Environmental Management Planning
To a build a more sustainable business requires developing a vision that includes your environmental commitment (policy and strategy) and the plans to drive environmantal improvement.
To develop your environment management plan follow the steps below:
- Describe the document
- Outline the Project / Process / Site
- Make a statement of Commitment
- Define the Management Context
- Identify Statutory Compliance requirements
- Identify and rank environmental issues
- Document how issues are to be addressed
- Prepare Emergency Response Plan (EPR)
- Assign Responsibility
- Provide Appropriate Training
- Prepare Monitoring and Reporting Plan
- Have the EMP endorsed for use
Step 1
Describe the document
Identify at the commencement of the document:
- Name of the document including name of site to which the document relates
- Identify the author and document version number and date.
- Identify the organisations responsible for implementing the EMP
Step 2
Outline the Project / Process / Site
Specifically define or describe:
- The physical scope of the area/site subject to this EMP, the project outline including environmentally sensitive features of the site
- The scope of the operational process(s) subject to this EMP
- The relationship of the project to the organisations overall activity and geographic spread
- The relationship of the site to surrounding areas including usage of those areas e.g. residential, bushland etc
- Include plans and diagrams as need to illustrate the nature of the site or process.
Step 3
Make a statement of Commitment
Identify the environmental objectives and outcomes desired from the application of this EMP.
State the context of those outcomes in terms of how they relate to the broader environmental vision, goals and objectives of the organisation.
Where appropriate refer to the organisation or project's Environmental Policy. Include performance targets where appropriate.
Step 4
Define the Management Context
Specifically define:
- The management context of the EMP in particular how it may relate to the organisation/site's Environmental Management System (EMS) and any other applicable operational plan
- How the EMP fits into the overall project delivery or operational planning process
- The author of the EMP and the lines of responsibility involved in executing the EMP including revisions
- The document control or project management system that governs the preparation, review and revision of the EMP including the frequency of EMP reviews.
- The implementation period of the EMP
Step 5
Identify Statutory Compliance requirements
- Define in detail the scope of regulatory, statutory, development consent conditions or operational licence conditions that relate to the scope of the EMP, the project or process.
- Include copy of consent requirements/licence requirements in EMP and if approvals are required and when.
- Identify the process employed to ensure amendments to statutory or regulatory requirements potentially applicable to the project/process will be identified, evaluated and the EMP revised accordingly.
- If relevant, identify how subcontractors will be bound by the EMPs statutory responsibilities.
Step 6
Identify and rank environmental issues
Identify the range of environmental aspects and related impacts in relation to the site, the project or process including all activities related to the above.
Through a risk assessment process identify and prioritise risks based on likelihood and consequence. Consider impacts within the site and adjacent to the site. Consider also the key performance areas and commitments of the organisation's Environmental policy and the risks related to this project/process. Identify the general risk mitigation or management approach. This will be detailed in step 8.
Keep in mind the scale of operational or financial impacts resulting from failure of the EMP to adequately address risks. This includes potential penalties as well as loss of revenue and reputation
Step 7
Document how issues are to be addressed
Identify the range of procedures or work instructions required to effectively manage the environmental impacts, achieve opportunities and meet the EMP objectives. The procedures should provide simple guidance on how the issues should be addressed. They may include step by step detail on what will be done, who will do it and when it will be done in the sequence of site, project operations.
These procedures or work instruction should clearly identify how they relate to the environmental objective or outcomes listed in the EMP.
These procedures can be developed around stages of the project or operational processes on site (e.g. stage 1 site clearance, stage 2 construction) or based on the issues to be managed (e.g. stormwater control, energy efficiency, water conservation and reuse, noise abatement, soil erosion, storage of hazardous materials, waste management, air emissions etc)
Procedures may be grouped into separate self contained plans located within the framework of the EMP (e.g. Erosion Control Plan, Inspection & Test Plans, Waste Management Plan, Air Quality Plan, Site Remediation Plan, Energy Management Plan etc. This approach is often used where there are complex operational controls, specific legal requirements and requests by consent authorities for such plans.
