Environmental Management Plan (EMP) is an integral part of the technical documentation which is intended to provide adequate implementation of the proposed environmental protection measures. This plan also makes it easier to understand the effects of protective measures and the introduction of necessary improvements and corrections in the stage of preparatory work and also in the construction works phase of the Project.
The EMP also has to be prepared to comply with conditions imposed by the EIA Study and technical documentation of main project.
Environmental Management Plan identifies potential environmental impacts and defines the procedures that must be implemented by the Contractor or institutions that bear responsibility for construction work.
EMP is always specific to a particular location or site, and it is made to ensure all the necessary measures to be identified and applied in order to protect the environment in accordance with the legal regulations governing the environmental protection.
Monitoring and measures proposed by EMP are carried out together with conducting of construction works.
Services of registration and application for the National and Local Register of pollution sources, as well as prepare of:
– The annual report on balance sheets of emissions of pollutants in water, air and land according to the Rulebook on the methodology for the preparation of the national and local pollutant source registry, as well as the methodology for the types, manner and deadlines for data collection (“Official Gazette of RS”, No. 91/10, 10/13 and 98/16);
– The annual report on waste according to the Low on Waste Management (“Official Gazette of RS”, No. 36/09, 88/10, 14/16 and 95/18 – other law) and the Rulebook on the forms of daily records and annual reports on waste with instructions to complete it (“Official Gazette of RS”, No. 95/10 and 88/15);
– The annual report on the products that after use become special wastes (PTP2) according to the Decree on products that after use become special waste streams, the form of daily records on the quantity and type of manufactured and imported products and the annual report, the manner and deadlines for submitting the annual report, the taxpayers, the criteria for calculation, the amount and manner of calculation and payment of compensation (“Official Gazette of RS”, No. 54/10, 86/11 and 15/12, 41/13- other Rulebook, 3/14 and 95/18 – other law).
Legal deadline for the submission of the report is March 31st, of the current year for data from the previous year.
Due Diligence includes evaluation of:
The aim of the assessment is to assess the current state of environmental protection and health and safety at work in order to complete the diagnostic report – Due diligence, in the process of privatization or sale of the company.
SYSTEM MANAGEMENT STANDARDS
ISO 9001:2015 (QMS-Quality Management System)
This standard is international, widely recognized as basic management standard applicable for all kinds of organizations (regardless of their size or activities). ISO 9001 standard is based on eight management principles of good business practice of the most successful companies.
In practice, ISO 9001 is commonly used as basic management standard, compatible with other, specific management standards such are: ISO 14001, BS OHSAS 18001, HACCP etc.
ISO 14001:2015 (EMS – Environmental Management System)
This standard is especially interesting for the organizations which are significant polluters.
It is fully compatible with ISO 9001 and very often, implemented together with ISO 9001 as Integrated Management System.
The ISO 14001 is an international standard for the control of environmental aspects and the improvement of environmental performance. Minimizing harmful effects on the environment and achieving continual improvement in environmental performance.
EMAS (Eco Management and Audit Scheme)
The Eco-Management and Audit Scheme (EMAS) is a voluntary program for environment protection management which enables companies to verify their environment protection system in accordance with the relevant regulation of the European Parliament and Council. Our legal regulations partly define EMAS in Law on environmental protection (Official gazette of RS 135/04, 36/09).
EMAS includes all ISO 14001:2015 requirements, as well as some additional requirements, which makes it a more strict standard.
BS OHSAS 18001:2007 (Occupational Health and Safety Management System)
OHSAS 18001 is a standard for occupational health and safety management system. It is intended to help organizations to control occupational health and safety risks. It is fully compatible with ISO 9001 and very similar in the structure to ISO 14001.
Water permit defining the method, conditions and scope of water use, then, method, conditions and the volume of discharge of waste water, storage and discharge of hazardous and other substances that may contaminate water, as well as conditions for other works affecting the flow regime.
The water permit is not a condition for issuing an Use permit; it is issued for a limited period, and the longest for a period of 15 years.
The water permit, in accordance with the provisions of this law, is obtained by the investor when the water requirement stipulates the obligation to obtain it. The issue of a water permit is performed outside the process of the unified procedure.
