text:
Twinning Project RO2004/IB/EN-09 Implementation and Enforcement of the Environmental Acquits at National Level and Coordination of the 8 Regional Twinning Projects Combined and Integrated Mission Report Missions No. 52, 53, 54, 55 Component No. 4 Support to Operational Duties Activity 4.6 Support in enforcement Also supporting the National Environmental Guard Guideline for professional development in inspection and enforcement for the National Environmental Guard, based on the minimum criteria on inspection Mission dates: Calendar Weeks 17, 20, 26, and 46 of 2006 Bucharest, National Environmental Guard Experts: Marcel van de Knaap, Marcel Stigter, Chris Smit DCMR Environmental Protection Agency, the Netherlands With staff members of the National Environmental Guard, Bucharest 1 Contents 1 Mission goals 3 2 Mission program 3 3 Specification of Training Issues – Inspection 7 4 Mission results 12 Attachments 12 2 1 Mission goals The goals of mission 4.6a in the Twinning Project RO2004/IB/EN-09 - Development of a draft guideline for professional development in inspection and enforcement based on the minimum criteria on inspection - Workshop (3 days) and other training activities for discussion of the draft guideline with all staff of NEPA, REPA and NEG involved in inspection and enforcement. The discussion will lead to a draft implementation plan - Writing of a national guideline; finalizing the guideline with an implementation plan, based on the mission reports - 2 Mission program Week 17 Planned Description Time, experts activity Week 4.6a-1 Identify and define the inspection and enforcement strategy Week 17, Workshop 1 Presentation Dutch professional development starting 24 April Use the inventory on existing tasks, knowledge, skills, vision and 2006 strategy Define the expectations of NEG and NEPA for the near future Stigter Define the timeframe in which this future is expected to be there Van der Knaap Define the human resources who will be made responsible for the Smit implementation and the quality management of the strategy Discuss enforcement strategy, present competences, enforcement quality, quality management and the expectations Draft an improved enforcement strategy document Assign to all participants in the workshop to discuss the document in their home organizations The main goal of the mission in week 17 was a needs assessment to identify the needs and develop a guideline for professional development in inspection and enforcement (based on the minimum criteria of the EU) on inspection by the NEG. Needs assessment In the mission in week 17, April 2006 the results of the interviews and discussions with NEG staff are: - The NEG is well organized, has a good structure and is ISO 9001 certified. - NEG staff is well educated and must be able to participate as a full partner during discussions with companies. - The knowledge of the environmental laws is good. - There is no structural knowledge about financial issues and how to use them on operational level at the NEG. - NEG staff in common has all required authorizations to accomplish their task, but has no authorization to verify inspection results in the (financial) book-keepings. - The enforcement instruments are: - Warning, fine, temporary closure, permanent closure. - There are no instruments to deprive the financial profit of a violation. - The enforcement process is a reactive process. - Inspection →violation→reaction 3 - Inspections are carried out by one inspector who is responsible for the complete installation. - Every inspector has a package of installations which (s)he is responsible for. - A systematic approach can improve the work of the inspector. - There is no NEG budget for measurements or sampling. - Sufficient knowledge of the actual situation and the relevant process which is inspected is very important and can be improved. Recommendations The expert team developed the following recommendations which are based on the outcome of the needs assessment. The process of inspection and enforcement of the NEG can be improved by: 1. The development of legal tools to figure and to deprive the financial profits of an environmental violation. (According to an agreement with the General Commissioner, Mr. Silvian Ionescu, there is attachment A included: Translation of the Dutch Penalty Law about instruments to deprive the financial profit of a violation). 2. Develop a budget to verify measuring figures or to take own samples. 3. Develop a path to provide NEG staff the skills to execute a pro-active enforcement approach. 4. NEG inspections can be improved with a systematic approach of the field inspections. 5. Based on the assessment the NEG needs a guideline to improve the performance by the development of a practical trainingsprogramme: a. Develop a train the trainer course. This course provides a group of NEG staff the right skills to train all NEG employees (700 p). b. Set up a study visit for a small group of Regional Commissioners to show them what can be achieved with an IPPC permit in combination with a pro-active enforcement approach. c. Develop a ‖training on the job‖. NEG inspectors can practice their enforcement skills and the systematic approach in accompaniment with experienced enforcement experts. Week 20 Planned Description Time, experts activity Week 4.6a-2 Drafting the professional development plan Week 20, Workshop 2 Discuss and assess the results of the discussion in April on the starting with 15 enforcement strategy document May 2006 Make clear conclusions on the directions of the professional development. Smit Define a number of subprojects that contribute to the Van der Knaap professional development and describe SMART objectives Stigter Assign a local project coordinator on the professional development plan Assign subproject leaders and time deadlines Assess the reactions on the developed subprojects in the framework of the professional development plan The main goal of the mission in week 20 was the evaluation of our observations and recommendations with NEG staff of the results of week 17, and also has feedback on the recommendations and the draft guideline in headlines. Results mission week 20 In the mission in week 20 the results of evaluation with NEG-staff were: - NEG staff recognized the outcome of the needs assessment in general and supports the recommendations of the expert group. - NEG staff corrected their statement about the lack in authorization in verifying inspection results in the (financial) book-keepings. They are possible authorized but do not have the knowledge and the experience to carry it out. 4 - NEG staff corrected the point about not having possibilities for measurements or sampling. NEPA has a fully equipped laboratory which NEG can use. If the NEPA laboratory is not able to carry out a requested measurement NEG has no budget to hire a commercial laboratory. - During several meetings NEG staff and the expert group developed an approach to execute the recommendations mentioned in the results of the first mission week. - To accomplish the minimum criteria, mentioned in the recommendation of the European parliament and the recommendations of the first mission, the project team (NEG staff and expert group) concluded that the approach of a Study tour, a ―Train the trainer‖ course and ―Training on the job‖ would be the best solution. - Besides this approach it is recommendable that the Romanian law is extended with legal tools to figure and to deprive the financial profits of an environmental violation. - It is also recommendable to re-consider the reward system of NEG-inspectors and commissioners. The fee-system on extras, depending on number of inspections, number of fines and total amount of fines, doesn't encourage a long term approach, complex investigations and a pro active approach. Meetings of the project group resulted in the following action points for the next mission week: 1. The expert group will develop an execution plan for the ―train the trainer‖ course (attachment C); 2. The human resource manager of the NEG will contact the Financial guard and will request a training of NEG-staff in simple financial verifying issues. The expert group will provide the HR manager in a list of subjects in this matter (attachment D); 3. The expert group will develop an execution plan for the ―training on the job‖ (attachment F); 4. The human resource manager of the NEG will study on the possibility to set up a training for aimed NEG staff in PowerPoint skills; 5. The expert group will provide the NEG in a translated copy of the depriving articles of the Dutch penal law (attachment A); 6. The expert group will investigate the subjects and costs of a study tour for a small NEG group in the Rijnmond area of the Netherlands; 7. Systematic approach (attachment B). Week 26 Planned Description Time, experts activity Week 4.6a-3 Co-write the draft guidelines Week 26, Drafting Discuss the results of the subprojects with the different starting with 26 guidelines subproject leaders June 2006 Define draft guidelines on the basis of the minimum criteria and on the results of the subprojects Stigter Deliver these draft guidelines to all relevant institutions and Smit persons The main goal of the mission in week 26 is the evaluation of the results of week 20, the assignment of duties, finishing the draft guideline and evaluates the project with the NEG and project-management. Results mission week 26 The results of evaluation and assessment in the mission in week 26, lead to the following completion of different issues. - The Financial Guard is willing to carry out the training on the proposed financial issues. - In discussion with the chief of the juridical department of the NEG, we discovered the basics behind the needs on juridical training: - First of all is the need of good inspection reports when the lawyers go to court. - Using not accredited laboratories leads to loosing cases in court by the NEG. - Inspectors should understand the basics of the juridical system related to their reports, fines and collected evidence. 5 - Judges are not familiar with the environmental law. - Their should be a very good coordination between NEG-staff and the people who make the permits. - The timetable of the different parts of possible training programs is discussed. Recommendations Based on the out come of the evaluation and assessment it is recommendable: - Inspection reporting by inspectors, suitable for court appeal should be a subject in the draft guideline (training issue NEG-staff). - Use accredited laboratories should be a subject in the guideline. - The inspectors should have an idea about the juridical consequences of their reports (training issue NEG-staff). - To improve more positive court cases for the NEG, it is recommendable to organize periodical conferences Lawyers NEG, judges, public prosecutors. - Adjust the agreements and procedures with the permitters: there should be sufficient involvement from NEG in the permitting procedure. - The timetable we discussed is showed here: Appointments With the NEG-staff we made the following appointments. - Dutch examples on ‗'Natura 2000' will be arranged if they are available. - The juridical staff delivers a text about the needs juridical based. - Reaction on proposal of the timetable. - Reaction about the timescale of financial training. - General comment about the draft guideline we discussed in the mission week. - Reaction from Mr. Tablet about his need to translate Dutch information about human resource matters. 6 Week NOVEMBER 2006 Planned Description Time, experts activity Week 4.6a-4 Discussing the draft guidelines Week ??, Workshop 3 Presentation of the draft guidelines; starting with in Discussing Discussing improvement to the draft guidelines; October 2006 the Approving and adopting the improved guidelines. guidelines Van der Knaap; and the Sremer trainings Kramers, program Du Maine Basic recommendation This document contains issues and trainings to improve the NEG inspections and enforcement. There should be a program or project to execute the trainings. 