Management of Environmental Responsibility
Orion’s environmental, health and safety policy defines the Group-level commitment on how we manage environmental matters and promote the well-being of our workforce.
Our responsibility as a company is to recognise and manage our impact on the environment and drive the reduction of our business’s environmental burden. Orion’s environmental, health and safety policy (EHS Policy) defines the Group-level commitment on how we manage environmental matters and promote the well-being of our workforce. Our EHS Management System for managing, monitoring and developing environmental matters also comprises energy efficiency, process safety and occupational health and safety. The EHS Management System ensures effective management and compliance with valid legislation, and also with other regulations and requirements concerning our operations.
The environmental management system is built upon the principles set out in the ISO 14001 environmental standard. In the development of energy efficiency, we apply the principles of the ETJ+ energy management system and practices consistent with the ISO 50001 standard. In the management of occupational health and safety we apply OHSAS 18001 guidelines and the ISO 45001 standard that will replace the former one in the future. The management of EHS matters is monitored through annual internal audits. We are committed to continuously improving our performance in environmental, health and safety matters and strive to achieve the high objective we have set for managing them.
We have identified the most significant environmental aspects for the Orion Group and its businesses. These relate to the consumption of raw materials, energy and water, emissions into the air and waste water, and the amounts of waste created by our operations. Orion’s most significant environmental aspects and the related approaches to continually improve our performance in them are as follows:
Waste water management
Emissions into air
|Managing sustainability of our suppliers||
We continuously measure and monitor matters related to the environment. The two key figures of sustainable environmental development are included in the strategic KPIs monitoring the implementation of our Group strategy.
We are committed to the extension period of the joint Energy Efficiency Programme for members of the Confederation of Finnish Industries (EK). Under the new programme, the savings target for 2025 is 7.5% of energy consumption in 2016 and the intermediate target is 4% by 2020. For Orion, this means a saving target of slightly over 12 GWh.
Our goal is to reduce the amount of hazardous waste in particular, but also our levels of total waste at the same time.
Measuring our performance is vital in managing sustainability and in monitoring the development. Some of the monitored items are obligatory, based on requirements specified in the local and site-specific environmental permits. Environmental and chemical safety authorities are examples of external instances to which we deliver regulatory follow-up data on our environmental performance. More importantly however, gathering data and assessing indicators is a tool for us to monitor and improve our own performance.
We aim to reduce the burden on the environment caused by our operations by implementing programmes and measures. We plan, choose, buy and invest predicting and considering the environmental risks and impacts of our solutions. The core principle behind this is material and resource efficiency: achieving more with less. To be successful, we manufacture our products right first time and use our resources ─ materials, labour, energy, water, time and money ─ as wisely as possible. In doing so, we also create a substantial economic benefit.
In addition to our activity programmes, we encourage the achievement of good results by keeping our processes up to date, investing in improved process technology and methods and a more efficient use and handling of chemicals and other manufacturing materials.
Environmental investments are made at our operational sites on an annual basis, either with the primary purpose of reducing our environmental burden or as part of major upgrading and replacement investments carried out in accordance with the Group’s long-term investment plans. Risk assessments also provide guidance for the planning and implementation of our investments and other measures to reduce their environmental impact.
Elementary legislation to be attended to in the management of environmental affairs includes that concerning environmental protection, waste, chemicals and energy.
We produce pharmaceuticals and active pharmaceutical ingredients (APIs). All of the Group’s production plants are in Finland, and the manufacturing plants have the valid environmental permits required for operations as required by the Finnish Environmental Protection Act. The prerequisites for granting an environmental permit include, among others, that the plant shall neither cause harm to health nor significant environmental degradation or the risk thereof. The environmental regulations and permits are location-specific. They provide the acceptable maximum levels of emissions into air, soil and water, as well as the methods and scopes for the measurement, monitoring and reporting of the items detailed in the permits to authorities.
All production sites of the Orion Group have contracts on the handling of industrial waste waters with their local waste water treatment operator. The acceptable limits for the waste waters are determined in the contracts. We regularly monitor and analyse the quality of our waste waters.
All our sites are required to have permits to store and handle hazardous chemicals, with the exception of the pharmaceutical manufacturing sites in Kuopio and Salo as they do not handle hazardous chemicals on a broad scale.
In accordance with Finnish waste legislation, we aim to reduce waste, avoid producing waste and deliver usable fragments for re-use and recovery.
The Orion Group is subject to the provisions of the Finnish Energy Efficiency Law, which obliges us to improve energy efficiency continuously and to report on our actions and performance to the Finnish Energy Authority. Our Energy Management System helps us fulfil the requirements and the purpose of this legislation.
Fermion is the part of the Orion Group that is subject to the provisions of the REACH Regulation concerning Registration, Evaluation, Authorisation and Restriction of Chemicals, which require Fermion to register all solvents and intermediate products imported or produced by the company amounting to at least one tonne per year.
The CLP legislation (Classification, Labelling and Packaging of Substances and Mixtures) concerns the entire supply chain of Orion to a considerable extent. The purpose of CLP is to harmonise the classification and labelling system of chemicals within the EU.
