As the existing ISO 14001 environmental management system is replaced this year, FMs should be instituting the Energy Saving Opportunity Scheme, says Lee Calver
15 January 2015
The Energy Saving Opportunity Scheme (ESOS) is a hot topic. For large companies in the UK this is potentially the most significant new environmental regulation since the CRC Carbon Reduction Scheme was launched in 2010.
If you are a UK organisation employing more than 250 people or meeting the standard financial criteria for defining a large company, then you need to know about these regulations and be considering how to ensure your compliance to avoid the £50,000 maximum fine the Environment Agency (EA) is toting as the scheme administrator.
Participating organisations must inform the EA that they have complied with the scheme by 5 December 2015 and be able to show documentary evidence of this on request.
Meeting these regulations will on average cost £17,000 for each participant in the first audit cycle and if 6 per cent of opportunities identified are implemented, then it will bring a net benefit to the UK economy of £1.9 billion between 2015 and 2030.
The new regulations require participants to calculate their total energy use (including fuel for business transport) over a 12-month period overlapping with the qualification date (31 December 2014), and to carry out energy efficiency auditing covering 90 per cent of energy use. The good news is that those already collecting data for the CRC, EU ETS, mandatory GHG reporting and CCAs can use these submissions to eliminate the need to duplicate data collection. Ninety per cent of your organisation's energy use must be covered by:
- ESOS compliant energy audits
- Display Energy Certificates
- Green Deal Assessments
- ISO 50001 accredited energy management system
ESOS stems from article 8 of the EU Energy Efficiency Directive; this means that similar regulations are coming into force across all European Union member states. ESOS equivalent regulations have already been transposed into national law in the Irish Republic, France and Germany. There are minor differences in the way that energy auditing will be mandated in all jurisdictions, therefore it is potentially a significant headache to work out requirements for meeting all of these individual national obligations.
One mode of compliance using a single, harmonised strategy is implementation of ISO 50001. This excludes certified bodies from the need to comply, however, time for implementing this International Standard is running out and if this is something you are considering, you should act now.
FMs I have spoken to about ESOS have all had great ideas for realising significant energy savings, but have struggled to gain traction with these plans at a senior management level. ESOS is a great opportunity to get these plans seriously considered at board level (sign-off by at least one company director is a requirement of the regulations). As a result of several regulations over the past 10 years, it will be easy to see ESOS through cynical eyes - as just another environmental tax and a costly tick-box exercise. But the most significant benefits will be realised from organisations and FMs recognising the opportunities associated with these regulations.
ISO 14001 to change
The worldwide number of bodies with a certified ISO 14001 environmental management system (EMS) now exceeds 300,000. The rapid rise in popularity of the standard is testament to the business benefits it can bring to an organisation including economic savings, for example, from reduced resource use, plus reputational benefit arising from better management of environmental risks.
But the existing standard has been in place since 2004 and is nearing the end of a review that should result in publication of a revised version in Q3 of next year. Several significant changes are proposed to integrate consideration of the environment into an organisation's core business processes and strategic thinking. It places particular focus on the roles and responsibilities of top management, and also requires consideration of the effects on the organisation of a changing external environment. In addition, it puts emphasis on reducing environmental impacts across the lifecycle of products and services, including supply chains, and requires a higher standard of communications.
These changes will affect bodies with an existing certification and also those seeking to achieve certification to the standard.
If your organisation has a certified ISO 14001 EMS you will have a transition period of three years following publication of the new standard before you will be required to comply with the revised standard.
If you are working towards achieving the standard, or even thinking of doing so, there is time to gain certification against the existing version provided that this is achieved within 18 months of the new standard being published. You will still need to meet the requirements of the 2015 standard within the three-year transition period.
Are there benefits?
The structure of the new standard has been aligned with ISO management system standards, making it easier to put together an integrated system. While the requirements of the draft standard raise the bar, there will be uncertainties in both implementation and auditing until it has been in place for a while. But the required commitment of top management, together with the integration of environmental management into the business strategy should enhance the credibility of the standard and its benefits to an organisation.
Lee Calver is content developer at International Workplace