3 Specification of Training Issues – Inspection Improvements towards the minimum criteria of the EU According the recommendations of the European parliament and of the council of 4 April 2001 providing for minimum criteria for environmental inspections (2001/331/EC), there are basic skills to improve inspection and enforcement of the NEG1. The main EU-criteria are: - Planned approach - Different instruments and approaches - Based on risk assessment (analyze) - Budget for practice/execution - Trained personal Based on the observation the NEG we suggest a guideline for professional development by a practical trainings program. The issues to improve the NEG are: - Basic enforcement skills (Communication; Interview; Discussions with industry; Conflict handling)* - Technical subjects to investigate* - Information sources and exchange* - Inspection plan* - Collecting evidence* - Risk assessment (environmental risks, view on compliance, compliance risks) (see attachment B) - Prioritize topics (environmental and economical) - Advance a pro active approach - Improvement of the environmental performance - Long term strategy - Cooperation with company to achieve environmental performance - Prevention in stat of repression - Use enforcement tools as a pressure instrument 1 Official Journal L 118, 27/04/2001 P. 0041 – 0046. http://europa.eu.int/eur- lex/pri/en/oj/dat/2001/l_118/l_11820010427en00410046.pdf 7 - The actual situation is primary the baseline is and not only the permit - Inspection reports by inspectors, suitable for court appeal - Inspectors need overview of the juridical aspects in enforcement - Financial verifying (see attachment C) The goal of training these aspects is: - Enough knowledge to be able to use (financial) company administration as a tool; - Verifying compliance of environmental legislation and permits; - Figure and to deprive the financial profits of an environmental violation; - Figure financial consequences of environmental damage of costs for violator or community in case of recovery. The training of the NEG on financial skills probably can take place by the National Financial Guard. The following financial issues are relevant: - Basic organization knowledge - Basic administration en accounting - Basic control knowledge - How to use financial instrument (cases and examples) These basic issues are already described in the EU document ''Assuring Environmental Compliance: A toolkit for building better environmental inspectorates in Eastern Europe'' Developing the skills The trainings to improve the NEG towards the minimum criteria of the EU are: 1. PowerPoint training 2. Train the trainer 3. Training in financial verifying 4. Study visits 5. Training on the job Those training types enable the skills because of practicing during training. Therefore this gives more guarantee of practice and implementation of the skills. This can not achieved by simply hand over technical guidelines. 1 PowerPoint training (40 up to 80 trainers) The obtained trainers will be trained in working with MS PowerPoint The NEG is completely self supporting on this issue. Training-goals The trainer is able to work with PowerPoint to be able to use PowerPoint for preparation and presentation while training other NEG-staff-member in ‗Train the trainer'. Type of Training - Practicing with examples and study orders - Using PowerPoint tray out presentation in front of a group while training Training materials - Handouts with functions, study cases and orders - Computers - Beamer 8 2 Training in Financial verifying (see attachment C) The training of the hole NEG-staff (commissars) on financial skills take place by the National Financial Guard. The following financial issues are relevant: - Basic organization knowledge - Basic administration en accounting - Basic control knowledge - How to use financial instruments (cases and examples) Training-goals The goal of training on these aspects is: - Enough knowledge to be able to use (financial) company administration as a tool: - Verifying compliance of environmental legislation and permits; - Figure and to deprive the financial profits of an environmental violation; - Figure financial consequences of environmental damage of costs for violator or community in case of recovery. Type of Training - Conferences (presentations, group discussions) - Workshops with practical cases and basic financial control techniques mixed with inspection methods Training materials - Handouts or guideline with useful hints, tips and practices, addresses of the experts of the Financial Guard - Presentations - Cases and examples: based on environmental items, related to financial verifying - Evaluation sheet concerning the content and the organization of the training 3 Train the trainer (40 up to 80 trainers) The trainers will be trained first of all in some skills they need for the training. The training skills aimed to be sufficient before the trainer starts to train the others. * Necessary trainer skills are: - Working with MS PowerPoint (NEG is completely self supporting on this issue) - Presentation - Working with role-play - Working with cases (example in attachment G) - Working by plan The trainers will be trained in the named skills to improve (details in attachment B). They train the NEG- staff after that. Training-goals The trainer is able to train other NEG-staff-member in the skills in theory and practice. Practicing takes place by workshops and role-play. Type of Training - Seminar (presentations, group discussions) - Workshops with practical cases and inspection methods - Role-play (communication) Training materials - Handouts for the participants of the training: (Trainings Techniques, some useful hints, tips and practices) - The toolkit for building better environmental inspectorates in Eastern Europe 2 - Presentations 2 http://www.oecd.org/dataoecd/61/62/34499651.pdf 9 - Cases - Guideline for ―train the trainer‖ - Evaluation sheet concerning the content and the organization of the training 4 Training on the job (80 persons) Before starting training on the job the course member should already have followed the theoretical part, ―training NEG staff‖. The objects are common complex NEG situations like illegal waste dumps, complex site inspection, major incidents, etc. The subjects in this training are the named skills, with special attention on: - Technical subjects to investigate - Information sources and exchange - Inspection plan - Collecting evidence - Risk assessment (environmental risks, Not enough view on compliance, compliance risks) (see attachment B) - Advance a pro active approach - Systematic approach (in detail in attachment B) - Financial verifying (see attachment C) The NEG-inspectors work in a team of 4-5 people. Each team will be trained by a foreigner expert (detailed in attachment C). Training-goals - NEG-staff is able tot practice the named skills in common inspection situations, in complex site inspections and complex incidents Type of Training - Case training on regular (complex) NEG inspection situation in a small team (20 projects with 4 trainees each) - Coached by an expert trainer Training materials - Guideline for ―training on the job‖ - Evaluation sheet concerning the content and the organization of the training 5 Study visits The maximum of four persons visit some sites in for example the Netherlands. This aims to give them a picture of technical problems, solutions or used techniques and the way of working of the Dutch inspector. Interesting sites are refineries, waste treatment, waste incinerator, IPPC companies, and a steel company. De trainees get a summary of the permits, and activities a week before their trip. They visitors shall visit the sites in couple of two person accompanied by an experienced inspector. The mission is to show the actual situation on site and clear explanation of the permit and treatment solutions and used techniques. An important point is also the required registrations and reports and the way of verifying. The NEG investigates possible foundation for the study visits. There should be recourse for the trip and the stay. Training-goals - NEG-staff gets ideas by examples about technical solutions in practice and about the pro-active approach 10 Type of Training - Presentation - Site visits - Workshops Training materials - Guideline for ―study visits‖ - Summaries of relevant permits, with the parts of problems and solutions - Evaluation sheet concerning the content and the organization of the training 6 Juridical symposia / conferences To improve more positive court cases for the NEG, it is recommendable to organize periodical conferences with Lawyers from the NEG, judges, public prosecutors and maybe representatives of NGO's. Training-goals - Judges and public prosecutors become familiar with environmental law and cases Type of Training - Symposia / conference - Workshops??? Training materials - Cases - - Time table The timetable contents the schedule 11 4 Mission results The way of working in Romania is compared to the minimum criteria of the EU. It is not necessary to elaborate a complete program for professional development of the required EU minimum criteria. Nevertheless there are some aspects which should be approved. Those aspects are described in this document. Furthermore we developed a specific training program, based on the aspects that should be improved. The program is discussed with the NEG. Guidance is given in development to the required level of inspection and enforcement. Now it is important to execute the training program and pass the knowledge and findings on to the national en regional environmental inspectors. The execution of a trainings program was not in the activity program. The trainings program is extensive and will need a separate project. We suggest a twinning light proposal or maybe even a twinning project. Attachments Attachment A Example of legal instruments to deprive the financial profit of a violation Article 36e 1. La cererea procuraturii de stat este posibil ca să se ia o hotărâre judecătorească separată prin care să i se impună celui care a fost condamnat din cauza unei fapte pedepsibile obligaţia plăţii unei sume în bani în favoarea statului, sub titlu de retragere a unui avantaj obţinut nelegitim. 2. Această obligaţie îi poate fi impusă persoanei menţionate în alineatul 1, care a fost condamnat prin intermediul sau în urma faptelor pedepsibile în cauză sau a faptelor asemănătoare sau a faptelor pentru care se poate impune amenda în bani, aparţinătoare categoriei a cincia, referitor la care există suficiente indicaţii, că acestea au fost săvârşite de el. 3. La cererea procuraturii de stat este posibil ca să se ia o hotărâre judecătorească separată prin care, celui care a fost condamnat din cauza unui delict pentru care se poate impune amenda în bani aparţinătoare categoriei a cincia, şi faţă de care s-a desfăşurat o procedură de cercetare penală financiară în calitate de suspectat de comiterea unei infracţiuni, să i se impună obligaţia plăţii unei sume de bani în favoarea statului, sub titlu de retragere a avantajului obţinut nelegitim, dacă în urma cercetărilor efectuate se poate presupune că această faptă sau alte fapte pedepsibile au generat într-un mod sau altul ca condamnatul să beneficieze de un avantaj nelegitim. 4. Judecătorul stabileşte suma estimativă a avantajului obţinut nelegitim. Sub avantaj înţelegem economisirea de cheltuieli. Valoarea obiectelor, care, după considerentele judecătorului aparţin avantajului obţinut nelegitim poate fi estimată la valoarea pieţei în momentul deciziei sau făcând trimitere la preţul care poate fi obţinut în vânzarea publică, dacă suma trebuie să fie despăgubită. La cererea bine argumentată a suspectului sau a condamnatului judecătorul – în caz că posibilităţile financiare actuale sau din viitor ale suspectului sau ale condamnatului nu permit achitarea sumei respective – poate să ţină cont de acest fapt în momentul stabilirii sumei. În lipsa unei asemenea cereri judecătorul poate aplica această atribuţie din oficiu sau la cererea ofiţerului justiţiei. 5. Sub obiecte înţelegem aici toate lucrurile şi toate drepturile patrimoniale. 6. Când se stabileşte volumul sumei la care se estimează avantajul obţinut nelegitim, se va scade din această sumă revendicările atribuite deja de instanţă terţelor persoane. 