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Standards and Compliance Inspections are the Biggest Hinder for Development of Sustainable Productions
Dr. Jens Peter Mortensen
Environmental Inspector

Solrød Kommune

Solrød Centeret 1, DK-2680 Solrød Strand

DenmarkDirect tel.: +45 56 18 22 41
E-mail: jpm@solrod.dk

Standards in permits to companies can be based on different principles but they will all ways be a result of average considerations. Standards are often used to equalize the economic conditions for companies competing inside the same branch in environmental matters. This is the basic understanding behind the Best Available Technology (BAT) thinking and the standards according to the European permit system formulated through the IPPC directive.
 The basic concept and understanding of continuously development of cleaner production is fundamentally based on benchmarking of variations and changes. Variations and changes consist of two outer points where the range in between will represent the potential for improvements. In the programming of standards and average considerations the IPPC directive diverges from the development of cleaner production though the BREF notes can be to some inspiration.

 BREF notes rely on average consideration of a range of companies competing inside the same branch often leads to solutions suitable to all the companies which often only can be expressed in general knowledge in treatment technology. Enforcement and compliance of the standards leads to costs for the single company and have to be done simultaneously for the different companies competing inside the same branch.
 Instead of focussing on extra costs the Danish local administrations have in the end of the eighties worked out some concepts to continuously support the development of cleaner production on the single company. Instead of focussing on compliance of standards the focus is changed to a focus on benchmarking of Win-Win situations and variations as an expression for cleaner production potentials or hidden incremental changes.
 The dialogue starts with the identification of the Win-Win situations in order to secure the success of the inspection and to break down the ice. It is not a meeting between equal partners and the companies have to rely on the good will of the inspector. The variations angle is used to identify the potentials. The inspector cannot go in to formulation of solutions because it is the responsibility of the private company it self.
 
The resent results are originated from different municipalities; Slagelse, Næstved, Frederikssund and Roskilde and companies from different branches such as electroplating, dry cleaners, candy factories, etc. The cleaner production angle is often inhibited through previous investment of treatment technology and the negation of the standards, so there is some resistance in the system both from municipalities and especially from DEPA.
 The experiences from the early days have been developed in to training programmes for environmental inspectors. The programmes are based on a company visit in photos and site plans so the inspectors in a classroom together visit the same company – see the same things and hear the same explanations. In this way it is possible to impose new angles and new methods. It is also possible to exchange views and understanding of the situations without the disturbing: “This is my case, so I know best”.
 
After testing in the classroom it is possible to test on inspections in the real world and exchange the results in the created network. The managers of the inspectorates often criticize this method of inspection for being time consuming and to difficult to understand. The experiences show different and with results way beyond the standards often with factor ten reductions as result.
 Today these kinds of inspections and network have very bad development conditions in Demark. The inspectorates are monitored and benchmarked through compliance and enforcement of DEPA and EU standards. Individual assessment of companies made by the single inspector doesn’t count anymore.

 The development of sustainable production needs the spreading of the methods at the local level and the frame for the inspectors to use them. As it is to day the standards and the concept of compliance is destroying the options for development of cleaner production.

Keywords: Inspection strategies, environmental management system, improvements, cleaner production.

 

All Submissions
7:00 AM-5:00 PM, Thursday, 28 April 2005, Oral

The Netherlands 2005 Meeting