CHAPTER 3: GETTING STARTED Decision by Top management to implement EMS
Appoint person responsible to lead EMS implementation
Establish committee to establish, develop and implement EMS
Conduct initial training to EMS Committee
Carry out company wide Initial Environmental Review
Development of Company’s Environmental Policy, Objectives and Targets and Programme
Development of Manuals and Procedures
Implementation and Training
Audit and Review
Monitoring and maintenance
FLOW CHART – IMPLEMENTATION OF ENVIRONMENTAL MANAGEMENT OF SYSTEM
3.1 Commitment and Leadership Before an EMS can be implemented, an organization needs to secure top management support of this endeavor. This is one of the most critical steps in the planning process and the success of the CEMS is highly dependant on this support and commitment from top management. Management must first understand the system and the benefits it brings to the organization. Management also has a role in ensuring that the goals for the EMS are clear and consistent with other organizational goals.
3.2 Environmental Management Representative An Environmental Management Representative needs to be appointed by the top management. This representative should have the necessary authority, an understanding of the organization, and project management skills. The representative should be a “systems thinker”, should have the time to commit to the EMS-building process and must have top management support
3.3 Environmental Management System Committee A committee with representatives from key management functions can identify and assess issues, opportunities and existing processes. Consider including subcontractors, suppliers or other external parties as part of the project team, where appropriate. A cross-functional team can help to ensure that procedures are practical and effective and can build commitment to and “ownership” of the EMS. To successfully implement the system, this team will need to undergo specific training programs pertaining to the development and implementation of the environmental management system.
3.4 Scope of EMS Once top management has given the green light for implementing the system, it then needs to determine the scope of the system. The scope of the environmental management system is essential in setting the boundary for the initial environmental review, development and implementation. In determining the scope the organization is required to determine the activities and the level of influence and control involved with respect to each activity. The scope will help the organization to specify the boundaries, number of project sites and/or services to be covered, implementation time and the credibility of the environmental management system. The scope has to be explained in the Environmental Manual because this provides clear boundaries of the environmental management system coverage. Once the scope or boundary is identified, then the organization can proceed to the initial review process.
3.5 Initial Environmental Review (IER) In order to be able to identify what should be done to implement an environmental management system, the current situation concerning the environmental impacts of
the contractor's activities should first be established. The baseline assessment provides a quick and easy approach to gaining greater understanding of the current level of environmental performance and issues. The assessment considers existing management practices, the likely main environmental aspects and associated impacts, environmental costs, views of interested parties and key legal requirements. The assessment evaluates the existing environment – the ecology, drainage, topography, sensitive areas and others and identifies the current strengths and weaknesses in environmental protection plan. To achieve this, the contractor can conduct an initial environmental review (IER). Initial environmental review is a preliminary review of the existing environmental programs and systems in the company. It identifies areas of improvement as well as quantifies baseline environmental conditions. It reviews the day to day working conditions of the organization s well as the construction program planned. An organization with no existing environmental management system should, as a first step, establish its current position with regard to environment by means of a review. The aim should be to consider all environmental aspects of the organization as a basis for establishing the environmental management system. The review should cover four key areas: a. legislative and regulatory requirements - For example during planning and design activity, there are part where the output has to comply to legal requirements: or during actual construction work organization is required to comply with local by law. b. an identification of significant environmental aspects - The identification process should cover all activity, product and services associated with the organization with the defined scope. The process shall consider normal operating conditions, abnormal operating conditions and during emergency situations. c. an examination of all existing environmental management practices & procedures – Availability of procedures to follow during planning for land clearing or how to dispose our waste engine oil at construction site or what criteria do we follow when we want to locate our diesel skid tank. Are we following good environmental practice when we locate our diesel skid tank near a stream or storing waste oil drum on the ground without proper coverage or conducting land clearing activities during raining season covering large area, or discharge the oil waste direct into the stream? d. An evaluation of feedback from the investigation of previous incidents - Land slide or stop work order for releasing discharge that are not in compliance to Sewage and Industrial Waste Regulation. There are no fix tools or methods for undertaking the review. However the organization through team effort should walk through the process. An initial environmental review is done via discussion, interview, site inspection and existing document examination. Relevant employees most likely to give information are suppliers, vendors, community groups, government agencies.
