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ETIV EMAS TECHNICAL IMPLEMENTATION

AND VERIFICATION

MODULE 10
Implementation of EMAS in a fish
processing industry

Developed in the scope of the project:

ETIV EMAS IMPLEMENTATION


AND VERIFICATION
Agreement N. P/02/B/F/PP-125531

Prepared by:

IPIMAR

November 2004

ETIV EMAS Technical Implementation and Verification

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ETIV EMAS TECHNICAL IMPLEMENTATION


AND VERIFICATION

Authors:

Maria Leonor Nunes


IPIMAR Instituto de Investigao das Pescas e do Mar, mlnunes@ipimar.pt
Andreia Martins
IPIMAR Instituto de Investigao das Pescas e do Mar, amartins@ipimar.pt
Carlos Cardoso
IPIMAR Instituto de Investigao das Pescas e do Mar, ccardoso@ipimar.pt

This project has been funded with support from the


European Commission. This publication reflects the
views only of the author, and the Commission cannot
be held responsible for any use which may be made of
the information contained therein.

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IMPLEMENTATION OF EMAS IN A FISH PROCESSING INDUSTRY

TABLE OF CONTENTS

TABLE OF CONTENTS
1

INTRODUCTION............................................................................................5

1.1.

DEFINITIONS............................................................................................................5

1.2.

APPLICABLE LEGISLATION ..................................................................................8

1.2.1

General Aspects .....................................................................................................8

1.2.2

Water .......................................................................................................................8

1.2.3

Air ............................................................................................................................8

1.2.4

Waste.......................................................................................................................8

1.2.5

Noise........................................................................................................................9

1.3.
1.3.

ADVANTAGES OF EMSS ......................................................................................10

FISH PROCESSING INDUSTRY .................................................................11

2.1.

GENERAL ASPECTS.............................................................................................11

2.2.

MAIN ENVIRONMENTAL CONCERNS .................................................................12

2.3.

DESCRIPTION OF THE FISH PROCESSING FACTORY.....................................15

2.3.1

Frozen Fish Industry............................................................................................15

2.3.2

Canning Industry..................................................................................................17

2.4.

IMPLEMENTATION OF CLEAN TECHNOLOGIES...............................................22

2.4.1

Product Modifications .........................................................................................22

2.4.2

Acquired Material Modifications.........................................................................22

2.4.3

New Equipments ..................................................................................................22

2.4.4

Use of Waste Materials on the Site ....................................................................23

2.4.5

Control and Monitoring .......................................................................................23

2.4.6

Organizational Measures.....................................................................................23

EMAS APPLICATION..................................................................................25

3.1.

PLANNING..............................................................................................................25

3.1.1

Environmental Policy...........................................................................................25

3.1.2

Environmental Review.........................................................................................25

3.1.3

Environmental Legal Requirements...................................................................30

3.1.4

Environmental Objectives and Targets .............................................................30

3.1.5

Environmental Programme .................................................................................32

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TABLE OF CONTENTS
3.2.

ORGANIZATION AND PERSONNEL ....................................................................37

3.2.1

Responsibilities....................................................................................................37

3.2.2

Training .................................................................................................................39

3.2.3

Communication ....................................................................................................39

3.2.4

Documentation .....................................................................................................40

3.2.5

Documentation Control .......................................................................................42

3.2.6

Operational Control .............................................................................................42

3.2.7

Prevention and Emergency Preparedness........................................................46

3.3.

OPERATION ...........................................................................................................47

3.3.1

Monitoring and Measurement .............................................................................47

3.3.2

Non-Conformances and Corrective and Preventive Actions ..........................51

3.3.3

Environmental Records.......................................................................................53

3.3.4

Internal Audits ......................................................................................................54

3.4.

ENVIRONMENTAL MANAGEMENT SYSTEM VERIFICATION ...........................58

3.4.1

Management Review............................................................................................58

3.4.2

Public Communication ........................................................................................58

3.4.3

Validation, Verification and Records .................................................................60

REFERENCES.............................................................................................62

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INTRODUCTION
1

INTRODUCTION

In the XXI

st

century, industrial companies must possess other dimensions beyond the competitive

capacity as economic success will depend even more on the companys good integration in the
social medium, starting obviously with the local community where the factory is located.
This reality calls for a new management philosophy, more concerned with the environment. With
this purpose, was created EcoManagement and Audit Scheme (EMAS).

1.1.

DEFINITIONS

The EMAS is an environmental management scheme for organisations operating in the European
Union and the European Economic Area. It aims to promote continuous evaluation and
improvements in the environmental performance of participating organisations.
The EMAS can be seen as a tool bringing together environmental protection and economic
development. Such a sustainable development is a fundamental goal for the European Union and it
cannot be achieved without the mobilization of all parts of our society. EMAS does not replace
Community or national environmental legislation or technical standards nor does it remove a
companys responsibility to fulfil all its duties under such legislation or standards.
In contrast to other standards (namely, ISO 14001), EMAS requires companies to publish an
environmental statement and provides for a certification system with independent environmental
verifiers and registration bodies. All companies operating one or more industrial sites are invited to
sign up with the standard.
At first, the company must adopt an environmental policy in which its overall environmental aims
and principles of action are established. In its policy, the company commits itself to complying with
all relevant environmental regulations and to continuously improving its environmental performance.
Afterwards an environmental review is conducted. This review is an initial comprehensive analysis
of the environmental issues, impacts and performance which are related to the activities of the site
to be registered. On the basis of the environmental policy and the results of the environmental
review, an environmental programme is established. The programme must have specific goals,
along with measures and deadlines for their application. Furthermore, an Environmental
Management System (EMS) has to be introduced which encompasses the organizational structure,
responsibilities, procedures and resources of the sites environmental activities. Once the EMS has
been implemented, an environmental audit is performed which evaluates whether the system is
suited to ensure compliance with all relevant regulations and the companys own environmental
goals. From the audit findings, appropriate corrective action is taken and new environmental
objectives are set. In order to inform the public about the companys environmental activities, an
environmental statement is prepared. And, finally, the company has to commission an independent
environmental verifier with the careful examination of the environmental policy, programme,
management system, review or audit procedure and the validation of the environmental statement.
Afterwards the company can apply to be registered under EMAS.
When registration is granted, the company has the right to use a statement of participation and
employ it for advertising purposes. After three years, if the company wants to remain registered, it
has to repeat the environmental audit, to update the environmental statement, and to get through
another examination and validation by an environmental verifier.
For the purposes of EMAS regulation there are some important concepts that need to be clearly
defined:

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environmental policy shall mean an organisations overall aims and principles of action with
respect to the environment including compliance with all relevant regulatory requirements
regarding the environment and also a commitment to continual improvement of environmental
performance; the environmental policy provides the framework for setting and reviewing
environmental objectives and targets;

continual improvement of environmental performance shall mean the process of enhancing,


year by year, the measurable results of the environmental management system related to an
organisations management of its significant environmental aspects, based on its
environmental policy, objectives and targets; the enhancing of the results need not take place
in all spheres of activity simultaneously;

environmental performance shall mean the results of an organisations management of its


environmental aspects;

prevention of pollution shall mean use of processes, practices, materials or products that
avoid, reduce or control pollution, which may include recycling, treatment, process changes,
control mechanisms, efficient use of resources and material substitution;

environmental review shall mean an initial comprehensive analysis of the environmental


issues, impact and performance related to activities of an organisation;

environmental aspect shall mean an element of an organisations activities, products or


services that can interact with the environment; a significant environmental aspect is an
environmental aspect that has or can have a significant environmental impact;

environmental impact shall mean any change to the environment, whether adverse or
beneficial, wholly or partially resulting from an organisations activities, products or services;

environmental programme shall mean a description of the measures (responsibilities and


means) taken or envisaged to achieve environmental objectives and targets and the deadlines
for achieving the environmental objectives and targets;

environmental objective shall mean an overall environmental goal, arising from the
environmental policy, that an organisation sets itself to achieve, and which is quantified where
practicable;

environmental target shall mean a detailed performance requirement, quantified where


practicable, applicable to the organisation or parts thereof, that arises from the environmental
objectives and that needs to be set and met in order to achieve those objectives;

environmental management system shall mean the part of the overall management system
that includes the organisational structure, planning activities, responsibilities, practices,
procedures, processes and resources for developing, implementing, achieving, reviewing and
maintaining the environmental policy;

environmental audit shall mean a management tool comprising a systematic, documented,


periodic and objective evaluation of the performance of the organisation, management system
and processes designed to protect the environment with the aim of:

(i) facilitating management control of practices which may have an impact on the environment;

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INTRODUCTION
(ii) assessing compliance with the environmental policy, including environmental objectives and
targets of the organisation;

audit cycle shall mean the period of time in which all the activities in an organisation are
audited;

auditor shall mean an individual or a team, belonging to the organisation personnel or external
to the organisation, acting on behalf of the organisations top management, possessing,
individually or collectively, the competences referred to in Annex II, point 2.4 of Regulation
(EC) N 761/2001 (2001) and being sufficiently independent of the activities they audit to make
an objective judgment;

environmental statement shall mean the information detailed in Annex III point 3.2 ((a) to (g))
of Regulation (EC) N 761/2001 (2001);

interested party shall mean an individual or group, including authorities, concerned with or
affected by the environmental performance of an organisation;

environmental verifier shall mean any person or organisation independent of the organisation
being verified, who has obtained accreditation, in accordance with the conditions and
procedures referred to in Article 4 of Regulation (EC) N 761/2001 (2001);

accreditation system shall mean a system for the accreditation and supervision of
environmental verifiers operated by an impartial institution or organisation designated or
created by the Member State (accreditation body), with sufficient resources and competency
and having appropriate procedures for performing the functions defined by Regulation (EC) N
761/2001 (2001) for such a system;

organisation shall mean 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 administrations.

The entity to be registered as an organisation under EMAS shall be agreed with the environmental
verifier and, where appropriate, the competent bodies, taking account of Commission guidance,
established in accordance with the procedure laid down in Article 14(2) of Regulation (EC) N
761/2001 (2001), but shall not exceed the boundaries of one Member State. The smallest entity to
be considered shall be a site. Under exceptional circumstances identified by the Commission in
accordance with the procedure laid down in Article 14(2) of Regulation (EC) N 761/2001 (2001),
the entity to be considered for registration under EMAS may be smaller than a site, such as a subdivision with its own functions.

site shall mean all plant location and surroundings at a distinct geographic location under the
management control of an organisation covering activities, products and services. This
includes all infrastructure, equipment and materials;

competent bodies shall mean the bodies designated by Member States, whether national,
regional or local, in accordance with Article 5 of Regulation (EC) N 761/2001 (2001), to
perform the tasks specified in this Regulation.

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INTRODUCTION
1.2.

APPLICABLE LEGISLATION

The Portuguese environmental legislation is somewhat vast, nonetheless there are some
fundamental laws encompassing water, waste, air and noise. All these legislation seeks to ensure
the environmental protection of valuable natural resources (water, air and soil) but also to defend
public health from chemically hazardous substances, biological threats or other dangers that can
arise in a disrupted environment. It must be emphasized that the Portuguese legal frame follows
closely all European legislation, moreover Portuguese authorities have made great efforts to
guarantee the application of the European environmental high standards to national reality.
Following these general comments, a list of the main laws is presented and each one of these is
explained in detail.
1.2.1

th

The law n 11/87 (L 11/87), published on the 7 April, is fundamental in the Portuguese legal
frame dealing with environmental issues. This law seeks to defend the quality of natural
resources, such as, air, light, water, soil, flora and fauna. Furthermore, it forbids pollution and
attributes all responsibilities to the organization that produced the pollutant agent(s).

1.2.2

General Aspects

Water
st

The law n 236/98 (DL 236/98), published on the 1 August, deals with the water issue.
Different water categories are defined by the main water applications: human consumption,
aquatic life support, bathing and irrigation. The norms that regulate wastewater discharge are
thoroughly defined. There was an important alteration to this law, establishing environmental
regional departments (DRA) as competent entities for setting discharge parameters of
industrial wastewaters for a particular site. This parameters setting must follow the criteria
established in article 64.

1.2.3

Air
th

The law n 286/93 (P 286/93), published on the 12 March, sets limit and reference values for
atmospheric pollutants. Namely, for sulfur dioxide, nitrogen dioxide, carbon monoxide, particles
in suspension, lead (limit value) and ozone (reference value). It also establishes reference
methods for sampling and analysis and, as well, the necessary criteria for selecting the most
suitable methods. Furthermore, are defined emission limit values that are applied generally or
to specific sectors.