Example: List the tasks that specific site staff are required to do to minimise waste creation during the handling or processing of materials; storage of wastes, separation of wastes into designated bins and the location of bins to facilitate removal by contractors. Other procedures may include how waste is to be included in staff induction training or standards referenced in waste contractors services contracts.
Step 8
Prepare Emergency Response Plan (EPR)
If necessary, prepare an ERP or response procedure detailing the actions to be taken and assigned responsibilities for response to environmental incidents and emergencies related to the implementation of the EMP or the operations in which the EMP relates.
The ERP may be a component of an existing site or facility ERP. Existing plans may be referred to in the EMP provided the assigned responsibilities are clear between the sites designed ER Coordinator and the staff implementing the EMP.
Nominate the 24 hour emergency contact person. Organisations storing or handling flammable or toxic material are required to have a EPR in place together with adequate staff training.
Example: If the site stores or handles hazardous or flammable waste materials the EMP should identify what steps need to be taken to reduce the risk and allocate responsibility for review. Generally issues to do with response to spills of liquid wastes should be included in whatever overall ERP is in place for the site.
Step 9
Assign Responsibility
Assign responsibility for implementing and monitoring effectiveness of the management procedures listed above. Include team responsibilities and accountabilities and lines of reporting.
Schedule responsibilities of the key site/facility/project team including title, name, contact details and nature of responsibilities for each. Ensure reporting responsibilities are clear.
Identify divisions of responsibility between staff, contractors and suppliers as necessary. Ensure individuals responsible for implementation have the necessary delegated authority.
Example: There should be an individual responsible for waste performance across the site. Depending upon site complexity there may need to be individuals at specific areas of activity (e.g. Goods Incoming) to ensure, for example, that waste transport packaging is handled and disposed of as per the waste plan. Contracts with the waste removal contractors should include the level of service required, and the key contact in the contracting organisation.
Step 10
Provide Appropriate Training
Identify the skills required to effectively implement the EMP and its procedures or sub plans. Ensure the skills of relevant contractors working on the site are also included.
As a minimum everyone must be familiar with the EMP, their roles and responsibilities detailed in it and what it requires of their job.
Develop an induction training plan which explains the purpose of the EMP and any issues to new starters, whether permanent or contractors, need to be aware of.
Identify and describe how specific operations skills training will occur, when and with which staff. Ensure all site/facility staff are aware of their responsibilities in implementing work instructions or procedures contained in the EMP.
Ensure the EMP clearly lists who will require training, the frequency of training, and the procedure to document training activities. Identify also to what basic level or standard training will be targeted.
Step 11
Prepare Monitoring and Reporting Plan
Explain how the actions listed in the EMP will be monitored as well as the performance of relevant sub-contractors e.g. waste contractor.
Prepare a schedule that lists what will be monitored, by whom, the frequency and the responsible sign-off person to confirm monitoring has been undertaken.
Monitoring procedures, forms and checklists may be required. Ensure legislative requirements and licence standards/limits (eg. dust emissions), if existing, are listed and the metrics for measurement clearly stated.
Identify the contingency plans or actions required to mitigate failures identified through monitoring. These should include corrective action procedures. Preventive actions should be identified and detailed in the Plan.
Example: A simple waste schedule will allow weekly or monthly waste data (from each waste stream on site) to be recorded and compared to any targets set. The metrics for reporting should relate the amount of waste created, recycled and land filled to the amount of production e.g. total waste / unit production; recycled waste / unit production etc. This will assist in tracking the efficiency of any measures implemented to reduce or better manage waste. Monthly reporting to senior management will assist in evaluating overall progress and provide a basis for review and improvement decisions if necessary.
Step 12
Have the EMP endorsed for use
Ensure the EMP is reviewed by an appropriate management personnel/team and, dated and signed-off as authorised for use.