Updating of environmental information
To maintain the EMAS registration, an organization must: «transmit the necessary validated annual updates of its environmental statement to the competent body and make them available to the public. This update frequency may be waived in circumstances established by the Commission in the guidelines adopted in accordance with the procedure referred to in Article 14 (2), in particular for small organizations and small businesses within the meaning of Commission Recommendation 96/280 / EC (1), and if no significant operational changes are envisaged in the environmental management system ".
It is stated that: «The organization must update the information referred to in point 3.2 and each change must be validated every year by an environmental verifier. Exceptions to the expected update frequency are possible in the circumstances contemplated in the Commission's addresses ".
"Furthermore, the verifier, at intervals of no more than 12 months, validates all information updated in the environmental statement. Exceptions to the expected update frequency are possible in the circumstances provided for in the guidelines adopted by the Commission ".
The rule provides in general that the data of the environmental declaration are updated and the variations validated every year.
The best and most cost-effective practice is to link the environmental statement validation to the ongoing verification program. The times, energies and costs required by the validation will depend on the quality of the data and information management and recovery system used for the environmental declaration.
Normally, the data and information on the organization's activities vary each year and must be updated in the environmental statement, in which, however, only the changes must be validated.
To update the information in the environmental statement, it is not necessary to publish a new declaration every year, but simply to make the new data available to the public.
The objective of the EMAS system is to encourage organizations to publish reliable information on improvements made in the field of environmental performance. This can be done, for example, by drawing up an autonomous environmental statement, or by entering the environmental data in the report attached to the financial statements; it is possible to use printed texts or a website.
Even if the presentation of bulky and expensive documents on glossy paper is not required for small businesses and small organizations, the EMAS Regulation allows them to reduce the frequency with which they have to update and validate the information.
Only small businesses and organizations are therefore exempt from the obligation to validate up-to-date information annually, unless the cases are connected to:
- activities, products and services that present significant risks for the environment;
- significant operational changes to their environmental management system;
- important legal provisions relating to their activities, products and services;
- relevant local issues.
In these cases, in fact, the verifier must request, also for small businesses and organizations, the annual update of the information from the environmental declaration.
In cases where the updating of the environmental declaration does not intervene annually, this must in any case be carried out within a period not exceeding thirty-six months.