Final Draft

ACKNOWLEDGEMENT The authors would like to thank the Contraction Industry Development Board, mainly the Construction Research Institute of Malaysia (CREAM), for awarding us a grant (LPIPM:CREAM/UPP03-02-05-06-05) to conduct this research and developing this manual. In preparing this manual, the authors had solicited input from a variety of organizations such as: • • • • • •

International Organization for Standardization The Hong Kong Environmental Protection Department Environmental Protection Authority (EPA) Victoria, Australia National Center for Environmental Decision–making Research, University of Tennessee Ellipson Management Consultants, Switzerland British Standards Institute

Feedback from participants of the ” Workshop on Environmental Management and Tender & Contract Document in the Construction Industry”, held throughout the country, was also crucial in helpful in framing the changes that are reflected in this manual.

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TABLE OF CONTENTS ACKNOWLEDGEMENT...............................................................................................i TABLE OF CONTENTS...............................................................................................ii LIST OF TABLES.........................................................................................................v LIST OF FIGURES......................................................................................................vi LIST OF PLATES.......................................................................................................vii INTRODUCTION TO GUIDELINES (PURPOSE)....................................................viii WHAT IS THIS MANUAL?.......................................................................................viii SCOPE......................................................................................................................viii WHO SHOULD READ WHAT IN THIS MANUAL?....................................................ix AIM OF THE CEMS.....................................................................................................x 1.0INTRODUCTION......................................................................................................1 1.1 What is EMS ?.........................................................................................................1 1.1.1 Key EMS concepts ..............................................................................................1 1.1.2 Key elements .......................................................................................................1 1.2 Why need an EMS ?...............................................................................................3 1.3 EMS Development and Implementation.................................................................4 1.3.1 Steps for EMS development and implementation................................................4 2.0CONSTRUCTION AND ENVIRONMENT................................................................6 2.1 Construction Industry in Malaysia...........................................................................6 2.2 Construction Process..............................................................................................6 2.3 Impacts of construction activities on the environment ...........................................8 2.3.1 Land degradation ................................................................................................9 2.3.2 Loss of flora and fauna ........................................................................................9 2.3.3 Solid wastes ......................................................................................................10 2.3.4 Water pollution....................................................................................................11 2.3.5 Air pollution.........................................................................................................11 2.3.6 Depletion of resources.......................................................................................12 2.3.7 Noise and vibration.............................................................................................12 2.3.8 Land Contamination...........................................................................................12 2.3.9 Players and their roles, commitment and responsibilities .................................13 3.0GETTING STARTED..............................................................................................14 3.1 Commitment and Leadership................................................................................15

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3.2 Environmental Management Representative........................................................15 3.3 Environmental Management System Committee...............................................15 3.4 Scope of EMS.....................................................................................................15 3.5 Initial Environmental Review (IER)......................................................................15 3.6 Identification of Environmental Aspects and Impacts...........................................17 3.6.1 How to Identify Environmental Aspects and Significant Impacts.......................18 3.6.2 Determining the issues to be managed.............................................................21 4.0DEVELOPING AND IMPLEMENTING THE SYSTEM..........................................22 4.1 Environmental Policy.............................................................................................22 4.1.1 The need for an environmental policy. ..............................................................22 4.1.2 How to Draft an Environmental Policy................................................................22 4.2 Legal and Other Requirements.............................................................................23 4.3 Objectives, Targets and Programs........................................................................24 4.3.1 Setting Objectives and Targets...........................................................................24 4.3.2 Developing Environmental Management Program............................................25 4.3.3 Monitoring of Objectives, Targets and Programme............................................25 4.4 RESOURCES, ROLES, RESPONSIBILITIES AND AUTHORITY........................26 4.4.1 Resources required to manage system.............................................................26 4.4.2 Roles, responsibility and authority.....................................................................27 4.4.3 Management representative..............................................................................28 4.5 COMPETENCE, TRAINING AND AWARENESS.................................................31 4.5.1 Determining competency requirements.............................................................31 4.5.2 Training and awareness.....................................................................................31 4.5.3 List of recommended training.............................................................................33 4.6 COMMUNICATION...............................................................................................35 4.6.1 Determining the need to communicate..............................................................36 4.6.2 Internal communication .....................................................................................38 4.6.3 External communication.....................................................................................38 4.7 DOCUMENTATION AND CONTROL OF DOCUMENTS ....................................41 4.7.1 Development of environmental manual.............................................................42 4.7.2 Content of environmental manual......................................................................43 4.7.3 Control of document...........................................................................................44 4.8 OPERATIONAL CONTROL..................................................................................47 4.8.1 Identifying need for operational control..............................................................47 4.8.2 Development of operational control...................................................................48

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4.8.3 List of operational control procedures................................................................49 4.9 EMERGENCY PREPAREDNESS AND RESPONSE...........................................50 4.9.1 Potential emergency situation & potential accident in construction sector........51 4.9.2 Development of relevant emergency preparedness & response procedure.....51 4.10 MONITORING AND MEASUREMENT...............................................................55 4.10.1 Identifying activities, product and services.......................................................58 4.10.2 Development of appropriate monitoring and measurement mechanism.........59 4.11 EVALUATION OF COMPLIANCE.......................................................................61 4.11.1 Demonstration of compliance...........................................................................62 4.11.2 Evaluation of compliance to legal requirements...............................................62 4.11.3 Evaluation of compliance to other requirements..............................................63 4.12 NON-CONFORMITY, CORRECTIVE ACTION & PREVENTIVE ACTION.........63 4.12.1 Non-conformity, corrective actions and preventive actions..............................65 4.12.2 Evaluating actual non-conformity to corrective actions....................................65 4.12.3 Evaluating potential non-conformity of preventive actions...............................70 4.13 CONTROL OF RECORDS..................................................................................73 4.13.1 Identifying environmental records....................................................................73 4.13.2 Management of environmental records...........................................................74 4.14 INTERNAL AUDIT..............................................................................................75 4.14.1 Determining internal audit objectives ..............................................................75 4.14.2 Development of internal audit program............................................................75 4.14.3Selection and appointment of auditor................................................................77 4.14.4Implementation of internal audit........................................................................77 4.14.5Internal audit finding and reporting....................................................................78 4.15 MANAGEMENT REVIEW..................................................................................78 4.15.1Roles of top management.................................................................................78 4.15.2Objectives of management review....................................................................79 4.15.3Input to the management review.......................................................................79 4.15.4Output from management review......................................................................80 5.0EMS AND ISO 14001.............................................................................................82 5.1Current Situation of Construction industry in Malaysia..........................................82 5.2Certification Process..............................................................................................82 5.3Opportunities for improvement and cost saving....................................................83 APPENDIX 1 : IDENTIFICATION OF ASPECTS AND IMPACTS FORM...................85 APPENDIX 2 : LIST OF LEGISLATION IN THE CONSTRUCTION INDUSTRY.......88

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LIST OF TABLES Table 1 : Integrating environmental management considerations into the construction approval process.................................................................................6 Table 2 : Construction Players................................................................................13 Table 3 : Sequence involved during the aspect and impact identification process......................................................................................................................19 Table 4 : Examples of associated environmental aspects and impacts from land clearing activities.....................................................................................................20 Table 5 : Examples of objectives and targets.......................................................24 Table 6 : Examples of Objectives, Targets and Programs...................................25 Table 7 : Examples of roles and responsibilities..................................................27 Table 8 : Example of responsibility matrix............................................................30 Table 9 : List of trainings that can be considered for relevant employees........33 Table 10 : Example of a training log.......................................................................34 Table 11 : Basic steps to communicate.................................................................37 Table 12 : An example of a summary of monitoring requirements for a road construction..............................................................................................................57 Table 13 : Example of the evaluation of non conformity to EIA approval conditions for the construction of a marina as gathered from site surveillance and auditing..............................................................................................................67

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LIST OF FIGURES

Figure 1 : Approach to EMS development and implementation...........................4 Figure 2 : Planning, Organization and Methods for Sustainable Construction. .8 Figure 3 : Implementation of Environmental Management System....................14 Figure 4 : Examples of Environmental Aspects and Impacts from Land Clearing 20 Figure 5 : Workflow example for evaluation of aspect significance...................21 Figure 6 : Key steps in developing a training program........................................32 Figure 7 : Environmental management system documentation pyramid..........42 Figure 8 : Basic steps to document control..........................................................46 Figure 9 : Examples of activities to include in a monitoring and measurement program.....................................................................................................................58 Figure 10 : ISO 14001 Certification Process Flowchart.......................................83

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LIST OF PLATES

Plate 1 : Example of land degradation.....................................................................9 Plate 2 : Example of forest degradation and loss of flora and fauna.................10 Plate 3 : Example of construction waste...............................................................10 Plate 4 : Example of water pollution.......................................................................11 Plate 5 : Example of Air Pollution...........................................................................11 Plate 6 : Example of noise, vibration and air pollution........................................12 Plate 7 : Example of land contamination...............................................................13

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INTRODUCTION TO GUIDELINES (PURPOSE) This EMS Guidelines is prepared to facilitate contractors to set up an EMS for their company and as such be able to understand and implement a system suitable for their company. This is envisioned to bring about confidence and prepare the way to attain the International ISO 14001 Certification which would allow Malaysian companies to compete globally in an equal footing with their counterparts from other countries.

WHAT IS THIS MANUAL? More and more companies are implementing Environmental Management Systems (EMS) to reduce their environmental impacts, improve their efficiency, comply with legislation and demonstrate to clients their commitment to environmental protection. Many companies have chosen to obtain independent certification of their EMS to the international standard ISO14001. Construction Industry Development Board Malaysia has developed a support package of Construction Environmental Management Standards (CEMS) based on the ISO 14001 EMS, for the construction industry to implement in order to: i) ii) iii)

provide assistance to the local construction industry to conform to the environmental stewardship beseeched by the regulations (to stay competitive in the environmentally-conscious world business market); help the local construction industry to get prepared for future pressure in ISO 14001 EMS; and enhance the environmental performance of local construction industry

This EMS support package is designed to help local construction industry to implement an effective environmental management system. The support package comprises of: • •

Generic ISO 14001 EMS Templates – to be used as a basis of the CEMS by companies that can tailor them to suit their specific needs. User Manual – with easy-to-use guidance on how to apply the Generic ISO 14001 EMS templates in the company and work progressively towards successful CEMS implementation.

This User Manual and Generic ISO 14001 EMS Templates are designed to be of assistance to any construction in any sector. The construction environmental management system is meant as ‘A more holistic approach involving procedure to identify total environmental and social costs and alternative solutions to construction problems’.

SCOPE Any development projects, irrespective of size, type and location that will cause impacts onto the environment arising from the construction activities, for as long as the construction goes on until the commissioning stage

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A Guide for Environmental Management System in the Construction Industry

WHO SHOULD READ WHAT IN THIS MANUAL? An effective CEMS requires the involvement of all staff in the organization, from top management to the general workers. However, this guideline should be made known and made available for understanding and implementation at all levels. One of the key players that would be responsible for the smooth implementation of these guidelines would be the Environmental Management Representative (EMR). The EMR would be able to guide and be responsible for the effectively implementation of the company policies, develop EMS documentation and eventually, to achieve a level that would allow the organization to be ready for ISO 14001 Certification. Even so, other staff will still need to be involved in various ways. Different parts of this support package should be read by the relevant people as follows:

Responsibility

Which part to read

Expectations

Top Management

User Manual (Introduction, and sections on policy and EMS manual)

•

General perspectives on ISO 14001

•

Provide the resources needed for a successful EMS

•

Develop a tailored documentation

•

Implement an effective EMS

•

Develop plan to achieve ISO 14001 certification or selfdeclaration

i. Director

EMS Manager / This User Manual, Coordinator the Generic ISO 14001 EMS i. Senior Templates, and Engineer Practical Examples ii. Site Engineer of ISO 14001 EMS iii. Quality Manager

EMS

iv. Site Manager v. Safety Manager vi. Environment al Management Manager vii. Contracts manager Department Heads

User Manual and Practical Examples of ISO 14001 EMS

•

Knowledgeable on how their functions need to support the EMS

Frontline Staff

Practical Examples of ISO 14001 EMS

•

Manage the environmental impacts related to the daily working activities, and how

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A Guide for Environmental Management System in the Construction Industry

they can be controlled. Who should read the manual  Contractors  Developers  Subcontractors  EMS Manager / Coordinator  Site Supervisor  Environmental officer  Health and Safety Officer Others who should read the manual • Project Management • Suppliers • Civil Engineers • Mechanical and Electrical Engineers • Architects • Quantity Surveyors • Regulators • Councils • Others who are directly or indirectly related to the industry

HOW IS THIS GUIDELINES STRUCTURED? • • • •

Describes the guidelines and how it should be used Summarises the EMS concept with an overview of the development and implementation approach Describes the process for planning an EMS Explains the general ISO 14001 certification process and steps involved leading to the ISO 14001 certification.

AIM OF THE CEMS     

To project the environmental issues that might arise from the construction To prevent unwanted environmental problems To minimize environmental risks associated with construction To comply to laws and regulations To improve the overall environmental performance of the construction industry of Malaysia

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A Guide for Environmental Management System in the Construction Industry

1.0 INTRODUCTION 1.1

WHAT IS EMS ?

An Environmental Management System (EMS) is a system that is dedicated to achieve a continual business cycle of planning, implementing, reviewing and improving the processes and actions that an organization undertakes to meet its environmental obligations and continually improve it’s environmental performance. An effective EMS is developed on the concept of “Plan, Do, Check, Act” (PDCA) model which embodies the concept of continual improvement. Implementation of an EMS is a voluntary approach to improving environmental performance. 1.1.1

Key EMS concepts

An effective EMS is built on Total Quality Management (TQM) concepts. To improve environmental management, the need to focus is not only on what things happen but also on why they happen. Over time, the systematic identification and correction of system deficiencies leads to better environmental (and overall organizational) performance. One key aspect of this is the concept of continual improvement. In the EMS model described in this Guidelines, the “Plan, Do, Check, Act” steps have been expanded into seventeen elements that are linked together as shown in Section 1.2.2. 1.1.2

Key elements

The EMS is built on the “Plan, Do, Check, Act” model to ensure that environmental matters are systematically identified, controlled, and monitored. This ensures that the performance of the organisation's EMS improves over time and the set goals are met for implementing the EMS. The 17 EMS elements that are common to most EMS models are described here and the key linkages among these elements are also identified.

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A Guide for Environmental Management System in the Construction Industry

Environmental Policy — Develop a statement of your organization’s commitment to the environment. Use this policy as a framework for planning and action. Environmental Aspects— Identify environmental attributes of your products, activities and services. Determine those that could have significant impacts on the environment. Legal & Other Requirements— Identify and ensure access to relevant laws and regulations, as well as other requirements to which your organization adheres. Objectives, Targets & Programs— Establish environmental goals for your organization, in line with your policy, environmental impacts, the views of interested parties and other factors. Plan actions necessary to achieve your objectives and targets. Resources, Roles, Responsibility & Authority— Establish responsibilities for environmental management and provide resources.

roles and appropriate

Competence, Training & Awareness— Ensure that your employees are trained and capable of carrying out their environmental responsibilities. Communication— Establish processes for internal and external communications on environmental management issues. Documentation— Maintain information on your EMS and related documents. Control of Documents— Ensure effective management of procedures and other system documents. Operational Control— Identify, plan and manage your operations and activities in line with your policy, objectives and targets. Emergency Preparedness & Response— Identify potential emergencies and develop procedures for preventing and responding to them. Monitoring & Measurement— Monitor key activities and track performance. Conduct periodic assessments of compliance with legal requirements. Evaluation of Compliance Non-conformity & Corrective Action & Preventive Action— Identify and correct problems and prevent their recurrence. Control of Records— Maintain and manage records of EMS performance. Internal Audit— Periodically verify that your EMS is operating as intended. Management Review— Periodically review your EMS with an eye to continual improvement.

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1.2

WHY NEED AN EMS ?

EMS is a systematic approach to achieve your environmental and other organisational goals. Does your organization need an EMS? Well, ask yourself the following questions: Is your organisation required to comply with environmental laws and regulations? Are you looking for ways to improve your environmental performance? Is the state of your organisation’s environmental affairs a significant liability? Does a lack of time or resources prevent your organisation from managing its environmental obligations effectively? Is the relationship between your organisation’s environmental goals and other goals unclear?

If you answered YES to one or more of the above questions, an EMS can help your organisation —and so will this Guidelines! Implementing an EMS can help you demonstrate your commitment to the environment in several important ways. First, an effective EMS makes good sense, whether your organisation is in the public or private sector. By helping to identify the causes of environmental problems and then eliminate them, an EMS can help you save money. Think of it this way:  make a product (or provide a service) right the first time without having to fix it later  prevent a spill in the first place rather than clean it up later  prevent pollution instead of managing it later Second, an EMS can be an investment in long term viability of your organisation. An EMS can help you to be more effective in achieving environmental goals. An EMS adds value to your organization in keeping existing customers and attracting new ones. Much of what you need for an EMS may already be in place! The management system framework described in this Guidelines includes elements that are common to managing many organisational processes, such as quality, health and safety, finance, or human resources. As you review this Guidelines, you will probably find that your organisation has many EMS processes in place, even though they may have been designed for other purposes. Integrating environmental management with other key organisational processes can improve financial, quality and environment.