What will be the best way to carry out Initial environmental review? 1. Appoint a team from relevant department to conduct the review. 2. Establish a simple procedure or methodology including criteria to identify the environmental aspects and impacts associated with our activities, product and services. 3. Define our scope of our activities and the scope to be covered under environmental management system. The key factor that determines our scope is the extent of control and influence of the activities, product and services. No point including in your scope activities, product or services when you cannot control and influence. And you should not only include activities, product and services that cause minor impacts to the environment and leave activities that cause significant environmental impacts to the environment. 4. Conduct an on site and off site assessment through interview, review of past record and review of existing practices. 5. Maintain record of assessment and evident of decision made. 6. Finally formalize the simple methodology or procedure into procedure. In the construction sector it is environmental aspects and impacts identification process should be carried out at two levels. The first level is at organizational level and the level is at the project site before the start of the activity. This is due to the fact that at project site, environmental aspects and impacts varies depending on the actual site, work method and other factors.
3.6 Identification of Environmental Aspects and Impacts The first thing an organization has to do is determining the environmental issues that they have to manage. Environmental issues are those issues that are associated directly and indirectly with the organization activities, products and services. In the construction sector, the environmental issues can be one or more of the following: water pollution, erosion and siltation, loss of biodiversity, air pollution, noise pollution, flash flood, loss of top soil, scheduled and construction wastes, resource consumption, energy conservation and many more. These can happen during the course of the project, after completion of the project, during its operational phase and end of life, abnormal cases such as during heavy rain and during emergency situations such as landslides. Therefore these environmental aspects should be taken into consideration at every stage of the project implementation process, from conception to completion. A project can have a number of environmental aspects related to their activities. Some will be directly within their control (e.g. direct aspects such as air emissions and water discharges) and some will be of a nature that can only be indirectly influenced (e.g. indirect aspects such as activities of raw material suppliers). As both types can lead to significant environmental impacts, both should be assessed for significance. The contractor will need to identify the environmental aspects and determine their significance. Having evaluated environmental aspects for significance it is possible to prioritize actions that address issues relating to the organization's operations.
Such impacts may be local, regional or global, short or long term, with varying levels of significance. An organization should understand the activities, products and services that fall within the scope of its environmental management system, and may find it useful to group them for identification and evaluation of environmental aspects. Grouping or categorizing activities, products and services can assist an organization in identifying common or similar environmental aspects. A grouping or category could be based on common characteristics, such as organizational units, geographical locations, operations workflow, materials or energy use in product groups, or environmental media affected (e.g. air, water, land). To be useful, the size of a category should be large enough for meaningful examination, yet small enough to be clearly understood. Appendix 1 is a generic form which can be used as a guide for contractors to identify environmental aspects and significant impacts
3.6.1 How to Identify Environmental Aspects and Significant Impacts 1. Select a related construction activity. 2. Identify as many as possible environmental aspects associated with the chosen activity. Remember that environmental aspects can be positive (e.g. recycling waste) and negative (e.g. generation of toxic waste). Consider also aspects rising from normal and abnormal operating conditions as well as potential emergency situations. The Method Statement can be used as a reference to identify environmental aspects. 3. Identify as many as possible environmental impacts associated with each aspect. Keep in mind that the relationship between environmental aspects and environmental impacts is one of cause and effect. 4. Evaluate the significance of the aspects and associated impacts. Evaluation of significance can be done using a set of criteria appropriate to the construction sector. Among the criteria which are widely used are frequency, severity, probability, duration, legal requirements, environmental consequence, corporate concerns, resource depletion, human health effects etc. Application of the methodology and evaluation criteria should be consistent through out the process 5. From the evaluation process, develop a register, listing out all activities which have significant environmental aspects and their associated impacts.
Table 3.1: Sequence involved during the aspect and impact identification process. Identification of activities, product and services within the identified scope • • •
Design of township, highway or multi story apartment. Land clearing and earth work. Construction of hospital, school or road.
