MANAGEMENT TOOL: ENVIRONMENTAL AUDITS
A Leading Edge article in the September 1992 edition asked "After the (Environmental) Audit, What? .". The article went on to suggest that a plan with alternatives and priorities leading to actions was a vital outcome of an environmental audit. The article dealt with the Bata case in which a situation arose where, although aware of the problem and considering a solution, management had not documented a time table for any action they planned to take.
Since an environmental audit is a document given to a Board of Director on a regular basis, the responsible parties must document any actions taken or planned and any accomplishments achieved. In the Bata case, even after appeal, it still cost the two executives involved $6,000 each in non-reimbursable fines. With legal fees the cost was over ten times that of an initial clean-up.
Environmental planning is not a standalone function, it must be integrated with engineering and managerial assessments involving Risk, Health, Safety, Building and Equipment appraisals and should be viewed as an ongoing activity, one that is integrated into the regular management process.
The plan will never be complete, except in an instant. It must be constantly changed to reflect the other changes that take place in the market place and within the organization.
This applies whether the organization involved is part of the government, an NGO, or Industrial Commercial Institutional, or classed as a major chemical or chemical process industry such as smelting, pulp and paper, a petro chemical, or commercial laboratory.
There are typically a dozen features that such a plan might cover; here are a half dozen which might be considered of particular importance as examples:
∆ Due Diligence in the context of environmental management system. There are a number of successful models in environmental management to be found in the ISO 14000 series, CSA models and guidelines such as Z750 for EMS and Z751 Due Diligence auditing. There are also planning budgeting, implementation, commitment, environmental policies and workable procedures. There needs to be clearly outlined communication protocols, continuous improvement monitoring and, or course, the whole process should be integrated into the regular management system.
∆ The input should include both internal and external auditor reports. Emphasis should be on sustainable facility life cycle and or product life cycle. Life cycle type audits are particularly significant in the case of corporate acquisitions. It should be noted that in a TQM setting, environment audits can be combined with the health and safety audit (WHMIS) report.
∆ If the organization is involved in transportation, a Transportation of Dangerous Goods (TDG) impact could be given a special review place in the reporting. This would be particularly important if the company takes product stewardship responsibility.
∆ With the government emphasis on waste reduction ("3Rs") the report would deal with progress not only in the control of office paper but also report on changes in the process to eliminate waste at the beginning of the operation rather than at the 'end of pipe'.
∆ In certain instances Storage Tank Management should receive special attention.
∆ Abandoned Sites, sites once in control of the organization but never decommissioned, can represent an ongoing charge and remediation action plans or decommissioning reports may be required. A typical case would be a PCB lighting capacitor storage site awaiting the MOEE decision as to its disposal.
Every environmental report needs to be tailored specifically to the organization's needs and requirements and must reflect the need for continuing vigilance on the part of the Board of Directors of this importance aspect of the modern world.
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