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A Guide for Environmental Management System in the Construction Industry

Benefits  improved environmental performance  reduced liability  competitive advantage  improved compliance  reduced costs  fewer accidents  employee involvement  improved public image  enhanced customer trust  more favourable credit terms  meet customer requirements

1.3 1.3.1

EMS DEVELOPMENT AND IMPLEMENTATION Steps for EMS development and implementation

This guide recommends the four step “PDCA” approach to implementing an EMS. When an EMS is to be initially set-up, two preliminary steps (initial planning and management commitment) are also recommended as shown in Figure 1. These steps are useful to facilitate the development and implementation of the EMS. The figure also illustrates the different tasks for each phase. The detailed implementation of each phase is described throughout the rest of this Guideline.

Initial EMS Planning

Management Commitment

PLAN Environmental Aspects Legal & Other Requirements Objectives & Targets Environmental Management Programs

ACT Management Review

CHECK Monitoring & Measurement Nonconformance & Corrective & Preventive Action Records EMS Audit

Continual Improvement DO

Structure & Responsibility Training, Awareness & Competence Communication EMS Documentation Document Control Operational Control Emergency Preparedness/Response

Figure 1 : Approach to EMS development and implementation SOME OF THE KEY STEPS TO A SUCCESSFUL EMS INCLUDE: a) Top Management Commitment Applying TQM principles to the environmental area and providing adequate resources are the job of top management. To initiate and sustain the EMS effort, top management must communicate to all employees the importance of: 4

A Guide for Environmental Management System in the Construction Industry

 making the environment an organisational priority (thinking of effective environmental management as fundamental to the organisation’s survival)  integrating environmental management throughout the organization (thinking about the environment as part of product/service and process development and delivery, among other activities)  looking at problems as opportunities (identifying problems, determining root causes and preventing problem recurrence) b) Focus on Continual Improvement The concept of continual improvement recognises that problems will occur. A committed organisation learns from its mistakes and prevents similar problems from recurring. c) Flexibility An effective EMS must be dynamic to allow an organisation to adapt to a quickly changing environment. For this reason, the EMS must be flexible and kept simple. This also helps make your EMS understandable, user friendly and be easy enough for implementation by any organisation's managers and employees. d) Compatibility with Organisational Culture The EMS approach and an organisation’s culture should be compatible. For some organisations, this involves a choice:  tailoring the EMS to the culture, or  changing the culture to be compatible with the EMS approach. Keeping this compatibility will ensure that the EMS meets any organisation’s needs. e) Employee Awareness and Involvement To overcome potential difficulties, everyone needs to understand:  why an organisation needs an effective EMS,  what their role is, and  how an EMS will help to control environmental impacts in a cost-effective manner. Employee involvement helps to demonstrate the organisation’s commitment to the environment and helps to ensure that the EMS is realistic, practical and adds value. Building or improving an EMS (with the help of this Guideline) provides an opportunity to assess how your organisation manages environmental obligations and to find better (and more cost-effective) solutions. Difficulties are to be expected in the early stages of implementation but the focus is on continual improvement. 5

A Guide for Environmental Management System in the Construction Industry

2.0 CONSTRUCTION AND ENVIRONMENT 2.1

CONSTRUCTION INDUSTRY IN MALAYSIA

The construction industry translates idea of knowledge into reality and this reality is the embodiment of the built environment. Buildings and structures change the nature, function and appearance of our cities and countryside. Sustainable development in the construction industry, or also known as sustainable construction, would require the creation of buildings and infrastructure to shape communities in a way that sustains the environment, generates wealth over the long term and enhances the quality of life of people without the expense of the future generation. The economic, social and environmental benefits which can flow from a more efficient and sustainable construction industry are potentially immense. Reducing consumption materials and land, minimizing waste, using recycled materials, embracing energy efficiency and managing site operations to avoid pollution are good for business as well as the environment. Achieving long term sustainability in the construction industry requires analysis and changes to what is built, where it is built, how it is built and the operation of the built facilities. 2.2

CONSTRUCTION PROCESS

Construction industry is the industry that concerns construction works and that includes construction extension, installation, repair, maintenance, renewal, removal, renovation, alteration, dismantling or demolition of: a) any building, erection, edifice, structure, wall, fence or chimney, whether constructed wholly or partly or below ground level; b) any road, harbour, railway, cable way, canal or aerodrome; c) any drainage, irrigation or river control works; d) any electrical, mechanical, water gas, petrochemical or telecommunication works or; e) Any bridge, viaducts, dam, reservoir, earthworks, pipeline, aqueduct, culvert, driveshaft, tunnel or reclamation works. Table 1 : Integrating environmental management considerations into the construction approval process Approval process Project Identification: Consult local agencies

Environmental Management Considerations Site suitability

Feasibility Study Concept layout

Initial environmental review Identification of aspects and impacts Identification of legislature and regulations; Develop Environmental Management Plan

Project Appraisal Land use compatibility, Conservation values of area

Identification of legislature and regulations; Develop Environmental Management Plan Develop environmental policy, objectives & targets

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A Guide for Environmental Management System in the Construction Industry

Project Master Plan

Develop environmental policy, objectives & targets Incorporating environmental management plan Establish and train in Environmental Management System

Project Design

Establish and train in Environmental Management System

Project Constructions Site investigations, Site preparation Constructions

Incorporating environmental management plan Establish and train in Environmental Management System Monitoring environmental aspect & impacts; Mitigating measures Environmental auditing Environmental Performance Evaluation

Commissioning

Construction is not inherently environmental friendly industry and many research conducted has portrayed construction as a major contributor to environmental disruption and pollution. Construction activity is one of the major contributors to the environmental impacts, which are typically classified as air pollution, waste pollution, noise pollution and water pollution. The construction activities have a significant impact on the environmental across a broad spectrum of off-site, on-site and operational activities. Off site activities concern the mining and manufacturing of materials and components, land acquisition and project design. On site construction activities relate to the construction of a physical facility, resulting in air pollution, water pollution, traffic problems and the generation of construction wastage.

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A Guide for Environmental Management System in the Construction Industry

PLANNING AND ORGANISATION

Environmental Impacts of Construction Activity

Construction Planning

Work Sites

Construction Materials

Traffic Planning

Machinery

CONSTRUCTION METHODS Structures

Underground Works

Earthworks Runoff and Drainage

Environmental Mitigation

Figure 2 : Planning, Organization and Methods for Sustainable Construction 2.3

IMPACTS OF CONSTRUCTION ACTIVITIES ON THE ENVIRONMENT

Activities in the construction industry are complex, highly dispersed and resource demanding. The industry contributes to the loss of important natural assets and imposes severe impacts and stress on the environment. Construction activities and practices that fail to control its impacts and the environment can cause damage to rivers, lakes and environmentally sensitive ecosystems, kill fish and aquatic life, upset ecological systems and wildlife habitats, and result in contamination of land and groundwater. The impact on the environment is particularly high when work is done on highland, on slopes, near coastal areas, rivers and lakes. When construction occurs near built-up areas, poor practices may result in noise and air pollution which may cause a nuisance and affect the health of neighbouring communities.

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A Guide for Environmental Management System in the Construction Industry

2.3.1

Land degradation

Large projects usually involve extensive land disturbance involving removing vegetation and reshaping topography. Such activities make the soil vulnerable to erosion. Soil removed by erosion may become airborne and create a dust problem or be carried by water into natural waterways and pollute them. Due to the soil erosion of the exposed and loose earth, there will be a deterioration of water quality in the surrounding water bodies due to siltation and sedimentation. Siltation and sedimentation in the water bodies can result in mud floods and flash floods in the downstream area during heavy downpour. Landslides and slope failure can occur at unstable slopes or when saturated with water during heavy rainfalls. Measures to address the impact of land disturbance on the environment should be included in the planning and design phase of the project before any land is cleared. Extent of exposure of bare surfaces to rainfall needs to be limited. Surfaces need to be covered with turfing and plastic sheets as soon as possible.

Plate 1 : Example of land degradation 2.3.2

Loss of flora and fauna

The biological environment includes non-human animal and plant life, the distribution and abundance of the various species and the habitats of communities. Species forming a community are often interdependent so that a direct environmental effect on one species is likely to have indirect effects on either species. Unfortunately, the loss of flora and fauna is imminent in any development. Planning is essential to ensure minimal losses during the implementation stages and steps must be taken later to ensure that the losses are “replenished.” This is essential especially when development is within the vicinity of a mountain range, a densely forested area and catchment areas. At the Planning stage, if the environmental considerations are described in detail and allowances made for implementation during the construction stages, then, the losses would be minimised and and better protection could be put in place for the conservation of the flora and fauna.

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A Guide for Environmental Management System in the Construction Industry

Plate 2 : Example of forest degradation and loss of flora and fauna 2.3.3

Solid wastes

Solid waste can be either hazardous or non hazardous. Construction projects generally generate more non hazardous waste than hazardous wastes. Some of the types of wastes found at a typical construction site are construction waste, domestic waste and scheduled waste. Construction waste are solid inert waste which usually consists of building rubble, but may also include as demolition material, concrete, bricks, timber, plastic, glass, metals, bitumen, trees and shredded tires. Such wastes should be reused, recycled, or disposed of to an approved landfill. Disposal methods adopted depend on the nature of the material. Improper disposal can lead to the outbreak of diseases such as malaria, dengue and schistosomiasis, transmitted by mosquitoes and snails. Domestic waste can be found on construction sites which have base camps for the workers on them. Domestic wastes need to be properly disposed of to avoid the infestation of rodents, roaches and other pests. These pests bring with them vector borne diseases such as cholera and rabies. The contractor is also responsible in proper handling, storing, transporting and/or disposing of scheduled wastes. Examples of scheduled or hazardous wastes are used oil, hydraulic fluid, diesel fuel, soil contaminated with toxic or hazardous pollutants, waste paints, varnish, solvents, sealers, thinners, resins, roofing cement and more. It is the responsibility of the contractor to meet the Scheduled Waste regulations under the Environmental Quality Act 1974. The responsibility covers the proper handling, storing, transporting and disposal of these wastes.

Plate 3 : Example of construction waste

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A Guide for Environmental Management System in the Construction Industry

2.3.4

Water pollution

Water quality is important for economic, ecological, aesthetic and recreational purposes. Changes in water quality may affect water treatment costs or even deny some uses of the water. The potential for soil erosion and impacts on water quality are greatest during construction when removal of vegetation for initial clearing and grading activities exposes soil and makes it susceptible to erosion. The impacts are greatest during rainy season where extensive land clearing has been carried out.

Plate 4 : Example of water pollution 2.3.5

Air pollution

Activities or major concerns for air quality are the burning of waste, the emission of dust and smoke, and the emission of chemical impurities such as heavy metals, acid and other toxic bases. Principle effects are on human health, aesthetic values (sight and smell) adjacent land uses, temperature modification and humidity changes. Air quality impacts from construction include increased dust and airborne particulates caused by grading, filling, removals and other construction activities. Air quality impacts may also result from emissions from construction equipment and vehicles.

Plate 5 : Example of Air Pollution

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A Guide for Environmental Management System in the Construction Industry

2.3.6

Depletion of resources

Activities in the construction sector are complex, highly dispersed and resource demanding. The sector contributes to the loss of important natural assets and imposes severe stress on the environment. Agricultural land is often lost through urbanization and extraction of raw materials. Forest timber is harvested for construction and building materials faster than it can replaced by planting new trees or by natural growth. Many raw materials used in construction are limited resources. For example, the reserves of some metals will be gone in less than 30 years, if the current rate of exploitation continues. The consumption of fossil fuels contributes to increased air pollution and emissions of greenhouse gases. 2.3.7

Noise and vibration

Noise and vibration would be generated by various activities and equipment used in the construction project. Noise and vibration levels due to construction activities in the project area would vary depending on the types of equipment used, the location of the equipment and the operating mode. During a typical work cycle, construction equipment may be idling, preparing to perform tasks, or operating under a full load. Equipment may be congregated in a specific location or spread out over a large area. Adverse impact resulting from construction noise and vibration are expected to be limited to areas adjacent to the project and temporary in nature. The construction noise and vibration impacts would be localised near the area where construction is taking place.

Plate 6 : Example of noise, vibration and air pollution 2.3.8

Land Contamination

Although it may be necessary to store chemicals and fuel on project sites, this inevitably creates an environmental risk. Spills can severely pollute waterways and land. Reducing the quantities of chemicals and fuel stored on-site to minimum practicable levels is desirable.

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Plate 7 : Example of land contamination 2.3.9

Players and their roles, commitment and responsibilities

The key players in any project development are the Owner, the Designer or Design Professional and the Constructor or Contractor. Other entities such as the Authorities or Regulators, subcontractors, material vendors and so forth are important supporting players in the development process, the major development of the project revolves about these three major players. Table 2 gives a list of players’ involvement at different stages of project development. Table 2 : Construction Players Main Process

Main Players

Design

The process of translating business/social needs to knowledge products

a) b) c) d) e)

Developer/Client Architect Engineer Quantity surveyor Regulatory authorities

Procurement

The process of securing the best process for transforming the k-product to built environment

a) b) c) d) e)

Developer/client Architect Engineer Quantity Surveyor Main Contractor

The process of transforming the k-product to a built environment

a) b) c) d) e) f) g) h) i) j)

Architect Engineer Quantity Surveyor Regulatory authorities Project Manager Main Contractor Skilled and unskilled workers Suppliers Plant operators Financiers

a) b) c) d)

Developer/Client Management Corporation Regulatory Authorities Consensus

Construction

Operation and maintenance

The process of utilizing the built environment to meet the business /social needs

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3.0 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

Figure 3 : Implementation of Environmental Management System

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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

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A Guide for Environmental Management System in the Construction Industry

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.

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A Guide for Environmental Management System in the Construction Industry

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.

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A Guide for Environmental Management System in the Construction Industry

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.

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A Guide for Environmental Management System in the Construction Industry

Table 3 : 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.

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A Guide for Environmental Management System in the Construction Industry

Table 4 : 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

Environmental Impacts Beneficial Adverse -Revenue from sale -loss of tree cover of marketable trees -reduced aesthetics or plants -blocked waterways -use of tree trunks for causing flooding temporary erosion -loss of terrestrial control habitat -air pollution -reuse in landscaping

slope instability -vehicular emissions -vehicular movement

Loss of terrestrial habitat, loss of biodiversity

Air pollution Emission to air

Loss of land fertility, erosion Removal of topsoil

Removal of vegetation

Resources, fuel, machinery, land area, vegetation, topsoil

-erosion and siltation -water pollution -flash floods landslides -air pollution -land contamination -water pollution -air pollution -vibration -noise pollution -risk to public safety

OUTPUT

INPUT

Cleared land

Land clearing

Generation of waste Land degradation, loss of aesthetic values

Surface runoff Erosion, siltation, flash floods

Figure 4 : Examples of Environmental Aspects and Impacts from Land Clearing

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A Guide for Environmental Management System in the Construction Industry

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 5 : Workflow example for evaluation of aspect significance 3.6.2

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.

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A Guide for Environmental Management System in the Construction Industry

4.0 DEVELOPING AND IMPLEMENTING THE SYSTEM 4.1 4.1.1

ENVIRONMENTAL POLICY The need for an environmental policy.

Commitment towards managing environmental issues is depicted in an Environmental Policy. Essentially, the environmental policy is the central focus and the driver for implementing and improving the organization’s environmental management system. It provides direction to the organization in setting its objectives and targets, development of manuals and procedures etc. The policy should be appropriate to the environmental impacts of the organization's activities, products and services (Contractors, Developers, Consultants, and Architect etc). The responsibility for setting the environmental policy rests with an organization’s top management. The top management is responsible for implementing this policy and acts as guidance to all persons working for or on behalf of the organization. This policy should be established within the scope of the organization’s environmental management system. The policy has to be reviewed from time to time preferably annually during the management review after assessing the organization environmental performance. 4.1.2

How to Draft an Environmental Policy

1. List all of organization’s existing commitments and goals related to environment (if any). 2. Analyze results of IER. Information from the review can help define specific policy commitments. 3. Brainstorm ideas to identify what other commitments can be included. Other sources of input can be from organization’s values and beliefs, organization’s strategic and business plans, view from external parties, written standards and other existing policies (Quality and Safety and Health Management). 4. Remember to keep to the three key issues of an environmental policy (Figure 2). 5. The policy should be simple, concise and general to avoid making frequent alterations and re-issues. 6. Once the policy is ready, it needs to be documented, dated and signed by top management. 7. Then the policy needs to be communicated to all employees throughout the organization, including sub-contractors. Examples of ways to communicate the policy:  on the back of key cards or name tags  read out during monthly tool box meetings  displayed on notice boards around site  uploaded on organization’s website  included in annual report The key indicator that implies effective dissemination is when employees or subcontractor understand the content of the policy and is able to explain their role and responsibility towards achieving the organization’s goals and objectives. 22

A Guide for Environmental Management System in the Construction Industry

4.2

LEGAL AND OTHER REQUIREMENTS

It is important to be aware of the environmental legislative requirements affecting the organization in order to ensure compliance and prevent prosecution, fines, and any potential bad publicity. Therefore the contractor shall establish and maintain a procedure to identify and have access to legal, and other requirements to which the organization subscribes directly applicable to the environmental aspects of its activities. Once identified, these legislations will need to be maintained in a legal register which has to be updated and changes to applicable legislation should be tracked. As this subject is wide and varied, the relevant environmental legislation will be unique to each organization and site. This is usually done after gaining and maintaining management commitment and should be carried out by the environmental management system representative, nominated individuals working for, or on behalf of the organization or specialist contributors. Organization in the construction industry should review specific process and construction site where it may requires special operating license or permit, environmental impact assessment study, building by law for control of noise etc. During the environmental aspect and impact evaluation process, the organization should be able to identify the environmental aspects and its relevant legal and other requirements. The identified applicable legal and other requirements that are associated to organization activities should be tabulated in a Legal Register. Appendix 2 lists the example of the applicable legal and other requirements that associated with the construction activities. It is essential to: 1. Identify applicable legal and other requirements 2. Maintain a procedure to identify and have access to legal and other requirements 3. Ensure that these requirements are communicated to employees and taken into account in the organization’s operations 4. Establish and maintain a list of laws and regulations as a method to keep track of legal requirements. This list has to be kept up to date. Sources of legislation and regulations:     

Local Authority Government Agencies Universities Newspaper Industry Associations

Examples of Other Requirements  Industry Codes of Practice  Industrial Standards  Sustainable Development Strategies (e.g. Agenda 21)  Contract Documents  Client Requirements

Output from the process above: • •

Establish a mechanism or a procedure to access to the applicable legal requirements and other requirements to ensure an up-to-date information A Legal List or Register addressing those requirements that applies to organization’s environmental aspects.

