Development, Monitoring and Maintenance of Emergency Plans in Relation

to Environmental Pollution
3.5

A business continuity plan should therefore consist of the following:

1. Analysis of the business.

2. Assessment of the risk.

3. Development of a strategy.

4. Development of a plan.

5. Plan rehearsal.

Handling the Press and Other Media

Dealing with the press and other media is often an issue that is not given full consideration until an emergency
incident takes place and it then becomes clear that there is significant interest from local and possibly national media
organisations. The reputation of an organisation is arguably one of its most important assets and one that is easily lost
or damaged through poor communication to the public via the media.

In the absence of any accurate, open and honest information coming from the organisation, it is potentially inaccurate
information that is publicised. Once that information is in the public domain, the organisation is in the position of
having to deny or correct the information.

During the planning process for emergencies, it is important that:

• Specific people are identified as being those who will communicate with the media during an emergency.
• All other employees are given clear instruction not to talk to reporters and to direct any enquiries to those
members of staff who have been allocated this role.
• Nominated staff members are properly trained in how best to communicate with the media.
• When an emergency occurs, there are systems and procedures in place to ensure that nominated staff are kept
fully informed of the situation regarding the emergency.
Building good relationships with local press, radio and television reporters can be very beneficial, should an emergency
incident occur, as they will automatically approach the member of staff they normally deal with, who is likely to be
someone trained and experienced in dealing with the media. Local media can also be supportive in getting important
mitigation information to the local population, such as the need to stay indoors and close all windows. This information
will be more effectively distributed if the different parties involved are used to dealing with each other.

STUDY QUESTIONS
14. Outline the contents of an internal emergency plan.

15. Outline the key ways in which an emergency plan could be tested.
(Suggested Answers are at the end.)

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 Summary

Summary

Key topics covered in this element:

• Environmental management systems are based on the Plan-Do-Check-Act model.
• ISO 14001 consists of seven key parts: context of the organisation, leadership, planning, support, operation,
performance evaluation and improvement.
• The Eco-Management and Audit Scheme (EMAS) contains elements additional to those in ISO 14001 (e.g.
publicly verified environmental statement).
• An initial environmental review is the starting point to implementing an EMS. It enables organisations to
determine the current level of environmental performance.
• Implementing an EMS is beneficial for numerous stakeholders, including the company, customers, shareholders,
the local community, lenders, insurers, etc.
• Health and safety and quality management systems can be integrated with environmental management systems.
There are both advantages and disadvantages to this approach.
• Environmental data may be quantitative, qualitative, absolute and normalised.
• Corporate environmental reports, CSR reports and sustainability reports are commonly used by organisations to
publicly report their environmental performance.
• Benchmarking is commonly used as a tool for organisations to assess their environmental performance either
internally or externally.
• Environmental requirements should be implemented into general business policies, procedures and systems of
work.
• Contractor management involves selecting the contractor, planning the work and monitoring the contractor.
• Emergency plans are often required by law.
• An emergency plan may consist of two elements, an internal (on-site) and external (off-site) plan, although the
two should be closely linked.
• Emergency plans can be practised by undertaking drills, seminar exercises, walk-through exercises, desktop
exercises, or live exercises.

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 Exam Skills ES

Exam Skills

QUESTION
BS EN ISO 14001:2015 does not set specific requirements for the method of development and type of
objectives to be set. Using suitable examples:
(a) Explain the difference between strategic and low level objectives (targets). (8)
(b) Explain how an organisation should proceed in setting its objectives. (6)
(c) Describe actions that should be considered if an objective is unlikely to be achieved within
the specified time period. (6)

Approaching the Question

• Read the question.
• Consider the marks available - this time there are three sub-questions so the time allocated should be
approximately 14 minutes for (a) and 11 minutes each for (b) and (c).
• An outline plan might include:
(a) Strategic objectives - long-term, linked to policy, examples; low level objectives - requirements of performance,
SMART.

(b) Environmental review/policy, present performance, measures, objective-setting.

(c) Data review, corrective measures, project effect of changes, objective revision.

This is the first example of a 20-mark question, which is the format of all the questions in the NEBOSH Diploma in
Environmental Management exam. This question is, however, split up into three sub-questions of varying marks, which
is how a 20-mark exam question is sometimes formatted.

Part (a) focuses on strategic objectives and low level objectives, which are linked but consist of some fundamental
differences. Your answer to all parts must be based on objectives and use specific examples. You must also identify
differences (not similarities). For part (b) the word ”proceed” is used, so you must identify the key stages of the setting
of objectives. The last part requires a description of what should occur if an objective is not likely to be achieved; it does
not state that failure to reach the objective has occurred.

Suggested Answer Outline

Now you have completed your answer, compare it to the following suggested answer.
(a) Strategic objectives are classed as longer-term goals that have a direct link to a commitment in an organisation’s
environmental policy. The policy commitments themselves are largely based around the significant environmental
impacts of the organisation. For example, for a food manufacturer an objective may be set to reduce water
consumption, which will be directly linked to a policy commitment to reduce the number of resources that are
used by the organisation. The aspect in the case would be water consumption, with the impact being use of a
natural resource.
Every significant impact is likely to have at least one strategic objective. Low level objectives have a direct link to
strategic objectives. They provide further detail on how the objective (and associated policy commitment) is to be
achieved.

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ES Exam Skills

Low level objectives are often Specific, Measurable, Achievable, Realistic and Time-bound (SMART). As such,
measuring against the low level objective can be a method used to assess the environmental performance of the
organisation. Examples of low level objectives include ‘Reduce water consumption by 20% by 2017 (based on a
2015 baseline)’ or ‘Increase recycling of cardboard by 30% by 2016 (based on a 2011 baseline)’. Action plans are set
following the identification of a low level objective and provide further detail on how the objective will be achieved.
(b) Objectives identify information that is usually collected as part of the Initial Environmental Review (IER). The IER
process will provide information on the organisation’s current environmental performance. It will help identify the
significant environmental impacts of the organisation. For each significant impact at least one strategic objective
and associated low level objective will often be set. The improvement measures required would then need to be
considered, which will form the basis of the objectives.
Following this, a means of determining how to track performance with the objective would need to be considered.
Environmental performance indicators could be set for each low level objective. For example, for an objective to
reduce waste to landfill by 30% by 2017 (2014 baseline) the kg of waste per unit of product produced could be
measured. This would allow tracking of performance against objectives, which is a requirement of ISO 14001.