The law n 78/2004 (DL 78/2004), published on the 3 April, establishes rules for prevention
and control of atmospheric pollutants. It defines measures, procedures and obligations for the
industrial operators, aiming to avoid or reduce to acceptable levels the atmospheric pollution
due to industrial activity.

rd

1.2.4

Waste
th

The law n 239/97 (DL 239/97), published on the 9 September, deals with the waste issue,
setting rules to which waste management has to comply. Namely, it forbids waste discharge

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INTRODUCTION
except in previously authorized locations and requires previous authorization for all operations
involving waste, such as, storage, treatment and elimination. Only storage of industrial waste in
the production site is exempt of authorization. Waste is defined as any substance or object that
its owner discards or intends to discard, in particular, all the substances or objects referred to
in the European list of wastes.
th

The law n 335/97 (P 335/97), published on 16 May, establishes rules for waste transport on
Portuguese territory. Only some entities are allowed to transport waste: the producer, the
elimination or treatment operator, the entity managing urban waste and licensed companies
according to a list approved by the waste institute (IR). It must be stressed that producer,
owner and transport operator are all responsible for any damage that waste transport may
cause. Producer/owner have to guarantee that all waste travels with a specific document,
describing type and amount of the waste. Urban waste transport does not require such
documentation.

The law n 366-A/97 (DL 366-A/97), published on 20 December, establishes principles and
rules for packaging waste management systems. It defines responsibilities for the packaging
waste management operators.

The law n 209/2004 (P 209/2004), published on 3 March, approves the European list of
wastes. It possesses three annexes, the first dealing with the waste list proper, the second
mentioning waste dangerous aspects (explosion, fire, etc.) and a third annex encompassing all
waste elimination operations.

th

rd

1.2.5

Noise
th

The law n 292/2000 (DL 292/2000), published on the 14 November, addresses the noise
issue. It distinguishes temporary and permanent noise and, on the other hand, sensible and
mixed zones. The former ones encompass areas where houses, schools, hospitals and other
collective installations were built or are planned to be, the latter ones are occupied by other
activities such as commerce. Quantified limits are set for the two zones making a further
distinction between day and night time.

The law n 259/2002 (DL 259/2002), published on the 23 November, alters some aspects of
the previous law (DL 292/2000), namely, for activities generating temporary noise, the special
noise license is attributed by the municipalities and, regarding all surveillance and penalties
application, a bigger role is given also to the municipalities.

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1.3.

ADVANTAGES OF EMSs

The implementation of an environmental management system (EMS) can bring important benefits
for industrial companies. It is worth mention four different groups of reasons:

Cost reduction the operational efficiency can be improved by reducing raw materials wastes
and energy consumption. On the other hand, a better environmental behaviour allows cheaper
insurance quotes.

Risk reduction this means that the likelihood of serious and costly accidents is smaller.
Because an EMS guarantees better control processes for pollutants emissions, spillages and
various possible kinds of accidents. Therefore, penalties for breaking environmental laws are
avoided, which is another striking point with advantageous economic consequences.

Competitive benefits an implemented EMS improves the companys image with the
consumers, regulatory authorities and general public. It can also mean friendlier borrowing
conditions and a good relationship with the local community where the company is located.

Setting an active organizational structure this makes possible accomplishing all the
commitments subscribed in the environmental policy.

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FISH PROCESSING INDUSTRY


2

FISH PROCESSING INDUSTRY

2.1.

GENERAL ASPECTS

There are specific factors that bring an additional level of complexity to the environmental problems
found in the fish processing industry. Namely, this industry deals with a large number of products
due to the diversity of fish species and to the different forms in which fish are marketed (fresh,
frozen, smoked, canned and others). Such a reality means specific environmental problems within
each production line. Another factor is the highly perishable nature of fish compared with other food
products. As the quality of fish deteriorates over time, product yield decreases and product losses
contribute to the waste loads. However, pollution loads are highly dependent upon the type of fish
being processed. The processing of oily fish species generates more waste due to the high oil
content and the fact that these species are usually not gutted or cleaned on the fishing vessel.
Some limitations of the fish processing sector lead to serious difficulties in addressing
environmental issues. One can mention the companies small size, the absence of established
environmental policies and the low level technology. The automation of the handling of fish and
fillets is difficult because of the slippery surfaces, size variability and delicate nature of the product.
This means that operator practices have a significant impact on the plant environmental
performance.
In spite of these problems, there are some potentially positive interactions in fish processing
industry, bringing together environmental awareness and an enhanced factorys efficiency.

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FISH PROCESSING INDUSTRY


2.2.

MAIN ENVIRONMENTAL CONCERNS

First and foremost, fish processing industry has a huge impact on the sea life resources as
consumes over 120 million tonnes of fish per year (Nunes and Batista, 2002). Beyond this large
number lies another frightening reality, over 20 million tonnes of fish waste produced each year
(Figure 1). It is unsustainable such a mismanagement of an overexploited resource by the fish
processing industry. Secondly, the great amount of waste (solid waste and wastewater heavily
loaded with organic matter) poses itself a serious environmental problem. Another noteworthy
aspect relates to the significant levels of water and energy consumption. Like the first aspect, this
raises concerns about resources renewal (in particular, drinkable water is a precious asset).
Therefore, fish processing industry raises serious environmental challenges that must be tackled.

FISH PRODUCTION - 120 M.T.


HUMAN
CONSUMPTION

FRESH

Non-food
OTHER
USES
uses

17%

33%

INDUSTRIAL
WASTE
20 M.T.

HUMAN
CONSUMPTION

PROCESSED

50%
Figure 1 - Fish production applications and generated waste
A good knowledge of all common operations in fish processing industrys activity enables a more
detailed picture of the main environmental concerns already mentioned.
First, water consumption reaches high levels as fish filleting and canning processes absorb huge
quantities of fresh water. Water is used for transporting fish and offal around the factory, for
cleaning factory and equipment, for rinsing raw materials and products, and for thawing frozen fish.
Energy is another precious asset also intensively consumed by various process operations, as
heating, cooling, freezing, drying and many more. All equipments require electrical energy. This
exerts pressure on the fossil fuel resources (oil, coal or gas), whether such energy is bought as
suppliers largely produce electricity in thermo-electrical plants or produced in situ with steam
generators.
Effluent discharge is also an important concern because effluent streams generated from fish
processing contain a heavy organic load due to the presence of oils, proteins and suspended
solids. Furthermore, there are high levels of nitrates and phosphates. Many operations contribute to
this reality, raw fish handling, water transport, defrosting, gutting, scaling, portioning and filleting,
and, of course, the rinsing of fish products.
Solid waste is also a crucial aspect, specially, since large amounts of fish waste are produced in
several operations such as, gutting, de-heading, cutting and trimming and, necessarily, filleting. But
other solid waste must also be noticed, all cardboard and plastic from raw materials and final
products packages. The plastics constitute a serious concern, in that are non-biodegradable
materials unable to be broken down, safely and quickly, by biological means, into the raw
materials of nature, therefore, requiring thorough recycling.
For operations that require refrigeration systems based on chlorofluorcarbons (CFCs), the loss of
these gases to the atmosphere is an important environmental consideration, since CFCs are
deemed to be a major cause of ozone depletion. Happily, such deleterious gases have been
banned and the new refrigeration systems use other gases not so harmful for the environment as,
for instance, ammonia.

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FISH PROCESSING INDUSTRY


Odour generation can be an important environmental issue, arising from storage and handling of
fish waste or from cooking and drying operations necessary to produce fish meal. The factorys
location is particularly relevant since disagreeable smells may disturb possible neighbours.
Finally, noise caused by fish processing operations is a relevant concern, not only for the impact on
the factorys surroundings but also for the effect on the workers health. Specially, canning factories
generate much noise due to the various operations involving the metallic cans.
The near absence of chemically hazardous substances in the fish processing industry is a positive
environmental aspect, however it is worth mention the detergents and sodium hydroxide applied in
the equipment and floor cleaning operations.
An overall view of these environmental impacts is given in Figure 2 for frozen fish industry and in
Figure 3 for canning industry.

WATER

FRESH
OR
FROZEN FISH

WASTEWATER

SOLID WASTE

ENERGY

FROZEN FISH
INDUSTRY

REFRIGERANT
LOSSES

ODOUR

CHEMICALS

FROZEN
FILLETS

NOISE

Figure 2 Environmental balance of the frozen fish industry

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FISH PROCESSING INDUSTRY

FRESH
FISH

WATER

WASTEWATER

SOLID WASTE
ENERGY
REFRIGERANT
LOSSES
CHEMICALS

CANNING INDUSTRY
ODOUR

PACKING
MEDIA

CANS

NOISE

CANNED FISH

DAMAGED
CANS

Figure 3 Environmental balance of the canning industry

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FISH PROCESSING INDUSTRY


2.3.

DESCRIPTION OF THE FISH PROCESSING FACTORY

2.3.1

Frozen Fish Industry

The analyzed fish processing factory (always referred to as XPTO for reasons of anonymity) is a
Portuguese factory (located near Lisbon) that produces frozen fillets from frozen fish. It is a small
plant which processes 10 to 12 tons of fish per day and operates 5 days per week all year round.
Different fish species are processed, namely, hake, ling, sardine, mackerel, tuna, salmon,
anglerfish and many more. Moreover, some species of cephalopods, like octopus and cuttlefish and
of crustaceans, like crab and shrimp are also transformed into various frozen products.
Among such a variety, it was chosen the plants processing line for hake (Figure 4) as the
fundamental reference for this case study. This choice is due to hakes importance in the
companys product portfolio (total processed hake reached almost 850 tons in the whole year of
2003) and in frozen fish processing industry in general. Focusing on a specific production line
enables to refer all environmental assessment to a stable and unchangeable operations set.
Therefore as main process operations (Figure 5), it can be mentioned: cutting and trimming,
glazing, calibration, packaging and frozen storage. It must be stressed that this company buys
already de-headed, gutted and skinned fish, saving itself various waste generating operations. At
the outlet are sold fish fillets ready for delivery in retail shops.

Figure 4 External appearance of a typical hake fillet

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FISH PROCESSING INDUSTRY

RAW FISH

RECEPTION
AND
SELECTION

RAW FISH
STORAGE

FINAL PRODUCT
STORAGE

DESAGGREGATION
OF FROZEN BLOCKS

PACKAGING

CUTTING
AND
TRIMMING

FREEZING
TUNNEL

CALIBRATION
AND
WEIGHING

GLAZING

DISTRIBUTION

FINAL PRODUCT
IN RETAILER

Figure 5 Process diagram of the frozen fish factory

Reception and Selection


This operation generates some solid waste as a result of some cardboard and plastic removed
away when the raw fish packages are received in the factory. Also, during selection, some fish may
have to be rejected, thus, producing fish waste.
Raw fish storage
All that raw fish not used immediately after arrival is obviously stored in freezing rooms. The
operation of a vast set of freezing equipments entails an energy cost and also some refrigerant
losses to the environment (more precisely, ammonia).
Desaggregation
This operation involves breaking the great and unwieldy blocks of fish and ice. Necessarily, this
generates some amount of wastewater and some pieces of fish.

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FISH PROCESSING INDUSTRY


Cutting and trimming

Cutting fillets from the fish and removing any damaged areas. This is carried out with a set of
specific saws. As a result, an appreciable amount of energy is spent and, above all, a large quantity
of fish pieces (not only those corresponding to the damaged areas) is accumulated as waste.
Freezing tunnel

All the previous operations transfer considerable amounts of heat to the fish, so to ensure
thoroughly frozen fish fillets is needed to rapidly and efficiently remove all received heat. Therefore,
all fillets have to cross the freezing tunnel. This equipment requires large quantities of liquid
nitrogen, which, in turn, after absorbing the heat, will evaporate and mix with the atmospheric gases
(happily, this is not a problem since nitrogen is the main constituent of the atmosphere).
Glazing

This operation involves dipping the fillets in a cool water bath and, thus, wrapping each fillet in a
protective layer of water. Such an operation produces substantial amounts of a wastewater heavily
loaded with organic materials.
Calibration and weighing

In order to guarantee that the quantity of glazing water attached to each fillet does not surpass the
maximum limits is required to monitor this parameter. Furthermore, it is important to ensure a
uniform quantity of fish per package. These activities do not have important environmental impacts.
Packaging

The glazed and calibrated fillets are packaged in plastic pouches, which, in turn, are put inside
large boxes for delivery in retail shops. Associated with these operations there are always some
damaged packages that contribute to the global solid waste generated in the plant.
Storage and distribution

The final product (frozen fillets) requires storage in freezing rooms and once more this causes
energy consumption and some refrigerant losses inherent to the systems operation. Finally,
distribution has also some energy costs.
2.3.2

Canning Industry

The analyzed fish processing factory (always referred to as CCC for reasons of anonymity) is a
Portuguese factory (located in North Portugal) that produces canned fish. It is a small plant which
processes 20 tons of fish per day and operates 220 days a year. Different fish species are
processed, mainly, sardine, tuna, mackerel, octopus and squid. Furthermore, several packing
media are used: tomato sauce, vegetable oil, olive oil, brine and hot pepper sauce.
In order to characterize all environmental effects, it was found preferable to select a specific
processing line, therefore, was chosen canned sardines with tomato sauce (Figure 6). Moreover,

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FISH PROCESSING INDUSTRY


this production line is economically important for the company (total processed sardine surpassed
1500 tons per year) and the whole canning industry.
The process diagram encompasses several operations (Figure 7): freezing, washing, glazing,
thawing, brining, heading and eviscerating, canning, cooking, tomato sauce addition, can seaming,
can washing and sterilization. Additionally, there are some important auxiliary operations, namely,
brine and steam production, tomato sauce and chlorinated water preparation.