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A Guide for Environmental Management System in the Construction Industry

4.3

OBJECTIVES, TARGETS AND PROGRAMS

After the list of Significant Environmental Aspects has been compiled, the environmental management system requires that an organization establish its documented Environmental Objectives and Targets. Setting the objectives and targets will provide a systematic basis for the organization to improve its environmental performance and would lead to meeting the overall commitment of organization Environmental Policy and requirement of continual improvement promoted by the ISO 14001 standards. Objectives and targets should be developed to support the broad aims stated in the organization's environmental policy. They form a central part of the environmental management system and one of the criteria for its establishment lies with the output of environmental aspects and impact evaluation process. Objectives and targets are where you shift from identifying your environmental aspects and impacts to developing a plan to improve them. The other criteria is the applicable legal and other requirements to which the organization subscribes Considerations When Establishing Objectives & Targets  Organizational Commitment  Views of Interested Parties  Operations & Performance  Technology  Finance  Other Business Requirements

4.3.1

Setting Objectives and Targets

Setting of the objectives and targets must be consistent with the organization’s environmental policy and with its commitment to prevention of pollution. The objectives should be specific, and targets should be measurable, where practicable. Table 5 shows examples of objectives and targets. Table 5 : Examples of objectives and targets Comparing Objectives and Targets Objectives Reduce energy usage

Targets Reduce electricity use by 10% in 2005 Reduce natural gas use by 15% in 2005

Reduce usage of hazardous chemicals

Reduce use of high-VOC paints by 25%

Improve employee awareness of environmental issues Improve compliance with wastewater discharge permit limits

Hold monthly awareness training courses Train 100% of employees by end of year Zero permit limit violations by the end of 2005

It is essential for the organization to determine the appropriate objectives and targets that can be applied organization-wide or to projects, departments or functions depending on where the implementing actions will be needed. It should be developed by the people in the functional area involved because they will be in the best positioned to implement, monitor and achieve these goals. Once the objectives and targets have been set, it then has to be documented. 24

A Guide for Environmental Management System in the Construction Industry

4.3.2

Developing Environmental Management Program

In order to achieve the environmental objectives and targets, the organization needs an action plan -- also known as an environmental management program. The environmental management program should be linked directly to the organization’s objectives and targets — that is, the program should describe how the organization will translate its goals and policy commitments into concrete actions so that environmental objectives and targets are achieved, and should be prepared by the contractor before work starts on any construction project. To ensure its effectiveness, the environmental management programme should define:  the responsibilities for achieving goals (who will do it?)  the means for achieving goals (how will they do it?)  the time frame for achieving those goals (when?) However, the programme should be designed to be a dynamic one. For example, consider modifying the programme when:  Objectives and targets are modified or added;  relevant legal requirements are introduced or changed;  Substantial progress in achieving the objectives and targets has been made (or has not been made); or  The projects, services or processes change or other issues arise. How to Develop an Environmental Management Program: 1. Identify the actions required to implement a full environmental management system 2. Identify any timescale targets (milestones) for the system 3. Develop an outline plan showing tasks and timescales 4. Identify responsibilities, specifying those working for, on behalf of, the organization where possible 5. Ensure timescales and assumptions are realistic

Table 6 : Examples of Objectives, Targets and Programs Objective

Target

Programs

To reduce water pollution

To reduce soil erosion and siltation.

To implement earthwork or site clearance in stages. To carry out slope turfing. To construct and monitor silt trap and earth drain.

To reduce construction waste

To segregate waste according to type (reduce, reuse, recycle)

Establish segregation stations Inventory of wastes generated

4.3.3

Monitoring of Objectives, Targets and Programme

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A Guide for Environmental Management System in the Construction Industry

Monitoring and measuring on the achievement of objectives and targets on a regular basis and communicating the results of such measurement to top management are paramount to the organization. Without effective monitoring and measurement processes is like driving at night without the headlights on — the organization is moving but it can’t tell where it is going! Monitoring and measurement enables an organization to: • • • • •

evaluate environmental performance; analyze root causes of problems; assess compliance with legal requirements; identify areas requiring corrective action, and, improve performance and increase efficiency.

In short, monitoring helps the top management to manage the organization better. 4.4

RESOURCES, ROLES, RESPONSIBILITIES AND AUTHORITY

Construction enterprises should harmoniously utilize resources to minimize adverse environmental impacts through appropriate organizational assignments of roles and responsibilities. In a construction company, those in the top management should commit to provide resources that are essential in establishing, implementing, maintaining and improving the EMS. The essential resources may include human resources with specialised skills, technological, and financial resources. Human resources such as trained site supervisors in the area of environmental aspects and impacts, environmental engineer, technology such as spun drilling and financial resources for the implementation of mitigating measures such as silt traps and environmental training programmes among other things. Proper organizational structure of the construction company is needed to identify the line of responsibility and mode of reporting. This enables the organization to manage their on site operations to improve environmental performance. Top management should further ensure that desired role, responsibilities and corresponding authorities of key personnel are clearly defined, well documented and effectively disseminated. 4.4.1

Resources required to manage system

Identify organizational structure especially on site where most of the construction activities are happening. Responsible personnel to manage the system in a construction site is divided into on site and office management. Those that are involved on site include site manager, site engineer and site environmental officer. These personnel should have the correct attitudes, values and beliefs in the implementation of the EMS and should be assigned to manage the implementation of the EMS. Their roles, responsibilities and corresponding authorities, which should be clearly defined by the office management of the contractor or developer.

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A Guide for Environmental Management System in the Construction Industry

What to do? a) Identify the responsible personnel; eg site supervisor, site manager, environmental officer b) Determine the type, number and composition of the human resources, especially on site; c) Assign and mobilise these personnel; d) Monitor the needs of the personnel, such as the need to train the personnel in projecting and identifying possible impacts; e) Co-ordinate their roles so that the developer or contractor can 4.4.2

Roles, responsibility and authority

All personnel should clearly understand their environmental roles and responsibilities, as well as understand the importance of the environmental objectives and targets that they can affect. What to do: a) Identify the persons in the top and other management levels responsible for managing the implementation of the EMS; b) The commitment of the top management should be rely to the site office c) Define and communicate their EMS roles, job responsibilities and authority; Table 7 : Examples of roles and responsibilities EMS Reference Title

Environmental Policy

EMS Manual Section Number & Title

Accountability

A-1. Index

 None assigned

A-2. Introduction

 Maintain Section: EMS Representative

A-3. EMS Scope

 Define Scope & Applicability: Core team  Maintain Section: EMS Representative

A-4. EMS Manual Distribution

 Maintain Section & Distribute Manual: EMS Representative

A-5. EMS Manual Record of Revisions

 Maintain Section & Review Manual: EMS Representative

B-1. Corporate Sustainable Energy Development Policy and Principles

 Approve/Issue Env. Policy: Chairman, CEO  Comply with Policy: all staff  Maintain Section: EMS Representative

B-1. Environmental Policy

 Approve/Issue Env. Policy: Executive VP  Comply with Policy: all staff  Maintain Section: EMS Representative

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A Guide for Environmental Management System in the Construction Industry

B-2. Identifying  Establish/Maintain/Implement process at Environmental Aspects Director Environmental Affairs Environmental Aspects

Legal and Other Requirements

 Maintain/Apply Process & Develop/Maintain EMS Aspects database: B-2. Determining Director Environmental Affairs, EMS Significant Representative Environmental Aspects  Division Input to EMS Aspects database: EMS Reps, Divisions B-3. Interpreting Legal  Implement & Maintain Process: VP, Requirements Regulatory Affairs B-3. Interpreting other Requirements

 Implement & Maintain Process: VP, Regulatory Affairs  Maintain this Section: EMS Representative

Objectives and Targets

 Develop Objectives & Targets, Division Directors and EMS Core Team, Director Environmental Affairs B-4. Developing  Approve Objectives & Targets: VP Objectives and Targets Operations  Meet Objectives & Targets: Directors  Maintain Section: EMS Representative

Environmental Management Programs

B-5. Environmental Programs

4.4.3

 Approve Programs: Division Directors  Develop and Maintain Programs: Director Environmental Affairs  Maintain this Section: EMS Representative

Management representative

To implement the EMS, top management should give their commitment, play their roles, take responsibility and confer authority. They need to appoint their representative from a senior position with unambiguous job specifications. The motivations of the contractors in seeking to implement the EMS, the problems and costs to be faced and the lessons to be learned can be easily more explicit. What to do: Identify the persons in the top and other management levels responsible for managing the implementation of the EMS. This could be the project manager. Define the EMS roles, responsibilities and authority of the top management; Nominate the EMR and the Deputy EMR from the managerial level and those that are well trained in construction related environmental issues; Define the EMS job responsibilities and authority of the EMR Representative; and Disseminate the information to workers and subcontractors.

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A Guide for Environmental Management System in the Construction Industry

The following questions will need to be answered in order to determine whether the Structure and Responsibility Section meets the intent of ISO 14001: • • •

Have you defined the roles, responsibilities, and authorities of your employees with respect to the environmental management system? Have the above been documented and communicated on the project site as well as the main office? Have the following resources been provided to implement and maintain the system, especially at the project site?

   

human resources (manpower), special skills, technology, and

•

financial resources. Has a management representative been appointed?

•

Does the management representative have the following defined role:

   

establishing the EMS requirements, determining whether EMS requirements have been implemented, determining whether the EMS conformance is maintained, reporting to top management on conformance and continual

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A Guide for Environmental Management System in the Construction Industry

Table 8 : Example of responsibility matrix Communicate importance of environmental management Coordinate auditing efforts Track / analyze new regulations (and maintain library) Obtain permits & develop compliance plans Prepare construction progress and environmental monitoring and audit reports required by regulations Coordinate communications with interested parties Train employees Integrate environmental into recruiting practices Integrate environmental into the construction performance appraisal process Communicate with sub-contractors on environmental expectations Comply with applicable regulatory requirements Conform with organization's EMS requirements Maintain equipment / tools to control environmental impact Monitor key processes Coordinate emergency response efforts Identify environmental aspects of products, activities or services Establish environmental objectives & targets Develop budget for environmental management Maintain EMS records (training etc.) Coordinate EMS document control efforts Legend: L = Lead Role S = Supporting Role

Project M’gr

EHS M’gr

L

S

HR Maintenance M’gr

Purchasing /Materials

Engineering

Site Supervisor

Finance

EMS Mg’t Employee Rep.

S

L

S

S

L L

S

L L S

L L L L

L

L

S

S

S

S

S

S

S

S

L

L

S

S

S

S

S

S

S

S

S

S

L L

S S

S

L

L

S

L S

S

S

S

S S

S

L

L S

L

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A Guide for Environmental Management System in the Construction Industry

4.5

COMPETENCE, TRAINING AND AWARENESS

Significant activities: who is responsible / should be competent / trained Identify competent individuals: eg civil engineer (silt trap design) Top management should commit to train their personnel, such as the site supervisor, site engineer or the environmental, health and safety issue so that they are competent in the environmental issues. Competent in determining the aspects and impacts, competent in environmental monitoring and design of the mitigating measures such as silt traps, prevention of soil erosion, minimizing the noise level. The ultimate goal for training is to inculcate and the importance of EMS to personnel, and to explain their responsibilities for the EMS operations. Workers, personnel and project consultants (examples are bull dozer drivers, civil engineers, architects, project designers, etc) whose work may have significant impact on the environment should be competent on the basis of appropriate education, training and/or experience on environmental issues. The contractors and subcontractors must determine overall training needs required for competence with respect to the environmental management system. 4.5.1

Determining competency requirements

Training needs associated with environmental aspects and EMS should be identified, and training programmes developed to ensure awareness and competence at each relevant function and level. What are essential? a) The roles and responsibilities in achieving conformance to environmental policies and procedures; b) The importance of conformance to the environmental policy, the procedures and the requirements of the structured EMS; c) The significant environmental aspects – actual or potential – from their work activities, and the importance of control over such aspects d) The potential consequences of departure from specified operating procedures, e.g in land clearing on slopes and the importance of emergency preparedness, in case of soil erosion, flash flood or mud slide. e) Avoid resistance of field supervisors, site engineers and general 4.5.2

Training and awareness

Procedures should be established and maintained to identify the personnel’s training needs. Their awareness at each level and function should be enhanced. The 2- step approach below is one example that can assist in identifying training needs. Step 1 : Identify training needs and requirements • Review existing training programs. Other training (e.g. safety) may also satisfy the EMS requirements. • Consider both general and specific needs

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• •

Develop an EMS training package for new employee orientation Review the qualifications and training needs of trainers

Step 2 : Training Staff • Identify training needs and prepare training plan according to the training procedure. • Develop your EMS training materials. • Train EMS core team members on EMS requirements. • Conduct EMS awareness training with all staff to ensure them to be aware of environmental policy, objectives, relevant significant environmental aspects, EMS responsibilities and emergency procedures, etc. as appropriate.

Step 1 Conduct training needs & requirements

Step 2 Define training objectives

Step 3 Select suitable methods and materials

Step 4 Prepare training plan (Who, what, when, where, how)

Step 5 Conduct training Figure 6 : Key steps in developing a training program

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4.5.3

List of recommended training Table 9 : List of trainings that can be considered for relevant employees CEMS Training Plan

Training Type (examples ) 　 Raising awareness of the importance of environmental management (examples) 　 Implementation training 　 Emergency response training 　 Environmental best practice for construction site 　 Internal Auditor training

　

Target Staff (examples ) 　 All staff Site manager, EMR, etc

　

　

Responsible Personnel 　

　 Departmental Managers　 　 Relevant construction sites staff 　 All staff at construction site

　

　

　

　

　

　

　

　

　 Departmental Managers, Project Managers, EMR & DEMR 　

　 　

　

　

　

　

　

Length

Target Date

Examples of training in construction environmental best practices include soil erosion and its prevention, silting of water bodies and its mitigative measures, dust and noise impacts and how to reduce them. Air emission and noise sources, characteristics and regulatory requirements can form part of the training package. Proper training in handling chemicals is crucial that include its sources, characteristics, handling and disposal can avoid any encumbrances with the regulatory bodies such as the Department of Environment. Relevant disposal licenses and regulatory requirements should be part of the training. Training can also be determined in the identification of major types of solid wastes, generation quantity and disposal. The personnel that require these trainings comprehend the general employees on site, the site supervisor, the project manager, site engineer and even the management at the main office.

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Table 10 : Example of a training log Training Topic

Attendees* Frequency Course Course Comments Date Length Method Completed

EMS Awareness Supervisor EHS Training Hazardous Waste Management Hazardous Waste Operations Spill Prevention & Response Chemical and waste chemical Management Emergency Response Accident Investigation Hazardous Materials Transport Hazard Communication Personal Protective Equipment Fire Safety Dust and air emission control Hearing Conservation Confined Space Entry Bloodborne Pathogens ( mosquitoes) Job-Specific Training (list)

Attendees Code 1: All Employees 2: Project Manager 3: Operators 4: Maintenance 5: Site engineer 6. Site supervisor

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The following questions will need to be answered in order to determine whether the Training, Awareness and Competence Section meet the intent of EMS • Have training needs been identified? • Are all employees, whose work can cause significant environmental impacts, competent on the basis of education, training and or experience? • Have procedures been established to assure all employees are aware of the Environmental Policy, actual and potential impacts and their responsibilities? • Has the organization ensured that employees performing environmental specific tasks have the required knowledge (e.g. education, training experience)? • Does the communication process ensure that business partners, suppliers and contractors are aware of the relevant requirements of your CEMS? • Do the contractors working on site have the requisite knowledge and skills or have been trained to perform the work in an environmental responsible manner? • Are training records, certificates and licenses available to demonstrate the competence? • Have training needs been defined. • Have baseline training related to the following been provided? o importance of the CEMS, o

roles within organization related to the CEMS, and

o

consequences of deviating from the CEMS.

• Are trainings for those positions that could have a significant impact on the environment based upon education and experience required? • Are trainings with respect to emergency preparedness and response been identified? • Have the employees developed competency standards?

