PFAS – Forever Chemicals – What you need to know and how Future Policy will Impact your Business

What are PFAS?

Per- and polyfluorinated alkyl substances (PFAS) are approximately 10,000 different chemicals used in a wide range of products due to their water, oil and dirt repellent properties, their tolerance to high temperatures and pressures, and their non-stick qualities. These qualities are generated from a carbon-fluorine bond, which makes them very slow to break down in the environment.

They can be found in: textiles, cleaning agents, food packaging, pesticides, PPE, fire-fighting foam (FFF), cosmetics, pharmaceuticals, paints, sealants, varnishes, hydraulic fluids, surfactants, plastics, rubber, non-stick coatings. The list is endless.

Major manufacturers of PFAS products are moving away from their production and others, particularly in the US, are struggling with litigation costs due to the impacts affected on the environment and human health.

What is the Regulatory Position?

In the US restrictions are being imposed State by State with approximately 22 States currently banning PFAS for varying uses.

The EU have proposed a complete ban on all PFAS, with some use-specific, time-limited derogations but with a proposed entry into force of 2026-2027.

The UK’s Health and Safety Executive (HSE) have published their analysis of how to tackle PFAS in the UK, and they have stopped short of mirroring the EU’s complete ban. They have however recommended:

  • Research to potentially support one or more restrictions of PFAS under UK REACH for substances categorised as: carcinogenic, mutagenic or toxic to reproduction (CMRs); persistent and bioaccumulative (PBTs); very persistent very bioaccumulative (vPvBs); or substances of equivalent concern. 
  • Further evaluation and investigation of substances that have been highlighted to be of concern.
  • Continued collaboration across government and external stakeholders to bring together work on PFAS strategically, including a review of F-gas regulations to determine whether additional PFAS registered under UK REACH should be brought within scope. 
  • The development of statutory standards for PFAS in drinking water.

How will Your Business be Impacted and What can you Do?

Without doubt PFAS products that your business uses will be restricted by regulation sooner or later. Prior to this, availability of PFAS products will reduce as businesses see the writing on the wall and make decisions for their future.

All business will be impacted. Whether your business is in a key PFAS sector, e.g. chemicals or waterproofing or not, it will currently be buying and using products containing PFAS.

Start now to identify PFAS in your products, manufacture and supply chain and look to obtain alternatives prior to this risk impacting your day to day business operations.

EU Leading the way in Mandatory Corporate Sustainability Reporting

Last year the EU introduced of the Corporate Sustainability Reporting Directive (CSRD). This new framework will be rolled out from 2024, and will require companies to report on how sustainability issues impact their business and how their operations affect people and planet, together with governance elements, and must specifically include:                            

  • Environmental matters – including climate risk reporting. 
  • Social matters and treatment of employees.
  • Human rights.
  • Anti-corruption and bribery.
  • Diversity on company boards (age, gender, educational and professional background).

These reports must be independently assured to ensure they are accurate and complete.

Approximately 50,000 companies are expected to be obligated under CSRD, this includes:

  • Companies listed in the EU, and large companies (one that meets two out of three of the following criteria: more than 250 employees, a turnover of over €40 million and over €20m total assets).
  • Listed SMEs. 
  • Non-EU companies with a net turnover of €150 million in the EU, and with at least one subsidiary or branch in the EU.

CSRD requirements will be introduced in phases:

From 1/1/24Companies already reporting under the Non-Financial Reporting Directive (reports to be submitted in 2025 covering 2024 data)
From 1/1/25Large companies that are not currently subject to NFRD (reports to be submitted in 2026 covering 2025 data)
From 1/1/26Listed SMEs, small and non-complex credit institutions and captive insurance undertakings (reports to be submitted in 2027 covering 2026 data).
From 1/1/28Applicable non-EU companies. (report to be submitted in 2029 covering 2028 data).

If you need help in your preparations for CSRD, please don’t hesitate to contact us.  We have a wealth of experience with company reporting from a GHG, Sustainability and a CSR perspective as both consultants and independent assurers.  Let us help you build your reporting requirements into your core business processes and provide clarity for all your stakeholders.