When setting objectives, there are numerous factors which should be considered - for example, legal requirements.
Environmental permits often require an organisation to use the Best Available Techniques to deal with environmental
issues covered by the scope of the permit. Another factor will include the cost of the improvement. The resources of
the organisation may only allow for a limited budget for improvements to be made. The organisation will therefore
need to carefully consider what the financial implications are of implementing an improvement. This may mean
that a reduced objective is set. Other limitations might include the technological options available to the business
to initiate an improvement. In some cases, a reduction in environmental impacts may not be achievable, as the
technology is either not available or excessively costly.
(c) Should objectives not be achieved within a time period specified by an organisation within its EMS then there
are many actions that could be implemented. For example, the organisation may consider undertaking a check
of performance data associated with the objective to work out in more detail why the objective is not being
complied with. This will assist in determining why an objective is unlikely to be achieved and will help with the
identification of measures to be implemented to ensure that the objective is complied with in the future and
environmental performance improved. For example, budgetary constraints may limit compliance with an objective
for training staff. By identifying such a financial constraint, an alternative supplier of training could be found,
meaning that more environmental courses could be delivered in the time period owing to the reduced cost of the
courses.
The organisation should also estimate the results of the change in the future, as this will help improve compliance
with the objective. For example, by purchasing and implementing pollution abatement technology as an
improvement to help meet an emissions reduction target, the organisation should be able to accurately estimate
the reduced amount of a pollutant that is emitted from a stack to air. This will then provide a greater level of
reliability that the objective will be met.
Another action that could be considered is amendment of the objective. This might include altering the
timeframe, which will provide more time to implement the objective. An example might include giving another
year to implement an energy-reduction objective. Additionally, the level of improvement in environmental
performance may have been set too high, so the organisation could set a lower level of performance
improvement, e.g. reducing water consumption by 20% by 2015 rather than by 40% by 2014 (the initial low level
objective).

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 Element 4
Environmental Risk Evaluation and Control

Learning Outcomes

Once you’ve read this element, you’ll

understand how to:

 Explain the principles of environmental

aspect identification.

 Explain the principles of operational

planning and control relating to the
organisation's significant environmental
aspects.

 Explain the techniques for evaluating

environmental aspects arising from
workplace activities.

 Outline
 the purpose of an environmental
impact assessment and environmental
statement in relation to large
developments.

© RRC International © RRC International Unit ED1 - Element 4: Environmental Risk Evaluation and Control 4-1
 Contents

Principles of Environmental Aspect Identification with Reference to ISO 14001:2015 4-3

Environmental Aspects and Impacts 4-3
Source, Pathway and Receptor 4-3
Global, Regional and Local Environmental Effects 4-5
Effects on Quality of Life 4-6
Environmental Impact Assessment 4-7
Techniques to Identify Aspects and Impacts 4-7
Factors to Consider in Environmental Significance Evaluation 4-11
Recording of Aspects and Impacts 4-14
Action Plan Development 4-14
Monitoring and Review 4-14
Study Questions 4-15

Principles of Operational Planning and Control with Reference to ISO 14001:2015 4-16
Best Practicable Environmental Option (BPEO) 4-16
Assessment of Control Systems to Determine the Best Available Techniques (BAT) and the Importance of an
Integrated Approach to Pollution Control 4-17
Selection of Operational Controls 4-18
Factors Affecting Choice of Operational Control Measures 4-19
Possible Conflicts between Protection of Workers and Protection of the Environment 4-20
Selection of the Best Solution for an Organisation Based on Relevant Risk 4-21
Consideration of Fiscal Controls 4-23
Study Questions 4-23

Evaluation of Environmental Aspects and Impacts 4-24

Cost-Benefit Analysis 4-24
Environmental Modelling 4-26
Life-Cycle Analysis 4-30
Circular Economy 4-34
Assessment of Environmental Toxicity 4-35
Study Questions 4-37

Environmental Impact Assessments and Statements for Large Developments 4-38

Planning Environmental Impact Assessment (EIA) 4-38
Study Questions 4-40

Summary 4-41
Exam Skills 4-42

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 Principles of Environmental Aspect Identification with Reference to
ISO 14001:2015
4.1

Principles of Environmental Aspect Identification with

Reference to ISO 14001:2015

IN THIS SECTION...
• An environmental aspect can be defined as any “element of an organisation’s activities or products or services
that interacts or can interact with the environment”.
• An environmental impact can be defined as any “change to the environment, whether adverse or beneficial,
wholly or partially resulting from an organisation’s environmental aspects”.
• The Source-Pathway-Receptor (SPR) model can aid the identification of environmental impacts.
• Environmental aspects and impacts can be identified and assessed by selecting an activity, determining the aspects
and impacts of that activity and evaluating significance.
• Monitoring is an essential tool in the management of environmental risk. Biological indicators such as fish or
macroinvertebrates can be used to monitor quality of the environment.

Environmental Aspects and Impacts

As we saw in Element 3, an organisation must determine aspects and impacts that it can control and influence. This is
a key part of ISO 14001.

Reminder:
• An environmental aspect is any “element of an organisation’s activities or products or services that interacts or
can interact with the environment”.
• An environmental impact is any “change to the environment, whether adverse or beneficial, wholly or partially
resulting from an organisation’s environmental aspects”.

Source, Pathway and Receptor

The Source Pathway Receptor (or Target) approach is of fundamental
importance in the evaluation of environmental risk and is widely applicable
and a relatively straightforward tool to use. It works on the premise of:
• Identification and quantification of sources of hazards (e.g. chemicals,
noise).
• Determination and possible quantification of transport (pathway)
processes and mechanisms (e.g. air, soil, water).
• Characterisation, distribution and responses of sensitive receptors, such
as humans, plants and animals.

Plants are sensitive receptors

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 Principles of Environmental Aspect Identification with Reference to
4.1 ISO 14001:2015

TOPIC FOCUS
The SPR approach can be used to identify the potential effects on any of the environmental media (air, water
and land).

