (or the activity, product or service which causes it) is
covered by environmental laws and regulations, or contractual requirements; and
• the importance of the impact to interested parties – e.g. employees, neighbours,
regulators.

However it is up to the organization to decide the specifics of what should be assessed.

5.2.6 Operational control, targets and objectives

The results of the ‘environmental review’ and the ‘assessment of significance’ are used to
identify operational control measures and to set objectives and targets for environmental
improvement. Objectives and targets need to relate to the environmental policy and the
identified environmental aspects. All significant environmental aspects will require
operational controls to ensure that actions are carried out as planned and some of them will
require objectives and targets for improvement. Identified objectives and targets should be
agreed & approved by the General Manager as their progress/achievement will need to be
reported to the senior management team as part of the Management Review process. In
some instances it may also be a legal requirement of a country to report how the
orgnaisation is doing with respect to meeting its objectives and targets.

5.2.7 Environmental programme

The environmental programme turns the environmental objectives and targets into practical
actions that can be taken to improve overall environmental performance. The programme
should identify individual responsibilities and the means to achieve the defined objectives
and targets within the specified time scales. It should translate the commitment to continual
environmental improvement set out in the environmental policy into practical actions. This
may be represented as an Environmental Management Plan (EMP).

5.2.8 Structure and responsibilities

Line management will need to assign tasks to people so that everyone knows what has to
be done. It is vital, if the system is to operate effectively, to know who does what, how,
when and with what authority.

Different people in the organisation will need different types and levels of training: some will
require general environmental awareness training; others training as auditors; the design
team might need training on how to integrate environmental considerations into new
product designs. The key is to make sure that people are given the knowledge and skills to
fulfil their roles in the EMS and to be able to achieve the environmental targets and
objectives they have been assigned responsibility for. Personnel competence is an ever
increasing requirement and consideration needs to be giving for proving that a member of
staff is competent to carry out their job with respect to the potential environment impacts
associated with it is imperative.

5.2.9 Procedures and documentation

The EMS must be documented and procedures need to be established to ensure that
everyone knows how the system operates and what is required. Documents should be kept
up to date and controlled so that only the most recent versions are available for use. Links
with other key documents (such as the Site Environmental History File required by the
Environmental Standard) should also be identified in the EMS. Procedures should be

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 established to ensure that activities are carried out in the appropriate manner. Although in
some cases long narrative procedures may be required, a flow diagram might be equally
effective in ensuring that a task is carried out properly.

5.2.10 Monitoring, audit and periodic evaluation of legal compliance

Information on the company’s environmental performance is essential if it is to track

progress against its environmental objectives and targets. Without reliable and robust data,
it can not be sure that it is in control of its environmental performance, or that performance
is improving as intended. Monitoring (and reporting) activities should be undertaken in
accordance with the Corporate HSE Procedure SMART Close: Annual HSE Reporting of
[2009] Data (28/10/2009), the EP Procedures for the Estimation of Emissions and
Discharges (HSEQ-HQ-06-13-00) and the EP Standard Monthly HSEQ Recording (HSEQ-
HQ-08-02-01).

One of the important requirements in any EMS is periodic evaluation of legal compliance.
This is a key task, which will help to monitor performance against environmental laws and
regulations and provide information. The frequency with which the evaluation is undertaken
depends on the potential environmental impacts of the activity, with the most significant
being checked more often than those of lesser importance. Legal and other requirements
are changing all the time, it is important that the organisation keeps up to date with new and
upcoming legislation, corporate requirements and other guidance that will have the potential
to impact upon current and planned operations.

Auditing helps to determine whether the planned elements of the EMS are being
implemented as intended and that the EMS is functioning as planned. It also provides
information to management on the overall performance of the system since the audit
findings will help to improve the EMS through new plans of actions. Audit of EMS should be
undertaken in accordance with the requirements of the EP Environment Standard (HSEQ-
HQ-06-06-02)

5.2.11 Management review

The EMS operates as a cyclical process of identifying, improving and checking. Periodic
reviews by management ensure that the EMS is achieving the desired outcomes and that
the environmental policy is being implemented. It will also provide a means for
management to review the organisation’s environmental performance trends to ensure that
performance is being improved and to instigate changes to the system as necessary.

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