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A view from the inside

Successful audits are a win-win for the community and for businesses wanting to prove to themselves and others that they do what they say they do . By examining a business from the inside out an auditor confirms that the company is meeting the expectations of all interested parties.

Let’s think of the analogy of clothing.

When garments are viewed from the outside in there may be a glossy brand image, attractive packaging, convenience features.  Only when the clothes are turned inside out do the seams, patterns and structure become visible and understood.

What you see is the other side of the same thing. The garment hasn’t been deconstructed – just viewed in a different light, in all its reality, worts and all. The strengths and positives are seen and admired – the reinforced seams and new, unfaded materials and the creative effort gone into its design. But a closer look reveals some weaknesses – the fraying hems, broken stitching, worn fabric and repaired holes.

Just like a jumper that looks OK when its being worn, the deterioration of a company’s standards relating to environmental protection are not immediately apparent to key stakeholders – senior management, customers, the community, financial institutions and government regulators. Not until something unfortunate happens.

Like a loose button or pulled thread there’s been a deterioration – a few people left untrained, a couple of procedures not followed, a key piece of pollution control equipment not maintained. And so forth.

The loose thread may be spotted and repaired in time but when left unattended, things begin to unravel. In time the loose button will fall off  – there’s a major pollution incident or regulatory breach along with the high price of clean up, medical costs, fines, legal fees and loss of company reputation.  Ouch!

All elements of an Environmental Management System – like the level of training and competence and the effectiveness of operational controls – need to be rigorously checked by a program of regular internal and external audits.

The close scrutiny of a good auditor will warn the business owner(s) of weaknesses and threats so that corrective action can be taken before it is too late.

Enviroease consultants have years of experience in both audits and assessments.  Please feel free to contact me (Suzy) on 0418 862899 to discuss your needs for a gap analyses against key international benchmarks or compliance with local laws.

This article was updated to reflect the revised ISO19011:2018 Guideline for Auditing Management Systems.

 

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What makes effective training?

Deciding how much and what type of health, safety and environmental  training to conduct in your workplace can be a daunting task. Here are 5 tips to guide you through the maze.

1. Focus on high risk

Refer to the site’s Hazard/Aspect Register or Risk Register to establish the workplace tasks that may result in harm to people and the environment.  Determine the roles or job function of people commonly undertaking those tasks. There should be written procedures that outline the steps to take and the operating criteria that must be in place. These can form the basis of the training program.

2. Make the training measurable

Develop competency criteria for each of the high risks tasks that may cause harm. Ask “What should any person be able to do before they are allowed to work without supervision? What do they need to know? What level of language, literacy, and numeracy is required for them to function effectively?” Create a minimum set of performance criteria and a method of assessing individuals against them. For example: an observational checklist or a verbal or written test.

3. Cater for individual differences

Individuals who will be acting in the above roles may have been assessed as having skills and knowledge at a lower level than the minimum acceptable standard. Decide on the best method to address any identified weaknesses. Different approaches include one-to-one supervision or mentoring, tool box talk, an in-house group training course or a public training course by a Registered Training Organisation (RTO).

Recognise existing knowledge, skills and job-related experience when planning the approach to training and assessment. Develop training materials that are tailored to the learner’s level of LLN. In mixed groups this can be a challenge so include alternative techniques to support those with LLN difficulties.

4. Keep records

Keep records of the results of competency assessments and the actions taken when the learner was regarded as not yet competent. Retain records of training content, training provider’s qualifications and participant’s names. Even if the training is a simple “toolbox talk” you must keep a list of attendees with their signatures to confirm that they received the training.

Remember: “If there are no records, it didn’t happen”

5. Evaluate the effectiveness of the training

All elements of the training program should be evaluated to determine whether the goals of the training have been met. Are people competent? Have there been any incidents or near misses? Are people aware of how their workplace tasks may cause a significant environmental impact?Change the training content, techniques or provider to correct any weaknesses or deficiencies so that the training program improves over time.

Enviroease has 18 years experience delivering on-site customised courses direct to clients. We also conduct Nationally recognised management system training (ISO14001:2015;  AS/NZS4801:2001 and ISO19011 auditor training) on behalf of the Exemplar Global accredited Registered Training Organisation – SAI Global.

Call me, (Suzy) on 0418 862899 to discuss how I can help with training and workshops for staff – from Senior Management teams right through all levels of the organisation. .

Article reviewed to update the last section on experience and newer versions of international standards.

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How do you take a life cycle perspective?

While presenting a series of one day courses on behalf of SAI Global entitled “Preparing for the transition to ISO14001:2015″ I became aware that one of the concepts in the Standard is new to many people. Its the taking of a “life cycle perspective”.