4.6

COMMUNICATION

Those working for, or on behalf of the organization should know what to do and how to do it, if an environmental management system is going to work. It is important that the means for communicating information exists and that communications are regular. Getting feedback is also very important, so provision for two way dialogue will be necessary. Effective internal communication requires method for information to flow top-down, bottom-up and across functional lines. Since employees are on the “front lines,” they can be an excellent source of information, issues, concerns and ideas. Internal communications such as from the general employees at site to the site supervisor, to the site manager and site engineer. The site manager can relay to the manager at the main office or even the directors of the contracting company. In any event of environmental problems on site, communication between those on site with those at the main office is crucial since allocation of budget to address any issue normally come from the main office. Correct and real time data and information during the regular scheduled meeting should be recorded and submitted to the main management for review or action. Other internal communications that are deemed crucial is between the environmental consultant to other consultants and the project manager. 35

A Guide for Environmental Management System in the Construction Industry

External communication can provide a good opportunity to promote the organization's achievements and environmental performance and consult with customers and other external interested parties. External communications can be with the local authorities and the regulatory bodies such as the Department of Environment, Department of Irrigation and Drainage. Why communication is needed? The purposes and benefits of communication can include: a) Demonstrating the organisation’s commitment and efforts to improve environmental performance, as well as the results of such efforts; b) Raising awareness and encouraging dialogue about organisation’s environmental policy, environmental performance and achievements; c) Receiving, considering and responding to questions, concerns or other inputs; and d) Promoting continual improvement of environmental performance, for problem solving, for co-ordination of activities, for follow-up on action plans and for further development of the environmental management system serves to motivate them and encourage acceptance of the organisation’s efforts to improve its environmental performance. e) Assist employees to fulfil their responsibilities and the organisation to meet its environmental objectives and targets. Effective communication should be practised: a) To avoid untoward environmental events as a result of the construction activities such as land clearing, earthworks or the construction work itself b) To motivate personnel to abide to all regulations that are closely linked to the construction industry, such as noise level, dust generation, or inland water pollution; c) To inform the employees what actions should be taken for the sake of the environment and the best practices in the construction industry; d) To confirm their roles and procedures; e) To monitor environmental performance; and f) To serve as a channel for identifying any potential for improvement.

4.6.1

Determining the need to communicate

The contractor, the project proponent and /or the developer should establish, implement and maintain procedures for communicating – internally and externally – on its environmental policy, performance or other information, based on its own needs and the needs of interested parties. Interested parties can include, for example, neighbours, non-governmental organizations, customuers, contractors, suppliers, investors, emergency services and regulators.

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Table 11 : Basic steps to communicate Begin early in the process Let people know what type of construction is going to take place. In most cases, the cooperation of several people within the organization is needed to gather information and develop an environmental management system that will work. In small and large construction companies alike, early communication will pay off in greater acceptance of the environmental management system. Set communication objectives Decide what needs to be achieved through communication regarding the construction project. (Setting this goal will help get the right message across without overloading people with too much information, spending too much time, or missing the mark) It is helpful to create an EMS communication policy. How to report environmental incidents, such as spills, accidents and “near misses”. The procedure should include who reports what, to whom, and when. Communicate regularly and integrate EMS communication To build support for the EMS, try to communicate on a regular basis.  bulletin board posting, email messages, or articles in the organization newsletter.  direct word-of-mouth communication, particularly in smaller organizations.  talking directly with key individuals at intervals Examples of information to be communicated include: a) General information about the construction that is going to be conducted; b) Management statement of the possible impacts and measures the contractor or developer is going to undertake to minimize the construction impacts. c) Environmental policy, objectives and targets; d) Environmental management processes (including employee and interested party involvement); e) The organisation’s commitment to minimize changes to the environment as a result of the construction ; f) Information related to environmental aspects of the construction, g) The contractor’s motivation and commitment to have a proper EMS in place h) Problems that the contractor anticipated and measures to be taken. i) The attitudes, values and beliefs of the contractor towards the safeguarding of the environment j) The organisation’s compliance with legal and other requirements to which the organisation subscribes, and corrective actions taken in response to identified instances of non-compliance; k) Supplementary information in reports, such as glossaries; l) Sources for further information, such as contact person(s) or websites. For both internal and external environmental communication, it is important to remember that: a) Information should be understandable and adequately explained; b) Information should be traceable; c) The organisation should present an accurate picture of its performance; If possible, information should be presented in comparable forms (e.g. similar units of measurements).

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4.6.2

Internal communication

Communication between and among the levels and functions within an organisation is crucial to the effectiveness of the environmental management system. (multiple level – developer, managers, consultants, site supervisors and employees). Issues to communicate can include, licensing, disposal and handling of wastes, noise and air emission, public complaints, soil erosion, requirement to comply to certain environmental impact approval conditions, environmental monitoring and reporting to DOE. In cases, where impacts have taken place, such as heavy silting of river due to eroded soil surfaces on site, immediate communication to the top management needs to be carried out so that appropriate actions be taken and budget identified. Budget need to be allocated to implement or improve the mitigation measures. If the local authorities take action against the construction due to severe impacts, then frequent and more intense communication between the top management on the organization structure with the local authorities needs to be takes place. Information regarding the EMS – such as the policy, objectives, targets and the environmental management programmes – and environmental performance should be made readily available to employees on notice board, or be published on the intranet or newsletters. Employees with enquiries or complaints regarding the EMS and/or environmental issues should inform their site manager, project manager or site engineer (refer to the organizational structure) Records to demonstrate the response and corrective actions that are taken should also be maintained. Information to pass down to employees: a) Activities, aspects and impacts of the construction b) Types of mitigating measures implemented c) Maintenance of the measures d) Compliance to environmental regulatory requirements e) Possible implications that might arise from non compliance f) Materials usage and control 4.6.3

External communication

Communication with external interested parties can be an important and effective tool for environmental management. Proactive methods can increase the effectiveness of external communication. Authority reporting – EIA, monitoring, EMP

External Methods: • open houses • focus or advisory groups • web site or e-mail list • press releases • annual reports • advertising • informal discussions • attending community

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EXAMPLE OF EMS PROCEDURE FOR EXTERNAL COMMUNICATION I. Purpose This procedure is intended to establish a process for outreach and communication with external parties regarding the organization's environmental management system (Note: the organization should also consider external communication regarding its significant environmental aspects). II. Scope This procedure describes how the organization receives, documents, and responds to communications from external parties. In addition, it discusses proactive steps that the organization takes to maintain a meaningful dialogue with external parties on environmental matters. III. Definitions Interested Parties- Individuals or groups with an interest in the environmental impacts of the organization's products, activities or services. These parties include regulators, local residents, employees, stockholders, insurers, customers, environmental groups and the general public (adapted from ISO 14001). IV. General The organization uses a number of mechanisms to ensure effective communication with interested parties. These mechanisms include regulatory filings (such as permit applications and reports), open houses, the media, and informal discussions with regulators, community representatives, and local business leaders. To solicit the views of interested parties, the organization may use additional techniques, including (but not limited to) surveys, community advisory panels, newsletters, or informal meetings with representatives of external groups. General rules for external communications require that the information provided by the organization: • be understandable and adequately explained to the recipient(s); and • present an accurate and verifiable picture of the organization and its environmental management system, its environmental performance, or other related matters.

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A Guide for Environmental Management System in the Construction Industry

V. Procedure A. Management of Communications from External Parties 1. Inquiries and other communications (received by mail, fax, telephone, or in person) from external parties concerning the organization's EMS or environmental performance may be received by a number of the organization’s representatives, including the Plant Manager, the environmental manager, and the human resources manager, among others. All such communications are reviewed by the Plant Manager or his / her designee to determine the appropriate response. 2. Communication with representatives of regulatory agencies is delegated to the organization’s environmental manager, who maintains records of all such communications (both incoming and outgoing). In the absence of the environmental manager, communications with regulatory officials are delegated to the human resources manager. 3. Copies of all other written communications on environmental matters are maintained by the human resources manager. All non-written communications from external parties are documented using telephone logs or similar means. All records of external communications are maintained as discussed in Procedure # (Records Management). 4. A record of the responses to all communications from external parties is maintained by the human resources manager in files designated for that purpose. B. Outreach to Interested Parties 1. The organization solicits the views of interested parties on its environmental management system, its environmental performance, and other related matters. In particular, such outreach is conducted when significant changes at the facility are being considered, such as facility expansion or other actions that might affect the actual or potential environmental impacts of the organization’s products, activities, or services. 2. As part of the Management Review process, the team designated to conduct the Review evaluates proactive efforts to communicate with external parties. Based on this evaluation and other factors, the organization’s management determines the need for outreach with external parties in the coming year and how such communications can be carried out most effectively.

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The following questions will need to be answered in order to determine whether the Communication Section meets the intent of ISO 14001: • • • •

Do you have an internal communication process for the environmental management system? Do you have a process in place for receiving and responding to "relevant" external communications? Have you decided whether it will communicate to external parties’ information with respect to its significant environmental aspects? If you decided not to communicate information to external parties with respect to its significant environmental aspects, has it established a record of that decision?

Effective communications will help you: • motivate your workforce; • gain acceptance for your plans and efforts; • explain your environmental policy and CEMS and how they relate to the overall organizational vision; • ensure understanding of roles and expectations; • demonstrate management commitment; • improve your relationship with the community; • monitor and evaluate performance; and • identify potential system improvements.

4.7

DOCUMENTATION AND CONTROL OF DOCUMENTS There are a number of documents that are commonly linked to construction and these are environmental impact assessment (EIA), environmental management program (EMP), environmental monitoring, documents of aspects and impacts and the EMS manual. Many of these documents that are required under the regulation can positively provide great input into the documentation of the EMS documents, while maintaining its own identity. To ensure that its The environmental management system is understood and operating EMS documentation comprises four levels: effectively, an organisation should develop and maintain adequate documentation of the EIA, EIA approval conditions, EMP and environmental monitoring and auditing. CEMS Other documents include method statement, such as method statement for land Manual: clearing, dredging, soil erosion prevention, chemical waste handling, biomass handling and design of mitigating measures, for example silt trap and prevention of Top Level slope failure. The purpose of such documentation is to provide necessary information Overview of CEMS to employees and other interested parties as appropriate. Operating Procedures: Relevant to Locations/Functions Work Instructions Relevant to Departments/Tasks 41

Environmental Records

A Guide for Environmental Management System in the Construction Industry

Figure 7 : Environmental management system documentation pyramid Documentation should be collected and maintained in a way that reflects the culture and needs of an organisation, building onto and improving its existing information system. The extent of the documentation can differ from one organisation to another but it should describe the environmental management system (see Practical help – Documentation below). For effective management of its key processes – i.e. those related to its identified significant environmental aspects – an organisation should establish (a) procedure(s) that describe, in appropriate detail, a specified way of carrying out each process. If an organisation decides not to document a procedure, appropriate employees need to be informed, through communication or training, of the requirements to be satisfied. 4.7.1 •

Development of environmental manual

Each document should have the following information: ∗Title (subject) ∗Document number ∗Revision & Copy number ∗Issue/Revision/Effective Date ∗Document originator ∗Approval (signature) ∗Cross-references

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A Guide for Environmental Management System in the Construction Industry

•

EMS documents can be maintained electronically for easy access and reference. However it must be controlled and ensured that only the administrative department and EMR are able to change the documents on the server.

•

Hard copies of these documents must be labeled Controlled Copy, Master Copy and Uncontrolled Copy.

•

Keep the procedure simple. Start with a few copies, and then add more if the need arises.

•

Maintain a master list of documents. This list would show all the EMS documents and a history of its revision. Also maintain a distribution list, showing who has each copy. This would ensure ease in tracing the documents.

Linkages among EMS documentation, document control and records

4.7.2

Document Requirements

EMS Documentation

Procedures

Document Control Requirements

Preparation

Records Requirements

Identification

Policy

Others…

Issuance

Revision

Disposition

Retention

Storage

Disposition

Content of environmental manual

An organisation may choose to summarise information in the form of a manual, which constitutes an overview or summary of the environmental management system and can provide direction to related documentation.

What Constitutes EMS Documentation? Your environmental policy Your organizational structure and key responsibilities A description or summary of how your organization satisfies EMS requirements (e.g., “How do we identify environmental aspects?”. “How do we control documents?” How do we comply with legal requirements?”) System-level procedures (e.g., procedure for corrective action) Activity- or process-specific procedures / work instructions Other EMS-related documents (such as emergency response plans, training plans, etc.)

The structure of any such environmental management system manual need not follow the clause structure of ISO 14001 or any other standard.

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4.7.3

Control of document

The essences of EMS documentation controls are: a)They should be periodically reviewed, revised as necessary and approved for adequacy by authorised personnel; b)The current version of relevant documents should be available at all locations where operations essential to the effective functioning of the EMS are performed; c)Obsolete documents should be promptly removed from all points of issue and use or otherwise assured against unintended use; and d)Any obsolete documents retained for legal and/or knowledge preservation purposes should be suitably identified. Why need to control of environmental management system documents a) Documents can be identified with the appropriate organisation, division, function, activity or contact person; b) Documents (other than records) are regularly reviewed, revised as necessary and approved by authorised personnel prior to issue; c) The current versions of relevant documents are available at all locations where operations essential to the effective functioning of the system are performed; and d) Obsolete documents can be promptly removed from all points of How documents can be effectively controlled : a) Developing an appropriate document format that includes unique titles, numbers, dates, revisions, revision history and authority; b) Assigning the review and approval of documents to individual with sufficient technical capability and organisational authority; and c) Maintaining an effective document distribution system. Documents can be managed in any medium (paper, electronic, photos, posters) that is useful, legible, easily understood and accessible to

What EMS Documents should be controlled? Consider the following: Environmental policy Objectives and targets Roles, responsibilities and authorities EMS description document (“manual”) System-level procedures Process-or activity-level procedures / work instructions Related plans (such as emergency response plans

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TIPS

•Keep the documentation simple. • Use results from baseline assessment as a foundation or starting point. • Include organization’s mission statement, vision, guiding principles and annual objectives to emphasis importance of CEMS in overall business goals. • Continually reevaluate whenever changes occur.

The following questions will need to be answered in order to determine whether the EMS Documentation Section meets the intent of ISO 14001: • • •

•

•

•

Do you have existing documentation of your EMS? How is this EMS documentation maintained (electronically? In paper form?) Who is responsible for maintaining EMS documentation within your organization? Do you have a EMS manual or other summary document that describes the key elements of the EMS? If so, does this document describe the linkages among system elements? What does your EMS documentation consist of? (List components such as environmental policy, EMS manual, activity-level procedures or work instructions, emergency plans, etc.) Is your EMS documentation integrated with other organizational documentation (such as human resource plans or quality procedures)? If so, how do you ensure proper coordination between environmental and these other functions? How will you keep your EMS documentation up-to-date?

Top management approve and sign all EMS Documents Environmental Management Representative prepare and revise all EMS

documents.

Administration Department

DEFINITIONS Controlled copy-documents posted on the company server for read-only access or the hard copy. Subjected to automatic update when a new revision is released. Uncontrolled Copy - Not subjected to automatic update when a new revision is released. It is for reference only. Master Copy – original hard copy of the document that shall be approved and signed by authorized employees.

responsible for the EMS document control system ensure that only controlled and current copies of documents are used, & distribute controlled EMS documents to relevant employees whenever updated versions are available maintain and update Master List of EMS Documents. Functional or Department Manager review relevant EMS documents and procedures, ensure subordinates are familiar with updated EMS documents related to them, and report any proposed changes to EMS documents and forms to EMS Committee.

ASK: Is everyone working with the same set of documents? 45

A Guide for Environmental Management System in the Construction Industry

Control of Documents Procedure

New documents are written.

MY-QE-42-P01

Authorized personnel review documents and approve them for adequacy. They also review, update and reapprove documents.

Procedure

External Document

Obsolete Document

External Documents are identified and their distribution is controlled

Obsolete documents are identified and discarded or archived

Changes and the current revision status are identified

Up-to-date documents are available at work locations Documents remain legible and readily identifiable

Figure 8 : Basic steps to document control The following questions will need to be answered in order to determine whether the Document Control Section meets the intent of ISO 14001: • •

• • • •

Do you have an existing process for controlling EMS documents? If yes, does that process need to be revised? In what way? Who needs to be involved in this process within your organization? Who needs access to controlled copies of EMS documents? How do you ensure that they have access? How do you ensure that EMS documents are periodically reviewed and updated as necessary? Who has authority to generate new documents or modify existing ones? How is this process managed? How are users alerted to the existence of new EMS documents or revisions to existing ones?

•

How do you ensure that obsolete documents are not used?