Figure 6 Various kinds of canned sardine products


FRESH SARDINE

FREEZING

WASHING

GLAZING

BRINE
PRODUCTION

BRINING

STORAGE

THAWING

HEADING, EVISCERATING,
WASHING AND CANNING
TOMATO SAUCE
PREPARATION

WASHING

STEAM
PRODUCTION

COOKING

STERILIZATION

FINAL PRODUCT
STORAGE

TOMATO SAUCE ADDITION


AND CAN SEAMING

COOLING

CAN WASHING

COOLING

DISTRIBUTION

CHLORINATED WATER
PREPARATION

CANNED SARDINE
IN RETAILER

Figure 7 Process diagram of the canned fish factory

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Freezing

This operation is required in order to cope with all fluctuations in the fishing of sardines. All sardine
not processed immediately must be stored in freezing storage rooms. The freezing is achieved
through immersion in a brine tank at -20 C during 20 minutes. Obviously, this entails a substantial
quantity of wastewater.
Washing

After freezing, sardines are transferred from the brine tank to a cold water tank at 18 C. In this way,
sardines are washed. Once more, a substantial quantity of wastewater is generated.
Glazing

Once completed the previous operation, sardines are kept in freezing storage rooms at -20 C
during two or three days. Afterwards, sardines are dipped in a cool water bath in order to wrap each
sardine in a protective layer of water. Such an operation necessarily produces considerable
amounts of wastewater.
Storage

After the previous three operations, sardines are stored in freezing rooms. The operation of a vast
set of freezing equipments causes a huge consumption of energy and also some refrigerant losses
to the environment.
Thawing

Obviously, all frozen sardines must be thawed prior to further processing. This is done by leaving
the sardines overnight at room temperature. This operation generates a considerable amount of
wastewater.
Brining

Sardines are put in a brine tank and left there for 15 minutes (previously frozen sardine) or 45 to 75
minutes (fresh sardine). Once more, this is an operation associated with discharge of sizable
amounts of wastewater.
Heading, eviscerating, washing and canning

This operation involves cutting away the sardines heads and tails and, also, pulling all viscera. This
is performed manually using only scissors as a tool. Afterwards, sardines are rinsed with tap water
and put inside the cans. At the environmental level, there is production of a large quantity of fish
waste and wastewater heavily loaded with organic matter.

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Washing

The canned sardines are rinsed with water to remove small solid particles before sending them to
the cooker. This phase can be performed automatically in the machines. An environmental
evaluation of this operation reveals a critical problem with all generated wastewater.
Cooking

The canned sardines are cooked at 100 - 105 C for 30 to 35 minutes in steam ovens. The cans
pass through the ovens held upside down on perforated conveyors in order to achieve
simultaneously steam entry and drainage of all condensate and oil exuded from the flesh. From this
description, it can be realized that an oily wastewater leaves this operation, representing a serious
environmental problem.
Cooling

After passing through the steam oven, the canned sardines are left at room temperature, gradually
cooling. Meanwhile, some additional fat drips away from the cans. Thus, there is also some
generation of oily wastewater during this operation.
Tomato sauce addition and can seaming

The cans with the cooked sardines are carried to a liquid filling station where tomato sauce is
added automatically. Usually, the sauce is pumped continuously and there is recovery of the spilled
sauce. The cans (with all their content) are then transferred to can sealing machines where they are
closed automatically. In spite of all recovered sauce, this operation produces large quantities of
wastewater (after washing all equipment and floors with water).
Can washing

Coming from the can seaming machines, the cans usually have sauce remnants, which have to be
removed from the cans prior to the sterilization. Hence, they are placed on conveyor belts that carry
them through washing tunnels where chlorinated water combined with steam and detergent is
applied. At the end of the conveyor belts, the cans fall into a tank full with chlorinated water, thus,
avoiding any damage to the cans. Like other washing operations, there is a great amount of
generated wastewater.
Sterilization

The cans with the cooked sardines are taken to autoclaves where they are treated with steam
under pressure at 119 C for forty five minutes. In the CCC plant, is used a vertical batch autoclave
which presents some difficulties regarding those cleaning operations that must be performed on a
regular basis.
Cooling

The cans are washed with cool chlorinated water for ten minutes, gradually cooling. Therefore, this
operation has also some environmental impact, producing substantial amounts of wastewater.

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Final product storage and distribution

After all previously described operations, cans are put in cases before their placement in the
cardboard boxes. These are placed in a warehouse, where they are kept at room temperature,
away from excessive temperature and humidity, in order to avoid risks for the final product quality.
They must stay at least fifteen days in the warehouse before being sent to the market. During this
phase, a visual inspection of the cans is done in order to see if they start to bulge, a signal of
imperfect sterilization. The rejection of cans represents an additional contribution to the factorys
solid waste.
Besides all mentioned operations, there are auxiliary operations that provide essential materials or
energy for the process.
Brine production

In order to prepare brine, salt is simply added to tanks filled with cool water. The produced brine is
carried to the various destinations through pipes. It may happen that, on a particular day, the
produced quantities are superior to the real needs however this is not a problem since brine can be
stored for future days.
Steam production

The main energy source used for cooking and sterilization is saturated steam, which is produced in
a boiler house. Furthermore, steam is also applied in the tomato sauce preparation and for heating
the premises. The CCC plant uses fuel oil as main fuel source. This means a contribution for the
atmospheric pollution and, also, for the greenhouse effect.
Tomato sauce preparation

The tomato sauce is prepared in a specific tank with a capacity to produce 120 kg per batch. The
tank has mixing and heating systems to ensure that tomato is well mixed with other ingredients and
the final preparation thoroughly addresses customer requirements. This auxiliary operation makes
also a contribution to the plants wastewater as a result of ingredients spillage and rejected tomato
sauce.
Chlorinated water preparation

The water extracted from a well is chlorinated with addition of sodium hypochlorite (NaOCl) aiming
at a Cl concentration in the range 3-4 ppm. In the case of the canneries, chlorination is performed
in order to wash the cans before and after sterilization. Particularly, washing after sterilization is
very important as a means to destroy pathogenic bacteria that could persist on the cans surface.

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2.4.

IMPLEMENTATION OF CLEAN TECHNOLOGIES

The EMAS focuses mainly on the management issue, emphasizing new management values
concerning environmental issues. Nevertheless, in order to achieve an effective reduction of the
industrys environmental impact new technologies less harmful or even beneficial to the
environment have an important role to play.
In these circumstances, the application of less pollutant production processes is fundamental,
entailing a whole new vision of the enterprise. This means to take preventive measures within each
process step instead of corrective measures which only aim is to minimize the environmental
problems already present in the factory. This is a new approach that seeks to avoid the problems
and not to remediate them and which is currently referred to as Cleaner Production (CP).
The CP can make a decisive contribution for a sustainable development, bringing together the
economic imperatives and the environmental protection. This new vision enables the reduction or
even the elimination of some supposed oppositions between environmental protection and
economic growth, between workers safety and productivity or also between consumers safety and
competition on the international arena. Setting goals for a vast group of issues dealing with
sustainable development, it is possible to achieve win-win solutions that bring benefits to all. The
CP is precisely a win-win strategy as protects environment, consumers and workers and, at the
same time, improves productions efficiency, increases the profits and fosters competitiveness.
Obviously, CP entails new and cleaner technologies. However, implementation of clean
technologies embraces not only new equipments more friendly towards the environment but also
new operative procedures that ensure a reduced environmental impact maintaining the old
equipment, eventually with minor changes.
There are different groups of CP measures which can help to improve the environmental
performance of fish processing industry.
2.4.1

Product Modifications

In the fish processing industry, there are some difficulties to modify the industrys products (frozen
fillets, canned fish and others) in a way advantageous for the environment. Nevertheless, some
measures can be suggested:

Avoid useless packaging


Recyclable materials for packaging

2.4.2

Acquired Material Modifications

On the other hand, some acquisition choices or specific demands to suppliers are able to
meaningfully reduce fish processing industrys environmental impacts:

Plastic boxes instead of wooden boxes (obviously, this requires a thorough plastic recycling)
Acquisition and processing of larger fish (this reduces fish offal amounts)
Natural gas instead of fuel oil (for boilers operation)

2.4.3

New Equipments

This group of measures can span a wide range of technical alterations from simple and inexpensive
fixtures to entirely new equipments presenting latest technological possibilities:

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Drains with screens and/or traps to prevent solid materials from entering the effluent system
Vacuum hoses for fish cleaning
Blood and offal collection in separate containers
Fixtures that restrict or control water flow for cleaning (for instance, sensors or solenoid valves)
High pressure cleaning systems (make a more efficient use of water)
Offal transport systems that avoid or minimize the use of water
Sensors that power down lights and equipment when not in use
Insulation improvement of cooling or heating systems
Improvement of the boilers combustion efficiency
Replacement of the refrigerant gases (removal of CFCs and other gases that harm the ozone
layer)

2.4.4

Use of Waste Materials on the Site

Waste materials have sometimes some hidden economic potential or may be used in such a way
that environmental benefits are attained:

Utilization of fish offal (to produce fish oil and/or fish meal)
Thawing wastewaters reuse for offal transport or for the first cleaning steps in dirty areas

2.4.5

Control and Monitoring

To control and monitor is fundamental to identify the main sources of pollutants and the process
operations critical for the factorys environmental impacts. This makes possible to tailor solutions
that meet these impacts. To achieve a good monitoring, various technical ideas can be mentioned:

Install meters on high water consumption equipment


Register electrical energy consumption for different equipments
Chemical characterization of the wastewater generated in each process operation (for
instance, COD, BOD5, SST)

2.4.6

Organizational Measures

Organizational measures do not require new devices, nor new materials, but demand a set of
operative procedures dealing with each task performed within the process. Of course, all this
cannot be of any serious consequence unless all the staff is deeply involved in the endeavour. So,
teaching and training are crucial requirements to implement these measures:

Solid waste separation on the fish preparation tables


Collection of fish waste in tight containers
Separation of plastic and cardboard from other solid waste
Pre-soak floors and equipment to loosen dirt before final cleaning (Figure 8)
Report and fix leaks promptly
Regular equipment maintenance
Efficient cleaning practices
Identification of all valves correct settings

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This vast set of actions can be a valuable guide for fish processing plants aiming at a meaningful
improvement of their environmental performance. Moreover, many actions do not require high
expenditures of capital and are technically easy to implement in a small factory.
AFTER CP PRACTICES

BEFORE CP PRACTICES
WATER

DIRTY SURFACE

DETERGENTS

WATER

DIRTY SURFACE

DETERGENTS

PRE-SOAKAGE
MULTIPLE WASHING
OPERATIONS
SCRAPING

FINAL WASHING
CLEAN SURFACE

CLEAN SURFACE
WATER SAVING

Figure 8 Example of a simple organizational measure

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3

EMAS APPLICATION

The implementation of EMAS requires several fundamental aspects: planning, organization and
personnel, operation and environmental management system verification. The first deals with all
conditions needed for a successful accomplishment of EMAS, the second addresses all
components essential to build up all EMAS structure, the third aspect has to do with control and
guarantees of an effective EMAS application and, finally, the fourth deals with all validation and
verification of the implemented system by external entities.

3.1.