12 7. La impunerea reglementării se va ţine cont de obligaţiile de plată provenite din decizii anterioare sub titlu de retragere a unui avantaj obţinut nelegitim. Articolul 126 1. În caz că inculpatul este suspectat de comiterea unei infracţiuni pentru care se poate impune amenda în bani aparţinătoare categoriei a cincia, şi pentru care se poate obţine un avantaj de orice interes exprimabil în bani, în sensul dispoziţiilor acestei secţiuni se poate instala desfăşurarea unei cercetări financiare penale. 2. Cercetarea financiară penală vizează stabilirea avantajului obţinut nelegitim de către suspectat, având ca scop retragerea acestuia conform articolului 38 din Codul Penal. 3. Cercetarea financiară penală se va instala în vigoarea unei împuterniciri, care conţine motivele, fiind întocmită pe numele judecătorului-comisar la cererea ofiţerului justiţiei, care este însărcinat cu cercetarea faptei pedepsibile. 4. Cererea ofiţerului justiţiei va conţine motivele. În anexa cererii se va depune o listă a obiectelor, care au fost deja confiscate pe baza articolului 94a, cel de-al doilea, cel de-al treilea şi cel de-al patrulea alineat. 5. Ofiţerul justiţiei îl informează periodic pe judecătorul-comisar, din proprie iniţiativă sau la cerere, despre desfăşurarea cercetării financiare penale. Judecătorul-comisar – dacă consideră a fi necesar în sensul articolul 126, primul alineat –, informează tribunalul. Judecătorul-comisar notifică ofiţerul justiţiei în privinţa acestui fapt. Articolul 126a 1. În vigoarea împuternicirii date în sensul articolului 126 funcţionarul organului de cercetare însărcinat cu efectuarea cercetării financiare penale are competenţa ca – după prezentarea copiei împuternicirii –, cu scopul consultării situaţiei patrimoniale a celui împotriva căruia s-a instalat cercetarea, să ordone tuturor ca la prima solicitare: a. să i se raporteze ori să poată consulta ori să i se prezinte o copie a documentelor sau a datelor, acestea nefiind date conforme articolului 126, cel de-al doilea alineat, a treia frază; b. să se menţioneze, dacă există componenţi de patrimoniu – şi dacă există, atunci să se specifice, care dintre aceştia – aflaţi în prezent sau în trecut sub administrarea celui în cauză, care îi aparţin sau i-au aparţinut celui împotriva căruia s-a instalat cercetarea; şi să sechestreze documentele obţinute astfel. 2. Ordinul nu se îndreaptă către cel împotriva căruia s-a instalat cercetarea. 3. Articolul 96a, cel de-al treilea alineat, se aplică în mod analog. 4. La prima audiere a celui împotriva căruia s-a instalat cercetarea judecătorul care prezidează audierea sau funcţionarul îi prezintă celui în cauză copia cererii sau împuternicirii menţionate în articolul 126. Articolul 126b 1. Pe durata cercetării financiare penale ofiţerul justiţiei are competenţa ca fără împuternicire judecătorească specială să ordone confiscarea unor obiecte în vigoarea articolului 94a. 2. Dacă ofiţerul justiţiei consideră că în interesul cercetării financiare penale este necesar, îi poate revendica judecătorului-comisar percheziţia unor locuri în vederea confiscării, cât şi exercitarea altor competenţe ce îi revin în vigoarea celui de-al treilea alineat. 3. Pe durata cercetării financiare penale judecătorului-comisar îi revin aceleiaşi competenţe, ca şi în timpul cercetărilor judiciare preliminare, adică: a. el are competenţa să ordone extrădarea/punerea la dispoziţie spre confiscare a scrisorilor care pot fi de folos în dovedirea avantajului obţinut nelegitim de către cel împotriva căruia se îndreaptă cercetarea; b. el nu are obligaţia să permită accesul celui împotriva căruia se îndreaptă cercetarea sau al consilierului acestuia la activităţile de cercetare efectuate; Articolul 126c 1. Ofiţerul justiţiei, în caz de nevoie presantă, poate percheziţiona cu scopul confiscării orice loc, cât şi locuinţă fără aprobarea locuitorului, sau biroul oricărei persoane care refuză mărturia în 13 sensul articolului 218, dacă se poate presupune că acolo se află documente sau date conforme articolului 126a sau obiecte conforme articolului 94a. 2. Articolul 97, cel de-al doilea, cel de-al treilea şi cel de-al patrulea alineat, se aplică în mod analog. Articolul 126d Articolele 98, 99 şi 99a se aplică în mod analog, adică percheziţia specificată în articolul 98, cel de-al doilea alineat, referitoare la scrisori şi înscrisuri, se referă concomitent la tot ceea ce poate dovedi avantajul nelegitim obţinut de cel împotriva căruia se îndreaptă cercetarea. Attachment B Systematic approach in detail Baselines of the systematic approach are: Approach of risks in inspection situation This is not a limitative list of attention points that can be used doing inspections. This list aims to be a guideline to go for inspections from a critical point of view at risks. These risks can be directly environmental risks, but also risks for not getting enough picture of compliance. Investigation from an integrated and pro-active point of view Technical subjects to investigate This investigation aims at determining the company's ability to fulfill its obligations from a technical perspective. All risks that may appear at the interface of technology used and environment can be listed, e.g. maintenance of certain (vulnerable) installations or the handling of chemical substances. The focus of the technical investigation depends on the signals from the legislation investigation, the information investigation and the company economical investigation. It will show the potential areas of non-compliance. Applications for licenses (permits) constitute important sources of data for the technical investigation. Information sources An inspector who is well-informed about the company will be a credible partner for the company's management and will thus be respected by his counterparts. Therefore a key to successful on-site visits is awareness about the situation, activities and processes, compliance history, and other aspects of the site to be visited. Much information about the site or company is available, be it in the if les of the inspectorate, or publicly. Complaints of citizens, but also of (neighbouring) companies can be important indicators for inspectors in the preparation of their site visits. Citizen complaints sometimes lead to a sort of ―fire brigade approach‖, meaning that every complaint is followed by a reaction of the inspectorate by carrying out a site visit. This approach can, in spite of the (temporarily) positive radiation towards the public, be rather risky for several reasons: - Not all complaints reflect a situation of non-compliance; - Not all situations of non-compliance indicated by a complaint are equally relevant; - Complaints can be ―revenge-driven‖; - Complaints can be ―competition-driven‖; - Complaints often will not concern the real environmental priorities and can draw limited resources away from strategic approaches. Therefore complaints should not be a main driver in carrying out inspections. They should be carefully used for inspection planning and preparation purposes. Collecting evidence o What is evidence o Classes of evidence o What should be documented? o Interviewing o Field notes o Photographs and videos o Samples o Using of accredited laboratories Risk analyze 14 o Directly environmental risks o Not enough view of compliance o Concrete compliance risks Good preparation Have notice of: • Enforcement history of the subject • relevant – law / legislation – permit conditions • activities of the subject • involved companies • expectable – different kind of waste depending of the activities – emissions depending of the activities – different kind of dangerous goods depending of the activities • indication of cost and value of the different goods and waste • use of – energy – surface water – ground water – raw material – secondary materials • expectable crosslink's with different chains: – waste and animal foods – waste and fuels Inspection plan Contents: • reason for inspection (what is to be accomplished) • the scope of the inspection: – identifies the functional areas, assessment topics, and level of inspection • inspection procedures – which field and analytic techniques will be used – collect what information; – what recordkeeping systems will be reviewed – which personnel will be interviewed – which samples will be collected; and for each step – why they should be collected • Defines task assignments within the inspection team • Details resource requirements (costs) • Checkpoints for investigation bases on – weak points – critical points – critical moments in the process • what evidence should be collected and documented • choice of investigation methods • a safety contingency plan, where required • Informs management of the inspectors' activities ensuring clear expectations and an understanding of resource implications! • When appropriate, includes a sampling plan and a safety plan as annexes • Air photograph / (draft) drawing • Necessary equipment (personal safety equipment; photo camera; sample tools ……) Inspection Guidelines: • In case of integral inspection: see the whole site (use a drawing or map) • Look for: – use of use of energy; (kind of) process water ; raw material; secondary materials – storage of waste; dangerous goods – illegal goods as pesticides; coolants; radio activity; waste 15 – removal of waste and used process water – emissions – special waste aspect: radio activity; pesticides; bacterial / viral; toxic; explosive; asbestos – quantity of used materials; waste • Look for verifying this results by: – interviews of others; neighbors; ….. – registrations – other counterparts of the company like customers; • Look for: – non permitted activities Using basic enforcement skills • Communication • Interview • Negotiation • Conflict handling • Verifying – Evidence – Financial training After inspection • regular reporting – location description (specifics) – report data (date, time, reporter, reason of inspection, etc) – inspected aspect (what, depth of inspection on the aspect), including violations (why it's a violation, what was violated, circumstances, etc.) – reporting by inspectors, suitable for court appeal – description and calculation of the financial profits of environmental violation and financial consequences of environmental damage of costs in case of recovery – attention points for the next inspection – etc. • think about: – was everything checkable / controllable – if not maybe something for conditioning in the next permit • registration of gaps between permit and practice for conditioning in the next permit Attachment C Train the trainer How to Design Your Training Basic Steps in Training - Assessing the need - Choosing the best approach - Establishing a time frame - Setting learning objectives - Designing the - training content - Delivering the training - Evaluating training effectiveness As a learning facilitator within your organization, you will need to take a number of practical steps to develop an effective training program. 