•

Is your EMS document control process integrated with other organizational functions (such as quality)? If so, how do you ensure proper coordination

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4.8

OPERATIONAL CONTROL

Operation control procedures should be established and maintained to manage significant environmental aspects. All operations and activities that are associated with significant environmental aspects, carried out by employee or contractor, should be properly controlled. Operations that can and should be controlled are those that can spawn impacts and in construction industry these are associated with the construction activities. Control is applied to pre construction planning for the most effective environmental outcome and should be continuously applied during the construction phase. However, precautions and measures to prevent environmental problems are preferred to structural control that either reduces or controls impacts. Large construction projects that involve extensive land disturbance and removing of vegetation and reshaping topography will spawn land disturbance that need t be controlled. Measures to address the impact of land disturbance on the environmental should be included in the planning and design phase of the construction project before land is cleared. 4.8.1

Identifying need for operational control

Operational controls are one of the means through which the EMS can control the SEA’s. (The other is setting the objectives and targets and the Environmental Programmes). Control needs of identified impacts such as erosion has to be preventative rather than treatment. An example of control is keeping land clearance to a minimum. Control of activities that generate noise and vibration include fitting and maintaining appropriate mufflers on earth moving vehicles and or enclosing the equipment or provide noise attenuation screen. Other control needs are on the generation of air emission and dust, emergency situations and waste generations. Why operational controls are necessary a) Manage identified significant environmental aspects; b) Ensure compliance with legal requirements and other requirements to which the organisation subscribes; c) Achieve objectives and targets and ensure consistency wit hits environmental policy, including the commitment to prevention and continual improvement; and When identifying needs for operational controls, an organisation should consider all of its operations, including those related to management functions such as purchasing, sales, marketing, maintenance, laboratory analysis and product storage; and external processes such as delivery of products and services. An organisation should also consider how contractors or suppliers might affect its ability to manage environmental aspects, achieve objectives and targets, and otherwise comply with applicable legal requirements and other requirements to which the organisation subscribes. An organisation should 47

A Guide for Environmental Management System in the Construction Industry

4.8.2

Development of operational control

Operational controls can take various forms, such as procedures, work instructions, physical controls, use of trained personnel or any combination of these. The choice of the specific control methods depends on a number of factors, such as the skills and experience of people carrying out the operation and the complexity and environmental significance of the operation itself. There are several strategies that can be employed to control construction activities and reduce impacts. As an example, working in sequential and smaller sections of the project site at any one time. If rehabilitation is commenced immediately after works have been completed, the impacts of erosion, contaminated run off and dust is reduced. Keeping haul roads to a minimum and routing them to avoid erodible areas such as sloping terrain will also control dust and erosion problems. It is important to have accurate information about on site drainage for each micro catchment so those control devices are adequately designed for expected flow and load. Specifications for diversion drains and temporary storm water controls to reduce on site volumes should be included in the plan. Plans should identify the position and design specification of structures taken to control: a) sediment run off b) dirt on roads c) noise and vibration d) dust A common approach to establishing operational controls includes: a) Choosing a method of control; b) Selecting acceptable operating criteria; c) Establishing procedures, as needed, that define how identified operations are to be planned, carried out and controlled; and d) Documenting these procedures, as needed, in the form of instructions, signs, forms, videos, photos, etc In addition to procedures, work instructions, and other control mechanisms, operational controls can include provisions for measurement and evaluation and for determining whether operating criteria are being met. An organisation may choose to establish procedures to enhance its ability to implement controls in a consistent manner. Operational

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4.8.3

List of operational control procedures

Prepare list of operational control procedures. Follow these steps: a)Identify operations and other activities that are related to SEA’s and/or legal requirements; b)Define controls implemented at each operation or activity; c)Draft the instructions and review them with people who are responsible for their implementation to ensure these instructions are appropriate, realistic and practical.

 

    

Activities that might require operational controls: Land clearing Management of biomass Storage & handling of chemicals and construction wastes Piling Wastewater treatment Earthworks Movement of heavy vehicles

Other control measures that can be developed include: a) Increase inspection and surveillance and monitoring frequency so that new or underestimated impacts are quickly identified and managed b) implement a preventative maintenance program for pollution control installations to reduce impacts from equipment failure c) Implement contingency plans such as ensuring that corrective actions on a failing control measure is prompt. Such a contingency plan will reduce the environmental impact of a hazard. d) When work I is done near an environmental sensitive area, then special precautions should be identified in the control plan How to develop environmental procedures •Review the environmental aspects and potentially significant impacts which have been identified earlier. •Identify operations and other activities that are related to Significant Environmental Aspects •Develop procedures for controlling each operation / activity, keeping it simple. Use flow charts whenever possible. •Draft the instructions and review them with the people who are responsible for their implementation to ensure these instructions are appropriate, realistic and practical

Hints on Writing Procedure Understand the existing process. Start with a flow chart. Build on informal procedures where possible. Focus on steps needed for consistent complementation. Use a consistent format and approach. Review draft procedures with employees that will have to implement them. (Better yet, enlist employees to help write them.) Keep procedures simple and concise. Excessive detail does not provide better control and can confuse the user.

Factors that could affect the need for documented procedures •risk of activity •complexity of activity or method •degree of supervision •skills/training of workforce

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Remember to consider maintenance and calibration of equipment as these tasks might also have a significant impact.

The following questions will need to be answered in order to determine whether the Operational Control Section meets the intent of ISO 14001: •

•

Have you identified operations and activities associated with significant environmental aspects, legal requirements and environmental objectives? If not how will these be accomplished? Who should be involved? What operations and activities are associated with significant environmental aspects?

•

What operations and activities are associated with legal requirements?

•

What operations and activities are associated with environmental objectives and targets? How are the above operations and activities controlled? (list methods)

• •

•

How do you know whether these controls are adequate i.e., to manage significant aspects, to ensure compliance, to achieve objectives, carried out under specific conditions? How do you train employees and contractors on relevant operating controls?

•

If new controls are needed (or existing ones need to be revised), what is your process

4.9

EMERGENCY PREPAREDNESS AND RESPONSE

Sufficient personnel awareness on emergency preparedness should be maintained. To respond to emergency situations – in order to mitigate, reduce and/or eliminate the environmental health and safety impacts – emergency preparation and procedures should be implemented. This element requires the organization to establish and maintain procedures to: • •

identify potential for and respond to accidents and emergency situations prevent and mitigate these situations and the environmental impacts that may be associated with them with emergency plans/procedures

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•

review and revise these procedures where necessary, particularly after the occurrence of accidents or emergency situations. This will determine if more

An organisation should establish, implement and maintain (a) procedures(s) detailing how to identify potential emergency and potential accidents that can have an adverse environmental impact(s), and the appropriate mitigation and response actions if such situations occur. The procedure(s) and associated controls should include, where appropriate, consideration of: a) accidental emissions to the atmosphere b) accidental discharges to water and land; and training is needed or if the emergency plans / procedures should be revised. 4.9.1 Potential emergency situation & potential accident in construction sector A procedure should be established and maintained to identify potential emergency situations, and to respond to such situations. Examples of Potential Emergency Situations: Fire/Explosion Rainstorms or other unexpected weather conditions Major chemical spillage or leakage Accidents as a result of equipment failure Slope failure Flash floods Landslides

In establishing its procedure(s), the organisation should include 4.9.2 Development of relevant emergency preparedness & response consideration of: procedure a)The nature of on-site hazards (e.g. flammable liquid, storage tanks, compressed and measures to be preparedness taken in the event of An organisation shouldgases establish (an) emergency and response spillages orthat accidental releases); procedure(s) suits its own particular needs. b)The most likely type and scale of an emergency situation or accident; c)The potential for (an) emergency situation(s) or accident(s) at a nearby facility (eg plant, road, railway line); d)The most appropriate method(s) for responding to an accident or emergency situation; e)The actions required to minimise environmental damage; f)Training of emergency response personnel; g)Emergency organisation and responsibilities; h)Evacuation routes and assembly points; i)A list of key personnel and aid agencies, including contact details (e.g. fire department, spillage clean-up services); j)The possibility of mutual assistance from neighbouring organisations; k)Internal and external communication plans; l)Mitigation and response action(s); to be taken for different types of accident(s) or emergency situation(s); 51 m)Need for process(es) for a post-accident evaluation to establish and implement corrective and preventive actions;

A Guide for Environmental Management System in the Construction Industry

These procedures need to be tested out for practicality, suitability, effectiveness and efficiency. Below are information typically found in an Emergency Response Plan: General Information • Overview of operations and potential emergency scenarios • List of applicable regulations • Maintenance and distribution of plan • Designated employees (i.e., names and phone numbers of persons authorized to act as emergency coordinators) Emergency Notification Information/Procedures • Information or procedures to effectively notify persons listed in the plan, including facility coordinators and community emergency employees • Emergency hotline numbers •List of names and numbers of regulatory agency or other governmental contacts Reportable Information • Name and telephone number of person reporting incident • Name and address of facility • Time and place of incident • Name and quantity of material involved • Extent of injuries • Possible hazards to human health and/or the environment • Potential impact outside the facility • Occurrence of or need for evacuation of local areas Available Resources Listings • Spill equipment list, with locations identified • List of nearby medical facilities, with addresses and phone numbers • List of nearby fire stations, with addresses and phone numbers • Poison control center phone number Emergency-Specific Information/Procedures • Weather emergencies • Utility emergencies • Fire and explosion emergencies • Chemical release emergencies Evacuation procedures Site Map • Identification of evacuation routes • Identification of safety showers and eye-wash stations • Identification of fire extinguishers • Identification of chemical-spill supply carts Training and Awareness • Legal/regulatory training requirements • List of employees who require training • List of qualified training instructors

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Checklist for Emergency Preparedness and Response Plans Does your plan describe the following: ♦ potential emergency situations (such as fires, explosions, spills or releases of hazardous materials, and natural disasters)? ♦ hazardous materials used on-site (and their locations)? ♦ key organizational responsibilities (including emergency coordinator)? ♦ arrangements with local emergency support providers? ♦ emergency response procedures, including emergency communication procedures? ♦ locations and types of emergency response equipment? ♦ maintenance of emergency response equipment? ♦ training / testing of employees, including the on-site emergency response team (if applicable)? ♦ testing of alarm / public address systems?

How to Develop Emergency Procedures • Identify emergency procedures already developed and implemented. Start with the environmental and health and safety regulatory programs. • Identify whether any emergency or accident scenarios with major environmental impacts have not yet been covered. Most potential emergencies can be identified by asking a series of “what if” questions related to hazardous materials, activities, and processes employed at the site. Consider start-up and shutdown of equipment, and other abnormal operating conditions. • Develop and implement emergency procedures for these scenarios. Communicate these procedures with all the employees on site and also local officials (fire department, police, hospitals etc.) to determine how they can offer assistance and support. • Ensure that training needs and competencies have been assessed for those working for, or on behalf of the organization involved with emergency procedures. • Establish processes to check that emergency preparations are implemented and maintained (e.g. test drills).Post copies of evacuation plans around the site and at potentially high risk areas. Include numbers for your on-site emergency coordinator, local fire department, local police, hospital, rescue squad, and others as appropriate. • Develop a process for identifying requirements for emergency procedures for existing or new operations or areas. • Develop a process for recording, reporting and investigating incidents and near misses, to assist in reducing future risks.

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Planning for emergencies should include: - an emergency assessment process - preventive measures - organizational responsibilities - listing of key employees - defining emergency services & their capabilities - communication plans - actions to take in the event of emergencies

The following questions will need to be answered in order to determine whether the Emergency Preparedness & Response Section meets the intent of ISO 14001: • •

• • • • •

Have you reviewed your operations and activities for potential emergency situations? If not how will these be accomplished? Who should be involved? Do your existing emergency plans describe how you will prevent incidents and associated environmental impacts? If not how will these be accomplished? Who should be involved? Have you trained employees on their roles and responsibilities during emergencies? What emergency equipment do you maintain? How do you know that this equipment is adequate for your needs? How do contractors and other visitors know what to do in an emergency situation? When was your last emergency drill? Is there a plan/schedule for conducting future drills? Have you established a feedback loop so you can learn from your experiences?

CHECKING AND CORRECTIVE ACTIONS Key characteristics of EMS operations and activities should be monitored and measured on a regular basis. The results should be recorded together with nonconformances, and with the corrective and preventive actions. As part of the checking process, a periodic EMS audit should be carried out; its result should serve as a basis for management review. Checking is the series of processes used to measure and monitor the effectiveness of environmental policy, objectives, targets, legal and other requirements, and report the results to interested parties. Checking involves measurement, monitoring and evaluation of an organisation’s environmental performance. Preventive action should be used to identify and prevent possible problems before they occur. A corrective action consists of identifying and correcting problems in the environmental management system.

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4.10

MONITORING AND MEASUREMENT

Key characteristics of EMS operations and activities should be monitored and measured on a regular basis. Procedures should be established and maintained to track performance, relevant operational controls, and conformance with the organisation’s environmental objectives and targets, as well as for the calibration and maintenance of monitoring equipment. Measuring and monitoring is required to ensure that the EMS objectives and targets are being achieved. Monitoring of environmental parameters is essential to ensure compliance to the regulation as well as maintaining the effectiveness of mitigating measures taken up. The following are some examples of the issues that need to be monitored taken from an EMP of a road construction: i. Water quality (all affected rivers - 10 m upstream and downstream). Monitor the quality of water at all river crossings prior to construction to determine the baseline water quality and subsequently monitor the water quality by taking and analysing water samples for the following parameters: Dissolved oxygen, electrical conductivity, temperature, pH, biological oxygen demand, chemical oxygen demand, ammonia (NH3-N), nitrate NO3-N, PO4-P, oil and grease, turbidity, total suspended solids, total dissolved solids, total solids). For subsequent sampling parameters : pH, temperature, DO, BOD, COD, TSS, AN, and oil and grease ii. Air quality (dust, air particulate at boundaries)

residential areas and at project site

iii. Noise (residential areas and forest reserves and at project site boundaries) iv. Erosion risks ( erosion sensitive areas; temporary cover to control erosion and permanent erosion control – drainage, surface protection, gabions, rip rap) v. Slope stability /protection ( erosion sensitive areas; immediate revegetation, protect slope from concentrated surface runoff, hard plugs) vi. Solid and hazardous waste handling and disposal vii. Archaeological heritage sites viii. Waterway crossings ( waterways must not be hindered; crossings shall be adequate to permit heavy storm water flow, embankments stability/protection) ix. River bank protection ( riprap, gabion) x. Flora and fauna xi. Health and safety

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xii. Sediment/silt trap ( location, trap size, embankment, excavation, trap clean out, outlet, clearing, fill material, sedimentation, Inspection after each rain and repairs, construction operations to minimize water pollution) xiii. Conservation of agricultural land - protected from any deterioration and impact ( every month) xiv. Hydrology –drainage system- maintenance, drainage channels, flumes ( pipes to channel water across the right of way, berms and berm spacing and conditions) xv. Compliance with government regulations – permits Monitoring and measurements can serve many purposes in an environmental management system, such as: a) Tracking progress on meeting policy, achieving objectives and target, and continual improvement; b) Developing information to identify significant environmental aspects; c) Monitoring emissions and discharges to meet applicable legal requirements or other requirements to which the organisation subscribes; d) Monitoring consumption of water , energy or raw materials to meet objectives and targets; e) Providing data to support or evaluate operational controls; f) Providing data to evaluate the organisation’s environmental performance; and\ g) Providing data to evaluate the performance of the environmental management system. The contractor should develop procedures to: ♦monitor key characteristics of operations and activities that can have significant environmental impacts and/or compliance consequences; ♦track performance (including your progress in achieving objectives and targets); ♦calibrate and maintain monitoring equipment; ♦through internal audits, periodically evaluate your compliance with applicable laws and regulations. How to achieve the above To achieve these purposes, the contractor should plan what will be measured, where and when it should be measured, and what methods should be used. To focus resources on the most important measurements, the organisation should identify the key characteristics of processes and activities that can be measured and that provide the

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A Guide for Environmental Management System in the Construction Industry

Table 12 : An example of a summary of monitoring requirements for a road construction Environmental issue Air quality and noise

Person responsible Environmental officer

Soil erosion

Project Engineer

Water quality

Environmental officer

Parameters

Frequency

TSP

Construction phase: once a week during land clearing and earthworks Once a fortnight during other construction works Operational phase: none required:

Solid particles – all fuel burning equipment and asphalt plant

Construction phase: Standard C: 0.4 g/Nm3

Noise – border of construction area Sedimentation rates – silt traps

Construction phase: once a fortnight

Slope stability Identified locations

Construction phase: once a week Operational phase: Once a fortnight. Construction phase: Twice a week during land clearing and earthworks between month 1-20. Once a week during month 21 – 30

As per EQA

Operational phase: once fortnight

Construction phase: twice a week during land clearing and earthworks. Once a fortnight during other construction works. Operational phase: none required.

Construction phases: BOD, E.coli at sewage discharge.

Wildlife

Department of Wildlife

Solid waste

Environmental officer

No of locations – every kilometer: Physical surveys & observations. Ground mammals Base camp and along kilometer stretch of the construction site.

All parameters to comply with Std A continuously throughout construction and operational phases. Construction phase: once a week during land clearing and earthworks to detect and relocate displaced animals. Post construction phase: patrol area once a month. Construction phase: once a week. Post construction phase: once a month.

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How to conduct measurement Measurements should be conducted under controlled conditions with appropriate processes for assuring the validity of results, such as adequate calibration or verification of monitoring and measurement equipment, use of qualified personnel, and use of suitable quality control methods. When necessary to ensure valid results, measuring equipment should be calibrated or verified at specific intervals, or prior to use, against standards traceable to international or national measurement standards. If no such standards exist, the basis used for calibration should be recorded. Written procedures for conducting measurement and monitoring can help to provide consistency in measurements and enhance the reliability of data produced. The results of measurement and monitoring should be analysed and used to identify both successes and areas requiring correction or improvement. Example of measurement methodology and instrument for water quality analysis: Index

Method or Instrument

1. Bio-Chemical Oxygen Demand (BOD)

Standard method

2. Chemical Oxygen Demand (COD)

Spectrophotometer (HACH) DR/2010

3. Dissolved Oxygen (DO)

DO meter

Before sampling for chemical analysis, sample bottles were cleaned by soaking in detergent for 24 hours followed by rinsing several times with tap water until free of detergent, rinsed with 5% nitric acid and then thoroughly with distilled-demonized water.