PLANNING

3.1.1

Environmental Policy

The environmental protection is the main key to our development. All premises of XPTO and CCC
should adopt waste management policies, that be integrated, complete and, whenever possible,
independent. All working staff should accomplish the following:

Respect the environment and minimize the environmental impact of all activities;

Follow all applicable legislation and procedures;

Investigate permanently new recycling opportunities and industrial optimization;

Try to reduce raw materials, water and energy consumptions;

All accidents and environmental complaints reported, registered and investigated and
corrective actions implemented in all premises in order to avoid other similar events;

All workers and people involved informed and trained to act in a responsible way relatively to
all environmental issues

Keep a good and constructive relationship with all neighbours on a mutual respect and active
dialogue basis;

Cooperate with public and private organizations aiming to improve legislation and knowledge
about environmental protection.

3.1.2

Environmental Review

This review is an initial comprehensive analysis of the environmental issues, impacts and
performance, which are related to the activities of the site to be registered. All environmental
aspects of a companys activities, goods and services must be analyzed and those aspects with a
significant impact must be chosen based on criteria that take into consideration the EU community
legislation. Moreover, the significant aspects must guide in the definition of the environmental
objectives and targets. It has to be stressed that both the direct and indirect environmental aspects
must be examined by the company. The direct ones embrace the companys activities controlled by

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the company itself, whereas the indirect aspects arise also from the companys activities but the
company has no full control over them.
Frozen fish industry

The identification and evaluation of the significant environmental aspects of XPTO is carried out as
described in the system procedure, SP 01 Environmental Aspects. Additionally, the identified
significant aspects are recorded in a specific list, LEA Environmental Aspects, whose present
version is archived in a folder named General.
The frozen fish factory observed in this study (XPTO) has several environmental impacts that need
to be addressed. Focusing on the hakes processing line (850 tons/year), different impacts can be
referred and calculated, namely, water, energy, detergents and disinfectants, refrigerant gases,
solid waste and wastewater.
3
3
For water, it is estimated a consumption rate of 3240 m /year or, alternatively, 3.8 m /ton of
processed hake.
Regarding energy, it is possible to point out an estimate of 709 000 kWh/year or 834 kWh/ton of
processed hake. The main contribution for this result comes from the tremendous electrical power
associated with frozen storage.
Also for detergents and disinfectants, a global estimate of 1670 l/year can be mentioned and,
consequently, a proportion of nearly 2 l of various kinds of detergent per each ton of processed
hake.
Concerning refrigerant gases, there is an estimate for the cryogenic system gas of 60 l of ammonia
lost each year or 0.07 l/ton of processed hake and an estimate of 170 000 l of liquid nitrogen
consumed per year or 200 l/ton of processed hake.
There are different kinds of solid waste that must be mentioned separately, so the following
3
estimates can be mentioned, 25.4 tons of fish waste/year, 257 m of common garbage/year, 11.6
tons of plastic/year and 23.6 tons of cardboard/year. Alternatively, per ton of processed hake, 0.030
3
ton of fish waste, 0.30 m of common garbage, 0.014 ton of plastic and 0.028 ton of cardboard.
Finally, it can be estimated a volume of generated wastewater similar to the water consumption
3
3
level (3240 m /year or, alternatively, 3.8 m /ton of processed hake).
For an overview of all quantified impacts, see Table 1.
However, wastewater may have rather distinct organic loads, ranging from quite clean water that
was used by employees to wash their hands to wastewater heavily loaded with organic materials
produced in the glazing operation. Thus, in order to assess the problems dimension, glazing
received special attention and, accordingly, some estimates and analyses were made (Table 2).

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Table 1 Quantified environmental impacts of XPTO.

Environmental aspect

Value per year

Value per ton of


processed hake

Water consumption (m )
Energy consumption (kWh)
Detergents consumption (l)
Ammonia release (l)
Nitrogen release (l)
Fish waste production (ton)
3
Common garbage production (m )
Plastic production (ton)
Cardboard production (ton)
3
Wastewater discharge (m )

3240
709000
1670
60
170000
25.4
257
11.6
23.6
3240

3.8
834
2
0.07
200
0.030
0.30
0.014
0.028
3.8

Table 2 Characterization of the glazing wastewater problem

Glazing wastewater parameters


3

Volume (m /year)
3
Volume (m /ton of processed hake)
COD (mg O2/l)
BOD5 (mg O2/l)
Nitrogen (mg N/l)

Value
120
0.14
752
200
8.78

Concerning direct discharge to public sewerage, the maximum values allowed by Portuguese
legislation are 40 mg O2/l for BOD5, 150 mg O2/l for COD and 15 mg N/l for total nitrogen. Although
the glazing contribution to the total wastewater is not very large (about 4 %), it is possible that
sometimes such contribution surpasses all the others, for instance, when the glazing tank water is
discharged.
From all mentioned impacts, only a few were considered significant as a consequence of the
amount of released pollutants or consumed resources and of the kind of pollutant involved. On the
basis of quantity, the water and energy consumptions and, also, the common garbage and
wastewater production were classified as significant environmental aspects. Furthermore, as the
COD and BOD5 found in the glazing wastewater were five times higher than legal limits and this
particular wastewater could represent sometimes a large proportion of the total wastewater, the
organic load in the glazing wastewater was considered a significant aspect too. On the other hand,
the amounts of detergents were too small to be considered a significant environmental aspect.
Likewise, the ammonia amount released to the environment was not enough to deserve any special
attention. Regarding fish waste, cardboard and plastic, XPTO had already taken steps to solve
these problems, mainly, selling fish waste to a fish meal plant and paying to another company for
recycling all plastic and cardboard. Finally, the huge amount of released nitrogen was not
considered relevant since nitrogen gas is harmless (the main atmospheric constituent). Hence, an
environmental balance involving only significant environmental aspects can be presented (see
Figure 9).

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1 TON
3.8 m3

FROZEN HAKE

TOTAL WASTEWATER

3.8 m3
WATER

GLAZING WASTEWATER
(4 % OF TOTAL)
COD: 752 mg O2/l

XPTO

834 kWh
ENERGY
0.97 TON
FROZEN HAKE
FILLETS

BOD5: 200 mg O2/l

0.3 m3
COMMON
GARBAGE

Figure 9 XPTOs environmental aspects with a significant impact

Canning industry

The identification and evaluation of the significant environmental aspects of CCC is carried out as
described in the system procedure, SP 01 Environmental Aspects. Additionally, the identified
significant aspects are recorded in a specific list, LEA Environmental Aspects, whose present
version is archived in a folder named General.
From all described operations, it can be concluded that the studied canning plant (CCC) has
considerable environmental impacts. Evaluating only the production of canned sardines with tomato
sauce (1500 tons of processed sardine/year), different environmental aspects deserve attention:
water, energy, refrigerant gases, solid waste and wastewater.
3
3
For water, it is estimated a consumption rate of 6300 m /year or, alternatively, 4.2 m /ton of
processed sardine.
Addressing the energy problem, there are two different issues: electricity and fuel oil. For electricity,
it is possible to make the following estimate, 110 000 kWh/year or 74 kWh/ton of processed
sardine. On the other hand, for fuel oil, it can be referred a consumption of 75 ton/year or 0.05
ton/ton of processed sardine.
Concerning refrigerant gases, there is no available estimate. However, the value attained for frozen
fish industry (0.07 l of ammonia/ton of processed hake) can be mentioned as a possible upper limit
since all freezing system is quite more important in this industry than in the canneries.
In the canning industry, fish waste has a huge importance among the various kinds of solid waste
as can be proved with the following estimates, 600 tons of fish waste/year or 0.4 ton/ton of
processed sardine.
3
For wastewater, it is estimated a volume similar to the water consumption level (6300 m /year or,
3
alternatively, 4.2 m /ton of processed sardine).
For an overview of all quantified impacts, see Table 3.
In order to assess thoroughly the impact of all wastewater is crucial to chemically characterize the
global effluent leaving the plant (Table 4).

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Table 3 - Quantified environmental impacts of CCC

Environmental aspect

Value per year

Value per ton of


processed sardine

Water consumption (m )
Electricity consumption (kWh)
Fuel oil consumption (ton)
Fish waste production (ton)
3
Wastewater discharge (m )

6300
110000
75
600
6300

4.2
74
0.05
0.4
4.2

Table 4 - Characterization of the wastewater generated in the plant

Parameter
3

Volume (m /year)
3
Volume (m /ton of processed sardine)
COD (mg O2/l)
BOD5 (mg O2/l)
Nitrogen (mg N/l)
Phosphorous (mg P/l)

Value
6300
4.2
7700
3500
200
27

All presented chemical parameters are clearly above the maximum limits established by
Portuguese legislation for effluent discharge in the public sewerage (40 mg O2/l for BOD5, 150 mg
O2/l for COD, 15 mg N/l for total nitrogen and 10 mg P/l for total phosphorous).
The analysis of the CCCs environmental aspects revealed impacts of different magnitude. Applying
criteria similar to those used with XPTO was possible to select those aspects with a significant
impact. The criterion of quantity alone demanded to look upon the levels of water consumption, fish
waste production and wastewater discharge as aspects with significant impact. This last one,
presented an additional problem, a huge organic load released to the sewerage system. Moreover,
the pollutant gases generated by the combustion of fuel oil and the fact that fuel is a product of
crude-oil, a non-renewable source of energy, caused fuel consumption to be viewed as a significant
environmental aspect of CCC. Electricity consumption was considered also a significant aspect, in
spite of its small value when compared to the same parameter in XPTO (per ton of processed fish),
because the low technological level of the company entailed severe energy inefficiencies. On the
other hand, the refrigerant gases released to the environment were not viewed as problematic and
the reason was similar to that one pointed out for XPTO. From this overall evaluation, an
environmental balance involving only significant environmental aspects can be drawn (Figure 10).

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4.2 m3
WATER

1 TON
FRESH SARDINE
4.2 m3
WASTEWATER
COD: 32 kg
BOD5: 15 kg
Nitrogen: 1 kg
Phosphorous: 0.1 kg

74 kWh
ELECTRICITY

CCC

0.4 TON
FISH WASTE

0.05 TON
FUEL
0.5 TON
CANNED FISH

Figure 10 CCCs environmental aspects with a significant impact

3.1.3

Environmental Legal Requirements

The company has to establish and maintain a procedure enabling:

Access to all legal requirements and others;

Selection of applicable legal requirements among all legislation;

An updated knowledge of the whole legal frame.

3.1.4

Environmental Objectives and Targets

Accordingly to its environmental policy, the company establishes and keeps environmental
objectives and targets, whenever possible, measurable. The objectives and targets are set by EMS
team considering:

Legal and regulatory requirements;

Environmental aspects of all activities and operations with significant impact;

All available technological options;

Financial and operational requirements.

Objectives and targets are reviewed and, if necessary, corrected all years aiming at a continual
improvement of the environmental behaviour.