The Emissions Gap 2020 – a call for action at COP26

The UN Emissions Gap Report provides an annual review of the difference between where greenhouse gas (GHG) emissions are predicted to be in 2030 and where they should be to avoid the worst impacts of climate change.

The 2020 report has now been published and despite showing a reduction in GHG emission from the COVID-19 global pandemic and resultant slowdown in economic activity, this has made no significant difference to climate change and we are still heading for a catastrophic temperature rise above 3°C this century.

The time for action is now. We can no longer continue operating without Net-Zero targets for all organisations and governments. As the world looks to COP26 next week, we desperately need action from our leaders to help turn the tide on global temperature rise. We sit in hopeful anticipation……

Read the Emissions Gap Report here https://www.unep.org/interactive/emissions-gap-report/2020/

Are you ready for CORSIA?

On 27 June 2018, the International Civil Aviation Organisation (ICAO) Council adopted Annex 16, Volume IV – Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) – Standards and Recommended Practices (SARPs). CORSIA is operative from 1 January 2019, and for the first 2 years of the scheme, aeroplane operators will be required to monitor and report CO2 emissions from all international flights. Domestic flights are not included.

CORSIA will apply to you if you produce annual CO2 emissions greater than 10,000 Tonnes from international flights using an aeroplane(s) with a maximum certificated take-off mass greater than 5,700 kg.

You can assess whether you exceed the emissions threshold using your own annual fuel use data, or the ICAO CORSIA CO2 Estimation and Reporting Tool (CERT). Which is available here.

If you exceed the 10,000T CO2 emissions threshold, you will be regulated by the UK under the CORSIA if:

  • You have an ICAO Designator and the UK is the Notifying State in ICAO 8585;
  • You do not have an ICAO designator, but you hold a valid Air Operator Certificate (AOC) issued by the UK Civil Aviation Authority (CAA) or a CAA of an Overseas Territory or Crown Dependency;
  • You do not have an ICAO designator or a valid AOC, but you or your operation is registered as a juridical person in the UK, or in a UK Overseas Territory or Crown Dependency.

If you are an Aeroplane Operator attributed to the UK, you will need to have an approved CORSIA emissions monitoring plan (EMP) in place for the start of the 2019 baseline monitoring year. To achieve this you must submit your application for a CORSIA EMP to the EA by 30 September 2018, using the online application and reporting system, ETSWAP.

If you currently have an approved EU ETS EMP and will also be regulated by the UK under CORSIA, you must initiate a variation to your current EU ETS EMP.

Further guidance and SARPs are available here.

If you need any help with your preparations for CORSIA, please don’t hesitate to contact us.  We have a wealth of experience with international and domestic airlines from and environmental management and CO2 emissions monitoring, reporting and verification perspective.

EU MRV Regulation for Shipping – Time to Get Ready

On 1st July 2015 Regulation (EU) 2015/757 on the monitoring, reporting and verification of CO2 emissions from shipping came into force, the aim of which is to gather reliable information on such emissions from the sector within the EU.

The regulation applies to ships greater than 5,000 GT undertaking one or more commercial voyages into, out of, or between EU ports regardless of a ship’s flag. It requires per-voyage monitoring of emissions and annual disclosure of aggregated data on a ship basis.

Each Company must produce a monitoring plan by 31 August 2017. The monitoring plan must be reviewed and approved before the monitoring period commences on 1st January 2018.

Following the completion of each calendar year, each company must submit their emissions report for verification.

Companies therefore need to start considering the methodology that they will follow to fulfil their monitoring, reporting and verification obligations, and adapt their existing procedures to ensure they have a robust system for collecting and reporting their emissions.

Need help preparing your monitoring plan? Your monitoring and reporting procedures? Or preparations for verification? Contact us.

What’s the Right GHG Reduction Target for your Organisation?

Despite action on climate change mitigation by governments, companies, and civil society GHG emissions continue to rise. Under our current trajectory, global temperatures are estimated to increase by up to 4.8ºC by the end of this century, far beyond safe levels. Hence why many companies are aiming to reduce their own GHG emissions. However, how do you align your target with global climate science?

