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Doing The Right Things Easy Tools.pdf
1. Doing The Right Things
easyTools
IED Inspections
IED/IRAM Inspection Programme
IMPEL Projects on
Inspection Planning
Horst Büther, Germany OECD, 5 December 2022
European Union Network for
the Implementation and Enforcement
of Environmental Law
2. European Union Network for
the Implementation and Enforcement
of Environmental Law
History
1997: IMPEL – Minimum Criteria for Inspections
2001: EU – Recommendation on Minimum
Criteria for Environmental Inspections
2007: IMPEL – Step by Step Guidance Book for the
Planning of Environmental Inspections
2011: IMPEL – easyTools Risk Assessment
Guidance Book
2011: EU - Industrial Emissions Directive
2012: IMPEL – Guidance for IED Inspections
2013: IED/IRAM Inspection Programme
Since 2015: Common international Inspections
easyTools
Horst Büther 2
3. 1. Planning
4. Performance
monitoring
1b. Setting priorities
1c. Defining objectives
and strategies
1d. Planning and review
1a. Describing the
context
3. Execution and
Reporting
2. Execution Framework
ENVIRONMENTAL INSPECTION CYCLE
3
Horst Büther 3
4. 4
Article 23: Environmental inspections
4. Based on the inspection plans, the
competent authority shall regularly draw up
programmes for routine environmental
inspections, including the frequency of site
visits for different types of installations
- The period between two site visits shall be
based on a systematic appraisal of the
environmental risks of the installations
concerned and shall not exceed 1 year for
installations posing the highest risks and 3
years for installations posing the lowest
risks.
IED
Inspections
5. European Union Network for
the Implementation and Enforcement
of Environmental Law
easyTools Project 2010/11
Risk Assessment in Inspection Planning
Development of a web-based risk
assessment tool for inspections like
IED, Seveso, waste, wastewater, nature
conservation, agriculture and so on
easyTools
Horst Büther 5
6. European Union Network for
the Implementation and Enforcement
of Environmental Law
Objectives
Evaluation of existing inspection tools and
risk criteria
Development of a risk assessment tool for
environmental inspections that could easily
be used by every IMPEL member
Integration into the inspection cycle of the
Step-by-step guidance book (DTRT)
Availability from the IMPEL website as an
advanced interactive IT tool
easyTools
Horst Büther 6
8. RA tools identified
Three general types of methods for RA
were identified:
Linear Mean Value: mean values or sums of
all (weighted) criteria scores are assigned to
risk categories and inspection frequencies
(Spain, Germany)
Mean Value of Risk: mean values of impact
criteria multiplied by probability criteria are
assigned to risk categories (OPRA – EN, NL,
PO, PT)
Maximum Value: inspection task with
highest frequency determine inspection
frequency (France)
Horst Büther 8
10. Result of the questionnaire
Based on the results presented above
within easyTools project the
“Integrated Risk Assessment Method”,
IRAM,
was developed by
combining the advantages of the three
methods, while
limiting the disadvantages
Horst Büther 10
11. Risk Criteria
Potential impacts
Kind and type of installation
Risk of accidents
Handling and storage of waste
Actual impacts
Levels and types of emissions: into air and water
Sensitivity of the local environment
Incidents and accidents
Operator performance
Compliance with permit conditions
Attitude of the operator
Environmental management system (EMAS)
easyTools
Regional District
Admin. Cologne
Environmental permit
Rn: 53.8851-16- 03513
Horst Büther 11
12. Integrated Risk Assessment Method
Risk steered inspection frequency
The (potential) impact of the activity on
environment or human health is:
negligible ► no routine inspection
minor ► every 5 years
moderate ► every 4 years
relevant ► every 3 years
important ► every 2 years
serious ► every year
easyTools
Horst Büther 12
13. European Union Network for
the Implementation and Enforcement
of Environmental Law
Potential Impacts
no
5
4
3
2
1
0
1
2
3
4
5
Building
Permit
Environ.
Directive
Environ.
