SLC ENVIRONMENTAL POLICY 2022
This document sets out the environmental management policy of the Scottish Law Commission. It has been prepared in response to a request from Scottish Ministers that public bodies put such policies in place. It is intended to be both a statement of our commitment and guidance for new and existing staff.
At the Scottish Law Commission we have carried out environmental audits to establish where we are in terms of our environmental performance. The information gathered has been, and will be used to set annual objectives and targets in areas such as waste minimisation, paper and water use, and energy efficiency. Improving environmental performance requires changes in the way we carry out our day to day business, which must nevertheless be consistent with our health and safety obligations, and also requires the support of every member of staff.
A summary of our specific objectives and targets for 2022 is set out in the appendix to this document. The policy and its specific objectives and targets will be kept under regular review by the Commission.
Climate change is considered to be one of the biggest environmental issues facing the world today. The UK signed up to the Kyoto Protocol and is firmly committed to tackling climate change. The Climate Change (Emissions Reduction Targets) (Scotland) Act 2019 which amends the Climate Change (Scotland) Act 2009, sets targets to reduce Scotland’s emissions of all greenhouse gases to net-zero by 2045 at the latest. In common with other public bodies in Scotland the Commission aims to take appropriate steps to act sustainably, contribute to carbon emissions reduction targets and contribute to climate change adaptation, eg by minimising our energy use.
Since the commencement of the Nature Conservation (Scotland) Act 2004, all public bodies in Scotland have been subject to a statutory duty to further the conservation of biodiversity. The Commission is now required to take its impact on biodiversity into account in all aspects of its decision-making. The Commission's law reform functions themselves are unlikely to have implications for biodiversity (unless for example a law reform project were reviewing some aspect of environmental law). The duties do, however, impact on aspects of the Commission's operations such as purchasing of supplies, disposal of waste, use of paper, and water and energy resources.
The Commission generally purchases products and services through collaborative contracts of the Scottish Procurement Directorate (SPD). These contracts are for general use by the Scottish Government, Government Agencies, NDPBs, Associated Departments and the wider Scottish public sector. At present, the Commission uses such contracts for the supply of its electricity, water & sewerage services, taxi services, travel, IT consumables, paper, stationery and furniture.
To be awarded contracts by SPD, the contractors have to comply with a number of conditions in relation to their environmental performance. Further information can be found in the Scottish Government's Sustainable Procurement Action Plan for Scotland.
The availability of collaborative contracts of SPD and the nature of the Commission's work means that we have no need to put out to tender contracts for the supply of goods and services whose value would equal or exceed current EU Procurement Directive thresholds. If we did, we would comply with SPD's Procurement Policy Manual.
The amount of waste the Commission transfers to landfill sites has been measured. The data collected indicates that there is limited scope for setting meaningful reduction targets by volume. However, in 2016 we reduced our general waste collections from once a week to once a fortnight. We believe we can further reduce the amount disposed of by continuing to review our current practice and by employing the 4 R's - Repair, Reduce, Re-use and Recycle – whenever possible. Recycling schemes for cardboard, paper, toner cartridges, food tins, aluminium cans, glass, plastic bottles and plastic vending cups are already in place. Recycling of food waste has been investigated, however the costs of doing this in such a small office would outweigh any benefits.
We cancelled our subscription to daily newspapers resulting in less recyclable waste being sent for disposal. We have donated superseded books from our law library for re-use in Malawi and in Zambia. We disposed of surplus stationery supplies by donating to a local primary school. Superseded computer hardware is disposed of responsibly in accordance with Scottish Government protocols. We aim to reuse or recycle surplus office furniture. Disposal of waste to landfill should be a last resort after all the above options have been pursued. We will introduce more schemes, when and if available, through Changeworks, our current provider of waste management.
OBJECTIVE: to reduce further the amount of waste being transferred to landfill sites and increase the proportion of waste which is reused and recycled
For in-house printing and photocopying paper the Commission uses 100% recycled paper.
Since 2000 the Commission published on our website all discussion papers and reports. We also issued our publications in hard copy. Since then we have periodically reviewed our distribution lists to reduce printing orders, increasingly relying on online publication.
In 2016 we decided to publish Commission papers online only, where it is open to us to do so, for environmental reasons and in order to save costs.
The Commission’s news Bulletin issued twice a year is distributed as an e-Bulletin by e-mail only.
Paper carries a cost both in terms of purchasing and disposal that can be minimised through reduction in use, re-use and recycling. We will aim to reduce significantly the cost and amount of paper being used by following standard conservation guidelines in our day to day work. In particular we will:
- ensure photocopying is produced double-sided and on recycled paper whenever possible.
- use double-sided printing where possible and reuse paper for single-sided printing where feasible.
- cancel junk mail and unwanted publications.
- produce printed stationery in-house to reduce wastage by tailoring volume more closely to need.
- use electronic communication where possible to reduce printing and refrain from printing unless absolutely necessary.
- collect all paper that has been printed on one side and re-use it for printing in draft or for scrap message pads.
- re-use envelopes where possible, especially for internal mail within the Commission and with the Scottish Government; otherwise, recycle used envelopes.
- place all waste paper (white and coloured), including the contents of junk mail, in the recycling bins provided. Any cardboard will be collected by the messenger and sent for recycling. Confidential paper will be shredded and sent for recycling. Old telephone directories will be collected and sent for recycling.
Our paper consumption fell by 40% during 2016-17, a significant achievement reflecting our decision to publish reports and discussion papers online only where it is open to us to do so. During the period of the coronavirus pandemic from March 2020, the Commission’s work has almost entirely been carried out at Commissioners’ and staff members’ homes and the access to Commission printing facilities has therefore been severely restricted. This has resulted in a considerable reduction in the use of paper during the pandemic period. However, the Commission’s official record remains the paper file and so there has been a need to continue to produce some printing in order to fulfil our records management duties.