Welcome the Science Based Targets initiative. They aim to increase corporate ambition by encouraging companies to set targets consistent with the level of decarbonisation required by science to limit global warming to less than 2°C.

How do you go about achieving this? Well here are the steps:

  1. Select a base year and target year for your organization.
  2. Identify the sectors applicable to your organization.
  3. Calculate the organization activity in the base year and forecast activity for the target year in each sector.
  4. Calculate the carbon intensity of the company using activity data, scope 1 and scope 2 emissions in the base year.
  5. Estimate the target carbon intensity based on the 2°C sector intensity.
  6. Estimate the scope 1, scope 2 and overall absolute carbon budgets in the target year.
  7. Monitor progress against this target and update the target periodically to reflect company changes.

SBT approach

122 companies have already signed up including Coca Cola, Dell, BT, Carrefour, Ikea. Can you commit to aligning your targets with climate science? Let us help you. Contact us.

ISO 14001:2015 – Are you ready?

The new EMS standard was published last year and certified organisations have three years in which to transition.  14001:2015 has a number of areas in which organisations will need to review, revise and
expand their systems to address the new requirements and build a stronger system to manage their environmental business risks.

Strategic Environmental Management

Within the new standard there is an increased prominence of environmental management within the organization’s strategic planning processes. A new requirement to understand the organization’s context has been incorporated to identify and leverage opportunities for the benefit of both the organization and the environment. Particular focus is on issues or changing circumstances related to the needs and expectations of interested parties and local, regional or global environmental conditions that can affect, or be affected by, the organization. Once identified as a priority, actions to mitigate risk or exploit opportunities must be integrated into the operational planning of the EMS.

Leadership

To ensure the success of the system, a new clause has been added that assigns specific responsibilities for those in leadership roles to promote environmental management within the organization.

Environmental performance

There is a shift in emphasis with regard to continual improvement, from improving the management system to improving environmental performance.

Lifecycle perspective

In addition to the current requirement to manage environmental aspects associated with procured goods and services, organizations will need to extend their control and influence to the environmental impacts associated with product design and development to address each stage of the life cycle, including. acquisition of raw materials, design, production, transportation/delivery, use, end-of-life treatment and final disposal.

Let us help you address the changes required. Contact us to discuss how we can help with system design, training or internal auditing.

 

 

 

 

6000 EU companies to report on social and environmental issues

Last week the European Council adopted the Directive on disclosure of non-financial and diversity information by large companies. This requires that large companies with more than 500 employees will be required to disclose social and environmental information in their management reports. The content must include policies, risks and outcomes in relation to environmental matters, social and employee-related aspects, respect for human rights, anti-corruption and bribery issues, and diversity on the board of directors, including age, gender, educational and professional background.

The new Directive is expected to apply to some 6000 large companies and groups across the EU which will have until their 2017 financial year to start reporting, against national legislation implemented by their Member State.

The directive is the culmination of the Commission’s efforts to enhance business transparency on social and environmental matters and to improve corporate governance.

The Commission will develop guidelines to assist organisations with these new requirements.  When these are drafted we’ll update you.

New York Climate Week – What happened?

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With Climate Week NY and the news of man and celebs taking to the streets now fading away, you might be wondering what – if anything- was achieved. Were any decisions or commitments made?

The answer is a resounding ‘yes’, and here they are summarised in eight key areas:

Food Security – the establishment of a Global Alliance for Climate Smart Agriculture, to improve people’s food and nutrition security.

Cities – Amongst other things, more than 200 cities committed to reducing emissions by 454 Megatonnes by 2020.

Energy – The launch of a public-private partnership to double the global rate of improvement in energy efficiency.

Finance – pledges of public and private financing for low carbon and climate resilient pathways.

Pricing Carbon – A call on companies to apply the Business Leadership Criteria on Carbon Pricing.

Forests – the NY declaration on Forests, pledging to end the loss of forests by 2030.

Oil & Gas – Commitments from industry and government to cut methane emissions.

Resilience – A variety of initiatives to support the worlds most vulnerable countries.

Transportation – The launch of four global alliances to scale up proven low-carbon transport tech.

Full details of all announcements can be found here. For what they ultimately will achieve – follow this blog 🙂