Scrutinising environmental reviews

12th April 2012

Intraining 1

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  • Reporting ,
  • Management



Paul Reeve looks at how to compile an environmental review

Whether it’s called an initial, preliminary or preparatory environmental review, the review is the start point, en route to an effective environment management system. A review investigates an organisation’s environmental aspects and impacts, collecting and reporting information that can answer the basic management question: “Where are we now?”

As such, the environmental review has a different purpose to an environment management system audit, which aims to find out whether management processes are properly implemented and working. The audit should put the basic management question: “How are we doing?” And the answer should inform recommendations for further action to improve the management system.

A question of scope

It is vitally important to define the scope of an environmental review. It must reflect the activities, products and services to be covered by the environment management system.

A key question is whether a review will include products and services, or keep to site-based activities. Assuming the review is on-site, copies of the site plan will be invaluable. The site plan can be used to highlight essential features, such as:

  • Inputs – water meters; gas and electricity meters; delivery points; oil and chemical storage tanks; and material storage areas.
  • Processes and activities – production, assembly and finishing; on-site power generators, refrigeration and boilers; unloading, marshalling, materials and product storage/transfer/loading; packaging operations; administration offices; and car parking.
  • Outputs – discharge points to the sewer or to natural waters; chimneys; skip yard; and waste despatch points.
  • Environmental controls – effluent treatment; oil/water separators; emission abatement; waste storage, treatment and segregation; on-site waste recovery or reprocessing; and site screening and landscaping (for noise/visual aspects).

In addition, a local map can help to identify any significant environmental pathways and receptors. For example, how close is the site – and its access routes – to:

  • residential neighbours and sensitive communities, such as hospitals and schools;
  • local water courses – streams or rivers, for example;
  • local ecosystems, such as woodlands or lakes, and notable nature reserves or special conservation sites; and
  • local cultural heritage sites?

It’s also important to consider site exposure and orientation, for example its position relative to the prevailing wind and any slope direction, which would affect run-off.

The review should identify and report on a range of quantitative information. For instance, annual data on: energy consumption; water and materials; storage volumes of substances; amounts of recoverable waste and destination of other waste; and emission levels and effluent discharges. It is a truism that, no matter what an environment practitioner does, “they should always know where the drains go.”

Although sites offer the advantage of a physically defined boundary, the assessment of significant aspects and impacts may need to extend further, to include transport, supplier activities and product-related aspects. Broadening the scope of the environmental review can be part of the “continual improvement” of the environment management system, a key requirement in ISO 14001.

In practice

Having agreed on the scope, an environmental review should cover:

  • regulatory requirements;
  • significant environmental aspects (see panel);
  • environmental practices and procedures; and
  • records of any previous incidents.

The review should then enable an organisation to establish a relevant and effective environment policy and assess how well current arrangements are dealing with significant aspects. It should also help identify meaningful areas for improvement and provide a blueprint to implement an action plan to deal with polluting and other significant environmental aspects.

Last, it should support regulatory compliance and continual improvement. Ideally, the review should encourage the participation of site representatives to broaden understanding of the key elements of an environment management system. It also needs to highlight areas for more investigation and inspection. Documentary requirements may include:

  • Regulatory – process authorisation/installation permit; discharge consent; waste documentation (see below); register of relevant legislation/guides to legislation; details of regulatory non-compliance; and any complaints.
  • Site – site plan; map of surrounding area; organisation chart; process flow charts; emergency response procedure; previous audits or surveys; environment policy; staff environmental responsibilities; procedures; and records.
  • Utilities – supplier invoices; metering records; and fuel bills and renewable-energy tariffs.
  • Waste – duty of care transfer notes; hazardous waste consignment notes; waste management permit; waste storage facilities; and waste/recovery data.
  • Contaminated land – records of operations or incidents on-site; historic site plans and maps; and contaminated-land surveys.

Other considerations

Life-cycle assessment (LCA) is not easy, nor particularly common. It compiles information (if it is available) on material, energy and waste inputs and outputs linked to a product or service, throughout its life cycle.

A product life cycle spans the extraction of various raw materials, through various stages of manufacture, transport and use, to end-of-life – when the product is discarded or materials recovered. LCA tends to be a complex exercise, which may rely on assumptions as well as hard data – for example, if the average number of times a product is reused is not known, an educated guess may be used.

As such, LCA differs markedly from other forms of environmental assessment, such as the environmental review, which usually considers a particular location or life-cycle stage, such as manufacturing or use.

Features of a good LCA include transparency, impartiality, credible scoping, and communicating the limitations of data, assumptions and conclusions. Embodied carbon – the amount of CO₂ released as a result of material extraction, transport, manufacturing and related activities, from product cradle to grave – is a particular, and increasingly used, type of LCA.

Whatever the scope, an environmental review is the bedrock of the management system. A good-quality review will make the environmental management that follows much easier for all, and far more effective.

Significant Aspects

An organisation may have many actual (and potential) aspects and impacts. It’s essential to assess which are “significant”, and organisations working to a environment standard – such as ISO 14001 – must have a systematic approach to assessing significance.

There is no standard method for establishing significant environmental aspects but, in general, they should include aspects that:

  • are subject (or potentially subject) to regulatory control, or a code of practice signed up to by the organisation;
  • are of particular interest to key stakeholders; and
  • have the potential for a substantial impact on human health and/or the environment (perhaps owing to large volumes or toxicity).

Even within significant aspects, some further prioritisation for action may be required.


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