Examples

SPR analysis
Source Pathway Receptor or Target

1. Spill of chemicals or oil Drain Watercourse

2. Release of acid gases Air Land* or water

*In sensitive situations this could lead to chemical changes to the groundwater.

Note: Pathways may also be receptors (such as in the case of a watercourse), and receptors can include people
or land of varying sensitivities.

Example: A petrol-filling station - there are numerous sources, pathways and receptors, including the following:

SPR analysis

Source Pathway Receptor or Target

Product loss and dissolution in groundwater Groundwater in aquifer

Underground fuel tank
Vapour transport through soil Humans

Fuel dispenser Air-inhalation Humans

Spills by users Forecourt drains Local watercourses

Following the above methodology, you will appreciate that a great amount of analysis is required to understand
environmental harm. Although the receptor may be a watercourse, the effect may be on the fish or invertebrate
life in that watercourse, or to the humans or others who have use of that water.

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 Principles of Environmental Aspect Identification with Reference to
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4.1

An SPR analysis can be represented in a figure, as you can see below:

Source, pathway and receptor - an example

Global, Regional and Local Environmental Effects

We have seen that the environment can extend from
the workplace to the global environment (known as
transboundary). Environmental impacts do not respect
countries’ borders - indeed it is a requirement under the
Convention on Environmental Impact Assessment
in a Transboundary Context 1991 (sometimes known
as the Espoo Convention) for governments to notify
and consult each other on major projects that may have
a significant adverse impact across borders.

Consider, as an example, two very different air emissions:

a nuisance dust and a solvent emission. The former may
be confined to being a local problem, whereas the latter
has the potential to affect the global system (although
it does not follow that the solvent emissions from one
particular factory can do this on their own).

There can be direct effects of day-to-day activities; but

some broader issues, e.g. purchasing, may have far-
reaching effects, well beyond the company’s boundaries,
and will depend on the sourcing area. Relationship between local, national and international
environmental issues

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 Principles of Environmental Aspect Identification with Reference to
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Effects on Quality of Life

Nuisances such as Noise, Dust and Odour
Nuisances are matters that interfere with the normal common-law enjoyment of the use of our land or property.
Common nuisance issues include:
• Premises.
• Dust, steam, smell, etc.
• Smoke.
• Animals.
• Accumulations or deposits.
• Noise.
• Fumes and gases.
• Lights.
• Insects.

Visual Amenity
Visual amenity is an issue that is normally managed through planning law under development control responsibilities.
Among other things, these would cover the colour and design of buildings, landscaping, tree-planting, advertising signs,
etc.

There are other matters that are visually unacceptable, such as litter or fly-tipping. Matters such as graffiti may be the
underlying indicators of deeper social problems, but lessen the quality of life. Therefore, measures such as the provision
of certain surfaces or planting, which can deter these problems, may be a planning requirement.

Transport Effects
In the control of air pollution, transport effects include the emission of
combustion gases, such as carbon dioxide, carbon monoxide, nitrogen and
sulphur oxides (NOx and SOx), particles, and, in lesser quantities, up to 40
other gases, such as butadiene and benzene.

Other effects of traffic should not be overlooked, including:

• Noise.
• Dust.
• Congestion.
• Changes to the landscape.
• Land-take (land used for the building of new roads, etc.).
• The effects of refuelling, etc.
Effects of traffic
The overall trend is towards better technology, improved combustion, use of
catalysers and alternative fuel sources (e.g. Liquefied Petroleum Gas (LPG), biodiesel, hydrogen fuel cell) for commercial
as well as private vehicles. Many organisations, particularly in the public sector, have also implemented travel plans, with
the aim of making transportation more sustainable.

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 Principles of Environmental Aspect Identification with Reference to
ISO 14001:2015
4.1

Waste from Consumer Products

The environment is the ultimate resource for society, providing air, water, minerals and food. It is also the sink for
unwanted by-products of society: waste.

Waste and waste disposal are among the greatest issues of the 21st century. As our lifestyles change, so do the types
and quantities of waste we produce. More takeaway and convenience food, individual portions in supermarkets, ready
meals and DIY pre-packaged goods, all produce waste in large quantities. Packaging waste constitutes 24-30% of
household waste in the UK.

The impacts of waste disposal can be significant, including:

• Nuisance caused by:
–– Noise from waste transportation and site activities.
–– Odours from landfill sites or waste incineration.
–– Dust and litter.
• Release of methane containing landfill gas causing climate change and presenting a fire and explosion risk to those
near the site.
• Leachate discharged from a landfill site causing water pollution.

Environmental Impact Assessment

As we saw in Element 3:
• ISO 14001:2015 states that a life-cycle perspective should be considered when determining environmental
aspects and impacts, which means identification of aspects and impacts ‘from the cradle to the grave’. We will
cover this concept in more detail later in the element.
• The way in which significant aspects are identified and assessed must be documented, detailing responsibilities
and arrangements for identifying aspects, determining significance and periodically updating the information.
Below we will cover a methodology to identify and evaluate environmental aspects and impacts.

Techniques to Identify Aspects and Impacts

There are numerous techniques that can be used to identify environmental aspects and impacts and the Standard is
flexible as to which is used. Probably the most common tool used is the IER. This provides the sources of information
for an organisation to identify aspects and associated impacts. Other mechanisms include:
• Life-Cycle Analysis (LCA) - considers aspects and impacts across the full life cycle of a product.
• Environmental impact assessment - considers aspects at the planning stage of a development.
• Environmental audit - provides useful information that can be used to identify aspects and impacts.

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 Principles of Environmental Aspect Identification with Reference to
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Aspect and Impact Identification and Evaluation

A technique that can be used to identify aspects and impacts that may be included as part of the IER is as follows:

STEP 1: Select an activity, product or

service

STEP 2: Identify environmental aspects

and impacts of the activity,
product or service

STEP 3: Evaluate significance of impacts

Step 1: Select an Activity

The activity, product or service selected should be large enough for meaningful examination and small enough to be
sufficiently understood; e.g. an organisation may have many different compressors that use energy on-site, so depending
on the size of the site, the energy use for compressors may be identified as one aspect. A process-flow diagram is often
developed to identify activities on a site (from goods in to despatch) and ancillary activities that are not part of the main
process should not be forgotten (e.g. maintenance, fuel storage, office activities).