16 Training within a learning organization emphasizes the importance of a systematic approach to expanding people's work related abilities to achieve both organizational and personal goals. A key concept to keep in mind when fitting training programs into the organization fabric is that training is about people in the organization. A well-designed training program will ensure that: - Employees understand the organization's mission and goals and their contribution to that mission through their individual jobs - Employees are equipped to do their jobs, particularly when their jobs change or demand new knowledge and skills - Employees have opportunities to develop their skills and increase their level of contribution to the organization - The organization, as a whole, is functioning effectively - Evaluating training effectiveness There are seven basic steps in developing any training program Step One: Assessing the Need A need is a perceived gap or an opportunity to be met. Defining a training need means doing research on what is happening now that prompted a request for assistance from a member of your organization. It also means taking a proactive approach to identifying gaps in skills or resources that may be necessary to achieve organizational, departmental, and individual employee goals. The best way to define a training need is to ask questions. As an example, the following questions might help you respond to the ―we should do something about supervisory training‖ need: - Have supervisors expressed a need for some assistance in doing their jobs? What do they think they need? - What kind of training has been provided for supervisors? How recently? - Are supervisors experiencing difficulty in getting their jobs done? What kinds of problems? - Have there been specific indications of reduced productivity or performance problems, such as an increase number of grievances that might point to the need for a refresher session? - Have supervisors been asked to take on new responsibilities or oversee new functions recently? - What specific skills does supervisors need that would help them do their jobs better? Will they be asked to do so in the near future? - Is the organization planning to promote some employees to supervisory positions in the near future? Does it want to focus on providing skills for new supervisors to prepare them for their promotions? - How many current supervisors would benefit from some assistance in doing their jobs? How long have they been supervisors? Step Two: Choosing the Best Approach You will next want to select a training approach on the basis of audience, time frame, and available resources. If the need is broad, likely to recur, and involves a large number of employees within the organization, the response should be comprehensive. It may require introducing elearning programs into the organization or developing the internal capacity to respond to the need on a regular basis in a blended learning setting. In contrast, if the need is focused, experienced by an individual employee or a few employees, or is a one-time occurrence, the response will be more limited. It might involve sending a few employees out to a specific program or distributing information materials that can be used to educate and inform the affected employees. It could mean one-on-one coaching with an individual employee in which you, or someone you supervise, would work with the employee to develop specific skills that have been identified. It is important to ask yourself whether information or skill development is needed. Information needs can be better met through written communication or a short briefing session than through a longer group training session. Step Three: Establishing a Time Frame If you have decided that a group training session is the appropriate learning strategy, you will want to establish a time frame. Effective trainers plan sessions that will accomplish specific objectives rather than fill a designated time period. Unfortunately, time frames for training sessions are often set before the need is defined or the objectives established. You know you will have two hours, a half day, a full 17 day, or even several days to cover the specific topic or issue. Whenever possible, you should establish and adjust the time frame to meet the specific objectives. Regardless of the topic and the format of your training, keep some general guidelines in mind when you consider time frames for group training sessions: - For busy local government professionals, a series of shorter sessions scheduled over several weeks can prove very effective. For example, rather than conduct a 40-hour supervisory training session during one week, you can schedule one day a week for five weeks or even half days once a week for 10 weeks. This approach minimizes disruption to daily work schedules and provides opportunities to practice newly learned skills between sessions. - If you are a practical, once-in-a-while trainer, don't bite off more than you can chew. For example, three days is a very long time if for classroom training it is always better to run out of time than to send everyone home early. Remember, your job as the learning facilitator is to stimulate others to continue their own learning. If you run out of time but have done a good job introducing new ideas, participants will be ready, willing, and able to pick up where you left off. You don't have much experience leading groups and managing group process. You can accomplish a lot in one day of well planned activities. - If you're limited to only a few hours, use the time well to cover the specific issue(s). A couple of hours can fly by if you have a popular topic and a talkative group. You will need to incorporate some control devices to make sure you cover everything and allow time for group participation (see the sections on preparing an agenda and training dynamics). - Online training is not so time-sensitive. Usually learners can access the training program at times that best fit their individual schedules. However, you will still need to decide on the appropriate duration of the workshop or course, just as you would for a classroom training. Step Four: Setting Learning Objectives Objectives define the expected outcomes of your training and are based on the needs that prompted the training session in the first place. It is important to ask yourself what the group is likely to be able to accomplish given the topic, the group's interests and needs, and your best judgement of what can get done successfully within your established time frame. One way to develop learning objectives that will directly reflect participant needs and interests is to interview each member of the group before you begin your training design. You can begin to shape objectives by asking such basic questions as: - Why are we having the session? - What do you (the learner) want to know when you leave the session? - How do you (the learner) want to feel when the session is over? Practical learning objectives are ones that can be accomplished. You will most likely meet your objectives by the end of the training session by limiting the number of practical and specific objectives to four or five that are specifically defined. For example, your objectives might look something like this: - Identify the four main stages of team development - List five main barriers to team cohesiveness - Cite three benefits of teamwork - Develop an action plan for improving team communication A sample questionnaire for precession data collection is included in Appendix B. Step Five: Designing the Training Content The program design flows from the defined need, time frame, and established objectives. Program design covers everything that you will do during a training session. It is your plan for presenters, content, agenda, handouts, interactive group activities, and room arrangements. Deciding whom to use. Once you have settled on your topic and objectives, you will need to address the issue of who will conduct the training session. Will you rely on yourself, outside presenters or trainers, internal resources, or some combination? The learning objectives will help you answer this question. If your program is designed to present technical material to increase knowledge, you will want to rely on people who know the topic. For example, if you're organizing a one-day classroom or computer based training session on how to prepare annual budgets, you will need to involve top staff from your budget office. In this case, your role 18 would be to work with the in-house expert to develop a program design that defines what will be covered, what resources will be needed, and how much time will be allotted for each component. For classroom training, most topics lend themselves to facilitation rather than straight presentation. For example, if you are responsible for organizing a group retreat designed to improve the group's ability to work as a team, you will need a facilitator rather than a presenter. The role of a facilitator is to help the group identify issues, share information, and solve problems or reach conclusions. A presenter focuses on bringing helpful information to the group, but a facilitator focuses on processing information and ideas within the group. The facilitator can be from inside the organization, provided that individual is not a critical member of the team and that the facilitator and the group are comfortable with each other. For an e-learning program your role is generally that of presenter and facilitator. The learners form a virtual learning community and discuss the topics you present. You then help facilitate the discussion. (See Appendix C for an example of an e-learning classroom.) Employees of the organization can be valuable because they are familiar with the organization's culture, norms, and values. However, sometimes familiarity can be an obstacle if the group feels stuck and is looking for a new perspective. In that case, it may be useful to look to nearby universities, community colleges, or a state municipal league to find a facilitator. Deciding what to use. If you are responsible for planning and conducting a session from beginning to end, you have two options. You can design it yourself or you can use a packaged program as the basis for your design. Packaged programs. Packaged training programs are off-the shelf programs designed by organizations that specialize in training curricula. A well-designed classroom training program provides basic content in the form of reading materials or a handbook and training activities. In fact, it provides most of your program plan for Characteristics of Presenters and Facilitators Presenter Facilitator - Brings new information to the group - Draws information from the group - Focuses on facts - Focuses on processes - Decides what information is important based on knowledge and expertise in the identified area - Helps the group figure out what it needs to know based on an understanding of group process and of the needs of the particular group - Moves the group in a specific direction based on information and material that needs to be covered - Guides the group toward appropriate conclusions based on issues that are raised by the group - Provides handouts and back up material to supplement the presentation - Summarizes information and ideas developed by the group during open discussions - Generally talks more than members of the group - Generally lets the group do most of the talking - Answers questions - Raises questions - Has knowledge and experience in the specific topic that is being covered - Has knowledge and experience in organization development, group dynamics, and group process The training session. Learning management systems provide software for e-learning. These systems can be ready-made programs, or you can design the content yourself and the software will put your content into an appropriate computer-based format. Prepared packages, whether for classroom training or e-learning, can be enormously helpful when you don't have the time or experience to design a program from scratch. Most well designed training packages contain handouts and exercises that can add variety and depth to a program. In addition to complete packages, many other resources provide exercises on specific topics. These include assessments, instruments, games, or structured experiences that you can use in your own program. In fact, most experienced trainers rely on standard resources to find activities and exercises that will help them accomplish their objectives. To maximize the benefits of a packaged program, you should follow these guidelines: - Read the entire package very carefully. If you intend to use the program for your session, you will need to be familiar with it and be able to answer questions. You need to make it feel like your program. 