Many organisations are now aware of the implications of the EU Energy Efficiency Directive and the requirement for a high quality energy audit to be carried out by a competent person by 5 December 2015.
In the UK, you are exempt if you have a certified energy management system to ISO 50001. This seems fair enough.
In Ireland you are also exempt if you have a certified environmental management system to ISO140001 provided it covers 90% of the organisations energy consumption AND the energy audit that was initially carried out was the standard specified in the Directive.
Many organisations have responded, when prompted, that they don’t need to comply with the Directive as they have ISO14001. The problem is that with many environmental management systems (EMS’s), they lack the scope and depth required by the directive and thus many organisations will find that they are non-compliant.
A little consideration will show that most EMS’s will be non-compliant as regards the Direct.
- The EMS may well have been implemented before the EU Energy Directive was written and thus the directive’s requirements could not be known. It is unlikely that the implementation team would have second guessed the directive and thus the EMS will not be to the standard specified by the directive. This would be therefore a non-compliance and the organisation would be open to prosecution.
- ISO 14001 calls for only the significant impacts to be managed by objectives and targets. For most organisations, energy use is not the most significant environmental impact. Most EMS’s concentrate on emissions to air and water, noise and waste. In ranking the impacts it is likely that energy will be near the bottom of the list and thus there will be no need to manage this. This again would mean that the basis for exemption will be based on a faulty premise.
- The Directive calls for the energy audit to cover at least 90% of the organisations energy use. If the EMS considered energy use at all, it is likely to have only considered the big ticket items such as boilers, chillers and air compressors. Whilst these are large energy uses they are not necessarily going to make 90% or more of the organisations energy consumption.
- The Directive requires the use of Net Present Value to assess the benefits of energy efficiency measures. I have yet to see an EMS that considered NPV in forming the environmental objectives and targets.
- The directive requires the energy audit to cover buildings, process and transport. Again many EMS’s will have not covered all these three areas and thus will be non-compliment.
In summary, whilst many organisations will take comfort by having an Environmental Management System, in practice the EMS will not meet the requirements laid down in the Directive and therefore the organisation will be non-compliant.
The author, Bob Sutcliffe, is a Chartered Engineer, a Certified Energy Manager and on the UK ESOS register.