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Appendix 13
Practical guidelines for the
preparation of public HSE reports
The text below has been
extracted and adapted from the "CEFIC Guidelines on Environmental Reporting for the
European Chemical Industry", published in 1993. These guidelines covered
environmental reporting only. The text and examples have been updated to reflect HSE
reporting, while the detailed contents part that is superseded by the current guidelines
has been deleted. Some considerations on Sustainable Development that were developed in
1995 but were not published at that time, have also been included.
Most obviously the issue
of HSE reporting is presently in a state of "learning by doing" and a number of
developments can be expected in the coming years. For example, the following questions
remain open and need further consideration:
- It is generally accepted that publishing
environment reports for individual sites is a response to the publics demands and a
requirement of the current EU-Eco-Management and Audit Scheme (EMAS). However it is
recognised that some companies might prefer to publish reports just at corporate level
with no information given for individual sites.
- Publishing forecasts of emissions for
future years, however desirable to gain public credibility, is a sensitive issue left to
the decision of individual companies.
- Reporting on operations in joint ventures
can be integrated in corporate HSE reports. In this case the method used for such
integration should be mentioned in the report.
This appendix includes
the following sections:
- Suggested structure for
"corporate" HSE reports
- Suggested structure for "site"
HSE reports
- The dos and donts of HSE
reporting
When using the guidelines
in this appendix, authors of HSE reports should find the best compromise between the
format suggested and the specifics of the company or the site.
1. Suggested structure for
"corporate" HSE reports
It is suggested that HSE reports covering
the activities of a company or corporation include the following sections:
1.1 Foreword
- Chairmans address
- Brief description of the company
- Business data on the company
- Company HSE policy
- Environmental R&D
- Methodology for reporting (e.g. absolute
data, or aggregated index, etc.)
1.2 Production facilities
- Recent technical achievements, new units,
developments, etc.
- New technologies developed or used; impact
on the environment and on resource conservation (energy, raw materials, water, etc.)
1.3 Products
- New products developed (with lower
environmental impact)
- Product stewardship concept
- Products (and techniques) developed and
marketed for environmental protection
1.4 Sustainable Development
- Global environmental issues (e.g. climate
change, ozone depletion, etc.)
- Material and energy intensity
- Recycling
- Technology co-operation in the field of
environmental protection and resources conservation
- Global operating standards (i.e. how the
company ensures a convergence between its sites and the best current industry practice).
1.5 Plans, objectives, goals
- Major plans and programmes
- Qualitative objectives (medium/long term)
- Quantitative objectives (medium/long term)
1.6 Management Systems addressing HSE
- Company organisation for the management of
HSE aspects
- Human resources, training and education
- Environmental protection techniques
(highlights only)
- Monitoring systems, data
measured/calculated/estimated
- Environmental impact assessment/risk
assessment
- Safety and Health related
programmes/activities
- Audits
- Emergency preparedness
1.7 Data (including a comparison with
data of previous years)
- Emissions data
- Selected details (e.g. soil/ground water
protection, noise reduction, etc.)
- Energy generation and consumption
- Health and safety data
- Complaints, prosecutions (optional)
- Spending on environmental protection
1.8 Communications
- Community relations
- Dialogue with external audiences
- Open days
- Public advisory panels
1.9 General comments
1.10 Contact People
Note:
A corporate report may also include a section dealing with HSE performance of the
companys individual sites. In this case it is recommended that each individual
report follow the structure of the sites reports which follow, simplified as appropriate.
2. Suggested structure for "site" HSE
reports
It is suggested that HSE reports covering
the activities of an individual site of a company include the following sections:
2.1 Foreword
- Site Managers address
- Company HSE policy
- Company HSE objectives (medium/long term)
2.2 Site description
- Main units, main products
- Site put into perspective:
- usage of products
- economic contribution and employment
- relations with authorities and with local
community
- environmental situation: local conditions
of air/water/soil, sensitive areas in the neighbourhood, etc.
- Legal requirements: permits, emission
limit values, etc.
- Controlling authorities (national, local,
etc.)
2.3 Management Systems addressing HSE
- Structure (human resources, organisation)
- Programmes, objectives
- Environmental protection techniques (water
treatment, waste disposal, etc.)
- Integrated approach (recycling, new
technologies)
- Monitoring techniques/systems (data
measured/calculated/estimated)
- Emergency preparedness
2.4 Data (including a comparison with
data of previous years)
- Emissions data
- Selected details (noise, odours, etc.)
- Energy generation and consumption
- Health and safety data
- Complaints (optional)
- Spending on environmental protection
2.5 Communications
- Community relations
- Open days
2.6 General comments
2.7 Contact people
Note: Information
should be adapted to site specific conditions and local expectations.
3. The dos and donts of HSE
reporting
The following suggestions are proposed to
authors of HSE reports:
- Audiences should be identified and methods
of communication (e.g. presentation and discussion of the report) tailored to suit the
needs of the various audiences.
- Establish a dialogue with the target
audience and determine what it wants to know.
- The audience must know from where
supplementary information can be obtained, e.g. through a reply slip or an open telephone.
- Comparisons between the environmental
impact of different industries are not appropriate.
- Even an estimate is better than saying
nothing.
- Failures, accidents and prosecutions
should be made public and explained.
- Consistency across sites in a single
company and between sites in a single locality is desirable in order to pre-empt
differential criticism. (Nevertheless a company needs a certain flexibility to adapt the
information to its own specific requirements and to local expectations).
- It must be periodically checked that the
information supplied is being understood and accepted.
- Do not "blind the public with
science", nor patronise them with oversimplification.
- Dialogue must be the keynote.
- Information made available to the public
must also be given and explained to the workers on the site.
- Do realise that your first report is not
the definitive report.
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