19 - Think about ways to adapt the program to meet your objectives and respond to your group's interests. That might mean incorporating examples or case studies from your organization to replace or supplement examples that are included in the package. If there are segments of the program that don't apply to your audience or don't seem relevant, drop them. The overall impact of a well-designed packaged program can be diminished if inappropriate or irrelevant segments are left in. - If you don't understand parts of the program or are having trouble figuring out how to carry out certain activities, contact the organization that developed it. Most organizations will be anxious to help you make it work. Some even provide training for a packaged program cannot define your organization's need or the specific objectives that you are trying to achieve. Once you have defined the need and established the objectives, you can assess which program is best equipped to meet your needs. People who will be conducting their programs on a regular basis. Original content. The decision about whether to use internal or external resources and materials is important. While there is a tendency to believe that external is better, more and more local governments are recognizing that they have expertise available inside their organizations. Your job will be to tap those resources—or become a subject matter expert yourself! Using the Internet as a research tool can help you become an instant expert on just about any topic. Setting the agenda. Even if you are using packaged training, you will now want to develop two types of agendas that will help you closely guide the session from beginning to end: - A working agenda is for your own personal use and defines what will happen during each time block including what material will be covered, who will cover it, and what handouts or materials will be used. Your working agenda should outline what you intend to do at each point during your session. It provides the structure you'll need to move smoothly from one section or module to the next and to adjust as necessary. Perhaps more important, preparing an agenda will increase your comfort level in carrying out the training session. The less experienced you are as a group leader, the more meticulously you should prepare. Remember to design your session with your learners in mind. The group may want to spend more time on one aspect of your agenda and less on others. You'll need to be flexible so that you can adapt to the needs of the group. Although more and more information is being added to the Internet, the network still does not contain everything. Most of the world's knowledge remains in print, so don't forget your local library and, of course, the expertise of the librarian. Also, many research queries can be answered by directly contacting experts in the topic you are researching. Internet Search Tips Searching the Internet can be a quick and effective way to develop your training-session content. The Internet will provide you with the most up-to-date resources and information on an infinite number of topics. Here are some tips to follow as you're beginning your research: - Use the various information finding tools on the internet. Key ―finder tools‖ includes directories like Yahoo! that are selective listings of hand-selected sites and search engines like Google (www.google.com) or FAST (www.alltheweb.com). Search engines automatically scour the more than one billion pages on the Internet to locate information sources on the topic you are searching. - Brush up on the art and skill of creating a good search statement to improve your search results. This involves understanding which keywords and phrases are going to be most fruitful in returning relevant results, figuring out synonyms for your search words, understanding possible jargon, and learning how to experiment with different words and phrases until you have a set that works best. - Avoid information overload when you get back too many results from your search; make sure your keywords are as specific as possible. - Be particularly careful in evaluating the credibility and quality of the information you find, especially since anyone can be a publisher on the Internet, and there are no filters or screening processes. One excellent site on the Web that provides checklists and strategies for evaluating Web sites is Evaluating Quality on the Net at www.hopetillman.com/findqual.html. - Consider joining an e-mail-based discussion group on the topic you are researching in order to participate in an online conversation as well as pose your own specific questions to the larger group. One of the real strengths of the Internet is its ability to link you to other knowledgeable 20 people and experts around the globe. You can find out about names of these groups and find out how to subscribe by checking Kovacs Consulting at www.kovacs.com/directory/scope.htm. - A session agenda is for distribution and tells participants what will happen during the training program. It should parallel your working agenda but skip the details. For example, avoid including time blocks in the participants' agenda. Time limits can caules concern among some of your participants if you are not strictly adhering to the time frame—some people are less flexible than others! Preparing learning materials. Keeping in mind that people have individual learning preferences, prepare a variety of materials that appeal to different learning styles. As previously mentioned, materials may be purchased or developed in-house: - Handouts. These are materials that provide the substance of your session, usually in outline format. For classroom training it is helpful to include all handouts in a participant's packet so that you don't need to distribute them at different times. This approach may help you stay better organized during the session and also aids your participants in following the sequence of your session activities. - Backup materials. The materials that supplement your presentation. Articles, books, and lists of resources can be distributed or displayed for participants to view during breaks. Backup materials can add extra depth to your session. For e-learning, your additional materials can be displayed online, and you can refer to additional off-line resources such as books and archival information. Step Six: Delivering the Training The next step in your training process involves choosing the appropriate methods to get the information across, engaging the group in the learning process, and accomplishing your defined objectives. Interactive methods vary according to their purpose and the extent of learner involvement. Choosing the appropriate method depends on what you're trying to accomplish and what you're most comfortable with. If your program involves introduction of new Computer graphics can greatly enhance the appearance and readability of your handouts. If you are unfamiliar with the technical aspects of computer graphics you may want to solicit help from your IT department or a knowledgeable colleague. In addition, you may want to consider taking a computer graphics course. Material and information that participants will use on their jobs, you will probably rely on lectures and guided discussions. In contrast, if you are facilitating a team-building session, you may rely more on small groups and role plays as well as guided discussions. In most e-learning situations, lecture and guided discussion are the main teaching/training methods. You can also arrange for small-group discussion. Session logistics. Logistics for classroom training involve the physical details of preparing for the training session. This includes how you will organize the room and how you will organize yourself to ensure a successful group training session. A training room must be organized to establish an effective climate for learning. That means making sure it is comfortable, well equipped, and set up to do what you want to do. Room arrangements have a significant impact on the learning climate. If people are physically uncomfortable, they will have difficulty focusing, participating, and learning. It's your job to do everything you can to minimize distractions. The most typical room arrangements for group training sessions are: - Theater/classroom style. Theater style uses rows of seats facing a front table or podium. Classroom style uses tables and chairs, again facing the front of the room. This style is typically used for sessions with minimum interaction or group participation. It is usually not the best arrangement for an interactive group learning session. - Cabaret-style rounds. Eight to ten people sitting at round tables is an effective arrangement when you have a large group and are planning small-group activities because it provides ready-made groups. When you have 35 or more people and are trying to plan an active group session, this is usually your best option. One potential problem is that people may get locked Comfort and familiarity with the methods are equally important. As you conduct more training sessions, you'll find approaches that work well for you. When you choose techniques, remember that variety is nice, but results are important. Keep in mind what you're trying to accomplish, and choose approaches that will help you get there. Into one group and miss talking with others. Therefore, if you're planning several group activities, you should ask people to rotate among tables. 21 - Conference style. This arrangement can be set up in three ways depending on the size of the group. A small group of 10 to 15 can work around one large conference table. For groups between 20 and 40, you can create a large open square by joining smaller conference tables into a large square. Participants sit around the four sides of the square. If the group is larger than 40, you might create a U-shape with the conference tables—a long rectangle with the top left open. This gives you the option of seating participants inside the U. In addition, you can move down into the U during the session to get closer to the people on the far end. In all three arrangements, the head of the table is the side from which you choose to work. Conference style works well for most group programs, particularly if you have small adjoining breakout rooms for work sessions. - Living-room style. If the group is small and you're planning a team-building type of session, an informal setup with easy chairs is ideal. This setting creates the relaxed atmosphere that is Interactive Methods Purposes - Group method Warm-up and interaction - Brainstorming Information collection - Lecture Information presentation - Lecture/discussion Information presentation and processing - Guided discussion Information sharing - Small-group exercises Information sharing, problem solving, consensus building - Case study Problem solving, decision making - In-basket exercise Information processing, decision making, role identification - Role play Role identification, deal with feelings and role dynamics needed for an intensive group process. City or county libraries may be good locations for this type of room arrangement. One last thought on preparation for your training session. No matter how experienced you are as a group leader or how familiar the material is to you, every session requires careful preparation and practice. Effective training means being on your toes from start to finish. If you plan well, chances are the session will go smoothly and you'll accomplish your objectives. You'll also be better able to adjust your plan when the session flows differently from what you expected. Step Seven: Evaluating Training Effectiveness Evaluation tells you whether the training program contributed to any change in behavior, performance, or productivity. Therefore, it is important to define expected outcomes at the design stage to make sure that the selected approach can produce those outcomes. This step involves deciding how and when to assess whether the expected outcomes have been achieved. Consider this example. You have decided to provide a comprehensive communication-skills training program to employees who deal with the public; this course has been set up to respond to complaints about customer service as well as frustration among employees who deal with the public. The immediate purpose of the program is to help employees deal more effectively with the public, in general, and to handle angry or dissatisfied citizens when problems occur. An expected benefit of the program is an improved public image. Your evaluation plan should focus on identifying Passive learning Active learning - Written information - In-basket