4.10.1

Identifying activities, product and services Wastewater Discharges

Waste Generation

Groundwater Impacts

Water Use

Air Emissions

Monitoring and Measurement Corrective Action

Chemical Use

Energy Use

Unplanned Releases

Recycling Activities

Figure 9 : Examples of activities to include in a monitoring and measurement program.

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4.10.2

Development of appropriate monitoring and measurement mechanism Attributes of effective measurement programs  simple  flexible  consistent  ongoing  produce reliable data  communicate results

Monitoring emphasis on: a. Soil erosion risks: Estimate of potential soil erosion and soil loss to receiving waters. b. Flood risks: Estimates of flood flows and indication of areas subject to floods. c. Water pollution: Predict changes to water quality. d. Air pollution: Estimates of air pollution generation and predict changes to air quality. e. Noise Pollution: Traffic noise along selected positions based on projected traffic increase. Machinery noise projection if types of activities are known in the road construction. f. Ecological Impacts: Habitat loss and possible effects on species of fauna and flora. g. Roads and Traffics impacts: Projected traffic generation and distribution, safety and congestion. h. Socio economics impacts: Size of population affected and issues that may rise. Key Characteristics

Methods to track performance and operational control

Air Emissions

Periodic sampling; emissions trending; measurement of exhaust rates; frequent calibration of monitoring equipment; balancing of duct flows

Treatment efficiencies

Emissions trending; comparison to or use of documented efficiency factors; waste generation from process(es); frequent calibration of monitoring equipment

Recycling activities

Percentage of waste recycled; comparison of revenue generated and cost avoided

Unplanned

Trend of unplanned releases, trend of severity of unplanned

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releases

releases; cost or potential costs of cleanup versus

Energy use

Tracking of energy usage; cost of installing energy-efficient equipment; ensure energy conservation measures are deployed

Chemical Use

Chemical use trend; review of purchasing records to determine what areas are using most chemicals; reduction of targeted chemicals such as toxic or hazardous chemicals

Water use

Water use trend; cost of water conservation equipment versus savings over time; ensure water conservation measures are deployed

Wastewater discharges

Effluent sampling to ensure permit parameters are being met; emissions trending; frequent calibration of monitoring equipment

Waste generation

Waste generation trend; disposal and treatment costs; number of incorrectly shipped waste drums or packages, including errors in shipping papers

Storm water discharges

Effluent sampling to ensure permit parameters are being met; emissions trending; visual inspection runoff; frequent calibration of monitoring equipment

How to Develop Monitoring Procedures •Identify your needs. Define what kind of information is meaningful and should be collected. For instance :  key process characteristics  regulatory compliance  operational performance (effectiveness of operational controls of Significant Environmental Aspects)  progress on meeting objectives •Review existing monitoring systems. Determine if current systems are sufficient, and identify any additional monitoring or measurement if needed.

Which operations and activities can have significant environmental impacts?

•Develop measurement programs. Ensure your programs are simple, flexible, consistent and ongoing, produce reliable data and communicate results.

What are the key characteristics of these operations and activities?

•Monitoring and Checking. Establish an environmental management plan. Identify How do we time, place and persons performing the measure these measurements. Carry out monitoring to characteristics? ensure legal compliance, achievement of objectives and effective operational control. Implement corrective and preventive actions when non-conformances are identified during monitoring or operation. Procedures for calibration and routine maintenance of equipment utilized should be documented. 60

A Guide for Environmental Management System in the Construction Industry

•Communicating performance. Provide relevant monitoring results to staff will raise their awareness on your company’s environmental performance.

TIPS ♦ ♦ ♦ ♦

Keep monitoring requirements limited to KEY process characteristics. Make sure equipment is maintained and calibrated routinely. Ensure that regulatory compliance is included in the measuring and monitoring. Ensure monitoring and measuring will verify conformance with policy, targets and objectives of EMS. Focus on things that can be controlled Ensure adequate resources to implement the program Monitoring and measurement reports must be applicable to operational staff and meaningful for management Consider economic studies to determine cost of effort versus economic return on investment

♦ ♦ ♦ ♦

The following questions will need to be answered in order to determine whether the Monitoring & Measurement Section meets the intent of ISO 14001: • • • • • • •

How do you identify operations and activities associated with significant environmental aspects, legal requirements and environmental objectives? What type(s) of monitoring and measurement do you need to ensure that operational controls are being implemented correctly? What type(s) of monitoring and measurement do you need to ensure that you are complying with applicable legal requirements? What type(s) of monitoring and measurement do you need to ensure that you are achieving your environmental objectives & targets? How do you identify the equipment used for any of the monitoring or measurement listed above? How will you ensure that monitoring and measurement equipment is properly calibrated and maintained? What process do you have to periodically evaluate compliance with legal requirements? How effective is this process?

4.11

EVALUATION OF COMPLIANCE

To meet compliance to applicable legal and other environmental requirements, its status should be regularly monitored and evaluated. An organisation should establish, implement and maintain a procedure for periodically evaluating its compliance with the legal requirements and other requirements that applicable to its environmental aspects, as part of its commitment to compliance. The organisation should record the results of this evaluation.

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The scope of a compliance evaluation can encompass multiple legal requirements or a single requirement. A variety of methods can be used to assess compliance, including processes such as: a) Audits; b) Document and/or records reviews; c) Facility inspections; d) Interviews; e) Project or work reviews; f) Routine sample analyses or test results; and g) Facility tours and/or direct observations. An organisation should establish a frequency and methodology for evaluation of compliance that suits its size, type and complexity. Frequency can be affected by factors such as past compliance performance or specific legal requirements. It can be beneficial to have an independent review conducted periodically. 4.11.1

Demonstration of compliance

Compliance can be demonstrated with respect to laws, regulations, guidelines and other pertinent instructions. An example of commitment to compliance for the construction of a marina: “The CONTRACTOR shall comply with all applicable laws, regulations, standards, guidelines and terms and conditions of approvals issued by Malaysian Environmental Authorities. In particular the CONTRACTOR shall comply with the Environmental Quality Act 1974(Act 127) and all subsidiary legislations made there under. The CONTRACTOR shall take cognizance of all environmental issues and comply with all laws, by-laws, rules and regulations relating to the environment. This shall include but not limited to avoiding unnecessary felling or damaging of trees, restoration of the affected areas, proper discharge of effluent, dust control, emission of noise, fumes and handling of waste, toxic or otherwise including the construction of receptacles, incinerators, silt traps, filters and other appropriate methods of disposal or discharge.“ 4.11.2

Evaluation of compliance to legal requirements

There should be a list of some examples of regulations that a construction project need to be aware of. The purpose of this list of regulations is to direct project initiator and assessors to existing regulations issued under the EQA 1974 and other related legislation in Malaysia.

Below is a list of regulations made under ENVIRONMENTAL QUALITY ACT 1974 and other environmental related legislation.

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i. The Environmental Quality Act 1974 Laws of Malaysia, His Majesty’s gazette 14th March 1974 ii. Destruction of Disease bearing insects Act, 1975.Act 1564 Laws of Malaysia iii. Land Conservation Act 196- (No 3. of 1060) iv. Local Government Act 1976 Act 171/76, Laws of Malaysia v. National Land Code 1965 vi. Municipal and Town Boards (Amendment) Act 1972) vii. The Waters Enactment 1929 viii. Drainage Works Ordinance 1954 ix. Fisheries Act 1963 x. Factories and Machinery Act 1967 xi. The Road Ordinance Traffic 1958 xii. Poisons Ordinance 1952 xiii. Explosives Ordinance 1957 xiv. Malaria Eradication Act 52 laws of Malaysia xv. Street, Drainage and Building Act 1974 (Act 133) xvi. Occupational, Safety and Health Act 1994 ( Act 514) and regulations Safety and Health Officer regulations 1997 and Order 1997 Elements That Might Be Reviewed When Performing a legal Compliance Evaluation

4 . 1

• • • • • • • •

Environmental permit limits and corresponding data demonstrating compliance with these limits Procedures identifying training requirements that are based on legislation/regulation and evidence that the training has taken place reporting requirements and evidence that the proper reports have been submitted inspection requirements and evidence that the inspections have taken place labeling requirements and evidence that proper labeling is being executed records retention requirements and evidence that the records are maintained according to legal specification waste-handling requirements and evidence that these requirements are being met corrective action requirements and evidence that the corrective action is being managed properly

Evaluation of compliance to other requirements

An organisation should periodically evaluate its compliance with other requirements to which it subscribes. An organisation may wish to establish a separate process for conducting such evaluations or it may choose to combine these evaluations with its evaluations of compliance with legal requirements, its management review process or other evaluation processes. Records of these periodic evaluations should be maintained. A compliance evaluation programme can be integrated with other assessments activities. These can include management system audits, 4.12

NON-CONFORMITY, CORRECTIVE ACTION & PREVENTIVE ACTION

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Key characteristics of EMS operations and activities should be monitored and measured on a regular basis. The results should be recorded together with nonconformances, and the corrective and preventive actions. As part of the checking process, a periodic EMS audit should be carried out; its result should serve as a basis for management review. The result of monitoring and measurements, evaluation of compliance, audit findings and other systematic reviews should be documented and reviewed, and must lead to corrective actins which are intended to fix and avoid EMS problems in the future. Examples of non conformity: a) exceeding noise level and vibration level b) emission of excessive fumes and dust c) soil erosion and surface runoffs that cause heavy siltation of the water bodies, thus increase in water turbidity and shallowing of the water bodies d) mismanagement of handling and disposal of chemical hazardous waste e) do not comply to EIA approval conditions such as no open burning, requirements of monitoring and development of EMP f) solid waste mismanagement Non-conformity is non-fulfilment of a requirement. A requirement may be stated in relation to the management system or in terms of environmental performance. Situations may occur where part of the system may not function as intended or environmental performance requirements are not met. A process for identifying non-conformity in the environmental system and taking corrective or preventive action helps an organisation operate and maintain the environmental management system as it intends. Keeping records and managing them effectively gives the organisation a reliable source of information on the operation and results of the environmental management system. Periodic audits of the environmental management system help the organisation verify that For an environmental management system to be effective on an ongoing basis, an organisation should have a systematic method for identifying actual and potential non-conformity(-ies), making corrections and taking corrective and preventive action, preferably preventing Examples of such situations can include: a) System performance: i. Failure to establish environmental objectives and targets; ii. Failure to define responsibilities required by an environmental management system, such as responsibilities for achieving objectives and targets or for emergency preparedness and response; and iii.Failure to periodically evaluate compliance with legal requirements; b) Environmental performance: i. Energy reduction targets are not achieved;

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4.12.1

Non-conformity, corrective actions and preventive actions

Any non conformity must be recorded and corrective actions taken. Excessive exposure of soil that leads to soil erosion and surface runoffs can be abated by having immediate turfing. Prevention of surface runoff laden with silt from entering the water courses can be achieved by improving the silt ponds. Prevention of impacts and risks are worth considering in the planning stage rather than having to pursue treatment measures. Preventive measures on air quality degradation begins with recognizing the main sources of emission which are exhaust gases from machinery and heavy vehicles, followed by implementation of measures such as fitting vehicles and machinery with appropriate emission control and proper maintenance. Storage of chemicals and fuels on site is inevitable, however, reducing the quantities of these hazardous substances on site to a minimum practicable level is desirable. Management should ensure that corrective actins have been implemented, and that there is systematic follow-up to ensure their effectiveness. If potential problem is identified but no actual non-conformity exists, preventive action should be taken using a similar approach. The Department of Environment Compliance Checklist includes the followings 1. Any wastewater must be treated before releasing into and the inland watersnonand must Establishing procedures for addressing actual potential meet the Standard A, Third schedule Environmental quality Regulations (Sewage conformities and for tracking corrective and preventive actions helps to and Industrial effluent) 1979. ensure consistency in this process. Such procedures should define 2. Silt trap and proper drainage system that is effective in draining the surface runoff responsibilities, authority and steps to be taken in planning and carrying must be built before any earthwork is carried out. Any water released from the silt outtrap corrective and preventive actions. When the actions taken result in cannot exceed 50 mg/L. changes environmental management system, process 3. A reportto onthe the total suspended solids must be submitted to thethe state DOE asshould well as ensure: that all related documentation, training and records are updated the Federal DOE. 4. The design of the silt trap 4.12.2 Evaluating actual to river. corrective actions 5. Spent oil cannot be allowed to non-conformity be disposed into any Used oil will be kept in covered drums for recovery or disposed at an approved site.

Once non-conformity is identified, it should be investigated to determine the cause, conformity was also judged from site surveillance carried out for visual evaluation soNon that corrective actions can be focused on the appropriate part of the system.of In river conditions, probablenon-conformity, source of siltation of rivers, should and evaluate developing a plan identify for addressing an organisation consider implementation of mitigating measures including steps to reduce surface runoffs as well what actions need to be taken to address (mitigate) the problems, what changes as the silt pond conditions. Aside from site surveillance, monthly monitoring were carried need to be made to correct the situation (to restore normal operations(s)). The out to ascertain non-compliance so thatshould immediate remedial actions can be taken. character and timing of such actions be appropriate to the nature and scale of the non-conformity and the environmental impacts. Corrective and preventive measures for water quality during dam construction:

Non conformityand canregular be checked against list or quality regulations. An example a) Frequent monitoring of compliance the dam’s water is recommended takenespecially from theduring construction of a dam for water quality is given below. raining season. b) One of the goals for water quality management in the reservoir is to maintain a water quality that is suitable for survival of aquatic fish and which will not lead to eutrophication. To retard the eutrophication sharply, it will be necessary to impose effective controls on land runoff to contain phosphate and nitrate as well as point sources. c) To reduce the levels of total suspended solids in the dam, which in turn will reduce the siltation of the dam and subsequently reduces its water carrying capacity, the controls for suspended solids in the dam area are largely dependent on the measures established for soil erosion control as well as rehabilitation of the surrounding forests. 65 d) Frequent and regular monitoring of the dam’s water quality is recommended to ensure that water quality problems which do not arise can be detected early and appropriate intervention measures are taken before the problem reached unmanageable stage.

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Table 13 : Example of the evaluation of non conformity to EIA approval conditions for the construction of a marina as gathered from site surveillance and auditing

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Impact Noise Pollution

Solid Waste Generation

Schedule Waste

Suggested Mitigating Measures

Mitigating Measures Taken by Contractor

Noise levels shall not exceed 65 dB (A) at all times around the A Guide for Environmental System in the Construction Industry boundaries of the project area. - NoManagement preventative measure was - If noise level is high, the general workers at the site must be undertaken. provided with ear mufflers to reduce impacts on them. - Reduce noise level by decreasing operating level during quiescent periods in the local community. - The equipment used or the modes of operation can be changed to produce less noise, such as fitting with silencers. - Construction hours must be limited to the day to avoid disturbance to the residents nearby. - The wastes must be separated into categories for easy - Construction wastes generated were disposal o Segregation of wastes ( recyclable from no recyclable) disposed at the designated dumpsite. o Segregation of hazardous from non hazardous wastes. - The wastes are loaded onto tip off truck, should not be overfilled and must be covered with tarpaulin material so that no accidental fly rock or fly debris might take place while transporting. - No open burning is allowed - No disposal into the sea is permitted. Any accidental falling of solid wastes into the water must be immediately retrieved. - Construction wastes which are too large or heavy are placed temporarily in an area big enough to accommodate them without interfering with internal traffic or cause hazards to workers - For smaller wastes, a proper waste storage containers and drums must be provided. - Storage and collection of solid wastes must be done in a way that will not cause fire, health or safety hazards or provide food and breeding grounds for vectors of diseases - Disposal of hazardous waste using a certified contractor must follow the hazardous waste transportation guidelines - No preventative measure was delineated in the EQA 1974 undertaken. - Scheduled waste must be packaged, classified and labeled according to EQA 1974. - Temporary on site storage area for scheduled waste must be provided and protected from spillage onto the ground or into the sea and the effects of the weather. - Scheduled waste inventory must be supplied to the DOE on the regular basis as required by the EQA 1974. - A separate holding area could also be allocated for 68 construction wastes that cannot be recycled. - Wastes such as waste paints and solvent containers, lubricating and hydraulic oils must be segregated for disposal -

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4.12.3

Evaluating potential non-conformity of preventive actions

The internal audit process of an environmental management system, described in 4.5.5, is one way of periodically identifying non-conformities. Identification of nonconformities can also be made a part of routine responsibilities, with individuals closest to the work noting potential or actual problems. Potential problem can be identified using methods such as corrective action of actual non-conformities to other applicable areas where similar activities occur, trend analyses, or hazard operability studies. Why do EMS problems occur? Typical causes include:  poor communication faulty or missing procedures equipment malfunction (or lack of maintenance) lack or training lack of understanding (of requirements) failure to enforce rules corrective actions fail to address root causes of problems

Examples of potential problems identifed for the dam constrcution Drainage Landslides can occur due to poor drainage of slopes. Careful examination of existing drainage lines and potential change of drainage routes to sloping areas should be made. Such drainage may appear on the surface or may go underground and reappear as seepage water that may cause damage to slopes. Operational phase There are two primary erosion management tasks in the operational phase. One is slope stability monitoring and the other is the rehabilitation of scarred land to a semblance of its original form. The effort at this stage will depend entirely on how effectively erosion control measures were applied during the construction phase. However, for slope stability, continuous monitoring of all slopes that face into the reservoir is encouraged. Critical slope areas should be revisited every 2 weeks while the other slopes can be inspected once a month. The frequency needs to increase to once a week during the rainy season for vulnerable slopes. The frequent wetting and drying of the slopes around the waterline can weaken the natural cohesively of the soil causing the slope to slump. Slopes where the top soil integrity has been compromised by logging or land clearing are of particular concern.

