Compliance of the activities with environmental requirements
Environmental legislation
The minimum requirement of environmental management system is compliance with environmental legislation. All improvements to the environmental management system must also be in accordance with the requirements and restrictions set out in applicable legislation. To a large extent our Company´s environmental activities are regulated by requirements arising from EU as well as national and local government legislation.
At the EU level this means compliance with the EU Water Framework Directive (2000/60/EC). At 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 shall be ensured. At the local level we are obliged to comply with different rules and requirements both in Tallinn and its surrounding municipalities.
Amendments to the requirements and legislation are being constantly monitored and managers responsible for the implementation of the required changes are notified thereof each month.
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 (e.g. Ministry of Environment, Ministry of Justice, Ministry of Economic Affairs and Communications).
In 2014, we did active preparation work with regard to the following important draft legislations: amendment drafts of the Public Water Supply and Sewerage Act, the Atmospheric Air Protection Act and, continually, the Metrology Act; as well as the regulations by the Ministry of Environment, related to the Water Act, such as the “Specified requirements for the damming up of a water body, environmental monitoring, protection of water biota, dam, removing of damming and lowering the level of water level, related to the damming, and the methodology of identifying the ecological minimum amount of flow“ and “Procedure of issuing, amending and repealing the permit for a special use of water and temporary permit for a special use of water, list of materials required to apply for the permit and permit templates.“
Environmental permits
We act in accordance with the 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
- 1 waste permit
- 2 ambient air pollution permits
In 2014, we performed in conformity with all of the conditions set forth in applicable environmental permits. The matters related to the environmental permits, e.g. their extension, are resolved in cooperation with the Environmental Board.
Due to the Accession Treaty concluded between the EU and Estonia and compliance with the requirements of the Directive 98/83/EC regulating water quality, § 13¹ of the Water Act became invalid starting from 2014. Therefore, we have ensured the compliance of drinking water with quality requirements in Harku small town area and completed the process of transferring the area to drinking water supply from Ülemiste Water Treatment Plant, in co-operation with Harku Municipality Government and Northern Service of the Health Board. In 2013, we constructed the connecting network and in May 2014, a booster pumping station was built.
Additional information is available on the Health Board’s homepage www.terviseamet.ee.
Requirements of the Services Agreement
In 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 inspection body – 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.
96 levels of service out of 97 set out in the Services Agreement were met in 2014. One non-compliance was related to the interruption to water supply lasting for more than 12 hours (item WS7 of the Services Agreement). 7 customers were left without water supply for 13 hours. At the same time, continuous improvement of the service quality and achievement of better results than required are still our main objectives.
Requirements to contractual partners
As strict requirements apply to our activities, we consider it to be very important that also our suppliers and contractors meet both environmental and work environment requirements. We have established several criteria in our procedures which enable us to make sure that our partners follow the requirements. Providers of construction works must confirm that they comply with occupational safety and environmental protection requirements at our construction sites. Our specialists as well as the supervision staff of the Company’s subsidiary OÜ Watercom monitor the suppliers/contractors activities with regard to health and safety and environment at sites.
To improve the quality of feedback on the completed works and provided services, incl. on complying with the environmental and work environment related requirements, we have changed the system for assessing the suppliers. The new supplier assessment system enables to take improving actions, if necessary, on time and ensures feedback on performance from both parties. This new supplier assessment system supports our responsible operating.
In order to improve the awareness of suppliers, opening meetings were carried out for construction and reconstruction sites in 2014 (except for the constructions of individual connection points) by our subsidiary OÜ Watercom. The aim of the opening meetings is to additionally introduce to the contractors the Company’s objectives, contractual requirements, construction standards and the quality, environment and occupational health and safety requirements applicable to the Company before the commencement of the construction works. In addition, quality, environmental and safety requirements are separately introduced on the site right before the works start, and this is confirmed with a signature.
Management system control and audits
In 2014 various authorities monitored the compliance of our Company’s activities, incl. environmental activities, with the requirements. The Crisis Management Office of the Rescue Board’s Northern Rescue Centre made an onsite inspection for ensuring chemical safety, Technical Surveillance Authority completed the surveillance reg. chlorine containers, and the Health Board carried out a regular check as usual. Estonian Accreditation Centre checked the compliance of laboratory activity and management system with ISO 17025 standard requirements. In addition to supervisory authorities, the Company´s compliance with environmental legislation and Services Agreement requirements as well as with intra-Company requirements are also monitored throughout internal and external audits.
As a result of internal audits carried out in 2014, our internal auditors put forward a total of 35 non-conformities and 66 improvement proposals which provide a good input to managers for improving the management system.
In spring 2014, a recertification audit was carried out in the Company by 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).
Auditors highlighted in their report several positive observations regarding Company’s activity. Among other things, audit report pointed out a positive fact that the Company has the best investor relations in the Baltics (Nasdaq Balti).
As a result of external audit Det Norske Veritas confirmed the compliance of the management system and EMAS report with the requirements and issued respective compliance certificates which are valid for 3 years.