exercise - Lecture - Case study - Lecture/discussion - Small-group exercises - Guided discussion - Role play When you're working with room arrangements, don't forget that tables and chairs move. You may start with one arrangement and decide to evolve into something else. Or you might have several arrangements within the same room-a conference table in the front and a circle of chairs in the back. 22 Attachment D Financial verifying The following financial issues are relevant: - Basic organization knowledge - Basic administration en accounting - Basic control knowledge Basic organization knowledge Financial company types - Factory of Production Company, waste treatment, service company etc. - Administrative organization & internal control - meaning: management company, structure, financial inspector - examples administrative organization measures: administration set-up, structure, procedures, tasks separation For a good and reliability administration and justify or accounting, the management of the company has to take administrative organization (AO) measures, like a good, complete and well structured administration set-up in stat of a shoebox with some of the notes and invoices. Also the company needs good described procedures about how is registration what, where, when and how, using what system and so on. Depending on how small or big is the company you have to split up some tasks to prevent that one person controls every thing: buying, justifying, registration, responsible for pay. In that case that person could be easily fake sales by registration en put the money on his own bank account. So the management needs tot be in control and take internal control measures to prevent mismanagement. Internal control - aimed on accuracy, completeness of the registrations, compliance of the procedures, control on de company activities - Functions: registration (record en treatment by the administrator); accomplishment (protection employees, operators), control in behalf of the management (management, control department, accountancy) Record en treatment by the administrator The task of the administrator is writing down in a proper way conforming the procedures on paper or financial database (record) and depending on the bookkeeping system, the administrator has to take some actions, particular in a paper bookkeeping system. This treatment starts with a copy in the ledger from registrations in the day-book. Control in behalf of the management The company management needs to bee in control at any time and needs actual and adequate information about how the company is doing: for instance: do we have enough goods or materials in stock, do we have the money to buy necessary materials, do we pay the creditors in time, do the debtors pay us in time, how are we financial doing at this time or are we bankrupt. The director can delegate this control task to an employee or department of the company, depending on how big and complex is the company. They are in control in behalf of the management How to judge the working of internal control: - Take notice of organization structure, administrative organization, accounting manual, tasks and function profiles, procedures and instructions, responsibilities How to judge the working of internal control For financial verifying it could be necessary to have a picture of the reliability of the numbers and registration. To have that picture you should be able to take notice of organization structure, administrative organization, accounting manual, tasks and function profiles, procedures and instructions, responsibilities. When that's working properly you can say the internal control works OK and I trust the numbers and registrations. 23 Basic administration en accounting Relation between financial registration, goods registration (also material and waste), process registration Administrations parts: - Logistic, Process, Acquisition, Sale, Salary, Goods, Waste, Production / waste treatment, Financial Reason of registrations - Collecting documents and files, Recording, Treatment, provide Company administrations Material administration - stock (present quantity, mutations, mass balance - Financial administration - Important (annual account, (periodical) reports, balance-sheet, ledger, stock, debtors, creditors, day- book Process administration Relations between administrations - Stock increase - retail – debtor- or creditor - Processing / treatment – material stock decrease – good stock increase - Etc. Subject relevance Annual account Views the financial position of the company (capital, results and finance). Periodical reports Impresses the organization in a period. More periods' gives a trend and a view of details and aberrations. Ledger Views the mutations during a period about properties and obligations of the organization. Stock administration Views the stock quantities and mutations in the stocking debtor- and creditor Views witch costumers and suppliers the organization had in a period. administration Book-keeping cycle Depending on the Romanian book-keeping system, should the environmental inspector have a good picture of the book-keeping system and how the book-keeping cycle from the daily registries till the year reports (balance-sheet and profits- and losses overview). Basic control knowledge Control techniques Remarks Number judgment Analyze and interpretation of number sequences. The results can be used as indicator. Context control Analyze of hard context of quantities within bookkeeping and registrations. Deviation induces further investigation. For instance: start stock quantity + purchase – sale = end stock quantity Norm verifying Test by the basic norm. The norm can be described in internal or external documents. The internal or technical norm could be for instance: the waste incinerator should be burned 95% of the waste and reduces the volume to 10%. You can check how the company is doing by investigation on that yields or output. Example of norms are: (national or international) standards; Primary calculations; Budgets. Also: environmental legislation and permits. Control of existence Establish existing and completeness (qua registration and account) of possession and debts of a company. For instance: stock-taking; physical observation of technical measurements; Balance confirmation by bancs or debtor. 24 Random-sample within a period from some transactions to establish that Line checks is handled conform the procedures and to establish that is handled conform AO and IC measures. Detail control Investigate some records or transactions (administrative records and documents like invoices). Check on start and ending Follow start or ending of a record or registration. For instance: From a demand on a debtor the sale-order and the expedition-papers can be investigated. An ended possession or dept named in the justify report can be checked on real exist or real ending event. A claim of a debtor ends with receiving money. A creditor dept ends by pay. The company buys a car from a dealer today and pays, and then the car dealer is a creditor in that period. By paying ends the creditor. Stock ends by treatment or sale. Documentation from a A ‗fact' or event found in the registration can be checked by confirming by third party a third party. Examples: conforming the credit-balance by the bank or bookkeeper; information from the chamber of commerce; solvability conformation from Dun & Bradstreet; Observation on site The inspector has his own direct observation on site of the company of the technical installation, measurements and the processes. Examples: Inspection observation on site or on scene; Be present at stock-taking; Be present at an audit. This gives a picture of compliance of legislation, permits and procedures, but also the company culture. How to use financial instrument Examples of verifying: 1. Investigation of the debtors list of a wholesaler, so you can see the sale of goods to a company who should not have the goods (fireworks, dangerous goods, pesticides). 2. For legal treatment of waste you should see a legal waste company as a creditor in the creditor list of the deliverer and in the debtors list of the receiver. 3. To check the waste was created in the companies own process (legal?) or outside the company (illegal received), there can be a debtor and an invoice of the waste recorded. 4. To check waste is not burned or dumped there should be a creditor and an invoice from the receiver of the waste recorded. 5. The registration of stocked (goods registration) and incoming goods (debtor or creditor) related to the receipt give a picture of the treatment, process and the quality of the product. Examples of calculating depriving the financial profits: 1. The company received twice the permitted capacity of waste. In the ledger and debtors list there should be numbers and values or costs of the waste. The half of the profits should be deprived. 2. The company carried out an illegal activity. In the ledger and debtors list there should be numbers and values or costs of this activity. Also the costumer has information in his creditor-list and invoices about the hired services. The profits by doing that activity should be deprived. 3. Since 5 years there should be a measurement by the permit, witch is not there. The profit of the company is the write off per year over that period and should be deprived. Examples of calculating costs of recovery 1. A spill with gasoline caused soil pollution. The costs of the soil pollution treatment should be next to the violation part of the fine or recouped by the government. Specialized soil treatment companies can give a calculation. 2. A battery waste dump brings recovery costs like sampling, treatment of the dumped batteries and soil treatment. After recovery by the government this costs should be recouped at the violator. 25 3. Generally the costs of recovery are the costs to act in situations the violator did not, or to react by treatment to recover the illegal activity or the consequences. Attachment E Project proposal study visits Description A small group of inspectors and juridical experts follows lectures and visit some organizations and sites in a western European country. This provides them a picture of technical and juridical problems, solutions or used techniques and the way of working of the inspector of the receiving organization. Interesting sites are refineries, waste treatment plants, waste incinerator plants, Court, IPPC companies like a steel company. The NEG investigates a possible foundation for the study visits. There should be own recourses for the trip and the stay in the foreign country. The receiving organization will take care of the necessary personal safety equipment, the summary and the accompany of the visitors. Targets NEG-staff gets information and ideas during the study tour about technical solutions in practice and about the pro-active approach. Activity description The trainees get a summary of the permits, and activities a week before their visit. The visitors shall visit the sites in groups of two to four persons accompanied by an experienced inspector or juridical expert. The mission of the accompanies is to show the actual situation on site and a clear explanation of the permit and treatment solutions and used techniques. An important point is also the required registrations and reports and the way of verifying. Preparation/Training material The trainees will receive a description of the way of working of the foreign inspectors, a short resume of the actual environmental legislation and a short resume of the licences of the site which will be visited during the study tour. They have to study it before arrival in the receiving country. Technical visit This part of the study tour is developed for the technical experts of the delegation. The aim of this visit is to show the delegates how licences are established, the proactive approach, how specific problems are solved and the incident approach. The delegates will get explanation of the approach, join some site inspections and will bring a visit to the Court (if possible). Juridical visit This part is special developed for the juridical experts of the delegation and specific for a Dutch study visit. The Dutch environmental legislation knows two different approaches. The penal side and the administrative side. Every side had its own target. The penal side aims on punishing of the offender. The administrative side aims on repairing the environmental damage. Each approach has its own procedure and court. The legal practice knows also several possibilities, views and solutions. The target of the study visit for juridical experts is aimed on a picture of the structure of the Dutch environmental legislation, the possibilities and the impossibilities, the juridical solutions and the juridical procedure. If possible, a visit to the Council of State and the court will be a part of the programme. Evaluation At the end of the visit the delegates will be asked to discuss their impressions of the visit and to write down subjects which can be improved or changed in Romania. 