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To deal with system deficiencies, the contractor needs a process to ensure that: • • • •

problems (including nonconformities) are identified and investigated; root causes are identified; corrective and preventive actions are identified and implemented; actions are tracked and their effectiveness is verified.

This procedure applies to the handling of: a) enquiries (both internal and external) regarding contractor’s EMS or environmental performance; b) complaints (both internal and external) regarding contractor’s EMS or environmental performance; c) non-conformances related to contractor EMS requirements, shall include but not be limited to below : d) internal procedure non-compliance identified during regular monitoring / review e) non-conformances identified in internal EMS audits f) non-conformances caused by suppliers / contractors / service providers Nonconformities should be analyzed to detect or identify trends, which can be used to further anticipate and prevent future reoccurrences. Preventing problems are usually cheaper than fixing them after they occur. This procedure also addresses non-conformance through corrective and preventive actions so as to minimize impacts to the environment and the potential for reoccurrence.

How to develop corrective & preventive measures •Identify the problem •Determine the root cause of the problem. •Identify possible solutions and decide the best action to be taken. •Implement the solution to lower risks to acceptable levels and to further prevent reoccurrences.

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•Document the measures taken to correct the nonconformance. •Communicate the nonconformance and the corrective and preventive measures taken to other employees to increase environmental awareness. •Review non-conformances and agreed corrective/preventative actions for completion against target timescales and also for effectiveness. Rule of thumb: Corrective actions should (1) resolve the immediate problem (2) consider whether the same or similar problems exist elsewhere in the organization, and (3) prevent the problem from recurring. (4) define the responsibilities and schedules

TIPS ♦ Combine some elements of their management review and corrective action processes. ♦ Planning and documentation vary with the severity of the problem and its potential environmental impacts. Try to use simple methods. ♦ Resolve the identified problem in a timely manner. Specify responsibilities and schedules for completion and review the progress regularly. ♦ In the long run, problems may be identified by people doing the work. This should be encouraged. Develop ways to get employees involved in the system improvement process.

The following questions will need to be answered in order to determine whether the Nonconformance and Corrective and Preventive Action Section meet the intent of ISO 14001: • • • • • •

•

Do you have an existing process for corrective and preventive action? If yes, does that process need to be revised? In what way? Who needs to be involved in this process within your organization? How are nonconformities and other potential system deficiencies identified? (List methods such as audits, employee suggestions, ongoing monitoring, etc.) How do you determine the causes of nonconformities and other system deficiencies? How is this information used? How do you track the status of our corrective and preventive actions? Can information on nonconformities and corrective actions be used within the EMS (for example, in management review meetings, in employee training sessions, in review of procedures, etc.) How do you ensure the effectiveness of your corrective and preventive actions?

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4.13

CONTROL OF RECORDS

Environmental records are required to demonstrate compliance with the EMS and show that it is functioning properly. Key characteristics of EMS operations and activities should be monitored and measured on a regular basis. The results should be recorded together with non-conformances, and the corrective and preventive actions. Why records are needed? Records provide evidence of the on-going operation and results of the environmental management system. A key characteristic of records is that they are permanent and are, typically, not revised. An organisation should determine which records are required to manage its environmental matters effectively. 4.13.1

Identifying environmental records

Records are different from documents. Records are evidence that something has been accomplished (i.e., inspections, equipment calibration and training). This element requires the organization to establish and maintain procedures for the identification, maintenance and disposition of records. Environmental records need to be: • • • • • •

legible identifiable and traceable to the activity involved easily retrievable can be in hard copy or electronically kept protected against damage, deterioration or loss retained per established and recorded retention times

How to control records • Identify what EMS records are required. • Focus on records that add value. The records you choose to keep should be accurate and complete. • A master list of stored records that includes: name of record, why stored, where stored, format of storage, retention time, and final disposal determination and decision matrix. A record of those records destroyed, under whose authority and the date of destruction should also be kept. Hard copy records need to be protected from fire, flood and the like. • Determine the person responsible for collecting and checking the records and collection methods shall be specified.

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What should be in the records? Records should include: (LIST OUT EG LICENSE, APPROVAL PERMITS, EIA ETC) a) Information on compliance with applicable legal requirements and other requirements to which the organisation subscribes; b) Details of non-conformities and preventive actions; c) Results of environmental management system audits an management reviews; d) Information on environmental attributes (e.g. chemical composition and properties); e) Evidence of fulfilment of objectives/targets; f) Information on participation in training; 4.13.2

Management of environmental records

The effective control of these records is essential to the successful implementation of an environmental management system. The key features of environmental record control include means of identification, collection, indexing, filing, storage, retrieval and retention. Examples of Environmental Records Applicable governmental regulations List of significant environmental aspects Reports of progress towards meeting objectives and targets Environmental permits, licenses and other approvals Job descriptions and performance evaluations Training records Process hazard assessments Emissions modeling records External environmental reports Inspection, maintenance and calibration records Records of sub-contractor activities on premises Communications with customers, suppliers, contractors and other external parties Incident and corrective action reports Records of testing of emergency procedures Sampling and monitoring data Records of compliance and EMS audit results Records of management review

The following questions will need to be answered in order to determine whether the Records Section meets the intent of ISO 14001: • • •

Have you identified what records need to be maintained and disposed? Where is this defined? Include training records, results of audits and reviews. Are the records legible, identifiable and traceable to the activities?

•

Are the records maintained in a way that they are easily retrievable and protected against damage, deterioration or loss? Have you determined records retention times? Where is this defined?

•

Have you established an effective storage and retrieval system? 74

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4.14

INTERNAL AUDIT

Key characteristics of EMS operations and activities should be monitored and measured on a regular basis. The results should be recorded together with nonconformances, and the corrective and preventive actions. As part of the checking process, a periodic EMS audit should be carried out; its result should serve as a basis for management review. Internal audit should determine compliance with the ISO 14001 EMS. Why conduct internal audits (auditors must be trained; audit planning, frequency) 1. to determine and provide information to management on whether the system conforms to planned arrangements and has been properly implemented and maintained. 2. to identify opportunities for improvement in an organisation’s environmental management system. How to conduct internal audit environmental management system 1. at planned intervals 2. should establish an audit programme to direct the planning and conduct of audits and to identify the audits needed to meet the programme objectives. 3. audit programme should be based on the nature of an organisation’s operations, in terms of its environmental aspects and potential impacts, the results of past audits, and other relevant factors. 4. Each internal audit need not cover the entire system, so long as the audit programme ensures that all organisational units and functions, systems elements and the full scope of the environmental management system are audited periodically. 5. The audits should be planned and conducted by an objective and impartial auditor(s), aided by technical experts, where appropriate, 4.14.1

Determining internal audit objectives

Internal audits of an organisation’s environmental management system should be conducted at planned intervals to determine and provide information to management on whether the system conforms to planned arrangements and has been properly implemented and maintained. They can also be performed to identify opportunities for improvement in an organisation’s environmental management system. 4.14.2

Development of internal audit program

An organisation should establish an audit programme to direct the planning and conduct of audits and to identify the audits needed to meet the programme objectives. The programme should be based on the nature of an organisation’s operations, in terms of its environmental aspects and potential impacts, the results of past audits, and other relevant factors.

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Examples of suggested audit for the construction of a marina: The types of audit that can be carried out include compliance audit, green audit or specifically on the environmental management of the industry. Specific audit such as on the marine water quality, maritime audit and solid waste management audits can all be carried out.

Audit frequency will depend on the activity. The first year in operation is a starting point and subsequently once in two years, unless there is a drastic deviation from everyday operations. This element requires the contractor to establish and maintain procedures and programs for EMS auditing. The EMS audit program must cover the following: • • • • •

audit scope audit frequency audit methodology selecting and training of auditors responsibilities and requirements for conducting audits and reporting results

Scope • Applicable to all types of environmental audits Definitions •Defines key terms pertaining to environmental auditing including audit conclusion, audit criteria, audit evidence and audit findings Requirements for an Environmental Audit • There is sufficient and appropriate information about the subject matter of the audit • There are adequate resources to support the audit process • There is adequate cooperation from the client (auditee) General Principles • Objectives and scope-the audit should be based on the objectives defined by the client • Objectivity, independence and competence-the members of the audit team should be independent and should possess an appropriate combination of knowledge, skills and experience to carry out the audit •Due professional care-auditor should use care, diligence, skill and judgment • Systematic procedures-documented and well-defined methodologies should be used to enhance consistency and reliability • Audit criteria, evidence and findings-criteria should be agreed upon between the lead auditor and the client; appropriate information should be collected, analyzed, interpreted and recorded; audit evidence should be of such quality and quantity that competent environmental auditors working independently of each other will reach similar audit findings • Reliability of audit findings and conclusions-the desired level of confidence and reliability in audit findings and conclusions should be provided • Audit report-a copy should be given to the client and should include items agreed upon by

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the client and the lead auditor

4.14.3 Selection and appointment of auditor The audits should be planned and conducted by an objective and impartial auditor(s), aided by technical experts, where appropriate, selected from within the organisation or from external sources. Their collective competence should be sufficient to meet the objectives and scope of the particular audit and provide confidence as to the degree of reliability that can be placed on the results. 4.14.4 Implementation of internal audit •Determine what should be audited to provide a comprehensive review of the environmental management system (e.g. procedures, training, documents, and records). •Determine where these elements should be audited (e.g. by site, department, team, individuals, activity, product or service). •Determine when these elements are to be audited (frequency should be based on environmental importance, the nature of your operations and activities, your significant environmental aspects / impacts (which you identified earlier), the results of your monitoring processes, and previous audit findings). •Determine how all elements and areas will be audited (e.g. by procedure, by department) considering the audit time requirement. •Develop audit procedures and communicate these as necessary. •Determine who will conduct the audits (e.g. internal or external auditors).CEMS Auditors need to be selected and trained. Training requirements need to be identified and are both initial and ongoing. Auditors should be trained in auditing techniques and management system concepts. Familiarity with environmental regulations, industry regulations and operations will be of tremendous help. •From the above, compile an audit schedule and circulate as necessary. •Conduct audits and report results. Audit results can be used to detect trends and patterns in EMS deficiencies. •Review results of audits and follow up corrective actions. TIPS ♦Focus on objective evidence of conformance. ♦Review identified deficiencies with relevant employees ♦Train at least two people as internal auditors. ♦Before you starting, communicate audit scope, criteria, schedule, and other pertinent information to the people in the affected area(s). ♦An EMS audit is not an assessment of how well employees do their jobs.

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4.14.5 Internal audit finding and reporting Each internal audit need not cover the entire system, so long as the audit programme ensures that all organisational units and functions, systems elements and the full scope of the environmental management system are audited periodically. The results of an internal environmental management system audit can be provided in the form of a report and used to correct or prevent specific non-conformities, fulfil one or more objectives of the audit programme, and provide input to the conduct of the management review. The following questions will need to be answered in order to determine whether the EMS Audit Section meets the intent of ISO 14001: •

•

Have you developed an EMS audit program? If not, how will this be accomplished? Who need to be involved in the audit process? What will the audit cover? Is there another audit program with which your EMS audits could be linked (for example, your quality or health & safety management system audits)? Have you determined an appropriate audit frequency? What is the basis for the existing frequency? Should the frequency of audits be modified? Have you selected EMS auditors? What are the qualifications of our auditors?

•

What training has been conducted or is planned for your EMS auditors?

• •

Have you conducted EMS audits as described in the audit program? Where are the results of such audits described? How are the results of EMS audits communicated to top management?

•

How are the records of these audits maintained?

• •

4.15

MANAGEMENT REVIEW

Top management should periodically act, and review the EMS to ensure its suitability, adequacy and effectiveness. The review should be an essential portion of the continual improvement of the EMS. An organisation should periodically review and continually improve its environmental management system, with the objective of improving its overall environmental performance. 4.15.1 Roles of top management An organisation’s top management should, at intervals that it determines, conduct a review of its environmental management system to evaluate the system’s continuing suitability, adequacy and effectiveness. This review should cover the environmental

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aspects of activities and serves that are within the scope of the environmental management system. 4.15.2 Objectives of management review An organisation should periodically review and continually improve its environmental management system, with the objective of improving its overall environmental performance. How to conduct management review •Organization must identify the required frequency of the CEMS reviews. •Organization must identify who should be involved in the reviews. The committee should consist of the Management Representative, CEO, Director of EH&S and other senior management representatives. •Organization must determine what should be covered during the review. The agenda should include review of instances of nonconformance, Corrective Actions, continuous improvements associated with the EMS, results of compliance and EMS Audits, complaints, results of any pollution prevention programs, waste minimization programs and a summation of Measurement and Monitoring results. •Organization must develop a schedule for reviews. •The schedule is then communicated to all relevant parties •The organization must also determine what type of information will be needed by the committee for the review process. Information providers will need to be informed in advance. •During the review, the agreed actions should be assigned appropriately and given a timescale for implementation. A follow-up should be conducted at a later date to verify that the EMS modifications were effective. •Minutes of the review need to be circulated and recorded. 4.15.3 Input to the management review Inputs to the management review may include: a) Results of internal audits and evaluations of compliance with applicable legal requirements and with other requirements to which the organisation subscribes; b) Communication from external interested parties, including complaints; c) The environmental performance of the organisation; d) The extent to which objectives and targets have been met; e) Status of corrective and preventive actions; f) Follow-up actions from previous management reviews; g) Changing circumstances, including: i. Changes in the organisation’s products, activities and services; ii. Results of the evaluation of environmental aspects from planned or new developments; iii. Changes in applicable legal requirements and other requirements to which the organisation subscribes; iv. The view of interested parties;

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v. Advances in science and technology; and vi. Lessons learnt from emergency situations and accidents; h) Recommendations for improvement. 4.15.4 Output from management review Outputs from the review of the environmental management system may include decisions on: a) The system’s suitability, adequacy and effectiveness; b) Changes to physical, human and financial resources; and c) Actions related to possible changes to environmental policy, objectives, targets and other elements of the environmental management system; During the review:sources to consider: Information  • Audit Assess resultsextent of compliance or non conformance to the Standard • Internal suggestions  Assess effectiveness of Corrective Action communications  • External Suggest corrective measures to solve problems identified in EMS design, • Progress on objectives and intent or scope

targets • Other environmental performance measures Management reviews can be • Reports of emergencies, used to demonstrate top spills, other incidents management’s ongoing • New or modified legislation support for the environment and regulations • New scientific / technical data on materials and processes used by the organization Management Review: Questions to Ponder

· · · · · · · · · · ·

Examples of Changes to the CEMS That Might Demonstrate Did we achieve our objectives and targets? Commitment If not, why to Continual not? Should we modify our objectives? Improvement  Changes to the Is our environmental policy still relevant to what we do?environmental policy to reflect additional commitments Are roles and responsibilities clear, do they make  Identification of additional sense and are they communicated effectively? significant environmental Are we applying resources appropriately?aspects Changes to objectives and Are our procedures clear and adequate?Do we need targets which will lead to other controls? Should we eliminate some of them? improved environmental performance Are we fixing problems when we find them?  Technology upgrades Are we monitoring our EMS (e.g., via system audits)?  Enhance training program What do the results of those audits tell us?  Enhanced external communications What effects have changes in materials, products, or  Monitoring and measurement of services had on our EMS and its effectiveness? additional parameters  More tests of Do changes in laws or regulations require us tofrequent change emergency preparedness and some of our approaches? response procedures What other changes are coming in the near term? document What control  Enhanced impacts (if any) will these have on our EMS?  Enhanced operational control  Enhanced What stakeholder concerns have been raised sincepreventive our maintenance program

last review? How are concerns being addressed?

· Is there a better way? What can we do to improve?

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The following questions will need to be answered in order to determine whether the Management Review Section meets the intent of ISO 14001: •

• •

• • • • •

Do you have an existing process for conducting management reviews? If yes, does that process need to be revised? In what way? If no, describe your management review process. Who needs to be involved in this process within our organization? What are their roles in this process? When is the best time for you to implement this process? Can this effort be linked to an existing organization process (such as your budget, annual planning or auditing cycles?) How frequently are management reviews? What is the basis for this frequency? Should you conduct reviews more or less frequently? Who is responsible for gathering the information needed to conduct management reviews? Who is responsible for presenting this information? How do you ensure that changing circumstances (both internal and external to the organization) are considered in this process? How do you ensure that the recommendations of management reviews are tracked and acted upon? Who will document the review meetings? What changes have been made to the EMS as a result of the last review?