Step 2: Determine the Aspects and Impacts of that Activity

Following determination of activities, the next stage is to work out the aspects and impacts of that activity as you can
see below. A simple way is to consider the inputs and outputs from the activity - these are the environmental aspects.

Outputs:
Inputs: • Emissions to Air
• Energy • Release to Water
• Water
Activity • Waste
• Raw Materials • Land
Contamination
• Etc.
Input/output method of identifying environmental aspects

Issues that are commonly addressed include:

• Emissions to air.
• Releases to water.

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 Principles of Environmental Aspect Identification with Reference to
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4.1

• Waste management.
• Contamination of land.
• Use of raw materials and natural resources.
Following the aspects identification, we need to determine environmental impacts that the aspects cause or can
potentially cause. Research of what impact is caused by the aspect may be required. You should be aware that an aspect
can have more than one impact on the environment.

Environmental impacts are usually considered within a number of contexts:

• Direct/Indirect
Impacts can arise as a direct result of an organisation’s activities. For example, in the case of a coal-fired power
station, the operator of the power station clearly has management control and responsibility for the facility. The
environmental impacts associated with the power station are therefore the operator’s direct environmental impacts.

But we all use electricity, don’t we? We create a demand for electricity, and the more electricity we use, the more
emissions the power station makes. We also have some capacity to reduce the environmental impacts associated
with electricity generation by using less energy. We therefore accept some responsibility by recognising the
consumption of electricity as an indirect environmental impact of our activities.

Indirect environmental impacts are associated with many of the goods and services that we buy. For example:
–– Use of a third-party distribution contractor (air pollution from lorries).
–– Purchase of paper (cutting down forests; pollution from paper mills).
For many organisations, especially in the service sector, indirect environmental impacts may therefore have a very
high significance in their environmental programme.

• Normal/Abnormal Conditions
All planned activities need to be considered. These will include not only those associated with normal running but
also those associated with the non-routine (‘abnormal’), such as maintenance and cleaning.

• Accidents/Incidents/Emergencies
Reasonably foreseeable incidents should also be considered, e.g. fire or chemical/oil spillage.

• Past/Future Activities
You should consider the impact from past and planned activities. For example:
–– ­Past land contamination has impacts that continue into the present.
–– ­Business plans, such as increasing production, will have future impacts that should be taken into account.
Aspects and impacts must be documented - this is often done by producing an aspects and impacts register.

Step 3: Evaluate Significance

The next stage is to determine the significance of the list of aspects and impacts. There are many ways of doing this and
ISO 14001 does not provide guidance as to which technique should be used.

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 Principles of Environmental Aspect Identification with Reference to
4.1 ISO 14001:2015

We will look at two examples:

• Example 1: Simple Questions

For each aspect and associated impact the ‘yes or no’ answer to a set of questions may be used; e.g. a ‘yes’ answer
to any of the following questions will mean that an aspect is significant:
–– Compliance obligations - is there a general legal requirement, policy commitment, or corporate/office-
specific requirement?
–– Risk - does the activity present a significant risk to the environment, local or global?
–– Customers - is the aspect of concern to customers, visitors or members of the public?

• Example 2: Risk Assessment

A scoring system can be developed that looks at the likelihood and consequences of an aspect (as is often used for
general health and safety risk assessment).

The following process is used to assign a priority rating for each environmental aspect:
1. Likelihood scored according to the criteria identified in Table 1.
2. Consequences scored according to the criteria identified in Table 2.
3. Calculate a rating score:
Rating Score = Likelihood × Consequence
4. Those with a rating score greater than 6 are identified as significant.

Table 1: Example of likelihood scoring scheme

Likelihood Definition Score
Certain Once a year 4
Probable An incident which is reasonably foreseeable 3
Possible An incident which may occur 2
Unlikely An incident which is extremely unlikely to occur 1

Table 2: Example of consequence scoring scheme

Consequence Definition Score
Severe High environmental impact 4

Causing or may cause breach of law

Causing complaints and/or concern to stakeholders

Medium Medium environmental impact 3

Small change causing breach of law

Small change causing complaints or concerns to stakeholders

Low Slight environmental impact 2

Controlled by law but very unlikely to be a breach

Highly unlikely to cause complaints and/or concern to stakeholders

Negligible Negligible environmental impact 1

Not controlled by law

No risk of complaints or concerns to stakeholders

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4.1

Factors to Consider in Environmental Significance Evaluation

In order to determine the significance of environmental impacts, consideration should be given to a number of sources
of information.

Data on Environmental Problems

The subject of the environment, and hence environmental risk, is growing almost by the day. No course text could
hope to keep fully up to date with such constantly changing material. However, there is a very wide availability of such
information, largely through official and authoritative websites.

If you have access to the Internet, it is well worth while looking at the key websites, as they will prove to be useful
sources of information throughout the course, for the execution of your practical project (which is part of the course),
and for your future career.

There is a wide range of data available on environmental problems. Unfortunately, it is not available from a single
source. The following text shows where information may be found. It is important that both as part of this course and
in your work on your practical project you make use of these sources of information.

Sources of Information and Advice on Environmental Risks

Important sources of information and advice on environmental matters are numerous. Key sources include the following:
• Regulatory bodies - their websites have a great deal of guidance with regard to compliance with legislation.
• Local authorities - may provide guidance and information regarding pollution control, nuisance, etc.
• Government departments’ websites - often contain a huge amount of information explaining policy and providing
official guidance to environmental law, plus consultation on planned regulations, discussion and research papers.
There is also a very useful section on environmental statistics and public-opinion surveys.
• Professional bodies - such as the Institute of Environmental Management and Assessment (IEMA) and the
Chartered Institution of Water and Environmental Management (CIWEM) provide members with a wide range of
resources, including guides to legislation and current best practice.