Before starting preparation of the technical documentation necessary for the construction of a facility, referred to in Article 133 of Planning and Construction Law (“Official Gazette of the Republic of Serbia”, № 72/09, 81/09- correction, 64/10 – Constitutional Court Decision, 24/11, 121/12, 42/13- Constitutional Court Decision, 50/13- Constitutional Court Decision, 98/13- Constitutional Court Decision, 132/14, 145/14, 83/18 and 31/19), for which the building permit is issued by the authorized ministry, or the autonomous province, feasibility studies are made based on the results of preliminary work.
The main objective of the feasibility study is the elaboration of relevant data and analysis, based on which the appropriate national authorities and the investor could make a decision on granting approval for the construction, operation and providing financial support for the implementation of a specific project.
The feasibility study particularly determines the spatial, ecological, social, financial, market and economic justification of the investment into the chosen solution, elaborated by the preliminary design, based on which it is decided about the feasibility of the investment, for projects in which the beneficiaries of public funds participate, regardless of whether the investor is a beneficiary of public funds.
The ultimate goal of the feasibility study is obtaining a building permit.
The contracted company is responsible for the implementation of all environmental protection activities in planned time frames related to the implementation of the project. In order to realize all the activities prescribed by the Environmental management plan (EMP) and Waste management plan (WMP), it is necessary to conduct Environmental Supervision of implementation of the EMP and the WMP, checking of monitoring results in accordance with the relevant laws and standards of the Republic of Serbia.
If you need environmental control during your construction work, our consultants are at your service. Environmental monitoring on a monthly basis includes the following:
– Construction site and associated facilities visits and meetings with supervising authority during the works, which is carried out by agreement, once a week, biweekly or monthly;
– Compulsory going out to the site in the event of any accident or unforeseen event that could endanger the environment;
– monitoring activities on implementation:
– cooperation with environmental inspection bodies (municipal and republican), as well as keeping all necessary records on a monthly basis;
– writing weekly and/or monthly reports (bilingual if necessary), containing a description of the state of all environmental factors on the site, mitigation measures taken, conclusions on the degree of their effectiveness, recommendations for revision of existing and/or implementation of new measures, which are submitted to the Project Manager. Additional reports are written in the event of an accident.
Depending on the agreement with the client, environmental monitoring may include the following:
– Expert assistance to the client in the selection of an accredited laboratory for testing environmental parameters, both for the purposes of regular monitoring and in case of accident, and consulting services and assistance in the process of obtaining the results of environmental parameters testing (quality of surface and groundwater, soil, noise etc.);
– Expert assistance to the client in the selection of authorized operators for the takeover and disposal of certain types of waste;
– verification of documentation regarding waste movement and providing of training course for the Contractor employees in the field of waste management (keeping records and documentation on waste, classification of waste, etc.);
– and other services, additionally.
During the providing of consulting services period our consultants will be in constant communication with the client, contractor (via e-mail, telephone etc).
According to Article 19 of the Decree on limit values of pollutant emissions into water and deadlines for their reach („Official Gazette of the RS“, No. 67/2011, 48/2012 and 1/2016):
A legal entity and/or entrepreneur who has wastewater treatment plants and/or discharges it’s wastewater into a recipient or public sewer is obliged to adopt an Action Plan for gradually reaching the limit values of pollutant emissions into the water (hereinafter: the Action Plan) set deadlines for their gradual reaching, as well as act in accordance with the action plan, in accordance with the regulation that regulates the limit values of pollutants in water and the deadlines for reaching them.
In accordance with the aforementioned Regulation, a legal entity or entrepreneur who has wastewater treatment plants and/or discharges its wastewater into a recipient or public sewer shall be obliged to harmonize its emissions with the limit values for the emission of pollutants into the waters prescribed by the Regulation no later than 31 December 2025. The exceptions to this are:
The legal entity and/or the entrepreneur is obliged to submit a report on the implementation of the Action Plan to the ministries responsible for environmental and water management, every two years from the day of the adoption of the Action Plan.