26 Attachment F Project proposal Training on the job Targets The targets of this training on the job program are to instruct staff of the National Environmental guard (NEG) in: - Executing complex inspections in a systematic way; - To investigate complex incidents from an integrated and pro-active point of view; - To complete investigations as far as enforcement procedures allows. Activity description The training on job will be executed with coaching of NEG staff by foreign EU experts in team co- operation in projects dealing with practical examples of complex problems. The NEG will select some case examples of complex problems with companies. Every problem will have to be addressed by a team of NEG inspectors. The different cases will have to be different in nature, target and topic. For example: an industrial site or a company can be selected were the transparency in management and information flow is rather poor. Increasing the transparency as such will than be the basis of the development of a project, in which priorities of solving environmental problems will be discussed with the company. An other example is addressing illegal activities or an incident. Every inspection team consists of 4 persons, of whom one person will be appointed as a team leader. Training on the job: First day Foreign EU expert and team leader start with a site-visit to get a realistic picture of the problem. Foreign EU expert and team leader define the objective of the project, the working method, the time planning and the draft project plan, including an implementation plan. This probably takes one full day (two parts of a day). Training on the job: The First month After a month the foreign EU expert will return to discuss the project plan and the implementation plan and finalize it. It is very important that the suggested subject(s), approach and capacity are granted by the executives. After finalizing these plans they will discuss the practical execution and the task partitioning within the project team. Half a day is planned for reading and finalization of the project plan, the task division (including mandate setting), and the (approved) actions that are taking place. All planned activities are bound to take place within this first month. Training on the job: The second month Half a day is planned for discussion within the project team on the results of the activities, the shortcomings that come from the inspections and the format of the final report. The project team needs max. 1 month to correct the shortcomings and the negative impact on the environment. After the correction phase, the corrections to the shortcomings are prioritized. The priorities are described in a report and the advices to continue are described. The last half a day will be used to evaluate the actions and to finish the final report. The results of the project will be presented to NEG management. Training on the job: The skills The subjects in this training are the named skills to improve, with special attention on: - Technical subjects to investigate - Information sources and exchange - Inspection plan - Collecting evidence - Risk assessment (environmental risks, Not enough view on compliance, compliance risks) (see attachment B) 27 - Advance a pro active approach - Systematic approach (in detail in attachment B) - Financial verifying (see attachment C) Training on the job: The themes The experts in the training on the job-activities will focus on the following themes: - Objectives and planning - Time planning and tasks division - Assessment and verification of the results - Project management and project leader coaching - Economical and financial aspects - Final report, presentation preparation and presentation Time planning of training of the job activity for foreign EU experts # Participants 60 – 80 # Projects 20 # International experts 5 (4 projects per expert) # Travel time experts 20 days # Work time (prep., supervision, reporting) 20 days (4 per expert) Total contact days 50 days (2,5 days per project per expert) Total # of days final assessment 10 (5 times 2 day parts (incl. traveling)) Assistance, Translation and Interpretation 100 days The International experts will have to contribute for about 100 days for thorough project supervision and coaching. Every participant to the projects from NEG side should reserve at least 20 days per inspection project. General support for coordination, translation and interpretation about 100 days has to be scheduled. A final assessment and presentation of the results will be delivered by the inspectors to the NEG management at the end of the project. At this presentation event, there is ample opportunity to exchange experiences between the different inspection projects. Supervising experts will be invited to this event. The organization of this event will be prepared by NEG staff. All inspection projects can be executed a maximum of one time. This project could be finished in maximum 10 months including presentations, exchange of experiences and final reporting. Starting points For this project, it should be noted that: - Every county can contribute a maximum of 2 persons as input in one of the inspection projects - One project will be supervised and executed per 2 counties - A 'train-the-trainer course' and a course 'working in projects' are obligatory to be allowed to participate in an inspection project - Every participant should be an experienced inspector - Chosen topics or cases should be complex and include sufficient tasks and work for 4 persons - Every topic or case will be described on paper (in English) before the start of it as an inspection project - Communication and reporting between supervisor and project team will take place in English; assistance in communication will be provided 28 Attachment G Example of workshop presentation 29 30
Pages to are hidden for
"Draf Report"Please download to view full document


text:
Hotel Melton Mowbray
(24) for Hotel in Melton Mowbray
Harboro HotelBurton StreetLE13 1AF Melton Mowbray01664 560121
... have T.V., tea and coffee making facilities and direct dial telephones. The genial atmosphere at the Harboro Hotel makes it easy to relax with the emphasis being on friendly but efficient service.
Quorn Lodge Hotel46 Asfordby RoadLE13 0HR Melton Mowbray Frisby On The Wreake01664 566660
Hotel has a fully licensed bar and comfortable lounge where guests can relax and enjoy themselves day and night. Special parties such as weddings and other private functions catered for. Full...
Request for Quotation
Are you looking for Hotels & Accommodations ?Use our "Request for Quotation" service to get customized offers from companies in Melton Mowbray, tailored for your exact needs!
Melton Mowbray Hotel5 Norman WayLE13 1JE Melton Mowbray0871 527 9584
... market town's foodie history or exploring Belvoir Castle and the pretty Vale of Belvoir, make your way back to your Melton Mowbray hotel and dig in to a hearty meal at our on-site restaurant.
Sysonby Knoll HotelAsfordby RoadLE13 0HP Melton Mowbray Frisby On The Wreake01664 563563
hotel and restaurant in Melton Mowbray A luxury Hotel and restaurant in Melton Mowbray offering fantastic accommodation for weekend breaks, honeymoons and celebrations as well as providing a superb...
Oasis Dental Care Ltd16 Asfordby RoadLE13 0HR Melton Mowbray Frisby On The Wreake01664 564234Closed
Normandy Holiday Homes to rent House and Cottage close to Dinard Aitport, Le Mont St Michel and St Malo Brilliant self catering accomodation
George Hotel8 High StreetLE13 0TR Melton Mowbray01664 562112
... Century Coaching House, sympathetically restored and retaining its original features, the George Hotel is set in the heart of the market town of Melton Mowbray – famous for stilton and pork pies!
Kirmel Guest House23 Mill StreetLE13 1AY Melton Mowbray01664 564374
... accommodation, guest house
Beck Mill44 King's RoadLE13 1QF Melton Mowbray Long Clawson01664 852881
... guest house, accommodation
Beckmill Guest House44 Kings RoadLE13 1QF Melton Mowbray Long Clawson01664 852881
4 Star Bed And Breakfast located in Melton Mowbray, Leicestershire. Recently awarded the Visit Britain silver award for exceptional servce and hospitality as well as the Visit Britain award for...
Silverdale HostelScalford RoadLE13 1JZ Melton Mowbray Eastwell01664 569658
... accommodation, hostel
Harboro Hotel (East Midlands) Ltd28 Burton StreetLE13 1AF Melton Mowbray
... hotels
M.j.s. Hotels LimitedQuorn Lodge Hotel, 46 Asfordby RoadLE13 0HR Melton Mowbray
... hotels
Seven Star Events Limited17 Thorpe RoadLE13 1SE Melton Mowbray
... hotels
Middle Aston House LimitedPera Innovation Park, Nottingham RoadLE13 0PB Melton Mowbray
... hotels
Middle Aston House Trading LimitedPera Innovation Park, Nottingham RoadLE13 0PB Melton Mowbray
... hotels
Hidden England Ltd28 Burton StreetLE13 1AF Melton Mowbray
... Holiday Accommodation
Simply Morzine Ltd118 Redwood AvenueLE13 1UT Melton Mowbray01664 568902
Winter & summer alpine holidays Skiing, adventure, family activity, walking, painting & golf Luxury catered chalets, self catered apartments & family hotel Morzine, French Alps.
Gch Properties Limited5 Saddle CloseLE13 0SX Melton Mowbray
... Holiday Accommodation
Eye Kettleby Lakes Limited26 Park RoadLE13 1TT Melton Mowbray
... Accommodation Services
Regency Properties (Gb) Limited98 Asfordby RoadLE13 0HS Melton Mowbray
... Accommodation Services
Chapman Capacitors Limited4 Sherrard StreetLE13 1XJ Melton Mowbray
... Accommodation Services
De Bradelei Mill Shop Ltd33 Kings RoadLE13 1QF Melton Mowbray01664 852 881
... Guest House
Sysonby Knoll Hotel Limited24-26 Park RoadLE13 1TT Melton Mowbray
... Dormant companies
Micro-al Radiosystems27 Gartee DriveLE13 0AE Melton Mowbray Whitfield House01664 480347
Long range wireless panic alarms and paging systems. Design of specialist multizone wireless systems.
Search filters
Companies with:
- Website (9)
- E-mail (8)
- Opening Times (1)
- Reviews (1)
- Menu (3)

subset: commoncrawl


text:
I am a Sr. Engineering Director at a San Francisco software company.
I grew up in Chicago but fell in love with California.
I own my own home and respect those of others.
I'd rather be staying in a sunny lived-in home in an interesting part of town than a hotel.
I like traveling and getting out of the city to cycle.
I can't cook but I can fix a car.


text:
Virginia Hurricane Floyd (DR-1293)
Updates and Articles, Blogs, and News Releases
October 8, 1999
News Release
HAMPTON, Va. -- The Federal Emergency Management Agency (FEMA) and the Virginia Department of Emergency Services are taking their joint state and federal mobile Disaster Recovery Center (DRC) to Stony Creek (Sussex County) and Windsor (Isle of Wight) during the week of October 11, 1999, according to state and federal disaster assistance officials. The mobile DRC, which visited the Saxis and Onancock Volunteer Fire Departments (Accomack County) from October 4-9, will reopen for business at the following locations on the dates listed below:
October 5, 1999
News Release
HAMPTON, Va. -- Disaster victims of Hurricane Floyd in the City of Franklin and Southampton area are in immediate need of volunteers for manual labor. Volunteers are also needed for administrative duties like staffing phone lines and registering volunteers.