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5.0 EMS AND ISO 14001 In the era of borderless trade, international standards are important for achieving competitiveness and access to markets. Environmental management standards such as ISO 14001 can be used as the fundamental reference. ISO14000 provides organizations the framework for managing environmental impacts. International environmental standards are being developed for construction, utilizing the principles of ISO9000 and ISO14000 series. ISO 14001 Environmental Management Systems – Specification with guidance for use  

 

5.1

is an international standard which specifies the requirements of an environmental management systems; it is intended as a framework applicable to all types and sizes of organizations and to accommodate diverse geographical, cultural and social conditions using the “PDCA” approach; the success of the system depends on commitment from all levels and functions of the organization, especially from top management; enables an organization to establish and assess the effectiveness of procedures, to develop an environmental policy and objectives, achieve conformity with them, and demonstrate such conformity to others support environmental protection and prevention of pollution. CURRENT SITUATION OF CONSTRUCTION INDUSTRY IN MALAYSIA

In the near future, selection of contractors, especially for environmental sensitive project will be based not only for the abilities of the contractors to complete the project on time, within the specified cost and quality of works but also on their environmental track records and the incorporation of environmental management system in managing the project. Unfortunately, based on the year 2005 survey, the number of ISO 14001 certified contractors among the 64,000 contractors available in the country are extremely small. The contractors who are competing for oversea projects will have to equip their companies with ISO 14001 certification in order to increase the company’s competitiveness in the global market. To be a world class player, the Malaysian construction industry should strive for the highest standard of quality, safety and environmental practices by fostering quality and environmentally-friendly culture. 5.2

CERTIFICATION PROCESS

A DIY ISO 14001 Certification Scheme is planned to equip the contractors with the appropriate knowledge about the Environmental Management Systems (EMS). This scheme involved two steps certification process given as the following: Training (Training Certificate) Implementation (Implementation Certificate) During the training process, there will be a short course to equip the contractors with the appropriate knowledge about the EMS. At the end of the course, a certificate will 82

A Guide for Environmental Management System in the Construction Industry

be given to these contractors. There will be a certain period whereby this certificate will be expired. The contractors will either renew this certificate by re-attend the training or go to the next step; by implementing what they had been learned. During the implementation process, contractors will be given a duration of 6 months to implement what they had learned. As part of their implementation, the contractors have to prepare a report; summarise their implementation activity. There will be a periodic assessment during their implementation basically to make sure this contractors had implemented what they had been learned. This contractor will be given another certificate by the end of the assessment. This certificate will also be expired at certain period of time. The certificates obtained will be useful as an evidence of their appropriate knowledge and experience about the EMS at their construction site thus enhance their corporate image to secure the future projects. However, they have to obtained the ISO 14001 Certificate in order to compete with the other contractors (those already had their ISO 14001 Certificate) or to secure the overseas projects. The ISO certification process flowchart is given as the following: Enquiry  Complete Questionnaire  Proposal  Confirm Application and Schedule  Document Review  Certification Assessment  Major Non-Conformance?  Recommendation for Registration  Certificate Awarded  Surveillance Assessment  Renewal Assessment. (every 3 years once)

Figure 10 : ISO 14001 Certification Process Flowchart 5.3

OPPORTUNITIES FOR IMPROVEMENT AND COST SAVING

Continual improvement is a key to an effective environmental management system. Continual improvement is accomplished through the achievement of environmental objectives and target and the overall enhancement of the environmental management system.

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An organisation should continually evaluate its environmental performance and the performance of its environmental management system processes to identify opportunities for improvement. Top management should be involved directly in this evaluation through the management review process. Some useful sources of information for continual improvement include: a) Experience gained form corrective and preventive actions; b) External benchmarking against best practices; c) Intended or proposed changes applicable to legal requirements and other requirements to which the organisation subscribes; d) Results of environmental management system and compliance audits; e) Results of monitoring of key characteristics of operations; f) Results of progress toward achieving objectives and targets; and g) Views of interested parties, including employees, customers and suppliers. The identification of the environmental management system

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APPENDIX 1 : IDENTIFICATION OF ASPECTS AND IMPACTS FORM (1 activity per sheet)

1.0

Describe the activity that you can control or influence: ___________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________

2.0

List of Aspects Situation Emergency

Abnormal

3.0

Quantity

Normal

Aspects

Consume

Release

Discharge

Emit

Use

Are the aspect(s) governed by National/International/local government act or law? Yes 3.1

No

Specify the main act, regulation and applicable clause: ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________

4.0

Are the aspect(s) governed by other requirements? 4.1

Yes

No

Specify: (customer requirements, corporate requirement, trade association) ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________

5.0

Impacts to the environment:

Adverse

Beneficial

i.

Normal ______________________________________________________________________ ______________________________________________________________________

ii.

Abnormal ______________________________________________________________________

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6.0

Emergency ______________________________________________________________________ ______________________________________________________________________

Is there any procedure (s) to reduce and manage the risk to the environment? Yes

No

Specify: ______________________________________________________________________ ____ ___________________________________________________________________________ 7.0

Are there any environmental good practices that are in place to manage the environmental impacts? ___________________________________________________________________________ ___________________________________________________________________________

8.0

Have there been any past emergency situations and accident?

Yes

No

Specify ___________________________________________________________________________ ___________________________________________________________________________ 9.0

Evaluation of significant 9.1

Criteria for Significance High – 3; Medium – 2; Low – 1

9.2

High a. b. c. d. e.

9.3

Medium

Low

Scale of impact to the environment Probability/frequency of occurrence Severity of impact to the environment Concern to interested parties Risk of non compliance to legal and other requirements Total score

Score Total score greater than 10 is significant Total score below 10 is not significant provided it is not governed by environmental related legislation and other requirements.

10.0

11.0

Result: SIGNIFICANT

NOT SIGNIFICANT

Transfer to list of significant environmental aspects and impacts

Yes

No

If NO please state reason(s) ___________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________

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APPENDIX 2 : LIST OF LEGISLATION IN THE CONSTRUCTION INDUSTRY GUIDELINES FOR CONSTRUCTIONS INDUSTRY NO.

ACTIVITIES

1.

Planning & Design (Land Conservation)

2.

Planning & Design (Land use)

ENVIRONMENTAL CONCERN

TITLE

Control of water, air and land pollution

EQA 1974

Protection of wold animals and birds

Aboriginal People Act, 1954 Act 134 (Revised), 1974

AGENCY

DESCRIPTION

DOE

An act relating to prevention, abatement, control of pollution and enhancement of the environment.

Federal

An act to provide for the protection, well being and advancement of the aboriginal peoples of West Malaysia.

E.Q (Prescribed Activities) (Env. Impact Assessment Order 1987

Section 6 – Aboriginal areas Section 7 – Aboriginal Reserve 3.

Planning & Design (Land use)

4.

Planning & Design (Land Conservation)

Excavation work at archaeological reserves and disposal of antiquities and historical objects.

Antiquities Act 1976, Act 168

Federal

An act to provide for the control and preservation of, and research into ancient and historical monuments, antiquities and historical objects and exports of antiquities and historical objects and for matters connected there worth.

Soil erosion and protection of soil from erosion

Land Conservation Act 1960, Act 3

Federal

An Act relating to the conservation of hill land and the protection of soil from erosion and the in road of silt. Part II – Control of hill land Section 6 – Restrictions on clearing and cultivation of hill land Part III – Control of silt and erosion Section II – Notice to show cause against order

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GUIDELINES FOR CONSTRUCTIONS INDUSTRY NO.

ACTIVITIES

5.

Planning & Design (Land use)

6.

Planning & Design (Land use & Land conservation)

7.

Planning & Design (Natural Resources Protection & Management)

8.

Planning & Design (Natural Resources Protection & Management)

ENVIRONMENTAL CONCERN

TITLE

AGENCY

DESCRIPTION

Control of water, air and land pollution

Town and Country Planning Act 1976, Act 172

Federal

An Act for the proper control and regulation of town and country planning in local authority areas in the states of Malaya and for purposes connected therewith or ancillary thereto.

Protection of natural resources and wildlife

National Land Code, Act 56 & P.P 474, 1965

Federal

An Act to amend and consolidate the laws relating to land tenure, the registration of title to land and of dealings therewith and the collection of revenue there form within the states of Johore, Kedah, Melaka, Negeri Sembilan, Pahang, Penang, Perak, Perlis, Selangor & Terengganu and the purpose connected therewith.

Protection of natural resources and wildlife

National Parks Act 1980

Dept. of Wildlife & National Parks

An Act to provide for the establishment and control of National Parks and for matters connected therewith.

Protection of natural resources and wildlife

National Forestry Act 1984 Act 313

Dept. of Forestry

An Act to provide for the administration management and conservation of forest and forestry development within the state of Malaysia and for connected purposes

Wood Based Industries (State Legislatures Competency) 1984 – Act 317

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GUIDELINES FOR CONSTRUCTIONS INDUSTRY NO. 9.

ACTIVITIES Planning & Design (Natural Resources Protection & Management)

10.

Planning & Design

ENVIRONMENTAL CONCERN

TITLE

AGENCY

DESCRIPTION

Protection of natural resources and wildlife

Protection of Wildlife, Act 76 1972 (Revised), 1976

Dept. of Wild life & National Parks

An Act to consolidate the laws relating to and to further provide the protection of wild life and for purposes connected therewith.

Control of water

Water Supply Enactment

State of Government

An Act to consolidate the laws relating to and to further provide the protection of water supply.

Federal

An Act to provide for the control of rivers and streams. This act shall only apply to the state of Negeri Sembilan, Pahang, Perak, Selangor, Malacca, Penang & Federal territory.

(Natural Resources Protection & Management) 11.

Planning & Design (Natural Resources Protection & Management)

No. 3 of 1955

Control of river and stream River pollution

Water Act 1920 (Act 418) & Water Supply (Federal Territory of KL) Act 1998 (Act 581)

Construction at river bank

Section 7A – Prohibition of pollution of rivers. Section 7B – Restriction on construction of halls and buildings on banks of rivers or within flood channels. 12.

Planning & Design (Natural Resources Protection & Management)

Preservation of trees

Geological Survey Act, 1974

Dept. of Geological Survey

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GUIDELINES FOR CONSTRUCTIONS INDUSTRY NO. 13.

ACTIVITIES Planning & Design

ENVIRONMENTAL CONCERN Preservation of trees

(Natural Resources Protection & Management) 14.

Planning & Design (Design Stage)

15.

Planning & Design (Design Stage)

TITLE Town and Country Planning Act, 1976

AGENCY

DESCRIPTION

Local Authorities

Tree Preservation Order, 1995 Control of water, air and land pollution

Environmental Quality Act 1974

DOE

An act relating to the prevention, abatement, control of pollution and enhancement of the environment, and for purposes connected therewith.

Control of water, air and land pollution

City of Kuala Lumpur (Planning) Act, Act 1973

Federal

An Act to make provisions for the control and regulating of proper planning in the City of Kuala Lumpur, for the levying of development charges, and for purposes connected therewith and ancillary thereto.

Act 127

16.

Planning & Design (Design Stage)

Control of water, air and land pollution

Civil Aviation Act, 1966, Act 3, 1969

Federal

An Act to make better provision in the law relating to Civil Aviation and for the matters connected therewith and ancillary thereto.

17.

Planning & Design (Design Stage)

Control of water, air and land pollution

Housing Development Act (Licensing and control), 1965

Federal

An Act to provide for the control and licensing of business of housing development in West Malaysia and for matters connected therewith.

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GUIDELINES FOR CONSTRUCTIONS INDUSTRY NO. 18.

ACTIVITIES Planning & Design (Design Stage)

ENVIRONMENTAL CONCERN Control of water pollution through proper drainage system

TITLE Uniform Building By Law (UBBL)

AGENCY

DESCRIPTION

Federal

This Act shall apply to the State of West Malaysia only. Section 11 – Interference with drainage Section 12 – Construction of unauthorized Drains Section 19 - Right of access

19.

Planning & Design

Sewerage disposal

Sewerage Services Act, 1993

Department of Sewerage Services

An Act to amend and consolidated the laws relating to sewerage system and sewerage services throughout Malaysia for the purpose of improving sanitation and the environment and promoting public health, and to provide for matters connected therewith.

Control of water, air and land pollution

Street Drainage and Building Act 1974

Local Authorities

An Act to amend and consolidate the laws relating to street, drainage and building in local authority areas in West Malaysia, and for the purposed connected therewith

Control of water, air and land pollution

Local Government Act, 1976

Local Authorities

An Act to revise and consolidate the laws relating to local government. Whereas it is expedient for the purpose only of ensuring uniformity of law and policy to make a law with respect to local government.

Discharge of surface runoff to existing drain

Earthwork BS 6031:1981(Code of Practice)

(Design Stage)

20.

Planning & Design (Design Stage)

21.

Planning & Design (Design Stage)

22.

Earthwork

Federal

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GUIDELINES FOR CONSTRUCTIONS INDUSTRY NO.

ACTIVITIES

ENVIRONMENTAL CONCERN

TITLE

AGENCY

DESCRIPTION

23.

Earthwork

Requirement for silt trap and sediment control facilities

Earthwork By Law 1985

Local Authorities

24.

Earthwork

Use of explosives and control the effect of explosive to the environment. Eg. Air pollution, water pollution

Explosives Ordinance, 1957

Federal

An Act relating to the manufacture, use, sale, storage, transport, import and export of explosives

25.

Earthwork

Emission of smoke from vehicles and machineries

Factories and Machinery Act, 1967, Act 139 (Revised)

Federal

An Act to provide for the control of factories with respect to matters relating to the safety, health and welfare of persons therein, the registration and inspection of machinery and for matters connected therewith.

26.

Earthwork

Discharge of effluent water from the activities

Mineral Development Act 1994, Act 525 & Akta Pembangunan Mineral 1994 (Akta 525)

Federal

An Act to provide for the inspection and regulation of the exploration and mining of minerals and mineral ores and for other matters connected therewith.

27.

Earthwork

Control of air and noise pollution from vehicles

Road Traffic Ordinance, 1958

Federal

An Ordinance to make provision for the regulation of motor vehicles and of traffic on roads and otherwise with respect to roads and vehicles thereon; provision for the protection of third parties against risks arising out of the use of motor vehicles, and to provide for the co-ordination and control of means of and facilities for transport.

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GUIDELINES FOR CONSTRUCTIONS INDUSTRY NO. 28.

ACTIVITIES Earthwork

ENVIRONMENTAL CONCERN

TITLE

Prohibition of pollution of rivers and restriction on construction of walls and buildings on banks of rivers or within flood channels

Water Act 1920 (Act 418)

AGENCY

DESCRIPTION

Federal

An act to provide for the control of rivers and streams. This Act shall only apply to the State of Negeri Sembilan, Pahang, Perak, Selangor, Melaka, Penang and Federal Territory.

Water Supply (Federal Territory of Kuala Lumpur) Act 1998 (Act 581)

29.

Earthwork

Windblown dust

Environmental Quality (Clean Air) Regulations 1978

DOE

An Act relating to the prevention, abatement, control of pollution and enhancement of the environment, and for purposes connected therewith.

30.

Earthwork

Control of soil erosion

Guidelines for Prevention & Control of Soil Erosion and Siltation in Malaysia

DOE

Guideline for Environmental management Plan (EMP) – Design/Implementation Stage

31.

Construction

Open burning & Offensive odours

Environmental Quality (Clean Air) Regulation 1978

DOE

Smoke and gaseous emission from vehicle

Environmental Quality (Control of Emission from Diesel Engines) Regulation 1996

An Act relating to the prevention, abatement, control of pollution and enhancement of the environment, and for purposes connected therewith.

Noise from motor vehicles

Environmental Quality (Motor Vehicle Noise) Regulation 1987

Discharge of effluent and sludge onto land

Environmental Quality (Sewerage & Industrial Effluents) Regulation 1979

Storage and disposal of scheduled wastes

Environmental Quality (Schedule Wastes) Regulation 2005

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GUIDELINES FOR CONSTRUCTIONS INDUSTRY NO.

ACTIVITIES

ENVIRONMENTAL CONCERN

TITLE

AGENCY

DESCRIPTION

Occupational Safety and Health Act 1994

Federal

An Act to make further provision for securing the safety, health and welfare of persons at work, for protecting others against risks to safety of health in connection with the activities of persons at work, to establish the National Council for Occupational, Safety and Health of for matters connected therewith.

Federal

An Act to make provision for the regulation of motor vehicles and of traffic on roads and other matters with respects to roads and vehicles thereon; to make provision for the protection of third parties against risks arising out of the use of motor vehicles; to make provision for the co-ordination and control of means of and facilities for construction and adaptation of motor vehicles; and to make provision for connected purposes.

DID

The guidelines relating to drainage system for building and development area.

Majlis Perbandaran Subang Jaya

The guidelines relating to the prevention, abatement, control of pollution and enhancement of the environment, and for purposes connected therewith

32.

Construction

33.

Construction

Emission of smoke from vehicles and noise pollution

Road Transport Act 1987

34.

Construction

Environmental friendly drainage system

Manual Saliran Mesra Alam (MSMA)

35.

Construction

Control of air quality and soil erosion

Garispanduan Kesihatan Persekitaran, Pemeliharaan Alam Sekitar, Keselamatan Pekerja dan Pengurusan Sisa di Tapak Binaan dan Rumah Kongsi

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