Use of Environmental Monitoring Data to Evaluate Risk

Monitoring is an essential tool in the management of environmental risk. Monitoring enables the environmental
manager to:
• Ensure efficiency of the process, and any pollution control equipment.
• Ensure compliance with any relevant environmental controls.
• Ascertain whether the controls are adequate.
• Review the environmental impact of a process or activity.
The requirements of monitoring are frequently specified in any permit, consent or licence but monitoring may be
required continuously or periodically. There are many types of monitoring regime, but three are common:
• Controlled emissions monitoring - used for checking operating conditions, or against a particular specification
(e.g. for compliance).
• Ambient air-quality monitoring - to assess the general air quality, which comprises a mixture of emissions from
industrial and domestic premises, traffic and other sources.
• Fugitive emissions monitoring - which concerns emissions that escape through open sources such as landfills, or
escape from premises through leaks in pipelines, flanges, etc.

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All physical forms of materials can be subject to a monitoring regime. Solids, liquids and gases have different issues, but
all may require monitoring for environmental purposes.

In addition to monitoring carried out by companies, environmental regulatory bodies carry out monitoring to check for
compliance with legislation. These results are usually available to the public.

Use of Biological Indicators to Evaluate Risk

Harmful substances on the land, in the air and in the water can go unseen and unnoticed. How, then, do we determine
if there is any danger to ourselves or to others?

Clues can be gained about the condition of the environment by observing the plants and animals. Some plants and
animals react to conditions in the environment that are otherwise difficult to identify. For this reason, they can be used
as biological indicators or “bioindicators”. They provide a good understanding of the consequences of environmental
hazards.

Miners used to carry a canary in a cage into the mine shaft with them. If they hit a pocket of natural gas, the canary
would pass out before any of the workers would be affected. Observing the bird gave them time to retreat out of the
mine before they were in danger.

Likewise, the observation of the types and numbers of different animals can give us clues to the environmental
conditions. For example, some fish and invertebrates thrive in comparison to others in certain conditions. They may
flourish in waters with low oxygen content, an overgrowth of weeds, or abundant algae cover, and eat other plants and
animals that also do well in these conditions. Others may do better in clear, oxygen-rich waters, feeding off other plants
and animals that also do well in those conditions.

Macroinvertebrates are the most widely used organisms for biological assessment because they:
• Do not move far.
• Respond to a wide range of pollutants in the water.
• Are present in the water throughout the year and can reflect any changes in water quality that have occurred.
Biological indicators are sensitive to a wide range of stresses and, as such, provide a measure of the quality or health of
ecosystems. The improvements seen largely reflect reduced pollution.

Uses of External Data Sources

Land and Water Protection
Environmental regulators’ websites often have a wealth of information on water quality, groundwater source protection,
flood plains and vulnerable zones, and wastes. They can be a good source of information on pollution prevention.
There are often detailed guidance notes to explain the legislation. They may also provide up-to-date information on
current consultation papers and legal actions.

Commercial Sources of Information

There are many commercial databases that provide updates on legislation and topical articles on environmental matters.

The Institute of Environmental Management and Assessment (IEMA) also has a large website (www.iema.net) containing
current issues of importance to the environmental manager, and produces a regular magazine, The Environmentalist.

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Records Search
In order to ascertain likely past history, the following types of records may be
searched:
• Topographical maps.
• Special maps and plans, and other maps.
• Enforcement authority registers.
• Geological survey borehole logs and memoirs.
• Environment Agency groundwater vulnerability plans.
• Coal-mining records.
Many sources must be used if environmental risk is to be correctly evaluated.
Examples are:
• Trade directories for past business use of the site - current trade
directory entries also provide valuable information regarding Checking external data sources
surrounding land uses. They may indicate certain types of business that
could generate pollution or nuisances.
• Aerial photographs.
• Local site history.
• Enforcement history.
• Local knowledge.
• Property deeds.
• Local planning records.
The following will also provide very useful information in evaluating risk:
• Location of any nearby landfill sites.
• Location of any site holding authorisations/permits under legislation.
• Abstraction points of drinking water.
• Explosive sites.
• Sites registered for handling radioactive substances.
• Fuel stations.
• Pollution incidents of controlled waters.
• Prosecutions for discharges to controlled waters.
• Prosecutions related to an authorised process.

Site Sensitivity
The magnitude of the effect on the receptor may vary according to a number of factors. These factors include sensitivity
- for example, whether the site is protected under specific environmental legislation, including:
• Special Areas of Conservation (SACs).
• Special Protection Areas (SPAs).
• Ramsar sites (protected wetlands).
All these have special status in law, above and beyond the protection afforded to the environment in general.

Other factors include biological concentration effects and the ease and speed of transmission, which will depend on the
geology and hydrogeology of the land and soil.

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Limitations of Data Sources

Whatever source of information is used to assess environmental risks, certain
simple quality-control checks should be undertaken to ensure that it is:
• Accurate - uncertainties and assumptions within the data source are
understood and taken into account.
• Complete - any specific exclusions must be disclosed and justified.
• Consistent - consistent methodologies allow for comparison of data
over time.
• Faithful - the data should be capable of being depended upon by users
to represent faithfully that which it purports to represent, or could A mass of information is available on
reasonably be expected to represent. the Internet
• Not biased - data must avoid bias in the selection and presentation of information, and provide a credible and
balanced account.
• Relevant - services the decision-making needs of external users.
• Transparent - addresses all relevant issues in a factual and coherent manner and discloses relevant assumptions
and appropriate references to data sources.
A mass of information is available on the Internet, but there are no guarantees as to the quality of this free information.

Recording of Aspects and Impacts

As we saw earlier, environmental aspects and impacts are often recorded in the form of a register. Although there is no
set format for an aspects and impacts register, as a minimum it will often contain the following information:
• Activity that has been assessed.
• Environmental aspects associated with the activity.
• Environmental impact(s) associated with each aspect.
• Identification of whether the aspect is from normal, abnormal, or emergency context.
• Identification of the results of the assessment against significance criteria - for example, likelihood, consequence
and total scores if using a semi-quantitative method to assess significance.

Action Plan Development

Following completion of the aspects and impacts identification and evaluation process, it will be necessary to develop
an action plan consisting of recommendations and timescales for action to be undertaken for significant impacts. At
its simplest for each significant impact this would include developing tasks to prevent or control the significant impact,
setting a responsibility for the tasks and developing an appropriate timeframe for their completion.

