Information and Consultation of Employee Representatives on Resource Efficiency Issues in the European Steel Industry

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1 Information and Consultation of Employee Representatives on Resource Efficiency Issues in the European Steel Industry Conclusions and Recommendations April

2 Reminder of the framework for analysis Information, consultation and negotiation regarding investments in the European steel industry for resource efficiency encompassing within the concept both energy efficiency and material efficiency raises the question of the involvement of employee representatives and their union organisations in the process of modernising the European steel industry. Dealing with investment in a highly capital intensive industry such as steel comes down to determining future capacity and related jobs in terms of quantity and quality, in short industrial sustainability. We shall address the issue of resource efficiency investments in the European steel industry from three perspectives: energy, a common topic covered by industrial policy whose consumption has always been at the heart of society's choices; the environment, which can lead to immeasurable assessments involving economic aspects imposed by regulations; climate, closely linked to the issue of environment but with more distanced effects, less directly identifiable and subject to a more flexible approach with use of economic instruments. 2

3 CO 2 emissions CO 2 emissions are currently an important economic issue for steelmakers, who fear impacts on their profitability from 2020 onwards. Situations are diverse in Europe: from benchmark sites that meet the most demanding European criteria to sites suffering major handicaps due to lack of investment in energy efficiency. A CO 2 diagnosis for each site should be presented to employee representatives, specifying: the current status of each tool compared to best available techniques; possible ways to improve, through operations on the one hand and investment on the other; the possibilities for return on investment for each improvement method; possibilities for financing. 3

4 Pollutant emissions The four main European laws covering the steel industry are: the CO 2 emissions directive; the IED directive on industrial pollutant emissions; the Seveso III directive; the REACH regulation on chemical substances. They have all come into effect between 2005 and The major principles of these directives and regulations are: monitoring and evaluation of health risks; reference to best available techniques; access to information and possibilities for appeal on the part of stakeholders outside the company. An environmental diagnosis for each site should be presented to employee representatives, specifying: the current status of each tool compared to best available techniques, for environmental matters; possible ways to improve, through operations on the one hand and investment on the other; the possibilities for return on investment for each improvement method; possibilities for financing. 4

5 Energy investments and the choice of raw materials: two decisive factors The choice of energy investments requires an integrated approach, including: the production site s energy mix and its relationship with the country of installation; consequences of this mix in terms of pollutant emissions; consequences of this mix for CO 2 emissions. Economic calculations should be coupled with environmental factors, thus changing its terms: energy investment should no longer be solely considered an industrial choice, but also a local choice for living conditions both inside and outside of work. Employees representatives should be provided with full information on the subject the site's sustainability in the medium and long term depends largely on employee representatives relevant knowledge. Likewise, the choice of raw materials is key in: the technology and economy of the production process; CO 2 emissions levels; the nature of pollutant emissions. 5

6 Empower employee representatives Employee representative training appears to be a key issue in helping to make these representatives full stakeholders in the environmental, energy and CO 2 debate and to improve upon failing social dialogue. To be properly followed through, this awareness and improvement to employee representatives knowledge must be supported by an information and consultation process conducted in accordance with legal frameworks and/or in collective bargaining where management representatives also fully play their role. For this, in some countries clarification is required about who does what and work needs to be done on the complementarity between health and safety proceedings and social dialogue proceedings on economic matters. Employee representatives stress the need to have a binding framework for environmental information, or for sustainable development in its broader sense, to develop an independent and reasoned opinion on these topics, in relation to the various issues that affect the company (industrial, financial, strategic and social). Regroup within the same approach the health and safety of employees and the health and safety of surrounding populations. This raises the issue of relations between environmental NGOs and union organisations. Allow thought and development of independent union strategies to defend general interests. Not be sandwiched between company management and environmental NGOs claiming public interest. 6