So, what does this mean?

A life cycle is defined in the Standard as the “consecutive and interlinked stages of a product system, from raw material acquisition or generation from natural resources to end-of-life treatment”.

Life cycle assessment has been around since the 1990’s and is often called the “cradle-to-grave” approach for assessing industrial systems. This begins with the gathering of raw materials from the earth to create the product and ends at the point when all materials are returned to the earth.

LCA enables the estimation of the cumulative environmental impacts resulting from all stages in the product life cycle, often including impacts not considered in more traditional analyses (e.g., raw material extraction, material transportation, ultimate product disposal, etc.).

By including the impacts throughout the product life cycle, LCA provides a comprehensive view of the environmental aspects of the product or process and a more accurate picture of the true environmental trade-offs in product and process selection.

It should be noted that a full LCA on each product is not be a requirement of ISO14001:2015. The introduction of the term “life cycle perspective” will simply translate into a stronger expectation for companies to consider how their decisions impact further upstream or downstream of the company’s operations.

They will need to demonstrate how they used their influence on suppliers, contractors, customers and consumers to improve sustainability across the supply chain.

If you are thinking of developing an Environmental Management System or need ideas on how to integrate life cycle thinking into your existing EMS, I can offer help you directly or arrange for an LCA to be conducted by one of my associates. Call me (Suzy) on 0418862899 to discuss your needs.

This article was updated to remove the word “draft” as the final version of ISO14001

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Envisioning a clean water future

 

There have been large improvements in the quality of the world’s water resources over the last 25 years. Since 1990, 2.1 billion people have gained access to improved sanitation. The UN estimate that 91% of the global population uses an improved drinking water source, compared to 76% in 1990.1 That’s the good news. Now for the challenges.

Agricultural and coastal development and inadequate sanitation near river catchments still cause significant amounts of sediments, nitrogen, phosphorus and pesticides to be washed into the world’s seas. Nitrate concentrations continue to climb and recently the United Nations Environment Program (UNEP) reported 169 coastal dead zones across the globe with only 13 recovering and 415 coastal areas suffering a reduction in dissolved oxygen.2  The association with coral bleaching and polluted run off is well known.3

In 2012, 288 million tons of plastic were manufactured globally and 8 million tonnes of this was dumped into the world’s oceans.5 Almost 90% of the marine debris found on Sydney’s beaches is plastic, mostly bottles, caps and straws.6 Ocean plastic has been found in the deep sea and buried in Arctic ice. It has been ingested with dire consequences by some 700 species of marine wildlife. The plastic doesn’t break down completely and some of it ends up in the seafood we eat.

A clear role for business

As 80% of marine pollution comes directly from sources on land 2, improved practices by factories, farms, transport operations, mines, construction sites, oil and gas facilities and power generation plants can make a significant difference to the state of the world’s oceans, rivers and ground water quality.

1 Develop an understanding of water quality issues relevant to each facility

Identify all types of effluent and pollution leaving the company’s operations as surface or groundwater in a typical year. Record the total number and volume of significants spills, their location, volume and the specific contaminant. Find out the total water discharged by quality and destination and whether these were planned or unplanned; the water treated or untreated and the amount that was used by another organisation, meaning it was diverted from release into the environment.

2 Determine the level of associated threats, risks and impacts

Consider potential risks associated with the effluent and pollutant discharges you’ve identified. These may include fines, legal costs, loss of licence to operate, clean up costs, negative media, harm to flora and fauna, human health impacts and economic impacts on farms and fisheries.

3 Seek out ways to achieve zero water pollution leaving the facility

Go through a process of identifying and assessing improvement ideas. Aim to eliminate the discharge of oils/fuel, chemicals, sediment and solid waste into stormwater drains or areas where rivers and groundwater could be adversely affected. 100% of runoff should meet ANZECC water quality guidelines for the concentration of nutrients phosphorus and nitrogen, acidity, dissolved oxygen, salinity and turbidity. Investigate whether there are ways to treat waste water for re-use in another process. If there is an EPA licence or trade waste agreement (TWA) set an objective that all water quality samples will meet the required parameters.

4 Use your company’s influence to have a positive impact elsewhere

There may be opportunities to improve water quality by undertaking remedial works outside the company’s operations. Some performance indicators around this might be:

  • The number of or Km2 of local creeks or rivers rehabilitated
  • The no. of, kilolitres or percentage of spills cleaned up and the specific contamination eliminated
  • Kilolitres and percentage of total sewage or effluent treated for re-use by another organisation
  • The Kg or number of pieces of litter cleaned up from local streams, river or beaches, for example on “Clean Up Australia Day”

Your company may be able to improve water quality indirectly through the purchase of resources, provision of products and services, R & D processes and supply chain collaboration. For example, researchers at Flinders University have developed a new polymer that cleans up mercury from waterways, soil and groundwater using waste sulphur from the petroleum industry and waste limonene from the citrus industry. 4

Health and Beauty multinationals, Unilever and Proctor & Gamble are phasing out the use of microplastic ingredients in their facial scrubs and other cosmetic and toiletry products. 7

How the Enviroease team can help you

We have a range of services to help you improve the way that water discharges and spills are managed across your company’s operations.