October 1, 1999
News Release
HAMPTON, Va. -- The Federal Emergency Management Agency (FEMA) has authorized $500,000 to begin the process of mosquito control in areas of Southeastern Virginia flooded by Hurricane Floyd. Local and state health officials are developing plans to begin spraying to control mosquitoes in severely affected areas, according to the Virginia Department of Health.
September 30, 1999
News Release
HAMPTON, Va. -- A mobile Disaster Recovery Center (DRC) will be in Accomack County beginning Monday to reach victims of Hurricane Floyd according to Virginia Department of Emergency Services and Federal Emergency Management Agency (FEMA) officials. The mobile DRC is being used to reach disaster victims who have registered for assistance by calling FEMA toll-free 1-800-462-9029, but need additional assistance or have questions about their application.
September 29, 1999
News Release
HAMPTON, Va. -- Five more Virginia jurisdictions have been designated eligible to receive federal disaster assistance. Two previously designated jurisdictions are now eligible for an additional federal disaster program. The localities sustained damage when Hurricane Floyd swept through the Commonwealth.
September 24, 1999
News Release
HAMPTON, Va. -- A donation center has been established to assist Virginia residents affected by extensive flooding from Hurricane Floyd. The Donations Coordination Center will make sure that the gifts from citizens are directed to where the need is greatest. "Thousands of Virginians have suffered tremendous losses from the flooding," Governor Jim Gilmore said. "We appreciate the generosity of all those who are contributing to the relief effort. Volunteer efforts, support and donations are vital in helping people recover from Hurricane Floyd and returning their lives to normal."
Incident period: September 13, 1999 to September 26, 1999
Major Disaster Declaration declared on September 18, 1999
Main Content
» Virginia Department of Emergency Management
» Virginia Department of Emergency Management
» Virginia Hurricane Floyd Photographs
|Mayor Preson Williams, Montezuma, GA, front right, and Mayor Jim Council, Franklin, VA, front left, and businessowners pose for a picture during a visit. Franklin has suffered from devastating floods following Hurricane Floyd. Franklin officials visited Montezuma, which had suffered similar flooding in 1994. Franklin officials wanted to see recovery progress and get guidance from the Montezuma officials, who warned that recovery from Floyd could take between three and five years.
State/Tribal Government:


text:
What our customers are saying
Hotel guestRating:
Had a very nice stay with very helpful members of staff within a convenient location but was charged extra on the last day due to late checkout following a slight misunderstanding but overall a good stay
Hotel guestRating:
mihai liviuRating:
Excellent staff,extremely helpful and friendly.Very fine meals served at La Cupula Restaurant. I would come back happily any time.
Anna BratshteynRating:
Thank you for making our vacation to be memorable one. The staff was very helpful and deserve a great deal of praise for their excellent customer service and rooms are cozy, clean and fresh. We are sure that when we return to your city, we will go back to your hotel. Regards, Anna
Stephen CostelloRating:
Nice rooms and service, though it would be helpful if it stated at time of booking there was no breakfast provided.
young waterhosueRating:
It was excellent stay at Hotel Hispanos 7 Suiza. Everyone in the hotel was kind, friendly and helpful. We stay for three weeks and didn't have any issue at all. I can't recommend enough to anyone who wants to visit Barcelona.
Hotel response
Dear Mr. Waterhouse, Thanks for your long stay and thank you so much for your great review, It's a pleasure to know you have been feeling good in our apartments. We hope see you next time, ever we try to reward our repeat costumers. King regards, Front Desk
Hotel guestRating:
Lovely hotel, large room, clean, excellent staff, location is perfect for the Sagrada Familia! I only wish that the hotel policy was that the reservation was not prepaid in full. With travel, it's hard to be sure how the plans will go in advance of the trip, and the hotel stay is a big expense. So it would be preferable that the hotel did not charge the entire stay in advance. But I took the chance, and we had a fabulous stay there! Recommended hotel from seasoned travelers!
Hotel response
Dear Jayne, Thanks you for you stay in our apartments and thank you for your review, it's a pleasure to know you have had a fabulous stay with us, we are pleased to infom you we have two kind of rates, some cheaper with a full prepaid and not refund, and other with cancellation policy until 48 hours prior to arrival without fees and payment at check in. So anyway, for next time you contact us and we can negociate your rates and conditions. We are happy yo know you have had a good experience in Barcelona. King regards, Inma (Front Desk)
David NashRating:
The apartment was ideal for our family of 5. The location is excellent and we enjoyed our 5 night stay very much.
Hotel response
Dear Mr. Nash, Thanks for stay with us, and thanks for send your review, it's nice to know you have enjoyed your stay, so as you say our neighborhood is great quiet with local restaurants, supermarkets, and 15 minutes walking from Passeig Gracia (Main Street). We hope see you next time in Barcelona. King Regards, Inma (Front Desk)
Thomas DonnellyRating:
A clean, well organised and quiet hotel. Biggest hotel room I have ever had. Great value especially if there are four of you.
Hotel response
Dear Mr. Thomas, Thanks so much for your stay and your feedback, we hope have satisfied your expectations. We hope see us next time, we take care carefully of our repeat costumers Kng regards, Inma (Front Desk)
Hotel guestRating:
Staff excellent. Accomodations excellent.
Hotel response
First of all, Thanks you for your stay with us, often few and simple words tell a great expericencie. We hope see you next time in bacelona, We try to reward loyalty from our repeat costumers. Many thanks, On behalf of all our Staff


text: 500 pts Music Trivia <KSFA VIP What is the name of one of Katy Perry's new tracks? Click here to see the answer. Sign in to Participate Category: Trivia Ends: Monday April 22 at 10:59PM CDT Visit our sponsor: Click here to see the answer. Share on Facebook Share on Twitter More Leave a comment Send to a friend! Print this page Pin it! Reddit This! Share on Tumblr! More Ways To Get and Use Points Win a Polaroid Socialmatic Digital Instant CameraWin a $200 Home Depot Gift CardWin $2,500 Cash!How Much Do You Know About Texas?Spring Cleaning PollWhataburger Quiz


text:
- Home
- About
- Current Productions
Past Productions
- 2008-2009
- 2009-2010
- 2010-2011
- 2011-2012
- 2012-2013
- 2013-2014
- Student Matinees
- Education
- Gala
- Support
TSC's Southern Exposure Series Introduces the Tuesday Literary Salon
TSC's Southern Exposure Series Introduces the Tuesday Literary Salon
"If a story is in you, it has to come out."
- William Faulkner
As part of its Southern Exposure Series, which features new and classic literature by Southern writers with Southern inspiration, Tennessee Shakespeare Company this summer introduces two very special Literary Salons hosted by Memphis' newest Irish restaurant and by one of the city's great patrons of the arts.
Join us at the cooling hour of 6:00 pm for cocktails, hors d'oeuvres, live music, and some of the best words ever written. Elegant, intimate, and cool as a mint julep in shaved ice.
Our first Salon on June 10, Of Ireland Born, was a huge, fun, sold-out hit at downtown's Brass Door restaurant with Irish stage and screen star Bosco Hogan and endless pints of Guinness. We are already planning our return!
Don't miss our next Salon:
Mark Twain at Twilight
starring Pete Pranica (television play-by-play man for the Memphis Grizzlies)
and live ragtime music on the grand piano by Steven DiBlasi
Tuesday, July 22 6:00-8:00 pm
Hosted by Mr. Milton T. Schaeffer in his Germantown residence
The mighty humorist of the Mississippi wrote the reconstructing South into existence for much of America with his novels, short stories, and his live stand-up routine. Hear first-hand Mr. Twain's remarkable take on life during a remarkable period in the history of our country. With wit, honesty, and infinite charm, Mr. Twain will with soothe and delight!
Your $55 ticket buys you light appetizers, champagne, wine, live music, our star of the evening, and literature beyond compare. Seating is extremely limited. Tickets are now on sale while they last. Program subject to change.
To purchase tickets today, call the TSC Box Office at 901-759-0604 or purchase online.
Encourage Us
We need your expertise, your volunteerism, your good ideas, and your financial generosity.
Contact Us
(901) 759-0604
Monday-Friday, 9:00 am - 5:00 pm
Mailing address:
P.O. Box 382143
Germantown, TN 38183-2143
Office address:
3092 Village Shops Drive
Germantown, TN 38138
Latest News
- TSC Announces Open Enrollment for its Sixth Annual Shakespeare Training Camps
- Summer of Shakespeare
- Memphis Mayor AC Wharton, Jr. to Visit TSC's Romeo and Juliet Project
- TSC's Southern Exposure Series Returns its Popular Tuesday Literary Salons for March and April featuring Kate Chopin and Young William Faulkner
- TSC Kicks Off Fourth Year of Nationally-Recognized Romeo and Juliet Project


text: Myanmar movie song min ne ma chit tat lar pyi wit mone, Http://zawminoosg.blogspot.com/.The myanmar website :: myanmar videos, No. 6131 : title : starring: yan aung ye aung moe aung yin thu htoo san htun htun (examplez) moh moh myint aung tun eaindra bo thinzar wint kyaw moe yu san.Wut hmone shwe yee wikipedia free encyclopedia, Early life . wut hmone shwe yi was born on 10 august 1988 in yangon. career . wut hmone shwe yee started her acting with advertisements in 2009. she has made over 40.Shwe videos, Movies watch movies videos and audios shwe community shwevideos.net shwevideos.tv shwetv.com features music videos movies video streaming vcd music videos.