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Frozen fish industry

Taking into consideration all mentioned conditions, XPTO established a set of environmental
objectives and targets.
The environmental review identified several problems, which had to be addressed, thus, demanding
the establishment of the following objectives:

Reduction of water consumption and, consequently, of wastewater generation

Reduction of electrical energy consumption

Regular and rigorous monitoring of water and electrical energy consumptions

Reduction of COD and BOD5 levels in the glazing wastewater

Reduction of common garbage production

To accomplish these objectives detailed requirements were defined, the so-called environmental
targets:
3

Achieving 3 m of water consumption per ton of processed hake until the end of 2005 (this
means a 20 % reduction)

Reaching a level of electrical energy consumption lower than 750 kWh per ton of processed
hake until the end of 2005 (this means a 10 % reduction)

Beginning to register water and electrical energy consumptions for main equipments until the
end of 2005

Until the end of 2005, achieving COD and BOD5 levels in the glazing wastewater lower than
380 mg O2/l and 100 mg O2/l, respectively (this means cutting by half the COD and BOD5
levels)

Reaching a production of common garbage lower than 0.20 m per ton of processed hake until
the end of 2005 (this means cutting by a third this parameter)

Canning industry

Considering the legal, regulatory, technological, financial and operational conditions and those
environmental aspects with significant impact identified in the review, CCC established its own set
of environmental objectives and targets.
Namely, CCC set up the following objectives:

Reduction of water consumption and, consequently, of wastewater generation

Reduction of electrical energy consumption

Regular and rigorous monitoring of water and electrical energy consumptions

Utilization of natural gas instead of fuel oil

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Reduction of COD, BOD5, nitrogen and phosphorous levels in the wastewater

Utilization of the generated fish waste for fish meal production

These objectives required the definition of the following environmental targets:


3

Achieving 3.4 m of water consumption per ton of processed sardine until the end of 2005 (this
means a 20 % reduction)

Reaching a level of electrical energy consumption of about 65 kWh per ton of processed
sardine until the end of 2005 (this means a 10 % reduction)

Beginning to register water and electrical energy consumptions for main equipments until the
end of 2005

Exclusive utilization of natural gas in the boiler from 2006 onwards

Until the end of 2005, achieving a less polluting wastewater with the following chemical
characterization: COD - 3800 mg O2/l, BOD5 - 1700 mg O2/l, Nitrogen - 100 mg N/l and
Phosphorous - 15 mg P/l (cutting by half all these wastewater parameters values)

Selling all sardine waste generated in the process to a fish meal plant from 2005 onwards

3.1.5

Environmental Programme

On the basis of the environmental policy and the results of the environmental review, an
environmental programme is established. The programme must have specific goals, along with
measures and deadlines for their application. What is more, as a previous condition for achieving
the objectives and targets, the responsibilities have to be well defined at each level and function of
the company.
In order to accomplish all environmental objectives and targets in an efficient and effective manner,
XPTO (and, likewise, CCC) established an environmental management programme, EP xpto-aa
(EP ccc-aa), which must be reviewed every two years. The environmental management programme
was prepared by EMS team and, afterwards, analyzed and approved by management board. The
EMS coordinator monitors the accomplishment of the programme. It is possible, if needed, to
review and alter the programme before expiring its two years period.
Frozen fish industry EP xpto-aa

This environmental programme establishes which measures must be taken in order to meet those
targets set in the previous section for XPTO. In Table 5 can be seen a list of the necessary
measures for accomplishing each target:

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Table 5 XPTOs environmental targets and corresponding measures for its accomplishment

Target
3

1) 3 m of water consumption per ton of


processed hake until the end of 2005

2) Electrical energy consumption lower


than 750 kWh per ton of processed hake
until the end of 2005
3) Beginning to register water and
electricity consumptions for main
equipments until the end of 2005
4) Until the end of 2005, COD and BOD5
in the glazing wastewater lower than
380 mg O2/l and 100 mg O2/l, respectively
5) Common garbage production lower
3
than 0.20 m per ton of processed hake
until the end of 2005

Measure
- High pressure cleaning systems
- Efficient cleaning practices
- Pre-soak floors and equipment to loosen dirt before
final cleaning
- Vacuum hoses for fish cleaning
- Report and fix leaks promptly
- Insulation improvement of all freezing system
- Regular equipment maintenance
- Sensors that power down lights and equipment
when not in use
- Install meters on high water consumption equipment
- Register electrical energy consumption for main
equipments
- Drains with screens and/or traps to prevent solid
materials from entering the effluent system
- Screening of all common garbage produced

The screening enables to separate materials that can be recycled or even reused

The environmental programme demands a plan to assure a thorough and effective application of
the referred measures. The plan contains specific tasks that must be carried out within preestablished deadlines and with well defined responsibilities. The timing has to be carefully planned
with beginning and conclusion dates for every task. Hence, the implementation of XPTOs
measures obeys the following chronogram (see Figure 11):

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PERFORMANCE PERIOD (MONTHS)
TASK

RESPONS.
Set

Target 1: 3

m3

Oct

Nov

Dec

Jan

Feb

Mar

Apr

May

Jun

of water consumption per ton of processed hake until the end of 2005

Acquisition of high pressure cleaning systems

EMS
coordinator

Training workers in efficient cleaning practices

EMS
coordinator

Preparation of work instruction for pre-soakage


cleaning

EMS
coordinator

Installation of vacuum hoses for fish cleaning

EMS
coordinator

Preparation of operational procedure for finding


and fixing leaks

EMS
coordinator

Day 15
Day 15
Day 31
Day 15

Day 30

Target 2: Electricity consumption lower than 750 kWh per ton of processed hake until the end of 2005
EMS
coordinator

Commission better insulation of freezing rooms


Assuring regular equipment maintenance

Day 28

Production &
Maintenance

Day 15

EMS
coordinator

Day 15

Installation of energy saving sensors

Target 3: Beginning to register water and electricity consumptions for main equipments until the end of 2005
Installation of meters on high water consumption
equipment

EMS
coordinator

Day 31

Preparation of operational procedure for


registration of electricity consumption

EMS
coordinator

Day 31

Target 4: Until the end of 2005, COD and BOD5 in the glazing wastewater lower than 380 mg O2/l and 100 mg O2/l, respectively
EMS
coordinator

Installation of screens and traps in the glazing


tank drain

Day 31

PERFORMANCE PERIOD (MONTHS)


TASK

RESPONS.
Set

Oct

Nov

Dec

Jan

Feb

Mar

Apr

May

Jun

Target 4: Until the end of 2005, COD and BOD5 in the glazing wastewater lower than 380 mg O2/l and 100 mg O2/l, respectively

Preparation of work instruction for removal of the


solid waste retained in the glazing tank drain

EMS
coordinator

Day 31

Target 5: Common garbage production lower than 0.20 m3 per ton of processed hake until the end of 2005
Preparation of operational procedure for
screening all common garbage produced

EMS
coordinator

Training workers in separating all garbage


produced

EMS
coordinator

Raising workers awareness for environmental


issues

Day 30
Day 31

All EMS team

Figure 11 XPTOs chronogram for the environmental programme implementation

Canning industry EP ccc-aa

This environmental programme defines which measures have to be taken in order to meet those
targets set in the previous section for CCC. A list of all measures required for fulfilling CCCs
environmental targets is shown in Table 6:

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Table 6 CCCs environmental targets and corresponding measures for its accomplishment

Target

Measure

1) 3.4 m of water consumption per ton of


processed sardine until the end of 2005

- High pressure cleaning systems


- Efficient cleaning practices
- Pre-soak floors and equipment to loosen dirt before
final cleaning
- Fixtures that control water flow for cleaning
- Vacuum hoses for fish cleaning
- Report and fix leaks promptly
- Thawing wastewaters reuse for the first cleaning
steps in dirty areas
- Insulation improvement of all freezing system
- Regular equipment maintenance
- Sensors that power down lights and equipment
when not in use
- Install meters on high water consumption equipment
- Register electrical energy consumption for main
equipments

2) Electricity consumption of about


65 kWh per ton of processed sardine until
the end of 2005
3) Beginning to register water and
electrical energy consumptions for main
equipments until the end of 2005
4) Exclusive utilization of natural gas in
the boiler from 2006 onwards
5) Until the end of 2005, achieving: COD 3800 mg O2/l, BOD5 - 1700 mg O2/l,
Nit. - 100 mg N/l and Phosp. - 15 mg P/l
6) Selling all sardine waste to a fish meal
plant from 2005 onwards

- Installation of a natural gas boiler


- Drains with screens and traps to prevent solid
materials from entering the effluent system
- Blood and offal collection in separate containers
- Solid waste separation on the fish preparation
tables

The implementation of all measures mentioned above demands a plan with specific tasks, dates
and responsibilities. Hence, the implementation of CCCs measures has to obey the following
chronogram (Figure 12):

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PERFORMANCE PERIOD (MONTHS)
TASK

RESPONS.
Set

Target 1: 3.4

m3

Oct

Nov

Dec

Jan

Feb

Mar

Apr

May

Jun

Apr

May

Jun

of water consumption per ton of processed sardine until the end of 2005

Acquisition of high pressure cleaning systems

EMS
coordinator

Training workers in efficient cleaning practices

EMS
coordinator

Preparation of work instruction for pre-soakage


cleaning

EMS
coordinator

Installation of fixtures for water flow control

EMS
coordinator

Installation of vacuum hoses for fish cleaning

EMS
coordinator

Preparation of operational procedure for finding


and fixing leaks

EMS
coordinator

Preparation of work instruction for collecting


thawing wastewaters and use them in cleaning

EMS
coordinator

Day 15
Day 31
Day 31
Day 15
Day 30

Day 30

Day 31

Target 2: Electricity consumption of about 65 kWh per ton of processed sardine until the end of 2005
Commission better insulation of freezing rooms
Assuring regular equipment maintenance
Installation of energy saving sensors

EMS
coordinator

Day 28

Production &
Maintenance

Day 15

EMS
coordinator

Day 15

Target 3: Beginning to register water and electricity consumptions for main equipments until the end of 2005
Installation of meters on high water consumption
equipment

EMS
coordinator

Day 31

Preparation of operational procedure for


registration of electricity consumption

EMS
coordinator

Day 31

PERFORMANCE PERIOD (MONTHS)


TASK

RESPONS.
Set

Oct

Nov

Dec

Jan

Feb

Mar

Target 4: Exclusive utilization of natural gas in the boiler from 2006 onwards

Acquisition of a natural gas boiler

Production &
Maintenance

Installation of a natural gas line

Production &
Maintenance

Day 31

Day 30

Target 5: Until the end of 2005, achieving: COD - 3800 mg O2/l, BOD5 - 1700 mg O2/l, Nit. - 100 mg N/l and Phosp. - 15 mg P/l
Installation of screens and traps in the drains

EMS
coordinator

Day 31

Preparation of work instruction for removal of the


solid waste retained in the drains

EMS
coordinator

Day 31

Acquisition of specific containers for blood and


offal collection

EMS
coordinator

Day 15

Preparation of work instruction for collecting blood


and offal

EMS
coordinator

Day 15

Target 6: Selling all sardine waste to a fish meal plant from 2005 onwards
Preparation of operational procedure for
separating waste on the fish preparation tables

EMS
coordinator

Day 28

Making a deal with a company that produces fish


meal from fish waste

EMS
coordinator

Day 28

Raising workers awareness for environmental


issues

All EMS team

Figure 12 CCCs chronogram for the environmental program implementation

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3.2.

ORGANIZATION AND PERSONNEL

3.2.1

Responsibilities

The responsibilities, functions and authority have to be defined, documented and communicated in
order to ensure the effectiveness of the EMS. The management board must provide all resources
for the implementation and control of EMS, including human resources, specialized experts and
technological and financial support. Furthermore, the management board has to appoint a specific
management representative, who is responsible for EMS. This person must, notwithstanding other
duties, assure the definition, implementation and maintenance of the EMS requirements and report
to the management the level of performance of the implemented EMS.
Concerning EMS, the organizational structure of XPTO and, similarly, of CCC is schematically
drawn in Figure 13.

ADMINISTRATION
Mr. A

QUALITY CONTROL
Mr. B

ADMINISTRATIVE SERVICES
FINANCIAL DEPARTMENT
Mr. C

WAREHOUSE
Mr. D

PRODUCTION AND MAINTENANCE


Mr. E

Figure 13 Organizational structure concerning EMS

The quality control coordinator is also in charge of the environmental management system (EMS).
The responsibilities of each section of XPTO and, similarly, of CCC in the implementation and
maintenance of EMS have been defined and are presented in the Table 7:

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Table 7 - Section responsibilities in the EMS implementation and maintenance.

EMS Requirements

Sections
Adm.

Adm./Fin.

P&M

Warehouse

1- Policy
R
C
C
C
2- Environmental aspects
3- Environmental legislation
S
C
4- Objectives and targets
S
C
C
C
5- Environmental programme
S
C
C
C
6- Responsibilities
R
C
C
C
7- Training
S
C
8- Communication
R
9- EMS documentation
10- Document control
11- Operational control
C
R
C
12- Emergency plan
R
C
13- Monitoring
C
R
C
14- Non-conformances
S
15- Registers
C
C
C
16- EMS audits
S
C
C
C
17- EMS review
R
Table key: Adm. Administration; Fin. Finance; P & M Production and Maintenance;
QC Quality Control
R Responsible; C Cooperation; S Supervision

QC
S
R
R
R
R
S
R
C
R
R
S
S
S
R
R
R
C

A special team has been created (named, EMS team) to help the EMS coordinator (Mr. B) in the
implementation, maintenance and improvement of the environmental management system (see
Figure 14).

