Division 1

In order to improve the overall environmental performance of a tannery, BAT is to implement and adhere to an environmental management system (EMS) that incorporates all of the following features:

1. (i)

   commitment of the management, including senior management;

2. (ii)

   definition of an environmental policy that includes the continuous improvement of the installation by the management;

3. (iii)

   planning and establishing the necessary procedures, objectives and targets, in conjunction with financial planning and investment;

4. (iv)

   implementation of procedures paying particular attention to:

   1. (a)

      structure and responsibility;

   2. (b)

      training, awareness and competence;

   3. (c)

      communication;

   4. (d)

      employee involvement;

   5. (e)

      documentation;

   6. (f)

      efficient process control;

   7. (g)

      maintenance programmes;

   8. (h)

      emergency preparedness and response;

   9. (i)

      safeguarding compliance with environmental legislation;

5. (v)

   checking performance and taking corrective action, paying particular attention to:

   1. (a)

      monitoring and measurement (see also the reference document on the general principles of monitoring);

   2. (b)

      corrective and preventive action;

   3. (c)

      maintenance of records;

   4. (d)

      independent (where practicable) internal and external auditing in order to determine whether or not the EMS conforms to planned arrangements and has been properly implemented and maintained;

6. (vi)

   review of the EMS and its continuing suitability, adequacy and effectiveness by senior management;

7. (vii)

   following the development of cleaner technologies;

8. (viii)

   consideration for the environmental impacts from the eventual decommissioning of the installation at the stage of designing a new plant, and throughout its operating life;

9. (ix)

   application of sectoral benchmarking on a regular basis.

   Specifically for the tanning of hides and skins, it is also important to consider the following potential features of the EMS:

10. (x)

    to facilitate decommissioning, the maintenance of records of the locations on the site where particular process steps are carried out;

11. (xi)

    other items listed under BAT conclusion 2.