CSL has an Environment, Health, Safety and Sustainability (EHS2) Strategic Plan that ensures its facilities operate to industry and regulatory standards. This strategy includes compliance with government regulations and commitments for continuous improvement of health and safety in the workplace, as well as minimising the impact of operations on the environment. To drive this strategy, CSL implemented an EHS2 Management System (EHSMS) Standard. Internal audits at three sites confirmed compliance with EHSMS. Completion of the remaining internal audits will be over the next two years.
Development, implementation, and improvement of employee safety & health processes and programs continue to focus on enhancement of a strong safety culture. Our Australian operations continue classification as an Established Licensee in respect to CSL’s self-insurance licence as granted by the Safety, Rehabilitation and Compensation Commission.
The Environment Protection Authority (EPA) in Victoria, Australia or any other equivalent Australian interstate or foreign government agency in relation to CSL’s Australian, European, North American or Asia Pacific operations have not issued any notice for environmental breaches during the year ended 30 June 2019. CSL is currently finalising plans for remediation of impacted groundwater from historical contamination in a small portion of the Parkville site.
In 2018/19, CSL, Parkville, closed out the Stage 1 non-compliance notice issued by the local water authority for elevated sulphide in wastewater discharged from the Parkville site. Implemented corrective and preventive actions and continued sampling is demonstrating ongoing compliance. In July 2018, Seqirus, Liverpool, reported a refrigerant leak on a newly installed system. The local Environmental Authority responded with an inspection and compliance notice. Corrections were completed with no fines issued. In May 2019, CSL Behring, Broadmeadows, received a Stage 1 non-compliance notice from the local water authority for an elevated concentration of acetic acid in a sample of wastewater discharged to the sewer. CSL is investigating this event and is cooperating with the authority to resolve the issue.
Australian and foreign laws regulate environmental obligations and waste discharge quotas. Government agency audits and site inspections monitor CSL environmental performance. The EHS2 function continues to refine standards, processes, and data collection systems to ensure we are prepared for new regulatory requirements.
CSL has met its reporting obligations under the Australian Government’s National Greenhouse and Energy Reporting Act (2007) and Victorian Government’s Industrial Waste Management Policy (National Pollutant Inventory).
CSL’s environmental performance is particularly important and relevant to select stakeholders and CSL reaffirms its commitment to continue to participate in initiatives such as CDP's (climate change and water disclosures) to help inform investors of its environmental management approach and performance.
Our Environmental Impact Trends
We have restated our environmental data for the last three years against a new reporting timeframe (April to March) to support publication of our environmental performance at the same time as our financial performance.
Our environmental performance includes: manufacturing facilities held by Seqirus (three facilities in Australia, the United Kingdom (UK) and the United States of America (US)) and CSL Behring (five facilities in Australia, Germany, Switzerland and the US); CSL Plasma operations, including testing laboratories and plasma centres, across Germany, Hungary and the US; Administrative and R&D operations co-located with our manufacturing facilities; and the respective head offices for Seqirus (Maindenhead, UK), CSL Behring (King of Prussia, US), CSL Plasma (Boca Raton, US) and CSL Limited (Parkville, Australia). For April 2018/March 2019, increasing production output is reflected in an increasing environmental footprint, however environmental initiatives, together with increasing use of the production capacity of recently built plants, led to decreasing energy, greenhouse gas (GHG) and water intensities. Nonetheless, CSL’s facilities require significant amounts of energy and water for operational procedures such as test runs, validation of equipment and operation when not at full capacity. Furthermore, HVAC energy consumption for clean room areas is nearly independent of production output. CSL continues to be challenged by its expanding manufacturing footprint, which is growing to help meet product demand and deliver new and improved therapies to patients.