QUALITY CONTROL

Mr. B

ADMINISTRATIVE
SERVICES

WAREHOUSE

Mr. C

Mr. D
PRODUCTION AND
MAINTENANCE

Mr. E
Figure 14 Composition of the EMS team

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The indicated persons have the responsibility to implement all relevant aspects of EMS in each
section and must help the auditors whenever internal environmental audits are conducted.
3.2.2

Training

The company has to identify the training needs of its personnel and provide an adequate training
for any employee whose activity presents a significant environmental impact. Additionally, it must
establish and maintain procedures that assure for all employees a good knowledge of some
important issues:

The importance of compliance with the environmental policy and EMS procedures and
requirements

The significant environmental impacts, real or potential, of its activities

Its particular functions and responsibilities in order to achieve an effective compliance with the
environmental policy and EMS procedures and requirements

The potential consequences of non-compliance with the specified operational procedures

XPTO and, likewise, CCC, through the person in charge of EMS, has to pay attention to any
sign suggesting lack of training, knowledge and competence of workers and people involved.
Training is carried out to raise basic awareness among employees. The decision of whether training
can be carried out internally or externally depends on the level of skill and knowledge required. The
company's competence training programme ensures that training issues are focused upon every six
months.
The maintenance of an effective EMS implies significant cultural change within an organization. It is
very much a transition from long accepted work practices to new methods of working. To
accomplish the mentioned goals it is important to consider three groups of employees. Firstly, those
employees who have responsibility for some part of the EMS have to be identified. And such
employees have to enter on an internal EMS course. Secondly, the employees who are responsible
for a significant environmental impact have to be evaluated. These employees receive specialist
environmental training to ensure they can manage their environmental impact effectively. Finally, all
employees are subject to general environmental awareness raising initiatives.
The identification and execution of all training actions is performed as described in the System
Procedure SP 03 Training and Knowledge. The conducted training actions are recorded in a list
specially designed for this purpose, LTRAIN Training Actions. Furthermore, each executed
training action is recorded in a specific form (RTRAIN #) which identifies the action and includes a
list of participants, trainers names and session summary.
3.2.3

Communication

In what concerns the environmental aspects and EMS, the company must establish and maintain
procedures that ensure the internal communication between its different levels and functions and,
also, the reception, documentation and response to relevant communications from external
interested parties.
XPTO and, likewise, CCC environmental policy is supported by management at the highest
level and communicated to all employees who support the company in its quest of total commitment

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to environmental improvement. Feedback is expected from employees. Regular team briefings also
provide an opportunity for employees to give their input.
All internal and external communication regarding environmental matters and EMS is performed as
described in the System Procedure SP 04 Internal and External Communication. Additionally, all
established communications, internal or external, are recorded in two specific lists, LINTC Internal
Communication and LEXTC External Communication, and are archived in the adequate section
of a folder identified with the word Communication. For all direct contacts, like visits or phone
calls, a specific form (RNW # - Non-Written Communication) is filled and, afterwards, a written reply
is prepared. The received complaints, whatever communication medium used, are also recorded in
forms (RCOMP # - Complaints), analyzed and answered in written form.
3.2.4

Documentation

The information, on paper or electronic format, must be defined and maintained in such a way that
assures a description of the essential components of EMS and its interactions and, furthermore,
provides indications of connected documentation.
The EMS documents of XPTO and, also, CCC are organized in a hierarchical fashion that is typical
of most quality management systems (Figure 15).

SYSTEM MANUAL

SYSTEM PROCEDURES

OPERATIONAL PROCEDURES

RECORDS

OTHER DOCUMENTS

EXTERNAL
DOCUMENTS

Figure 15 Hierarchical documentation structure of EMS

XPTO (CCC) system manual, the most important document for EMS (see Figure 15), was
developed to be as simple and lean as possible. In the system manual, besides a description of the
st
nd
rd
company (1 chapter), of its internal organization (2 chapter) and of the productions process (3
chapter), are presented EMS and all procedures that must be followed in order to address the
normative requirements.

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Immediately below, at a second level, the system procedures describe all activities that must be
carried out for a thorough implementation and maintenance of EMS. These procedures set
important environmental objectives for the company and answer to various problems:

Operational control of the most meaningful aspects

Requirements concerning measurement and monitoring of all operational controls

Evaluation of conformance with legislation and relevant norms

Besides a fundamental procedure that explains how to prepare a procedure, a total of twelve
system procedures were created for XPTO (and similarly for CCC). The procedures names and
their objectives are shown in the Table 8.
Table 8 Set of system procedures developed for XPTO and CCC

Procedure
SP 00 Procedures Preparation
SP 01 Environmental Aspects
SP 02 Legislation and other Requirements
SP 03 Training and Knowledge
SP 04 Internal and External Communication
SP 05 Documentation Control
SP 06 Operational Control Operations and
Activities
SP 07 Operational Control Goods and
Services
SP 08 Emergency Preparedness and
Response
SP 09 Monitoring and Measurement
SP 10 Non-Conformances and Corrective
and Preventive Actions
SP 11 - Records
SP 12 EMS Audits

Objective
Preparation of procedures
Identification and evaluation of
environmental aspects
Identification and access to legislation and
other requirements
Identification and execution of training and
knowledge actions
Internal and external documentation
Control of documents
Identification and control of all operations
and activities with environmental impact
Identification and control of goods and
services with environmental impact
Identification and preparation of response
procedures for accidents and emergencies
Identification and control of monitoring and
measurement operations
Non-conformances record and response
Control of records
Execution and calendar of internal audits

Going down the pyramid, the operational procedures set operational criteria that enable an efficient
control of the environmental impacts of all activities conducted in the company. Thus, this class of
procedures represents the translation in specific terms at the operational level of the general
system procedures.
Finally, at the bottom of the pyramid, there are all those documents that assure an effective
implementation of the environmental management system in the company: forms, records (for
instance, RTRAIN # or RNW # - Non-Written Communication), lists (events lists as LTRAIN
Training Actions, documents lists, work instructions lists and others), reports, etc.

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3.2.5

Documentation Control

The company must establish and keep procedures that control all documents required for an
effective implementation of EMS. This control has several important objectives:

Localization

Periodic analysis, review and, if necessary, approval by authorized personnel

Availability of the latest versions of all relevant documents in the critical points for an efficient
functioning of EMS

Immediate removal of the obsolete documents from all emission and utilization points

An adequate identification of all obsolete documents kept due to legal reasons and/or
preservation of knowledge

Regarding XPTO (or, CCC), the control of all documents that matter for the environmental
management system is performed as described in the system procedure SP 05 Documentation
Control. This procedure requires that all documentation must be dated (with review dates), legible
and easily identifiable, carefully organized and kept for specified periods of time. Namely, all
documents must be archived in appropriate folders (for instance, the lists of internal and external
communications are archived in the folder Communication) for an easy localization.
3.2.6

Operational Control

An adequate operational control requires the identification of all companys operations and activities
connected with the significant environmental aspects. These activities, including maintenance, must
be carefully planned, thus, assuring some fundamental conditions:

Definition and maintenance of documented procedures concerning all critical points for the
successful implementation of EMS

Definition of operational criteria in the procedures

Definition and maintenance of the procedures dealing with the significant environmental
aspects of those goods and services used by the company

Operational control encompasses the way XPTO and, likewise, CCC controls all its operations
in order to assure that the environmental objectives and targets are systematically achieved and
furthermore that all environmental aspects are adequately monitored.
The implementation of an efficient operational control requires a thorough analysis of the
environmental issues found in the site and, of course, the establishment of straightforward
objectives and targets. The next step is to identify which critical points in the site must be controlled.
This is the only way to monitor the involved environmental aspects.
Additionally, operational control must follow some rules:

Identify, at least, one operational control for each objective and target

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Control all operations that have any connection with the environmental aspects, including
maintenance

Establish procedures for all critical points

Communicate these procedures to suppliers and contractors

As previously referred in 3.2.4, two system procedures were developed as guidance for all
operational control activities, SP 06 Operational Control Operations and Activities and SP 07
Operational Control Goods and Services. The former procedure establishes the identification of
those operations and activities concerning environmental aspects and, also, the preparation and
divulgation of all work instructions that describe how to carry out each operation and activity.
Moreover, the identified operations and activities are recorded in a list specially designed for this
purpose, LOCOA - Operational Control Operations and Activities, where, for each operation and
activity, are mentioned the related work instructions and their localization in the companys
archives. On the other hand, the latter procedure establishes not only the identification of those
goods and services with environmental impact but also the identification and divulgation to
suppliers and contractors of all relevant procedures and requirements. The identified goods and
services are recorded in a specific list, LOCGS - Operational Control Goods and Services,
mentioning the corresponding suppliers and contractors and, also, the document (letter, meeting
minutes, etc.) used for divulgation of procedures and requirements.
Frozen fish industry

Regarding operations and activities, XPTO was able to identify, at least, one operational control for
each environmental target and established procedures addressing the implementation of all
operational controls. An overview of the operational control structure is shown in Table 9:
Table 9 Operational controls implemented for each environmental target set by XPTO

Environmental target
3

1) 3 m of water consumption per ton of


processed hake until the end of 2005
2) Electrical energy consumption lower than
750 kWh per ton of processed hake until the
end of 2005
3) Beginning to register water and electricity
consumptions for main equipments until the
end of 2005
4) Until the end of 2005, COD and BOD5 in the
glazing wastewater lower than 380 mg O2/l
and 100 mg O2/l, respectively
5) Common garbage production lower than
3
0.20 m per ton of processed hake until the
end of 2005

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Operational control
- Verify monthly water consumption and
calculate the amount of hake processed
each month
- Verify monthly electricity consumption and
calculate the amount of hake processed
each month
- Management review each trimester

- Perform monthly chemical analysis of the


glazing wastewater
- Estimate monthly production of common
garbage and calculate the amount of hake
processed each month

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Each operational control must be the most straightforward way to assess the convergence towards
the established target, in Figure 16 is exemplified a typical operational control that was
implemented in XPTO.

Number of dumpsters filled each month

Garbage production per ton


of processed hake

Amount of hake processed each month

Figure 16 Operational control concerning XPTOs target 5

Canning industry

CCC identified, at least, one operational control for each environmental target and established
procedures regarding the implementation of all operational controls. An overview of its operational
control structure is shown in Table 10:

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Table 10 Operational controls implemented for each environmental target set by CCC

Environmental target
3

1) 3.4 m of water consumption per ton of


processed sardine until the end of 2005
2) Electricity consumption of about 65 kWh per
ton of processed sardine until the end of 2005
3) Beginning to register water and electrical
energy consumptions for main equipments
until the end of 2005
4) Exclusive utilization of natural gas in the
boiler from 2006 onwards
5) Until the end of 2005, achieving: COD 3800 mg O2/l, BOD5 - 1700 mg O2/l, Nit. - 100
mg N/l and Phosp. - 15 mg P/l
6) Selling all sardine waste to a fish meal plant
from 2005 onwards

Operational control
- Verify monthly water consumption and
calculate the amount of sardine processed
each month
- Verify monthly electricity consumption and
calculate the amount of sardine processed
each month
- Management review each trimester

- Management review each trimester


- Monthly chemical analysis of the
wastewater generated in the plant
- Estimate monthly amount of fish waste
separated on the fish preparation tables and
calculate the quantity of sardine processed
each month
- Management review each trimester

For target 6, the first operational control (Figure 17) is crucial since it enables to compare the
separated fish waste to the total amount of this kind of waste (0.4 ton/ton of processed sardine). In
this way it is possible to assess whether all sardine waste is separated on the fish preparation
tables or not.

Quantity of fish waste separated on


the heading and eviscerating tables

Separated sardine waste per


ton of processed sardine
Amount of sardine processed each month

X ton/ton of processed sardine

COMPARISON

Total sardine waste per ton


of processed sardine
0.4 ton/ton of processed sardine

Figure 17 Operational control concerning CCCs target 6

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3.2.7

Prevention and Emergency Preparedness

The company must establish and keep procedures enabling the identification of possible accidents
and emergency situations and must be prepared to prevent and reduce all connected
environmental impacts. The procedures and the emergency preparedness of the company have to
be analyzed and, if needed, reviewed, particularly, after occurrence of accidents or emergencies.
The mentioned procedures must also be periodically tested, where applicable.
The accidents and emergencies that may occur in XPTO (CCC) are identified and controlled as
described in the system procedure, SP 08 Emergency Preparedness and Response. For each
identified situation is developed a plan for emergency response (PER # - Type of Situation) where
several items are referred, namely, immediate response actions, who to call and, if applicable,
who must reduce the environmental damage and which authorities must be informed. The
occurrence of any accident or emergency must be recorded in a specific form, RAE Accidents
and Emergency Situations.

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3.3.

