A view from the inside

by Suzanne Orme

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 or 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 applied to 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.

Call us on +61 294111764 if you need help

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

 

What makes effective training?

by Suzanne Orme

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. For high risk activities 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 talks” 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 deliver Nationally recognised management system training (ISO14001:2015;  AS/NZS4801:2001 and ISO19011 auditor training) on behalf of Exemplar Global accredited Registered Training Organisations.

Call us on +61 294111764 if you need help

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

How do you take a life cycle perspective?

by Suzanne Orme

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 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 its operations.

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

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This article was updated to remove the word “draft” after the final version of ISO14001 was published.

Envisioning a clean water future

By Suzanne Orme

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. To contribute to cleaner oceans, businesses can adopt the following steps.

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

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

Call us on +61 294111764 if you need help

 

 


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/

 

One small paradox

by Suzanne Orme

The notion that we are powerlessness to act in the face of global challenges is being questioned by forward-thinking people the world over.

Regardless of their role in society, more and more individuals are perceiving themselves as tiny parts of a greater whole, as citizens of the planet, governed first and foremost by natural laws and principles of universal. They are  exercising their freedom to make considered choices to live within natural planetary boundaries while considering their impact on others.

The paradox

This humbling realisation of smallness need not make one feel powerLESS. In many cases it leads to empowerMENT. As individuals with a common ethos, some people now perceive themselves as global citizens connecting with likeminded people living in any part of the world.

The fact that there is a transition already happening to this unstoppable idea is clear.  It is evidenced by this year’s rising up of younger people in the School Climate Change Strikes and the  Extinction Rebellion protests.

Western society is transitioning to a new era, hastened by a wave of eco-awareness combined with technological advancement and enhanced connectivity.

The 20th paradigm of “big is better” is being supplanted by “smarter and more efficient”.  It manifests in micro technology, small-localised markets and consumer choices to smaller, more efficient cars and houses.

As business leaders we need to be aware of an embrace these changes. The green economy has been assessed as presenting a $21trillion potential to 2030.

This article, originally published in 2016, has been updated to reflect events of 2018-19

 

Is your company at risk of waste dumping?

by Suzanne Orme

Large fines, jail terms and damage to a company’s reputation can easily result from failing to effectively manage the risks associated with waste disposal in NSW.

If waste is illegally dumped on land that is not licenced as a waste facility and harms the environment, the maximum penalty is $5million or a 7 year jail sentence. Illegally transporting waste, or causing it to be taken to a place that cannot lawfully receive the waste can cost $1million. Other states also have high fines.

These figures are staggering but while waste represents a compliance issue for all companies, the amount of effort and time spent should be consistent with the degree of risk imposed.  A key issue is that as producer of waste or a consignor of waste from another facility, your company is responsible for ensuring that high-risk waste is properly tracked.  This means you must not allow it to leave your facility unless you are sure that the necessary documentation and checks have first been completed.

To determine whether the waste must be tracked refer to Schedule 1 of the NSW Waste Regulation (2005).  If the final destination is interstate check that State’s regularly requirements which may differ.

All trackable waste loads must be accompanied by a hard copy Transport Certificate (TC) which is derived from the Consignment Authorisation (CA) from the person authorised to transport the waste. The relevant sections of the TC must be signed off as correct by you or your agent (the consignor), the transporter and receiving facility.

The TC contains information such as the character of the waste (solid, liquid, sludge, compressed gas or a combination of types); waste classification (based on the Environmental Guidelines); Waste code; Waste description and Dangerous Good properties.

To manage risks of illegal waste dumping, question the contractors you are dealing with and don’t assume that everything is correct. Go on line to check that the Environment Protection Licence for the landfill or waste processing facility covers the type of waste you are sending. Obtain copies of licenses of drivers of vehicles transporting trackable waste to make sure they are authorised to drive the vehicle.

If you are concerned about what has happened to previous waste shipments, ask the receival facility for completed TCs. These provide information on all stages of the waste movement – picked up, arrived, accepted or rejected, rejected/delivered, processed and they must be kept for 4 years.

Consider obtaining a user ID for the free on-line waste tracking system where you can access this information and keep your eye on what is happening.

Call us on +61 294111764 if you need help

 

 

 

Get ready for risk based licensing

By Suzanne Orme

Failure to develop and implement an Environmental Management System (EMS) at each site could become a costly exercise as the NSW EPA progresses towards its risk based licencing system.

The EPA will change the calculation of licence administration fees by introducing an Environmental Management Category – either A, B, C, D or E. The Category will act as a multiplier to the fee, resulting in either an increase, decrease (or no change). For example any sites classified as “E” will have their fee doubled, those classed as an “A” will be recognised as having the highest level of performance and receive a 5% reduction.

New approach under the Protection of the Environment Operations (General) Amendment (Licensing Fees) Regulation 2013

  • Each licence will be allocated an overall risk level of 1, 2 or 3. A higher risk level may result in more intensive monitoring and reporting obligations on the licensee.
  • Each site will be allocated an environmental management category considering the site’s enforcement history and regulatory actions, if any.  Answering “yes” to the question “Does the licensee have an EMS certified to ISO14001?” provides an automatic reduction of 40 points.  If the EMS is not certified, certain elements of a system such as records of regulator training earn points.

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Which office paper is the most sustainable?

With logging of old growth forests still a contentious issue in Australia and rainforest destruction continuing across the globe, companies and individuals need to think carefully about how to exercise their purchasing power if they desire a sustainable pulp and paper industry.

Now that technology has enabled the electronic storage of documents, environment and sustainability policies should focus on elimination of paper as the number one priority with a long term goal of the “paperless office”.  Such a transition presents a win-win for the environment and the economy due to the productivity gains of reducing office clutter together with easy retrieval and safe storage of records.  In the short term companies can reduce the consumption of paper with double sided printing as the norm, carefully implemented so that people don’t make mistakes and re-print.

The big question is that when its necessary to buy paper, which one is the most sustainable?  In an effort to help decision makers make sense of the many eco-labels that appear on reams of office paper, the Buying Better Project at the Total Environment Centre in Sydney released a useful policy on Printer Paper dated December 5, 2012.

They don’t endorse any particular product but suggest that the most important buying criteria are in the following order:

  1. Recycled content with 100% ideal and verification against ISO14021 desirable.
  2. A label from  a recognised sustainable forest management certification body such as the Forest Stewardship Council( FSC) or PEFC.
  3. Carbon neutral or carbon reduced,  if it is verified by a recognised 3rd party such as National Carbon Offset Standard (NCOS).

The Buying Better Project guidance is the result of a simplified life cycle assessment (LCA) process which determined the most significant (material) stages in the lifecycle of office paper to be raw material (extracts and processes) and  manufacturing. Download the guide at: http://www.greencapital.org.au/projects/buying-better.html