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Cooperation in Poland
02.06.05 Following the Memorandum of Understanding on the implementation of the EEA financial mechanisms between Norway and the EU and EFTA and EU respectively, the Norwegian Pollution Control Authority and the Polish Chief Inspectorate for Environmental Protection expressed their desire to establish a formal cooperation in a Letter of Intent signed September 2004.
The funding of the project still remains to be secured, as the call for tender still not have been given by the Polish authorities (June 2005).
The goal of the desired cooperation is to contribute to improved implementation and enforcement of environmental legislation in Poland, with the purpose of achieving more effective inspections.
The planned cooperation evolves around four main themes:
1. Effective system for handling of data on inspections
The current system for inspections undertaken by the Voivodships is quite time consuming. The inspectors use a substantial amount of time to investigate historical data in the preparation phase before the inspection. This includes checking the requirements that apply for the company in question, how the company in question have performed on earlier inspections, reports submitted by the company to the authorities etc. All the documentation mentioned above is stored in paper files. The paper files must often be retrieved from different locations. During and after the inspection, the findings are documented on paper. The report from the inspection is a bulky document of approximately 100 pages.
In order to make this system more effective it is proposed to develop an electronic system for handling and storing of data. This will ease the preparation phase as all data required will be easily available, it will also make the reporting easier as the data that are put into the system will be used to generate reports.
As the inspectors will bring lap tops to the inspection, this will further stimulate the efficiency. The findings will be fed directly into the system, and updated in the database when the inspectors return to their desks. The inspectors will also be able to retrieve any information desirable during the inspection. The database should be designed in a manner that makes it possible also to extract data for other purposes than merely inspections.
As the responsibility for inspections mainly lies at the Voivodship level, two Voivodships will take part in the programme as pilots. The inspectorate, as being superior to the Voivodships and responsible for training and guidance, will be the project manager at the Polish side. The responsibility for the database will be at the Inspectorate level; however the WIOSs will be responsible for continuously feeding data into the system.
A working group responsible for output 1 will be established. This working group will investigate existing database systems used for environmental management in other European countries. This phase will, inter alia, include a study trip to Norway to scrutinise the Norwegian systems “Forurensning”, “Inkosys” and “BMI”.
After having identified the requirements of the future system, a consultant will be hired to design the database. Adequate time should be allocated to designing and testing of the database, as experience from similar development projects show that this process can and will take time.
Procedures for operation and maintenance will be established. At each WIOSs one or two super-users will be subject to special training. These will be responsible for internal training in their respective Voivodships, after the project has terminated.
2. Procedures for prioritization and performance of inspections, with emphasis on specific branches
The Inspectorate has developed and is using manuals in relation to inspection tasks. However, these manuals are not focused in relation to specific branches. They are general, but nevertheless mandatory to use. Due to the general formulation of the manuals and their mandatory status, time during the inspection is used for activities which not necessarily are relevant for the company under inspection. Hence, it is proposed to develop inspection guidance documents that will be sector specific, as well as general procedures for planning, performing and reporting inspections, to ensure that the data put into and drawn from the new database has the right quality.
When setting up a system for inspections, it is vital to have a risk-based plan for the frequency to inspect the various companies under your jurisdiction. This plan should take into account the potential environmental impact of the activities of the company, the size of the company, history of compliance etc. The current strategy of GIOS is to focus on the largest companies with the greatest pollution potential. However, the strategy is not written down in a formal document. It should be noted that the small and medium enterprises are rarely examined by the inspectors. The project proposes to establish formal procedures for how to define frequency of inspections for various kinds of enterprises.
Before being able to elaborate the procedures described above, it is important for the participants to obtain knowledge on routines for environmental management in other countries. It is thus proposed to conduct several workshops on relevant themes in Poland, as well as sending delegates from the Inspectorate and the Voivodships to other European countries to learn more about their management systems. EU environmental legislation relevant in the context of this output will be translated into Polish.
As the responsibility for inspections mainly lies at the Voivodship level, two Voivodships will take part in the programme as pilots. The inspectorate, as being superior to the Voivodships and responsible for training and guidance, will be the project manager at the Polish side for this output.
3. Equipment for investigation at site
To verify compliance to the requirements of a given company the inspectors often depend upon sample-taking. These samples are currently taken to laboratories for analyses. This also applies for quite simple tests. This procedure is both time consuming and expensive. The result is that it is difficult, and in most cases impossible, for the inspectors to verify compliance at the time of inspection – this is first verified when the analyses from the sample-taking are made available.
This practice is unfortunate, as it makes it impossible to conclude the inspection and to present the findings to the management of the company at the time of inspection. The result is that the dialogue between the company and the authorities is hampered, and are completed in a written manner. Dialogue between the companies and the authorities is considered vital in order to bring about change relating to environmental performance of the companies. Consequently it is proposed that equipment necessary for the inspectors to conclude the inspections at site is procured.
As the responsibility for inspections mainly lies at the Voivodship level, two Voivodships will take part in the programme as pilots. The inspectorate, as being superior to the Voivodships and responsible for training and guidance, will be the project manager at the Polish side for this output. Equipment will only be procured for the participants taking part in the project, and it is assumed that the remaining Voivodships will procure similar and compatible equipment during or after the termination of this project.
4. Dissemination of information to the general public
Environmental awareness among the general public is an important mechanism in environmental management. Higher environmental awareness may for example result in a greater attention to the performance of the industry. This may result in a raised number of contacts from the general public to the environmental authorities regarding companies that are operating in non-compliance to the requirements. These companies will subsequent to such communication be subject to more frequent visits by the authorities. This will have an educational effect on the industry. Not only will they be subject to a tighter scrutiny by the authorities if they misbehave, but their reputation amongst the general public will also be at stake. The latter will be of increasing importance to the private sector taking into account the rapid integrating with the rest of the EU economy.
The communication between the authorities and the media will also be facilitated by a systematic approach to information dissemination. If the information given out is systematic and well presented, this will ease the job for the media, and the questions to the authorities will be more focused and relevant. It is also possible to use such a tool to direct the interest of the media. Furthermore, Poland as a signatory to the Aarhus convention has an obligation to make environmental information available. A dissemination system will facilitate a greater openness in the administration.
If the information given is focused and relevant the general public will have a better basis to know to where in the environmental administration they should direct inquires. This will lead to a higher efficiency in the administration as the staff will deal with fewer misplaced inquires.
It is also possible to target information to special groups that might have a greater need for information than the general public. This might be people with asthmatic problems etc. These could, inter alia, find information concerning the level of air pollution, and thus take the necessary precautions.
The project envisages that the general public should have one major portal for information. This portal should attain information from all relevant sources, e.g. the database described in output 1. The presentation of the information must be systematic, focused and understandable for the average lay man.
After the requirements for the portal is established, a consultant will be in charge of designing and testing the portal. A system for maintaining the portal will also be established.