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Evaluering af virksomheders erfaringer med miljøtilsyn Summary and conclusions
BackgroundThe Danish Environmental Protection Agency has a wish to strengthen the environmental inspections at companies, in a way which seems efficient and providing development of the companies, without compromising the authorities need to enforce the rules in force. As part of this work the Danish Environmental Protection Agency has required the present project which should result in a better understanding and insight into how the companies experience the control and enforcement of the environmental authorities, as part of the environmental site inspection at the companies.. In a retrospective perspective the project has evaluated whether the environmental inspection has influence on the environmental efforts of the companies, including an assessment of the use of self-monitoring, and if this has an effect on their own environmental work. Moreover an assessment has been conducted of the companies experience in environmental inspections, including an evaluation of the competences of the supervising authorities. Forward-looking the project has identified which wishes the companies in question have regarding the environmental inspections in the future. Interviews, questionnaires, workshops and other sourcesThe evaluation has been conducted in a combination of telephone interviews, electronic questionnaires and revision of additional source material. By gathering 3 different data sets which individually illustrate the main questions of the evaluation, it is secured that the main questions are illustrated in more than one way and from different approaches which, at the end, will ensure a better foundation for the right conclusion. The participating companies have been selected to maintain a representative cross section with regard to parameters such as geographical location, the environmental influence from the companies, the size of the company, the companies approach to the environmental work and line of business. Furthermore, The Danish Environmental Protection Agency has emphasised the importance of selecting companies with different inspection frequency from their respective environmental authority. In practice The Danish Environmental Protection Agency has selected the companies by asking a range of authorities in 3 chosen geographical areas to provide them with lists of companies, which have had an environmental inspection in 2009. From these lists the companies have been selected so the before mentioned criterias, have been fully complied with. The received lists did not contain any relevant contact details such as contact persons or email addresses which could be used for sending out the questionnaires. Therefore all selected companies where contacted by telephone to gain this information. In connection with this preliminary contact a number of companies indicated that they did not want to participate in the evaluation. As a consequence of the relatively large amount of companies which directly declined to participate in the evaluation (appr. 20% of the consulted companies), the results of the project should be taken with some reservations. Therefore the evaluation might not show an entirely precise picure of the situation since a number of companies which might be more critical towards the environmental inspection have not been part of the dialogue. Result: Common satisfaction with the possibility of improvementOverall a positive attitude can be seen from the respondents of the project and statements from the data material, towards environmental inspection as they are today. In continuation hereof, it is important to note that this is the answer from the companies which themselves wished to participate in the investigation. It is not possible to assess how the result would have been if all the contacted companies had answered. The experience of the environmental inspection is dependent on the size of the company and the professional background of the person responsible for environment. In particular minor companies think that the environmental inspection increase their attention to environmental conditions, that the inspection take precautionary measures against problems and that the instructions during the inspections add great value to the company. For the larger companies with more thorough environmental knowledge and a complete environmental organisation , the most important part is the possibility of a dialogue, including a dialogue about the future and the possibility of preventing problems through dialogue, the possibility of a check from outside the company and to justify the environmental work internally (both up and out in own organisation) and externally. The companies do not consider the environmental inspection as the main reason to conduct environmental work. On the contrary there is a widely held view that the company has to follow the rules. During an inspection the company gains more focus on concrete environmental conditions and this has a positive effect. It is consistent that self-monitoring in the present form is not used actively in the operation of the company. The collected data is not used as management parameter and is primarily considered as input to the control work of the authorities. An expression of satisfaction is given towards the supervisor´s professional knowledge and understanding of the conditions of the company. Though there is a great variation in the assessments of this. Similar the assessments varies a lot concerning whether the supervisor has the ability to make decisions and the pace of it. Factors with the most extensive influence to the environmental efforts of the companiesThe elements in the inspection process with the most extensive influence on the specific environmental effort of the companies are:
Finally, the tendency shows that the environmental inspections help a lot of companies to maintain their long-term focus on the environmental work. However, there is a difference regarding what large and small companies place their emphasis on, especially in relation to the content of the dialogue which takes place during the inspection. Small companies without special environmental competences find it important that the dialogue seems like a guidance. It also turns out that the awareness of the inspection has a greater influence on the environmetal efforts in the small companies compared to the larger ones. Large companies, where some has their own environmental competences, place their emphasis on the more critical assessment of the environmental efforts of the companies during the dialogue, conducted by a professional. Some considers the inspection as an extra audit which provides the companies with the possibility of using the results of the inspection in the continous development of the environmental efforts. Factors which provide most value for the companiesFor the large companies with more thorough environmental knowledge the most important part is the possibility of a dialogue including the possibility of preventing problems, the possibility of a check from outside the company and to justify the environmental work internally (both up and out in own organisation) and externally. For small companies the value of the inspection is to be updated regarding the environmental requirements they have to follow. It is also important for the small companies to be aware where they should place an extra focus to comply with the environmental demands, It is common that the environmental inspection provides a sense of safety compared to unpleasant environmental surprises with the risk of damaging the operation and image of the company. Through the inspection the companies have the possibility of being confirmed in their present work in accordance to the demands from the authorities, or to correct to the level requested and by doing so prevent problems which could arise. Finally it is appreciated that all companies in a line of business has mutual demands which also are enforced the same way. Factors with most value for the environmentThe environmental inspections create value for the environment when they gain specific improvements of the environmental conditions in companies, compared to if an inspection had not taken place. Therefore it creates most value for the environment when the supervising authority discovers companies which do not fulfil the requested level and makes sure that they do so through relevant enforcement. As mentioned earlier there is an evident tendency that the inspection is part of maintainance of many companies´ long-term focus on the environmental work, so they as a minimum complies with the present environmental demands. On the contrary there is no basis for an expectation of improvement of the environmental issues in the companies due to the inspection. This fact does not eliminate that some authorities in certain situations has played an active role in relation to help companies to an effort beyond legal requirements, but this project has not documented such a role. Potential for a strenghten more efficient environmental inspectionThe project concludes that the potential for a more strenghten and efficient environmental inspection lies within these areas:
As supplementary exampel of the above, could be mentioned the proposal of conducting trade specific check lists to conduction of the inspection, to increase focus on the most important environmental conditions of the company, and in relation to development of the competences of the supervisor so the supervisor master audit techniques. Possible steps for further development of the environmental inspectionFinally, the project provides a number of non prioritised suggestions for steps which can be implemented to improve the environmental inspections in the future. This is an idea catalogue. Some suggestions are easy to implement such as the proposal of the introduction of a voluntary evaluation in connection with finalising each supervision, implemented by the municipalities and the environmental centres. This can either be verbal or in writing and aim towards a faster action from the authority when they discover something inappropriate. Other proposals require further assessment before they can be implemented. For instance it should be easier legally to revise terms in order to make the terms more relevant and updated in relation to the actual activities of the companies. The methodology in conduction of the environmental inspection should be strenghtened so it reflects the wishes expressed by the companies to a larger extent. Among other things this includes preparation of the inspections with checklists, awareness of important focus areas and clear summary at the end of each inspection. Another suggestion is to develop and provide training courses which handles other subjects than the ones provided today regarding environmental inspections. The new courses should focus more on the ”soft parts” of the environmental inspection, such as the authority role, handling of experienced conflict (e.g. enforcement). Such an environmental inspection course could also include training in audit techniques which are requested by a number of companies including methodology and questioning technique.
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