Compliance of the Activities with Environmental Requirements
Environmental legislation
To a large extent the Company’s environmental activities are regulated by requirements arising from the EU as well as national legislation and the legal acts issued by local governments.
On the EU level, this means compliance with the EU Water Framework Directive (2000/60/EC). On the national level, compliance with the Water Act, Public Water Supply and Sewerage Act, Waste Act, Chemicals Act, Ambient Air Protection Act, and subordinate acts based on these acts must be ensured. On the local level, we are obliged to comply with different rules and requirements applicable in Tallinn and its surrounding municipalities.
Amendments to the requirements and legislation are being constantly monitored and reported to the managers and specialists of a respective area who then assess the impact of the amendments on our activity.
In co-operation with the Estonian Water Works Association, we continue to participate in the approvals of the new draft acts concerning water economy and environment by submitting our opinions and making amendment proposals with regard to the draft legislation under discussion. Together with the Estonian Water Works Association we have participated in the working groups for developing legislation related to water economy and environment and expressed our opinions with regard to draft legislation directly to the relevant ministries. One of the highlights in 2015 was participating in the preparatory activities of the new Public Water Supply and Sewerage Act, a process that will actively continue in 2016. We also worked on the amendments to the Water Act and many other draft acts of relevance to us.
Environmental permits
We act in accordance with the terms and conditions set out in the environmental permits issued to the Company, and observe the precepts set out by authorities. The main licensing authority for us is the Environmental Board’s Harju-Järva-Rapla regional department, who has issued the following environmental permits to us:
- 4 permits for a special use of water and 1 temporary permit for a special use of water (11.2015-03.2016) (details on page 18);
- 2 waste permits (details on page 35);
- 2 ambient air pollution permits (details on page 39).
Requirements in the Services Agreement
On 12 January 2001 we concluded a tripartite Services Agreement with the City of Tallinn and investors, which, among other things, obliges us to comply with 97 Levels of Service. This makes us the most regulated water undertaking in Estonia. Our activities and levels of services are assessed once a year by an impartial monitoring unit – Supervisory Foundation for the Water Companies in Tallinn – to whom the Company annually, i.e. by the end of the first quarter, submits a report on compliance with the levels of service.
We met all the levels of service in 2015 and for some levels, achieved the best results of all times. For example, the Services Agreement requires our leakage rate to be below 26%, and the result achieved in 2015 – 14.68% - was the lowest in the Company’s history. At least 95% of the drinking water samples taken must be compliant with the requirements, our result in 2015 – 99.86% - was, once again, the best ever.
Requirements to contractual partners
As strict requirements apply to our activities, we consider it to be very important that our suppliers and contractors also meet the environmental and occupational safety requirements. We have established several criteria in our procedures which enable us to make sure that our partners meet our expectations. Among other things, the contractors must confirm that they comply with occupational safety and environmental protection requirements at our construction sites. Our specialists monitor the activity of suppliers/contractors with regard to the safety and environment at sites on a daily basis.
Management system control and audit
In spring 2015, a recertification audit was carried out in the Company by an accredited certifier Det Norske Veritas in order to evaluate the compliance of the management system with the requirements of ISO 9001, ISO 14001, OHSAS 18001 standards and with the Regulation (EC) No 1221/2009 (EMAS). The auditors did not find any non-conformities and, instead, highlighted several positive observations regarding Company’s activity. Among other things, the audit report pointed out a positive fact that the Company has achieved high level of compliance with its objectives (the best ever in several areas) plus significant cost savings.
Internal audits monitored the Company’s compliance with environmental legislation and Services Agreement requirements, as well as with the Company’s own internal requirements. As a result of internal audits carried out in 2015, our internal auditors put forward a total of 6 non-conformities and 39 improvement proposals, which provide a good input to managers for improving the management system. All non-conformities were rectified immediately.
The compliance of the activity and management system of Company’s laboratories against the requirements of ISO 17025 standard was audited by the Estonian Accreditation Centre in spring 2015. The auditor did not find any non-conformities.