OPERATION

3.3.1

Monitoring and Measurement

The company must establish and keep documented procedures for periodic monitoring and
measurement of the main parameters of all operations and activities with a significant impact on the
environment. These procedures require complete records, hence, enabling to monitor the
performance of the relevant operational controls and conformance with environmental objectives
and targets.
These activities are essential for an adequate control of all critical points and require environmental
performance indicators (EPI). Therefore, it is very important to identify a set of EPI able to portrait
the companys evolution towards its environmental objectives and targets. Moreover, for all EPI,
target values must be established and acceptance criteria have to be defined as well. In this way, it
is possible to compare the actual environmental performance with the previously defined objectives
and targets.
The creation of adequate documentation is equally important and, in order to reach such goal, all
detailed requirements were incorporated in the operational procedures. Furthermore, was
developed a system procedure, SP 09 Monitoring and Measurement, describing how to identify
the monitored operations and activities and, for each operation and activity, defining which
parameter(s) must be measured, the necessary equipment and the adequate records. All these
data are recorded in lists specially designed for this purpose, LMMOA Monitoring and
Measurement Operations and Activities and LMEQ Monitoring and Measurement Equipment.
For every equipment used by XPTO (or CCC) in the monitoring and measurement operations, an
equipment document must be filled out, DEQM Equipment for Monitoring. This document records
all maintenance and calibration operations performed in the device. Whenever possible, the records
present the established limit values, thus, enabling a rapid and simple assessment of the measured
values.
Frozen fish industry

XPTO sought to implement specific monitoring and measurement actions for each operational
control (Table 11). These actions typically involved calibrating the measurement devices, recording
the values attained in every operational control and comparing these values to the ones previously
established as targets.

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Table 11 Required monitoring and measurement actions for each operational control (XPTO)

Operational control
- Verify monthly water consumption and
calculate the amount of hake processed each
month (Target 1)
- Verify monthly electricity consumption and
calculate the amount of hake processed each
month (Target 2)
- Management review each trimester
(Target 3)
- Perform chemical analysis of the glazing
wastewater every month (Target 4)
- Estimate monthly production of common
garbage and calculate the amount of hake
processed each month (Target 5)

M & M action
- Calibration of water meters and scales
- Record monthly value of water consumption
per ton of processed hake
- Comparison with established target
- Calibration of electricity meters and scales
- Record monthly value of electrical energy
consumption per ton of processed hake
- Comparison with established target
- Record phase of the project
- Record delays to the schedule (chronogram)
- Report to the management board
- Record monthly values of COD and BOD5 in
the glazing wastewater
- Comparison with established targets
- Monitoring common garbage disposal and
calibrating scales
- Record monthly value of common garbage
production per ton of processed hake
- Comparison with established target

The monitoring and measurement actions established for target 5 are presented in a schematic
manner in Figure 18:

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MONITORING COMMON GARBAGE DISPOSAL


CALIBRATION OF THE SCALES
Measurement of the
volumetric capacity

2 kg

Work instruction for


determining the
number of
dumpsters filled
each month

ENABLES

1 kg

0.5 kg

ENABLES

RECORD MONTHLY VALUE


OF COMMON GARBAGE
PRODUCTION PER TON OF
PROCESSED HAKE
ENABLES

COMPARISON WITH
ESTABLISHED TARGET

Figure 18 Monitoring and measurement actions concerning XPTOs target 5

Canning industry

CCC implemented specific monitoring and measurement actions for each operational control (see
Table 12). As with XPTO, there were typical actions for the various targets: calibrating the
measurement devices, recording the values attained in every operational control and comparing
these values to the ones previously established as targets.

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Table 12 Required monitoring and measurement actions for each operational control (CCC)

Operational control
- Verify monthly water consumption and
calculate the amount of sardine processed
each month (Target 1)
- Verify monthly electricity consumption and
calculate the amount of sardine processed
each month (Target 2)
- Management review each trimester
(Target 3)
- Management review each trimester
(Target 4)
- Monthly chemical analysis of the wastewater
generated in the plant (Target 5)
- Estimate monthly amount of fish waste
separated on the fish preparation tables and
calculate the quantity of sardine processed
each month (Target 6)
- Management review each trimester
(Target 6)

M & M action
- Calibration of water meters and scales
- Record monthly value of water consumption
per ton of processed sardine
- Comparison with established target
- Calibration of electricity meters and scales
- Record monthly value of electrical energy
consumption per ton of processed sardine
- Comparison with established target
- Record phase of the project
- Record delays to the schedule (chronogram)
- Report to the management board
- Record phase of the project
- Record delays to the schedule (chronogram)
- Report to the management board
- Record monthly values of COD, BOD5,
Nitrogen and Phosphorous in the wastewater
- Comparison with established targets
- Calibration of scales
- Record monthly value of separated fish
waste per ton of processed sardine
- Comparison with established target
- Record phase of the project
- Record delays to the schedule (chronogram)
- Report to the management board

The monitoring and measurement actions established for both operational controls of target 6 are
presented schematically in Figure 19:

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CALIBRATION OF THE SCALES

2 kg

1 kg

RECORD PHASE
OF THE PROJECT

For instance, the


second task of target 6

0.5 kg

Negotiations

ENABLES

RECORD MONTHLY VALUE


OF SEPARATED FISH
WASTE PER TON OF
PROCESSED SARDINE
ENABLES

COMPARISON WITH
ESTABLISHED TARGET

Fish
Waste

FISH MEAL
PLANT

CCC

RECORD DELAYS TO
THE SCHEDULE

REPORT TO THE
MANAGEMENT BOARD

Figure 19 Monitoring and measurement actions concerning CCCs target 6

3.3.2

Non-Conformances and Corrective and Preventive Actions

Once implemented the monitoring and measurement structure, it must be defined what the
company (XPTO or CCC) shall do if any aspect of EMAS implementation stands beyond the
acceptance criteria. Such situation, commonly referred to as a non-conformance requires corrective
and preventive actions. The first kind of actions enables to take steps in order to reestablish the
concerned aspect within the allowed limits, while the second kind aims to avoid any serious
deviation.
For an appropriate implementation of this EMAS control structure, a specific group of documents
was created. Namely, was developed a system procedure, SP 10 Non-Conformances and
Corrective and Preventive Actions, defining responsibilities and authorities, investigation of nonconformances, minimization of any caused impacts and the establishment of corrective and
preventive actions. What is more, the organization is obliged to implement and record any
procedure alteration arising from corrective and preventive actions. For every detected nonconformance, a specific document must be filled out, RNC # - Non-Conformances, recording all
relevant information: section where the non-conformance occurred, requirement of the norm
disrespected, non-conformances description, all corrective and preventive actions performed and
altered documents.
In XPTO (or, similarly, CCC), the detection of non-conformances resulted from complaints,
emergency situations, audits and all monitoring and measurement actions.

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Frozen fish industry

There were some situations of non-conformance observed in XPTO that required minimization of
impacts and, of course, corrective actions to suppress the problems. Furthermore, to avoid the
occurrence of similar non-conformances in the future, it was necessary to take also preventive
measures.
Non-conformances were detected in the training, communication and operational control issues of
EMAS implementation (Table 13). The problems were aroused by lack of environmental awareness
among workers and a clear absence of experience of the management with any EMS previously
to the present effort towards an effective EMAS implementation, XPTO had no environmental
concerns whatsoever and, as a consequence, did not implement any EMS.
Table 13 Detected non-conformances and corrective and preventive actions taken by XPTO

Non-conformance

Corrective action

Preventive action

No specialist environmental training


provided for those workers whose activity
had a significant environmental impact
The two lists, LINTC Internal
Communication and LEXTC External
Communication were not filled out

Commission external
environmental experts
(for all training needs)
Fill out the lists with the
missing information

Delay in the installation of vacuum hoses


because of unforeseen technical problems

Ask advice from other


experts

COD and BOD5 levels did not show any


decrease because workers removed the
screen installed in the glazing tanks drain
(apparently, the drain was clogged)
Increase in the production of common
garbage per ton of processed hake

Reinstall the screen

Put a specific person in


charge of all training
actions
Explain to all workers the
importance of these two
documents
Immediately report any
serious technical problem
in the installation of new
equipments to EMS team
Teach workers to
periodically remove the
solid waste retained in the
drain of the glazing tank
Reinforce workers training
for common garbage
separation

Appointment of a
person for supervising
workers when they
screen the garbage

The referred corrective actions aimed at minimizing the non-conformances impacts or, at least,
avoiding, in the short term, the effects of the detected problems. On the other hand, to solve these
problems and, thus, avoid its consequences in the long term requires preventive actions based on a
good knowledge of the environmental aspects of the company. Training and raising environmental
awareness among workers are very important actions (useful with various non-conformances, as
can be seen in Table 13), leaving a permanent mark for the future.
Canning industry

Similarly to the case of XPTO, CCC experienced some non-conformances and took adequate
corrective and preventive actions. The non-conformances were detected in the training and
operational control issues of EMAS implementation (Table 14). Once more, the lack of
environmental awareness and the absence of any previous experience regarding environmental
management systems caused most of the fundamental difficulties.

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Table 14 Detected non-conformances and corrective and preventive actions taken by CCC

Non-conformance
No specialist environmental training
provided for those workers whose activity
had a significant environmental impact
The organic load in the wastewater did not
decrease as expected

Absence of the operational procedure for


separating solid waste

3.3.3

Corrective action
Commission external
environmental experts
(for all training needs)
Appointment of a
person for supervising
workers when they
collect blood and offal
Special meeting of the
EMAS team members
in order to prepare the
procedure

Preventive action
Put a specific person in
charge of all training
actions
Reinforce workers training
for collecting offal

Regular EMAS meetings


for analysis of all extant
and planned operational
procedures

Environmental Records

The environmental records including all those related to training, audits results and reviews
must be carefully kept since they prove the painstaking implementation of all EMAS requirements.
The records must be legible, clearly identified, connected with the respective activity and
adequately kept. Moreover, the time periods during which all records are kept must be established
and registered.
At the documentation level, was created a system procedure, SP 11 Records. This procedure
describes how to carry out the identification, archiving, maintenance and elimination of the records.
As a result of the EMS implementation are defined several kinds of records depending on the
function which they are intended to serve. For an easy and rapid access, all records are archived in
the appropriate folders, Training, Operational Control, Monitoring and Measurement, etc.
An overview of the environmental records system applied to XPTO (CCC) can be seen in Figure
20:

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RECORDS:

ESTABLISHED FOLDERS:

ELIMINATION:
AFTER:

REVIEW RESULTS
DEFINITION OF OBJECTIVES AND TARGETS
ENVIRONMENTAL PLAN (chronograms)
DEFINITION OF RESPONSIBILITIES
TRAINING RECORDS
COMMUNICATION LISTS AND RECORDS
LISTS OF DOC. REMOVED, MODIFIED, etc.
LISTS OF WORK INSTRUCTIONS
EMERGENCY PLANS AND RECORDS

ENVIRONMENTAL REVIEW

TO BE DEFINED

OBJECTIVES AND TARGETS

TO BE DEFINED

ENVIRONMENTAL PROGRAMME

TO BE DEFINED

RESPONSIBILITIES

TO BE DEFINED

TRAINING

2 YEARS

COMMUNICATION

3 YEARS

DOCUMENTATION CONTROL

5 YEARS

OPERATIONAL CONTROL

TO BE DEFINED

PREVENTION AND EMERGENCY


PREPAREDNESS

5 YEARS

MONITORING AND MEASUREMENT

5 YEARS

NON-CONFORMANCES AND CORRECTIVE


AND PREVENTIVE ACTIONS

5 YEARS

AUDITS RESULTS

INTERNAL AUDITS

3 YEARS

REVIEW RESULTS

MANAGEMENT REVIEWS

3 YEARS

ENVIRONMENTAL STATEMENTS

3 YEARS

LISTS, MAINT. & CALIBRATION RECORDS


NON-CONFORMANCES RECORDS

ENVIRONMENTAL STATEMENTS

Figure 20 System of environmental records applied to XPTO and CCC

3.3.4

Internal Audits

The performance of internal audits is determined by a number of reasons:

To observe whether EMS agrees with the previously defined environmental programme
(including the requirements of EMAS)

To verify if the system was correctly implemented and maintained

To provide information for the management review

There are two instruments that guide the execution of an internal audit, the internal audits
programme and the audit procedures. The internal audits programme, including its calendar,
specifies which activities must be audited taking into consideration the environmental importance of
the companys activities. Moreover, the programme must be improved, incorporating the
contributions of previous audits. On the other hand, the procedures must specify the audits scope
and frequency, all methodological issues, the management responsibilities and, also, the
requirements for the conduction of audits and for the communication of results to the management
board and audited areas.
The internal audits span from simple procedures to complex activities and all companys activities
must be audited after some period of time, completing an audit cycle. Depending on the activities
complexity, importance and history of the environmental problems, an audit cycle can take more or

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less time to be completed, but it should not be forgotten that EMAS imposes a maximum period of
three years for completion.
In accordance with the previously mentioned requirements, the implementation of EMAS in XPTO
(and, similarly, CCC) entailed the elaboration of an internal audits programme and a specific audits
procedure. The program establishes the areas of XPTO (CCC) to be audited:

Production and Quality Control

Warehouse and Offices

Auxiliary Operations

Canteen and Exterior

Environmental Records

EMS Documents

The system procedure, SP 12 EMS Audits, defines how to carry out EMS audits. Namely, it
requires the analysis of the progress in accomplishing all environmental objectives and targets at
the productive and financial levels.
Being a small company, each internal audit simultaneously encompasses all relevant activities and,
therefore, an audit cycle is the interval between such overall audits. For XPTO (CCC), the system
procedure defines the time length of an audit cycle to be one year.
In order to ensure an unbiased audit, the internal audit is carried out by persons not involved with
the audited activities and, also, free from all those factors that compromise the auditors ability to
make a correct assessment. Hence, the organizations small size forced XPTO (CCC) to ask
external professional consultants to perform the audits.
The preparation of the audits required an audits plan (Table 15). The plan specifies all details
needed to conduct the audits process and guides the auditor in the plant.