We aim for the highest standards in the industry with respect to the environment. The minimum levels set in legislation, regulations and the environmental permits are usually not satisfactory targets for Orion in the management of environmental responsibility. We aim to be significantly better, and a higher target can often also prove to be more meaningful economically.
In the Orion Group, the conformity of operations with the environmental management, which is an elementary component in the EHS Management System, is coordinated by the Director for EHS and Facility Management, and by the EHS organisation with its EHS Specialists reporting to him. He reports to the Senior Vice President, Supply Chain, who is a member of the Group’s Executive Management Board. In Fermion, EHS activities are coordinated by a safety manager who reports to the President of Fermion. Fermion's safety managers are members of the group-wide EHS network. The core tasks of the EHS organisation in environmental management include, among other things, taking part in the preparation of continuous improvement programmes, external and internal EHS audits, guidelines and training sessions, following up of safety observations and the resulting corrective actions, risk assessments, investigations of events causing injury, EHS reporting and internal communications about EHS affairs.
The local site managers are responsible for arranging operations at the operational site in accordance with the EHS Management System. Each supervisor shall see to it that their subordinates are familiar with the guidelines concerning the reduction of our environmental impact. They shall also promote employees’ commitment to our development goals and motivate them to take corrective actions to prevent damage to the environment.
The management teams of the business divisions and line functions are primarily in charge of environmental affairs within their operational units, observing the nature of the unit’s operations, the regulatory and legal requirements, and the related environmental risks.
The units of the Group are also responsible for identifying the main environmental impact of their operations and to develop their operations and activities in an environmentally friendly manner. They also determine division and location-specific procedures for environmental damage and accidents, and document the main tasks and activities that have an impact on environmental safety. They also issue guidelines for them as well as establishing and maintaining operating procedures for the collection, processing and archiving of information related to environmental safety.
Acting according to our environmental principles in our daily work is the responsibility of each Orion employee.
In the event of an emergency, pre-determined procedures have been put in place by the Group management for taking control of the event and its consequences and for normalising the situation. Depending on the severity and the nature of the situation, predefined procedures are in place. Preparedness plans in case of different kinds of accidents and other exceptional events are based on continuously following up and monitoring our operational environment.
Emergencies classified as the most serious category pose an imminent threat towards our company and, in the worst case, they could jeopardise our operations or people’s health or safety and cause great damage and harm. The model of action established for the severest kind of emergencies stipulates that the Team for the Management of Exceptional Circumstances, chaired by the President and CEO and consisting of certain pre-defined persons, starts working in accordance with the Team’s charter and shares tasks and guidelines applicable in the event of an emergency. The basic composition of the Team is complemented with other persons depending on the type of event.
In less critical events, i.e., in which the consequences and damages are assessed to be clearly minor compared to those in the most severe category, the most suitable operational model is used from the selection of models established.
In the Rescue Plans established for each operational site, potential accidents and exceptional events involving risks of environmental hazard or workplace safety are described, together with related instructions as well as matters and responsibilities concerning preparedness, rehearsals, training and communications.
In case of emergency, we eliminate the threat and the hazard as soon as possible based on our procedures to limit the damage to people and property, and we appoint appropriate persons to take care of the situation. We take care of internal and external communications to ensure that up-to-date and reliable information is available quickly and transparently. We also observe the role of the relevant public authorities in managing the event. In addition to this, we also take care of continued operations, staff arrangements and alternative or temporary operational arrangements.
The following procedures are elementary in operating our EHS Management System and for predicting, preventing and observing exceptional events and situations and for taking corrective action:
A team of EHS experts investigates the observations recognised in risk assessments and audits or in the safety observation system as well as the notifications received from external instances in collaboration with management and relevant experts. In this process, the causes and the degree of severity are also assessed, and the necessary actions are planned to eliminate the defect or to mitigate the harm, and to prevent a similar event from recurring.
We follow up the implementation, applicability and efficiency of our EHS Management System by means of regular internal site audits and also in the annual management reviews. The audits and management reviews help us identify needs to develop and improve our operations and the management system. In addition, we make sure that the system and our operations follow the principles set out in the ISO 14001 standard.
In its annual management review, the Group’s executive management evaluates the applicability, sufficiency and efficiency of our EHS Management System. In the review, the management assesses things like the outcomes of the EHS audits, the results and the level of improvement of the EHS activities, the progress of the corrective and preventive actions taken, as well as the recent and upcoming changes in circumstances, requirements and obligations. In addition, the management evaluates our EHS Management System, Policy and targets, and considers possibilities for improvement and necessary changes.
Training is part of our active EHS culture and plays an important role. We maintain and promote our staff’s awareness of environmental, health and safety affairs as well as of our energy efficiency improvement programmes by providing information in our internal communication channels and by means of guidelines and various training events.
Supervisors have a special responsibility for ensuring that existing staff and new employees receive sufficient training on the safety procedures and environmental matters of the department and division they work in.