OBJECTIVE: to reduce the amount of paper used in the office.
TARGET: to reduce the consumption of A3 and A4 paper in the office in 2021 in comparison with the 2019 level
The Government's current guidelines advise that in a good practice office building the level of water consumption per person per year should be around 7.7m3 (7700 litres). Our aim is to further reduce consumption and we hope to achieve this by conserving water where possible by means of the following measures:
- ensuring that taps (especially hot water taps) are turned off properly and not dripping
- filling and boiling kettles no more than is required each day
- economic use of water when hand-washing, dishwashing and showering.
We have already introduced a dual flush system in all of the toilets. We have also replaced the existing mains water supply pipe with a smaller gauge pipe to reduce consumption further.
We replaced our bottled water dispensers with plumbed-in dispensers in order to reduce the detrimental environmental impact caused by the production and transportation of bottled water. We recognise that this will not lead to a decrease in our consumption of water. However, we decided that the overall environmental benefits of using plumbed-in dispensers outweigh any disadvantages, and we are still confident that our other water conservation measures will allow us to meet our target on consumption.
A change in our contract with our water supplier should make the monitoring easier as invoices are now submitted on a monthly basis.
OBJECTIVE: to monitor water usage.
TARGET: to reduce as far as practicable the level of our water consumption in 2021 to achieve the good practice benchmark of 7.7m3.
Due to the nature and age of the building and the heating system, the Commission's office is expensive to heat. However we make savings by switching off heating during the summer months. In addition, we aim to reduce our electricity consumption and consequently our CO2 emissions by following some simple guidelines:
- room thermostats have been set at the reduced level of 19°
- windows should not be opened when the heating is on unless absolutely necessary or unless in fulfilment of requirements or good practice resulting from the coronavirus pandemic
- turn down thermostats on hot water tanks where compatible with health and safety requirements
- natural light should be used whenever possible
- A "switch off" campaign is running to encourage staff to switch off their lights during the day whenever possible.
- All office machinery, including PC monitors, should be switched off when not in use, with the exception of photocopiers which take some time to warm up. In addition, all workstation PCs, including monitors and printers, should be shut down as well as switched off at the wall sockets at night where practicable.
- Identify little used or redundant machinery for disposal or relocation within the office in order to reduce running costs and maximise operating efficiency
- Our PCs run software which automatically shuts the machine down at 7 pm each night, should it accidentally have been left on.
- New Desktop Mini PCs were purchased utilising a Scottish Government Framework agreement. The environmental benefits of the new equipment include a reduction in carbon emissions
- We changed our web host to one which uses liquid rather than air cooling to reduce server temperatures. This is estimated to be 30% more energy-efficient than the equivalent air cooling.
The Commission has a programme to replace existing lights with more energy-efficient fluorescent tubes (T8s) when they fail; and to take into account energy consumption and green credentials when buying new equipment (following Scottish Government purchasing policy). We have fitted draught exclusion on all exterior doors, and installed a timer on the water immersion heater. All windows are double glazed.
Due to the complexity of our electricity metering system it has not so far been possible to monitor consumption reliably.
OBJECTIVE: To keep electricity consumption as low as practicable by following the conservation measures in place.
To contribute to an increase in sustainable travel, both for commuting and business, Commission staff are encouraged to consider whether their journey to work or any journey they have to make within Edinburgh on Commission business could be undertaken by bus, cycle or on foot rather than by taxi or their own car or, failing that, whether any informal car-sharing arrangement with a colleague would be possible. For making local deliveries we normally use cycle couriers.
Staff are encouraged to use telephone conferencing and the Scottish Government’s video conferencing facilities, where possible, to reduce the need to travel. In 2015 we purchased a Polycom SoundStation 2 conference phone for this purpose, but the introduction of MS Teams in 2020, with the resulting ability for all at the Commission to use audio and video conferencing while working remotely, has now superseded that technology.
We make eligible staff aware that the Scottish Government offers free purchasing advances for annual travel tickets, bicycles and accessories. Shower facilities are available on the 3rd floor. Although no bicycle parking rack is available, bikes can be kept in the south stairwell of the building. Even if it is not feasible for some staff to give up the car for commuting to and from work, "green driving" techniques can make a difference to fuel consumption and we encourage their use.
Our separate travel plan gives fuller details of these measures.
OBJECTIVE: to encourage use of audio and video conferencing where appropriate in order to reduce the need for travel.
Environmental management system
The induction for new members of staff includes information on the Commission's environmental policy. All staff will be brought up to date regularly on environmental issues through our redeveloped intranet, and other relevant material will be circulated for information when appropriate.
A quarterly reminder will be sent to all staff to make them aware of the importance of good environmental management
If you have any comments to make on the policy or any further suggestions as to how we can improve our environmental performance, please use the contact us page to contact the Environmental Strategy team.
APPENDIX: SUMMARY OF SPECIFIC OBJECTIVES AND TARGETS FOR 2022
To reduce further the amount of waste being transferred to landfill sites and increase the proportion of waste which is reused and recycled.
To reduce the amount of paper used in the office.
To reduce the consumption of A3 and A4 paper in the office in 2022 in comparison with 2019 levels.
To continue to monitor our water consumption.
To reduce as far as practicable the level of our water consumption in 2021 to achieve the good practice benchmark of 7.7m3 per person per year.
To keep electricity consumption as low as practicable by following the conservation measures in place.
To encourage use of audio and video conferencing where appropriate in order to reduce the need for travel.