Identification of environmental aspects during normal, abnormal and emergency situation. Examples of environmental aspects: • Consumption of Natural Resources. • Removal of top soil. • Removal of vegetation • Discharge of waste water, waste oil, building waste etc. • Consumption of electricity. • Emission of dust and other particulates.
Determining environmental impacts associated with each environmental aspect. Examples of environmental impacts: • Depletion of Natural Resources. • Loss of soil fertility. • Loss of flora and fauna. • Loss of habitat • Soil erosion • Visual impact • Water pollution – waste, siltation • Air pollution –dust and particulate • Global warming • Noise pollution • Flash flood Link between aspects and impacts is similar to “cause and effect”
List out all significant aspects activities into “ List of significant aspects register”.
Evaluation of Significance from the identified environmental impacts/aspects • •
•
•
•
Using established methodology and evaluation criteria appropriate to the • construction sector. The methodology can be qualitative, a. quantitative and semiquantitative. The evaluation team shall have common understanding on the b. methodology, application of the criteria. Application of the methodology and c. evaluation criteria should be consistent through out the process.
d.
From the evaluation process a list of significant aspects register shall be produced. The list leads the organization to the following: The activities, product or services that we need to manage in order to reduce the environmental impacts from our organization. Which activities from our organization that are covered under legal and other requirements. What type of works that require competent people in order to prevent environmental impacts and compliance to organization environmental policy? Which type of organization staff that requires environmental related training.
Prioritisation of the list of significant aspects register. The most significant shall be managed first. •
•
•
From the list it is critical for the organization to prioritize to ease the management process. Basis shall be its significant to the environment and legal compliance. The final list will guide the organization in setting its environmental policy and the environmental objectives.
Table 3.2: Examples of associated environmental aspects and impacts from land clearing activities Construction activity or process Land Clearing
Environmental Aspects -removal of existing vegetation
-biomass incineration -mulching of biomass -exposed soil surface slope instability -vehicular emissions -vehicular movement
Loss of terrestrial habitat, loss of biodiversity
Environmental Impacts Beneficial Adverse -Revenue from sale of -loss of tree cover marketable trees or -reduced aesthetics plants -blocked waterways -use of tree trunks for causing flooding temporary erosion -loss of terrestrial control habitat -air pollution -reuse in landscaping -erosion and siltation -water pollution -flash floods landslides -air pollution -land contamination -water pollution -air pollution -vibration -noise pollution -risk to public safety
Air pollution
Removal of topsoil
Removal of vegetation
Resources, fuel, machinery, land area, vegetation, topsoil
Loss of land fertility, erosion
Emission to air
OUTPUT
INPUT Land clearing
Generation of waste Land degradation, loss of aesthetic values
Cleared land
Surface runoff Erosion, siltation, flash floods
FIGURE 3.1: Examples of Environmental Aspects and Impacts from Land Clearing
Aspect NO
YES
Legal Requirement NO Environmental Consequences NO
YES
YES
SIGNIFICANT ENVIRONMENTAL ASPECT (SEA)
Use of Materials NO Corporate Concern
YES
NO NOT SIGNIFICANT
FIGURE 3.2: Workflow example for evaluation of aspect significance
3.6.3 Determining the issues to be managed Among the critical outcome from the whole exercise would be the list of significant activities that cause significant impacts to the environment. From the list, the organization is required to prioritize and determine the most significant aspects that need to be managed. This list would be the basis for any organization to establish and implement an EMS. The list would assist the management in setting the Policy, Objectives and Targets for the organization. The outcome would also be a critical input for the establishment of the environmental manual and procedures, training requirement, potential emergency situations, operational control, monitoring and measurement, prevention of pollution and continual improvement. To manage the environmental impacts, it is the significant aspects activity, product and services that we need to manage. Reducing or eliminating any interaction with the environment will directly reduce and eliminate the environmental impacts.
What should be the output of this process? 1. Documented procedure for identification of aspect and impacts where the methodology and criteria has been clearly defined. 2. Record of identified aspects and impacts for verification. 3. List of significant aspects and impact activities, product and services. 4. Prioritize list of significant aspects and impacts and the basis used to determine prioritization. 5. All activities, product and services under the scope have been adequately covered.