Monitoring and Review

An aspects and impacts assessment may need to be reviewed if monitoring or other forms of performance evaluation
identify the following:
• An incident relevant to the assessment has occurred, particularly if there appear to be inadequate controls.
• Processes and/or equipment changes.
• Staff changes, particularly if there is a loss of experience and/or historical knowledge.
• Legislation changes, imposing more onerous or new requirements.
• There has been a lapse of time since the last review - technology moves on and what is considered the best
available technique, or best practicable environmental option, today may not be in the future.

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STUDY QUESTIONS
1. Develop a source, pathway, receptor model for a fuel spill in a haulage yard.

2. What are the three steps that are required to determine aspects and impacts?

3. What are bioindicators and how can they be used to evaluate environmental risk?

4. Outline the factors that should be considered when assessing the quality of environmental data.

5. List four key environmental issues associated with transportation.

(Suggested Answers are at the end.)

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Principles of Operational Planning and Control with Reference

to ISO 14001:2015

IN THIS SECTION...
• ‘Best practicable environmental option’ involves the analysis of alternatives. The preferred option is that which
minimises harm to the environment as a whole, taking account of what is affordable and practicable.
• The fundamentals of ‘best available technique’ are that the selection of techniques to protect the environment
should achieve a balance between the environmental benefits that they bring and the costs expended to
implement them.
• Practical control strategies follow a hierarchy of: elimination; substitution; and reduction/change to the process.
• Factors affecting the choice of a control measure are long term/short term, applicability, practicability and cost.
• Health and safety and environment can sometimes conflict, creating a greater overall risk. Measures should be
implemented to ensure that the impact of such issues is minimised.
• Fiscal controls are those that implement policies by using some kind of financial incentive or disincentive. They do
not state what or how change should be achieved.

Best Practicable Environmental Option (BPEO)

DEFINITION
BPEO
“A BPEO is the outcome of a systematic and consultative decision-making procedure, which emphasises the
protection and conservation of the environment across land, air and water. The BPEO procedure establishes, for
a given set of objectives, the option that provides the most benefits or the least damage to the environment as a
whole, at acceptable cost, in the long term as well as in the short term.”

(Royal Commission on Environmental Pollution)

The concept of Best Practicable Environmental Option (BPEO) was first introduced in 1976 by the Royal Commission
on Environmental Pollution. (Note: this organisation closed at the end of March 2011.) BPEO involves the analysis of
alternatives. The preferred option is that which minimises harm to the environment as a whole, taking account of what
is affordable and practicable.

A BPEO assessment uses the following framework:

• Identification and quantification of all releases.
• Determination of whether the release will comply with statutory emission limits.
• A screening exercise to identify environmentally significant releases.
• Whether or not releases will comply with statutory environmental quality objectives in the foreseeable future.
• A determination of the acceptability of the releases.
• Identification of the BPEO from a number of environmentally acceptable options.
• Identification of the process control and monitoring requirements.

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Some of these, particularly acceptability options, are difficult. To assess the impact of a pollutant on the environment it
is necessary to have a detailed knowledge of its structure and its chemical, physical and biological properties, seasonal
fluctuation, biodegradability and persistence. In several instances, this information is not known in the literature and
companies have had to carry out research to identify the effects (and hence the acceptability) of releases.

Assessment of Control Systems to Determine the Best Available

Techniques (BAT) and the Importance of an Integrated Approach
to Pollution Control
Integrated Pollution Prevention and Control (IPPC) is a regulatory system that employs an integrated approach to
control the environmental impacts of certain industrial activities.

Operators of certain industrial processes are required to obtain an installation permit to operate (see EU Directive
2010/75/EU on industrial emissions (integrated pollution prevention and control)).

In order to successfully obtain a permit, operators have to show that:

• Their proposals represent the Best Available Techniques (BAT) to prevent and minimise pollution from the
organisation.
• No significant pollution is caused.

TOPIC FOCUS
Best Available Techniques (BAT)

“Best”, in relation to techniques, means the most effective in achieving a high general level of protection of the
environment as a whole.

“Available Techniques” means those techniques that have been developed on a scale which allows
implementation in the relevant industrial sector, under economically and technically viable conditions, taking
into consideration the cost and advantages, whether or not the techniques are used or produced inside the
United Kingdom (as long as they are reasonably accessible to the operator).

“Techniques” includes both the technology used and the way in which the installation is designed, built,
maintained, operated and decommissioned.

Various factors are considered when determining the best available technique, including:
• The use of low-waste technology.
• The use of less hazardous substances.
• The furthering of recovery and recycling of substances generated and used in the process and of waste,
where appropriate.
• Comparable processes, facilities or methods of operation which have been tried with success on an
industrial scale.
• Technological advances and changes in scientific knowledge and understanding.
• The nature, effects and volume of the emissions concerned.
• The commissioning dates for new or existing installations or mobile plant.
• The length of time needed to introduce the best available technique.
• The consumption and nature of raw materials (including water) used in the process and the energy
efficiency of the process.

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Environmental Assessment for BAT

BAT can be determined by conducting an Options Appraisal of candidate techniques.

The methodology involves six stages:

1. Define the objective of the assessment and the options for pollution control.
2. Quantify the emissions from each output.
3. Quantify the environmental impacts of each option.
4. Compare options and rank them in the order of the lowest environmental impact.
5. Evaluate the costs to implement each option.
6. Identify the option that represents the best available technique, taking costs and benefits into account.
The fundamentals of BAT are that the selection of techniques to protect the environment should achieve a balance
between the environmental benefits that they bring and the costs expended to implement them. BAT is described in
guidance that is produced at both the European and national government levels.

Selection of Operational Controls

The selection of appropriate operational controls should be based on the following factors:

• Control Hierarchy
In general, the following strategy should be adopted:
–– Elimination.
–– Substitution.
–– Reduction/changes to the process.
Elimination and Substitution is straightforward - the substance or process can be stopped, shut down or an
alternative (less hazardous) substance used instead - but there has to be an awareness of potential conflicts between
health and safety and the environment in carrying out this substitution.

• Reduction of Emissions and Changes to the Process

Process redesign and the introduction of new plant or equipment can bring environmental benefits in terms of
recovery and recycling of materials, energy savings and reduction of waste.