Permit
IED IED +
Directive
IED + 2
Dirctives
Inspection
frequency
(years)
Score
Type and Kind of Installation
easyTools
Horst Büther 13
14. Impact on the Environment
0
1
2
3
4
5
Horst Büther 14
Score
15. European Union Network for
the Implementation and Enforcement
of Environmental Law
Potential Impacts
no
5
4
3
2
1
0
1
2
3
4
5
No DW DW < 2t/y DW > 2t/y DW >
350t/y
DW >
3,500t/y
DW >
20,000t/y
Inspection
frequency
(years)
Score
Dangerous Waste
easyTools
Horst Büther 15
17. Risk of the Installation
Horst Büther 17
Impact
Operator Performance
18. European Union Network for
the Implementation and Enforcement
of Environmental Law
Influence of Operator Performance
Operator performance criteria:
► Compliance
► Attitude of the operator
► Environmental management system
Scoring of operator performance criteria:
► good: -1
► moderate: 0
► bad: +1
The average (integer) of the operator performance
scoring is added to each impact criteria score
risk score
easyTools
Integrated Risk Assessment Method
►
Horst Büther 18
23. European Union Network for
the Implementation and Enforcement
of Environmental Law
European Union Network for
the Implementation and Enforcement
of Environmental Law
IRAM principles
I. The inspection frequency is determined by
the highest impact score
II. The inspection frequency is reduced by one
step, if the set number of highest scores is
not met (the Rule)
III. The inspection frequency can be changed by
one step up or down based on operator
performance
IV. The more criteria are scored high, the more
inspection effort is needed
easyTools
Integrated Risk Assessment Method
Horst Büther 23
24. European Union Network for
the Implementation and Enforcement
of Environmental Law
European Union Network for
the Implementation and Enforcement
of Environmental Law
IRAM Principles II and IV:
Inspection Frequency and Effort
5
4
3
2
1
0
High Inspection Effort
IC 1 IC 2 IC 3 IC 4 IC 5 IC 6
5
4
3
2
1
0
Low Inspection Effort
IC 1 IC 2 IC 3 IC 4 IC 5 IC 6
easyTools
Horst Büther 24
25. Weight
Not all criteria have the same importance
Therefore: Weighting
Weighting is often Political
Weighting factors (*) and
Weighting terms (+)
Horst Büther 25
easyTools
26. European Union Network for
the Implementation and Enforcement
of Environmental Law
Web Tool and Database
The IRAM rules were implemented into a web-based
programme for risk assessment in inspection planning
The programme distinguishes between:
Coordinator ---► decides on inspection task, criteria,
and steering terms and factors
Inspector ------► does the risk assessment
Assessment data storage on the internet
The assessment data can also be downloaded as XML-
or CSV-files and imported into national data bases
(Access and Excel)
Address of the programme:
https://iram-impel.nrw.de/lip/authenticate.do
easyTools
Horst Büther 26
27. European Union Network for
the Implementation and Enforcement
of Environmental Law
IRAM on the Internet easyTools
Horst Büther 27
28. European Union Network for
the Implementation and Enforcement
of Environmental Law
New Language Versions
Lucom Interaction Platform
English
Czech
Deutsch
Français
Hrvatski
Portuguese
Slovenian
easyTools
Welcome, Koordinator BR Köln!
Date of the last logon: April 1, 2013 at 6:14 PM
You are on the IMPEL form server that provides you with an application for risk assessment in inspection planning.
Horst Büther 28
29. European Union Network for
the Implementation and Enforcement
of Environmental Law
easyTools
Lucom Interaction Platform
Horst Büther 29
30. European Union Network for
the Implementation and Enforcement
of Environmental Law
easyTools
Lucom Interaction Platform
30
31. European Union Network for
the Implementation and Enforcement
of Environmental Law
easyTools
Lucom Interaction Platform
Horst Büther 31
34. Guidance book
Introduction to Risk Assessment
Integrated Risk Assessment
Method (IRAM)
Manual of the online IRAM tool
Examples of impact and
probability criteria
Available on the Web-application
Final version February 2012
easyTools
RISK ASSESSMENT
GUIDANCE BOOK
Horst Büther 34
easyTools
35. European Union Network for
the Implementation and Enforcement
of Environmental Law
Cologne Workshop Conclusions
The methodology is accepted
The comparison with other systems confirms the value
of IRAM
The IRAM tool is an added value and organisations can
start implementation
Procedural
arrangements
in the member
countries need
to be made
easyTools
Horst Büther 35
36. European Union Network for
the Implementation and Enforcement
of Environmental Law
Utilisation of IRAM
IRAM is (considered to be) used by Inspection
Authorities of
Albanina, Austria, Belgium, Bosnia and
Herzegovina, Croatia, Cyprus, Czech
Republic, Denmark, Estonia, Finland,
France, Georgia, Germany, Greece, Iceland,
Italy, Kosovo, Luxembourg, Macedonia, The
Netherlands, Norway, Poland, Portugal,
Romania, Serbia, Slovakia, Slovenia, Spain
and Turkey.
easyTools
Horst Büther 36
42. IRAM II: Inspection Time
• For an efficient use of human resources
following questions should be answered:
o How much time is needed?
o What is the content and the focus of
certain site visit?
• With risk assessment we can not calculate time
needed for a site visit
• For that we have to do additional procedure
o Time estimation
43. GENERAL TIME CRITERIA
1. Complexity and size of installation
2. Number of emission sources to air
3. Diffuse emissions to air
4. Number of emission sources to water
5. Type of wastewater treatment (complexity)
6. Protection against contamination of soil and water
7. Number of waste storages and waste processing units
8. On-site energy production
9. Water abstraction / use of process water
Next: Time criteria for different industrial activities