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Key departmental publications, e.g. annual reports, budget papers and program guidelines are available in our online archive.

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EMS Substantiates Geelong Wool Combing's Environmental Approach

May 2000


Geelong Wool Combing Ltd. (GWC), felt it already had environmental matters under control when it began work on an Environmental Management System. Although some companies prepare an EMS to address environmental problems and bring about compliance with regulations, others, like GWC, use the EMS process to consolidate already efficient environmental systems.

The seven-year old company, with 130 employees, is located in Corio, near Geelong, Victoria. It is a member of the BWK Group of companies, whose headquarters are in Germany. BWK has a strong commitment to good environmental performance in its plants.

Wool scouring and combing are the first stages in the transformation of sheared fleece into useful products. In these processes, the sheared wool is cleaned to remove unwanted substances. In its untreated state, sheared wool contains wool grease, fine sands, plant and seed material, suint, (sheep sweat) and minute traces of pesticide residues. Chemical substances and sand are removed from the fibre during scouring, and plant material is removed during carding and combing. The final product is a clean, contaminant free wool rope or sliver ready for further processing into fine yarns by a spinner.

Wool scouring is classified as a noxious industry by most EPAs, but the seven-year old GWC facility had installed the best technology to ensure that it not only met all environmental requirements but also presented a clean image. It employs a cleaner production approach in its operations to ensure efficiency and claims to be the most productive wool combing plant in the world.

Preparing and implementing an EMS has verified that the company is performing up to the high standards it sets for itself. It has also helped to demonstrate to others that GWC takes the environment seriously, and this has led to a number of environmental awards.

Overview of the Process Used to Develop the EMS

Rationale: GWC began development of an EMS in mid-1997. Its parent company, the BWK Group with headquarters in Europe, had suggested that GWC might find it useful to become certified under ISO 14001. Certification would convey to clients and the public that GWC is 'environmentally friendly' unlike the conventional image of companies in their industry. BWK gives considerable attention to the environment, and its wool products have gained an Eco-Label. Audit: Work on the EMS began with a full audit of the GWC facilities. A consultant worked with in-house staff to identify all environmental aspects of the operation.

Major focus was given to issues affecting solid waste, water discharge and stormwater, air emissions, chemical use, raw materials use and electricity and gas consumption. They worked from a qualitative review of the nature of environmental aspects towards quantifying the extent of emissions and wastes.

Further analysis was used to decide on the significant environmental aspects. Highest priority was given to environmental aspects affected by regulatory requirements because this was felt to be the most cost-effective way of proceeding. The consultants and in-house staff together identified 10 significant environmental aspects of their activities along with the regulation or policy relevant to each aspect. The aspects identified included:

Store room

During the audit they generated schematic diagrams of the operations, identifying inputs and outputs. They also formulated a policy document and a procedures manual.

Responsibility: John Staniforth, Quality Assurance/Technical Manager, and Letitia Lucas, Systems Administrator, had primary responsibility for developing the EMS. The General Manager of the GWC facility was supportive of their efforts. Because of time pressure to complete the EMS quickly, general staff were not involved in the EMS development, except to the extent of providing information about specific operations. All department managers reviewed and signed off on procedures relevant to their areas of responsibility before the procedures were ratified and implemented.

Integration with Other Systems: In developing the EMS, care was taken to incorporate safety requirements and other matters relating to OH&S issues. The procedures used in the EMS are integrated with those required under the ISO 9002 quality management system.

The EMS built on earlier work done to develop ISO 9002 systems, but the consultant was instructed to make modifications where necessary to ensure that one set of procedures could be used to comply with requirements of both standards. The document management system developed for ISO 9002 could be adopted relatively unchanged for the EMS, as could the OH&S management system. In other cases, previous systems were changed or new ones created.

Implementing the EMS

Targets: The EMS contains a number of specific quantitative targets mainly reflecting the regulatory requirements for different discharges and emissions. In addition, there are targets for examining feasibility of new approaches, such as the potential for treating water to a standard that would permit its use for irrigation or reuse. Another target is to reduce use and cost of resources such as water and energy, but no specific level of overall reduction is specified, although targets are set on a project-by-project basis.


Training: New staff and contractors all attend an induction course that includes an environmental awareness component. In addition, training on individual operations builds in the specific environmental requirements associated with that operation.

Monitoring: Most discharges and emissions are automatically monitored and computer-recorded. Detailed monitoring procedures are used to review the recorded results for compliance as part of normal operations. Internal auditing of the overall operation is a continuous process, with each section reviewed at specified periodic intervals.

Documentation: GWC maintains an EMS manual containing the environmental policy and detailed procedures. Sampling and monitoring requirements are documented in a procedures manual.

Compliance Audits: External audits are carried out every six months by an accredited independent auditor. Each audit takes about one day to complete. The audits have a number of purposes:

Environmental staff have primary responsibility for review of the audit findings. Results are discussed with senior management, supervisors and managers, and relevant general staff. When new issues are identified during the audit, suggestions for corrective action and changes are sought initially from the relevant operating staff, then as necessary, with supervisors and senior management. Where relevant, new targets are set as a result of the audit findings.

Impediments to Implementation: No procedural or structural impediments exist to implementing the EMS as developed.


As Geelong Wool Combing prepared its EMS mainly to consolidate and demonstrate environmental actions already taken, it saw certification as providing validation of its efforts. In its view, a certified EMS would contribute to a good external perception of the organisation's environmental systems. It therefore sought and obtained certification under ISO 14001.

Resources Required

The process of preparing the EMS took about six to eight months. The cost of internal staff time was approximately $60,000, and consultants' fees amounted to $40,000. Thus the total cost was about $100,000.

During preparation of the EMS, Letitia Lucas spent virtually full-time on the project, and John Staniforth spent nearly half time. Other people contributed small amounts of time.

Certification to ISO 14001 added about $5,000 to $6,000 to the cost of the EMS.

Benefits of the EMS

Although the EMS was formulated around environmental management programs already in place, there is no doubt that the application of the EMS philosophy both before certification and continuing to the present has produced appreciable gains for GWC. Current projects are expected to realise significant financial gains in the near future.

Measurable benefits: The major savings and increases in income resulting from application of the EMS principles are:

An electrophoretic plating machine

Other Important Benefits: Some outcomes of the EMS have positive financial implications for GWC, even though it is difficult to assign specific dollar amounts to them. These include:

GWC also believes that less time and effort was involved in obtaining licensing of a new composting facility because the company had EMS certification and the confidence of the regulatory authorities

The company has received two environmental awards reflecting the public perception of the organisation's good environmental performance. These are:

Other benefits of the EMS depend heavily on worker awareness of environmental issues and participation in the aims of the EMS. This awareness is demonstrated in various ways:

GWC's environmental actions also contribute to an improved public view of the industry as a whole.

Future Plans

In the future, GWC will continue to implement its EMS and to bring about continuous improvement through identifying new areas where systems can be refined and upgraded and resource consumption can be decreased.

Contact Information

Mr. John Staniforth
Quality Assurance/Technical Manager
Geelong Wool Combing Ltd
Heales and Broderick Roads
PO Box 209
CORIO    VIC    3214
telephone: (03) 5274 1791
fax: (03) 5274 1838