• Process Design
The design of the plant and the introduction and strengthening of
engineering controls can greatly reduce the likelihood of an environmental
incident. Appropriate pollution controls should be adopted and,
wherever practical, process design should consider prevention of error
and consistency of results.

• Use of Competent Workers

In order to ensure the success of an operational control measure, those
involved with its design and implementation must be competent. As we
considered in Element 2, competency can be defined as the ability to
apply knowledge, skills and experience to achieve intended results.

• Procedural Controls
Procedures/safe systems of work need to be developed to ensure that Process design
processes are performed in a repeatable manner.

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• Monitoring and Measurement

Performance evaluation of the operational control must be considered in order to ensure the adequacy and
effectiveness of design and implementation.

• Documentary Information
An operational control will often need to be documented and will create documented records. A system needs to
be developed to ensure that such documents are controlled and managed.

Factors Affecting Choice of Operational Control Measures

There has to be a combination of methods. Control measures can basically be divided into ‘physical’ and ‘human’.
Examples include:
• Physical controls - bund walls, drip trays, safety devices.
• Human controls - information, instruction and training.
Note that the factors that affect health and safety risk also affect environmental risk in many aspects. All the control
measures have valid parts to play in the management of risk.

Long Term/Short Term

Wherever possible, risks should be ‘designed or engineered out’; i.e. the equipment should prevent the possibility of
the event occurring. For example:
• A detector to identify a leak in a tank will avoid the necessity of operators having to constantly monitor the
situation.
• A pH meter connected to a valve that cuts in as soon as a certain pH value is reached is preferable to an operator
carrying out physical checks periodically.
• Providing firewater lagoons of sufficient capacity.
Measures used in a temporary way usually involve higher risk than permanent solutions, e.g. the provision of spillage
control equipment close to a tank containing oil not surrounded by secondary containment. Many examples of this
can be found in both health and safety and the environment. Temporary solutions should be closely monitored and
removed or made permanent, as soon as practicable.

Applicability
The relevance of a control technique can be described in law in similar ways to health and safety. For example,
organisations under the auspices of an installation environmental permit are required to implement controls that
represent BAT. This is a broadly similar concept to reasonable practicability in health and safety in that the cost and
benefits of control measures need to be compared. BAT is described in industry-specific guidance notes produced by
regulatory organisations.

Practicability
Control measures chosen must be usable and practical if they are to be effective. Employees are unlikely to use control
measures correctly if they are complicated and difficult to understand. Procedures can be made easy to read and
understand by using photos or flowcharts, for example.

Cost
Usually, quick gains can be made with relatively little investment, but as risk requirements increase and greater and
greater reductions are required, a point of diminishing returns is met where additional risk reductions are only achievable
at excessive investment costs.

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Here, considerable trade-offs are apparent - for example, the increased energy requirement and subsequent carbon-
dioxide release of reducing micropollutants to lower concentrations from industrial and municipal wastewaters involves
a trade-off between reducing chemicals in the environment and increasing contributions to global warming through
energy use.

Again, the cost of risk reduction is often detailed in law. The essence of BAT is that the techniques selected to protect
the environment should achieve an appropriate balance between environmental benefits and the costs incurred by
organisations. However, whatever the costs involved, no installation may be permitted where its operation would cause
significant pollution.

Possible Conflicts between Protection of Workers and

Protection of the Environment
It is often very difficult to separate health and safety and the environment, and, on occasions, this can lead to conflicts.

Significant risk to health and safety should be a priority for risk control. Specifically, it must be ensured that when
environmental control options are considered (for example, the use of pollution abatement technologies, or the
recovery or recycling of materials), they do not reduce the standard of occupational or public health and safety. In fact,
where possible, they should reduce health and safety risk.

Example: The Vapour-Degreasing Process

Trichloroethylene (1.1.2.trichloroethylene) is a common degreasant. It is also widely used as a solvent and in the
manufacture of glue and rubber products. It enters the body by inhalation, where its principal effect is depression of
the central nervous system; it is also carcinogenic.

The use of trichloroethylene requires a safe system of work to be in place when cleaning out vapour degreasing
tanks. The normal strategy, following good health and safety principles, would be elimination of the process or, if
this is not possible, substitution of the substance with a less harmful one. Elimination of the substance may involve a
change to soap or detergent for washing, or dry degreasing using crushed walnut shells may be appropriate in some
circumstances. Solvent alternatives include terpenes and paraffin derivatives.

Because of the health issues associated with the use of trichloroethylene, an alternative solvent was eagerly sought
by industry. The solvent 1.1.1 trichloroethane seemed to be such an alternative, being less toxic to the human body.

However, this solvent is a strong ozone-depleting substance, implicated in creating holes in the ozone layer, and, as a
result, was banned from production under the Montreal Protocol and the EU regulations which brought that protocol
into effect.

In this case, industrial users who are unable to change their process to a non-solvent application have had to continue
using trichloroethylene, and increase the protection given to the workforce through extraction, PPE, etc.

Other Examples of Conflicts

• The widespread use of electric vehicles will prove extremely beneficial in terms of reducing air and noise
pollution, as well as significantly cutting fuel consumption. However, the silence of an electric engine will increase
the safety risks for pedestrians, cyclists and other vulnerable road users, as they may not be aware of the moving
vehicle until it is too late.
• The use of de-icing salt to improve the safety of winter driving may be harmful to the environment.
• In recent times, porous asphalt pavement has been used widely to take advantage of its capacity to reduce
road noise and channel rainwater off the road, thus having a positive impact on the environment and road safety.
However, there are indications that it may actually encourage motorists to increase their speed, and therefore
their safety risks, because the low noise level makes them feel overconfident.

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Reconciliation of Such Conflicts

In most cases, solving environmental problems will have a positive impact on health and safety. In some situations,
however, an action contributes positively to one sector but negatively to the other.

Decisions should be made on the basis of costs and benefits in order to resolve the problem when all dimensions of the
conflict have already been identified. Therefore, to find the best compromise between improved safety and a better
environment, an early evaluation of the impact of the control measure on both the environment and safety is required
to find solutions that will have the best results. This will also result in a significant cost reduction by limiting the need
to take curative measures to mitigate unexpected effects after implementation.