The sludge generated during the process of technological wastewater treatment must be treated, disposed of and used in accordance with the law governing waste management (Law on Waste Management, „Official Gazette of RS“, No. 36/2009, 88/2010, 14/2016 and 95/2018-267), except for sludge which is mining waste, generated in the process of exploitation and preparation of mineral resources (Law on Environmental Protection, „Official Gazette of RS“, No. 135/2004, 36/2009, 36/2009 – other law, 72/2009 – other law, 43/2011 – US decision, 14/2016, 76/2018 and 95/2018 and other laws).
Article 43, paragraph 9, of the Law on Waste Management is prescribed that the unit of local self-government is obliged to prepare the project of rehabilitation and reclamation for the existing non-sanitary landfills, in accordance with the law that should regulate environmental protection. The same article prescribes that a public utility company managing a non-sanitary landfill – a municipal waste landfill is obliged to submit to the competent organization for approval The work plan of the plant according to Article 16. with the programs of corrective measures and dynamic adjustments of the operations in accordance with this law and the regulation the landfilling of waste is regulated.
The work plan consists of corrective measures that the plant owner think are necessary to adapt to specific conditions over a period of time in order to reduce the impact on human health and the environment. This plan also defines the deadlines for fulfilling and correcting the defined corrective measures. The purpose of the preparation of the mentioned plan is to manage the generated waste in the prescribed manner in the following period until the final closure and reclamation and to reduce the present negative impact on human health and the environment.
Any utility company that disposes of waste in a non-sanitary landfill and manages a non-sanitary landfill, in accordance with Article 43 of the Law on Waste Management (“Official Gazette of RS”, No. 36/2009, 88/2010 and 14/2016), is obliged to submit to the Ministry responsible for environmental protection for approval Plan for non-sanitary landfill plants adaptation according to Article 16 of the same law.
In order to reduce the negative consequences of the operation of the non-sanitary landfill, in accordance with the statutory mandatory, the plan of adaptation of the non-sanitary landfill facility shall be prepared. The purpose of preparation of this documentation is to make plans for final closure and reclamation of the generated waste in a prescribed manner in the following period and to reduce the present negative impact on human health and the environment.
“The intermediary, i.e. the waste trader, is obliged to register in the register of waste management intermediaries, i.e. waste dealers.” (Article 28a of the Law on Waste Management, Official. Gazette of RS, no. 36/09, 88/10, 14/16 and 95/18 – other law)
In accordance with the Law on Waste Management, a trader is any legal entity or
entrepreneur who buys and sells waste on his own behalf, including a trader who does not
take possession of the waste. The activity of intermediation in waste management includes the
tasks of organization of treatment, i.e. reuse and disposal of waste, i.e. mediation in the
transfer of rights and obligations related to waste for the needs of others. The Ministry issues
a decision on the entry of an intermediary or trader in the register, if the intermediary or trader
meets the conditions. The decision on entry into the register is issued for a period of five
The Ministry issues a decision on the registration of an intermediary, i.e. a trader in the register, if the intermediary or trader meets the requirements, as follows:
1) That he has not been punished for any criminal offence, i.e. economic offense and misdemeanor in accordance with the law;
2) To have a person responsible for the performance of the tasks for which the application for registration is submitted;
3) It is able to meet financial obligations or obligations that may arise in carrying out operations, in particular the obligation to return waste in accordance with the regulations on cross-border waste movements.
An appeal may be filed against a decision rejecting the request for registration and issuing a certificate within 15 days from the day of receipt of the decision.
Registration can be renewed at the request of the intermediary, i.e. the trader which is submitted 30 days before the expiry of the registration.
The decision on registration can be revoked:
1) If the intermediary, i.e. the trader acts contrary to the decision on registration in the register of intermediaries, i.e. traders;
2) If the intermediary, i.e. the trader, through continuous conduct of business activities, could cause environmental pollution;
3) If the intermediary or trader acts contrary to the regulations on cross-border movement of waste;
4) If the broker, i.e. the trader does not fulfill obligations in accordance with the law.
The intermediary and waste dealer is required to submit an annual report on waste management to the Agency, in accordance with this Law.