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Table 15 Summary of the audits plan for XPTO (CCC)

Issue
Objectives
Criteria
Application areas
Calendar

Functions and responsibilities


Resources localization

Companys representatives
Reports issues

Logistics
Confidential issues
Future audits actions

Content
Verification of compliance with EMAS norm and the
environmental objectives and targets
EMAS requirements
The six areas mentioned above
Preparation two months
Inspection six months
Report preparation and presentation four months
Specific tasks assigned to the members of the audits
team
Where to find the main documents and devices
required for measurements and other inspection
activities in the critical areas
EMS team members
Audits objectives; application areas; company' name;
audited processes; clients identification; audits team
identification; dates and places of the audits activities;
criteria; audits results and conclusions
The planning of all visits and inspection tasks
List of the companys areas that must receive special
care regarding divulgation
Issues that raised some doubts or problems must be
followed in the future

With the purpose of making a correct evaluation of each audited aspect, audits include personal
interviews, inspection of operational and equipments conditions and analysis of records, written
procedures and other documents. For each single point, is assessed the compliance with norm and
established objectives and targets in order to determine the overall EMS efficiency. The audits
process itself follows a specific sequence of steps:

Understanding the implemented EMS

Finding all strong and weak points of the implemented EMS

Collecting meaningful data

Evaluating the audits results

Establishing the audits conclusions

Communicating the audits results and conclusions

This last step is carried out with the preparation of an audits report, which is presented to the
management board. The report achieves several goals, namely, documents the audits scope,
provides information about the accomplishment of the environmental policy, analyzes the suitability
of the monitoring and measurement activities for an adequate assessment of all environmental
impacts and, also, justifies the need of corrective actions. Furthermore, the audits process, once

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concluded, entails the preparation and application of a plan containing appropriate corrective and
preventive actions.
For both companies, the audits results (Table 16) revealed several problems in the implementation
of EMAS that must be dealt with in the future.
Table 16 Summary of the audits results for XPTO and CCC

Audits results - XPTO


The production of common garbage per ton of
processed hake did not decrease, therefore,
jeopardizing the accomplishment of target 5
Besides the glazing wastewater, there are other
operations that generate wastewater which
must be analyzed (for instance, cleaning)
The maintenance and calibration activities are
not correctly registered in the records
The responsibilities structure is unbalanced (the
number of tasks assigned to EMS coordinator is
quite excessive)
Absence of adequate environmental training for
all workers and, specially, for those whose
activity had a significant environmental impact

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Audits results - CCC


The organic load in the wastewater did not
decrease, thus, making difficult to cut by half
COD and other parameters till the end of 2005
The monitoring of the amount of fish waste
separated is not adequate since it does not
comprise other process operations besides
heading and eviscerating
The list of modified documents is missing
The responsibilities structure is unbalanced (the
number of tasks assigned to EMS coordinator is
quite excessive)
Absence of adequate environmental training for
all workers and, specially, for those whose
activity had a significant environmental impact

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3.4.

ENVIRONMENTAL MANAGEMENT SYSTEM VERIFICATION

3.4.1

Management Review

The management must review the implemented EMS, thus, ensuring that it remains adequate,
sufficient and effective. The management review has to consider possible alterations of
environmental policy, objectives and targets as a result of modified circumstances and, on the other
hand, it should embrace a thorough analysis of the results of the internal audit. From this review, it
should be possible to point out some guidelines for the improvement of EMS in the company.
Moreover, the review must be conducted when established by the company and all discussed
issues must be recorded in the review minutes.
The EMS described in this case study is reviewed each year by the XPTO (CCC) management
together with the EMS coordinator. This review is performed in a meeting that is held every year in
order to analyze the audit results and the compliance with all requirements defined by the norm
and, also, by the environmental policy and its objectives. All conclusions and results of this meeting
are written down in a specific report, RMR Management Review. The review conclusions (see
Table 17) emphasize the need to take steps further in rationalizing the processes described for the
fish processing industry and to reinforce training programmes.
Table 17 Conclusions of the first management reviews undertaken by XPTO and CCC

Conclusions - XPTO

Conclusions - CCC

All wastewaters generated in the plant should


be regularly analyzed for determination of COD,
BOD5, N and P
The company should search for new clean
technologies (for instance, fixtures that restrict
or control water flow for cleaning)
The company should develop a complete and
detailed training programme with clearly defined
deadlines for every task
EMS team members should enter EMS courses
in order to get a deeper knowledge of
environmental management
Responsibilities for EMS should be split more
evenly among EMS team members

Gas emissions from boiler should be monitored


on regular basis

3.4.2

The company should search for new clean


technologies (for instance, fixtures that restrict
or control water flow for cleaning)
The company should develop a complete and
detailed training programme with clearly defined
deadlines for every task
EMS team members should enter EMS courses
in order to get a deeper knowledge of
environmental management
Responsibilities for EMS should be split more
evenly among EMS team members

Public Communication

EMAS is much more demanding than other norms in what concerns public communication,
requiring the presentation of an environmental statement.
The objective of the environmental statement is to provide environmental information regarding
the companys environmental performance to the general public and other interested parties. For
the first EMAS registration of the company and, thereafter, every three years, an environmental
statement must be presented. Before presenting all relevant information to the public as an
environmental statement, the referred information has to be validated by an environmental verifier
and, afterwards, presented to the competent organism. In order to overcome successfully all

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difficulties connected with this process, there are several items that must be included in the
information:

A clear and unequivocal description of the organization requesting the registration under EMAS
and a summary of all its activities, goods and services

The environmental policy of the organization and a brief description of its EMS

A description of all environmental aspects of the organization that bring about significant
environmental impacts and an explanation of the relationship between the nature of such
impacts and those aspects

An explanation of the environmental objectives and targets and their connection with those
environmental aspects and impacts deemed meaningful

A summary of all available data concerning the organizations accomplishment of its


environmental objectives and targets

Other factors related to the environmental performance, including the compliance with all
relevant legal regulations

The name and accreditation number of the environmental verifier and the validation date

XPTO (CCC) prepared an environmental statement following all requirements mentioned above
(Table 18). The available raw data was used to calculate the values of environmental performance
indicators considered relevant to the companys environmental portrait. These indicators were
chosen based on their accurate performance assessment, intelligibility and comparability over time,
with benchmarks and, when needed, with regulations. Moreover, the values determined for the
production of solid waste and wastewater and, as well, for the consumption of raw materials, water
and energy were included in the statement.

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Table 18 Summary of the environmental statements prepared by XPTO and CCC

XPTO

CCC

Companys description (see section 2.3.1)


Environmental policy (see section 3.1.1)
Environmental aspects (see section 3.1.2)
Objectives and targets (see section 3.1.4)
Env. Performance indicators (October 2004):
3

Water consumption 3.5 m /ton

Water consumption 4.0 m /ton

Electricity consumption - 790 kWh/ton

Common garbage production 0.3 m /ton


3

Wastewater discharge 3.5 m /ton

Companys description (see section 2.3.2)


Environmental policy (see section 3.1.1)
Environmental aspects (see section 3.1.2)
Objectives and targets (see section 3.1.4)
Env. Performance indicators (October 2004):

Electricity consumption 73 kWh/ton

Fuel oil consumption 0.05 ton/ton

Fish waste production 0.4 ton/ton

COD (glazing wastewater) 400 mg O2/l

Wastewater discharge 4.0 m /ton

BOD5 (glazing wastewater) 100 mg O2/l


Environmental verifier:
Name - VVV
Accreditation number - #####
Validation date - ##/##/##

COD (wastewater) 7700 mg O2/l


BOD5 (wastewater) 3500 mg O2/l
Nitrogen (wastewater) 200 mg N/l
Phosphorous (wastewater) - 27 mg P/l
Environmental verifier:
Name - VVV
Accreditation number - #####
Validation date - ##/##/##

Ton of processed hake

Ton of processed sardine

As part of the effort to improve the relationship with the local community where the companys plant
is located, XPTO (CCC) communicated important aspects of its environmental information. These
data were extracted from the environmental statement and were validated by the environmental
verifier in order to assure their accuracy, relevance, clarity and environmental significance.
3.4.3

Validation, Verification and Records

A company that intends to request the registration under EMAS has to commission an independent
environmental verifier, which must undertake a careful examination of the environmental policy,
programme, management system, review or audit procedure. The validation is conferred only if the
verification process reveals full compliance with all EMAS requirements in the company and
validates the environmental statement. Afterwards, the company must submit the validated
environmental statement and a specific form duly filled in and must pay a registration fee to the
competent organism. Furthermore, the competent organism has to evaluate, based on the received
evidence and on investigation, whether the organization complies with all EMAS requirements. If
this question is affirmatively answered, registration under EMAS is granted and a registration
number is given to the company. Thereafter, the company has the right to use a statement of
participation in EMAS and employ it for advertising purposes. After three years, if the company
wants to remain registered, it has to repeat the environmental audit, to update the environmental
statement, and to get through another examination and validation by an environmental verifier.
XPTO (CCC) commissioned an environmental verifier with a thorough examination of EMAS
requirements compliance in the company. In spite of some minor faults, the verifier validated the
XPTO (CCC) environmental statement.

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Afterwards, XPTO and CCC requested registration under EMAS to the Portuguese competent
organism, Instituto do Ambiente (IA). After analyzing the EMAS implementation in the two
companies, the IA granted registration to both and, also, attributed the registration numbers
(REG.NO. ##### for XPTO and REG.NO. ##### for CCC). As a result of this registration, both
companies were allowed to use the EMAS logotype in the version 1 (see Figure 21), indicating that
each company has an EMS compliant with EMAS and in the version 2 (see Figure 22), for all
validated information and advertising campaigns.

Figure 21 Version 1 of the EMAS logotype

Figure 22 Version 2 of the EMAS logotype

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REFERENCES
4

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Decreto-lei 366-A/97 of 20 December 1997, Dirio da Repblica, 293-97, I Srie, Parte A,
6732(498)-6732(503)
Decreto-lei 236/98 of 1 August 1998, Dirio da Repblica, 176/98, I Srie, Parte A, 3676-3722
Decreto-lei 292/2000 of 14 November 2000, Dirio da Repblica, 263, I Srie, Parte A, 6511-6520
Decreto-lei 259/2002 of 23 November 2002, Dirio da Repblica, 271, I Srie, Parte A, 7368-7370
Decreto-lei 78/2004 of 3 April 2004, Dirio da Repblica, 80, I Srie, Parte A, 2136-2149
Lei 11/87 of 7 April 1987, Dirio da Repblica, 81/87, I Srie, 1386-1397
Nunes, M. L. and Batista, I. (2002), Aproveitamento de desperdcios e aplicao de tecnologias
limpas no sector da pesca, Actas das jornadas tcnicas e cientficas do IPIMAR Produtos da
pesca Qualidade, segurana e inovao tecnolgica, 11-12 October 2001, Publicaes avulsas
do IPIMAR, 9, 59-72
Portaria 286/93 of 12 March 1993, Dirio da Repblica, 60/93, I Srie, Parte B, 1169-1177
Portaria 335/97 of 16 May 1997, Dirio da Repblica, 113/97, I Srie, Parte B, 2440-2441
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Official Journal of the European communities of 24 April 2001

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