SpaEfV – alternative system – simplification of procedures for KMUs

As of the application year 2015 a so-called regular procedure as per the SpaEfV applies. This means that the DakkS (German accreditation authority) and the DAU (Deutsche Akkreditierungs- und Zulassungsgesellschaft für Umweltgutachter mbH) are now able to permit a simplification of procedures in regards to the execution of on-site inspections by means of evidencing an alternative system. This came into force on 16th September 2015.

The most significant aspect in terms of allowing such simplification procedures is the number of sites:

• Regarding companies with one site, a simplification of procedures may extend the frequency of on-site inspections, meaning that an annual, document-based inspection as well as on-site inspections every two years is sufficient in terms of providing the according evidence.

One condition is that a year with an additional on-site inspection is followed by an application year consisting of an inspection of the respective documents. This procedure is first possible in 2015, meaning that if a document-based inspection and an on-site inspection were to be carried out in the year of registration, namely in 2015, an on-site inspection would no longer be necessary in 2016.

• Companies with several sites may choose, whether they would like to use the so-called multi-site regulation (see point a), or whether they would like to extend the on-site inspection intervals (see point b). Both procedures may be applied as of the registration year in 2015 (once the simplification of procedures comes into force on 16th September 2015), however, it is not possible to combine options a and b.

1. a) The simplification of procedures by means of a multi-site regulation for companies with several sites (in accordance with DakkS 71 SD 6013) includes an annual on-site inspection of the head office and a number of sites selected as random samples.
2. b) The simplification of procedures by means of extending the on-site inspection intervals (in accordance with Art. 7 EMAS order) includes an annual document-based inspection, as well as an on-site inspection of selected company sites every two years for verification purposes. Here, it is to be ensured that following a full inspection during the 1st registration year, all company sites are inspected at least every 4 years.

Document-based inspections shall include the respective updated energy audit report DIN 16247-1 (Annex 1 SpaEfV) or an updated data log as per Tables 1-3 (Annex 2 SpaEfV), as well as an annual evaluation/decision by management in accordance with Figure 4 Annex 2 SpaEfV regarding the status of the respectively planned measures.

In case of any significant changes regarding the energy providers used and/or the respective amounts, as well as in case of significant changes in terms of the respective company structure, on-site inspections shall be a binding requirement (see DakkS/DAU simplification of procedures regarding the evaluation of energy efficiency as per SpaEfV). This also means that in a test year, during which a document-based inspection is planned, additional costs are incurred in terms of on-site inspections.

Additional information in terms of this subject area may be found in the publications released by DakkS/DAU in regards to the simplification of procedures SpaEfV.

Last updated: 7th March 2016