  • Assessment of risks and the effectiveness of current operational control measures
  • Identification of process control improvements
  • Life cycle assessment of products and packaging
  • Compliance audit against legislation, licences and Trade Waste Agreements
  • Water quality testing and analysis by a NATA accredited laboratory
  • Pollution Incident Response Management Plans
  • Spill response training, drill and report

Feel free to call me, Suzy, on 0418 862899 to discuss your particular needs.


References

1 http://www.undp.org/content/undp/en/home/mdgoverview/mdg_goals/mdg7/

2 http://www.unep.org/geo/pdfs/geo5/Measuring_progress.pdf

3 https://theconversation.com/cloudy-issue-we-need-to-fix-the-barrier-reefs-murky-waters-39380

4 https://theconversation.com/we-created-a-new-material-from-orange-peel-that-can-clean-up-mercury-pollution-49355

5 http://news.nationalgeographic.com/news/2015/02/150212-ocean-debris-plastic-garbage-patches-science/

6 http://www.marineconservation.org.au/pages/plastic-pollution.html

7 http://www.fauna-flora.org/initiatives/the-good-scrub-guide/

 

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One stop shock for Australia’s biodiversity

The aim of reducing so-called green tape via a “one stop shop” for environmental approvals is counterproductive and likely to result in a more rather than less complexity for Australian business.

While faster approvals will undoubtedly stimulate the economy, an inadequate level of community consultation is predicted to result in legal action from communities and groups pursuing other avenues to protect their land and wildlife. This makes no sense for businesses, individual people, communities or the natural environment.

Biodiversity is the variety of life forms including different animals, plants and microorganisms, the genes they contain and ecosystems they form. Diversity means richness and resilience to threats. All biodiversity indicators were assessed as being in a poor state in latest State of the Environment Reports.

1,340 plants and 445 species of animals are listed as National Threatened Species. Despite the efforts undertaken, there are recovery plans for only 10% of species. Sadly only one species has been taken off the endangered list since 1993, the saltwater crocodile..

Australia is a signatory to the 1993 Convention on Biological Diversity (CBD) an internationally binding treaty.  The Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) fulfils Australia’s international obligations giving legal protection to eight matters of National and international importance, among them threatened species, wetlands of international significance and migratory species.

But the amendments to the EPBC Act will have far reaching consequences for Australia’s biodiversity. The changes involve Bilateral agreements whereby state or territory governments will both assess and approve, on the Commonwealth’s behalf, projects and activities such as land clearing that potentially impact on plant and animal species.

Unfortunately most state governments have a poor track record of safeguarding the environment against environmentally destructive development.

Take Gladstone Harbour in Queensland for instance. The EIS guidelines fail to answer a  fundamental question: how can further port expansion, millions of cubic meters of dredge spoil dumped in marine habitat and thousands more coal ships travelling through the already stressed Great Barrier Reef every year not adversely impact biodiversity?

An independent report commissioned by commercial fishermen seeking answers to long-running disease issues in fish stated “the epidemiological pattern is suggestive of a common water-borne irritant across all groups…one (cause) is exposure to dredge spill and associated toxicants” (Source: The Courier Mail April 20, 2012).

There are two features of Australia’s environmental regulatory framework  to consider here. Firstly, that the Federal government has, up to now, effectively vetoed state developments that would have been environmental devastating.

Well known examples are the Franklin Dam and polluting pulp mills in Tasmania; Sandmining on World Heritage Fraser Island in Queensland; and uranium mining at Coronation Hill in the Northern Territory. There is good reason to maintain a healthy separation of powers between the assessment and approval process so that vested interests at state level do not overshadow the goal of biodiversity protection.

The second feature of environmental law in Australia to consider is the sheer complexity of different environmental legislation in every state.  A person fulfilling the role of National Health, Safety, Environment or Sustainability Manager must be across 8 sets of legislation, each with slightly different legal ramifications.

If reducing complexity, costs and delays is the genuine aim of legislative reform, then a more effective strategy would be greater harmonisation of environmental law across the Australian states and territories.  This would do a lot more to ease the compliance burden for Australian business than the “one stop shop”.