Additionally, the following measures will assist in conflict resolution between the two disciplines:
• Addressing most significant environmental risks of products or services at the design stage, with due regard to
health and safety.
• Employing competent people to deal with health, safety and environmental matters and obtaining competent
advice where necessary.
• Environmental professionals should have access to proper training in key principles of health and safety
management, such as hazard and risk assessment.
• Similarly, health and safety professionals should understand how their work might impact on the environment.

Environmental Opportunities
In addition to presenting risks to an organisation, environmental issues can
also present opportunities. These will be dependent on the specific issue and
organisation but common areas where opportunities can be realised include:
• Financial savings - through reductions in waste, energy and raw
materials use.
• Regulatory - having good standards of environmental management will
reduce the probability of an organisation breaching legal requirements
and the consequent associated adverse issues such as prosecution,
regulatory cost and negative corporate image.
• Sales improvement - where an organisation is considered to have
a high level of environmental performance it can lead to an increase
in sales and/or profit through access to new markets and increased Good environmental performance
customer share. can lead to an increase in sales
• Investment - investors are more likely to lend at a preferential rate to organisations that have a lower overall risk.
Environmental risk is an important form of risk that can have a financial bearing on an organisation.
• Staff - potential employees are more likely to want to work for an organisation that has reputable values.

Selection of the Best Solution for an Organisation Based on

Relevant Risk
The risk reduction strategy adopted by an organisation will depend on numerous factors, but will generally comprise
both human and physical (or engineering) controls. Controls should aim, where possible, to eliminate harmful
substances, or reduce harmful effects to a minimum. In doing so, the organisation will be complying with the spirit of
environmental law, the aim of which is the prevention of harm to the environment.

In the same way that physical controls can reduce the risk to operators and others in the field of health and safety, they
can be used to protect the environment.

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Examples of physical controls include:

• Leaks in bulk storage tanks can be contained within a bund wall.
• Spillages can be prevented from reaching a sensitive receptor by spill-containment devices and equipment.
• Abatement equipment can be used to collect and treat air emissions.
• Effluent-treatment plant can be used to prevent untreated effluent reaching the drains.
Human controls - information, instruction, supervision and training - are human strategies for controlling risk. Providing
adequate explanations is essential - explaining why something should be done, rather than a straight instruction, is
usually the most successful.

Depending on the circumstances, a combination of procedural and technical control strategies will be necessary.
Technical knowledge of the chemicals, machinery, etc. is essential before embarking on a risk reduction strategy.

Influence of Legislation on Control Strategies

Some control strategies may be specifically imposed by legislation; others through more general legislation, or as part
of EU and UK government policy.

• General Legislation
Legislation covers most areas of environmental management. There is legislation in place to reduce harm to health
and to the environment from air emissions, waste disposal, transport of chemicals, noise and other nuisances, and
water pollution, and to protect wildlife (this list is not exhaustive).

• Fiscal Strategies
Fiscal measures, such as levies and taxes, are frequently used as a control strategy - examples include carbon taxes
and emissions trading.

Effects of Government and Company Policy on Control Strategies

Some control strategies are imposed by policy, both Government policy and internal company policy.

Effects of Government Policy on Control Strategies

It is the policy of many governments to encourage waste reduction and recycling. There is a hierarchy of controls -
prevention, prepare for reuse, recycling, other recovery, and disposal - introduced as part of the Waste Framework
Directive. For this reason, recycling and recovery targets are imposed under legislation.

Effects of Insurers on Control Strategies

In some countries most environmental matters will normally be managed through a public liability insurance policy.
However, since 1991 these policies do not give cover for incidents unless they are ‘sudden and accidental’. The ABI
(Association of British Insurers) wording is:

“This policy excludes all liability in respect of Pollution or Contamination other than caused by a sudden, identifiable,
unintended and unexpected incident, which takes place in its entirety at a specific time and place during the Period of
Insurance.”

In practice this means that pollution from leaking tanks, or run-off from contaminated land, would not be covered by a
general insurance policy. Further, many policies only cover third-party damages and do not cover own site clean-up, or
regulatory authorities’ orders to clean up rivers, or third-party land.

This means that work is required to ensure that these incidents do not occur and insurance companies may also require,
or recommend, controls to reduce the risk of incidents.

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Effects of Internal Policies on Control Strategies

Companies may also impose control strategies in the form of an Environmental Policy. These policies should be backed
up by management systems, appropriate control procedures and associated information and training. Companies may
further develop specific policies to cover particular areas, such as purchasing, transport, or the use or elimination of
certain chemicals that are known to harm the environment, e.g. chlorofluorocarbons (CFCs).

Consideration of Fiscal Controls

Fiscal controls are those that implement policies by using some kind of financial incentive or disincentive. They do not
state what or how change should be achieved, unlike most legislative instruments, but work by altering price. They will
still often need some kind of legislative basis to be implemented.

Examples of fiscal controls include:

• Taxation
–– The Landfill Tax is a levy on the disposal of waste to landfill in the
UK and was implemented as a method of reducing waste production
and increasing waste recycling and recovery.
–– The Climate Change Levy is a UK tax on the use of energy that has
been produced from the combustion of fossil fuels.
–– The Aggregates Levy is a UK initiative to address, by taxation, the
environmental costs associated with quarrying operations (noise,
dust, visual intrusion, loss of amenity and damage to biodiversity). It
is also intended to reduce demand for aggregate and encourage the
use of alternative materials where possible.

• Tariffs
–– There are incentives in the form of feed-in tariffs and the
renewable heat incentives which constitute payment from the UK Landfill tax was implemented as a
Government for the micro-generation of electricity generated from way of reducing waste
solar power and heat from renewable sources respectively.
–– Renewables obligation - electricity suppliers are required to purchase renewable obligation certificates that
are generated from those that produce renewable electricity.

• Emissions Trading
Tradable allowances are derived for emissions of specific environmentally hazardous substances (e.g. tonnes of
carbon dioxide) that can be bought or sold. The amount of allowances that can be allocated is, however, capped.
Those that release over their cap can buy extra allowances on an open market where those that have emitted under
their cap can sell allowances. This works as a financial incentive to organisations which have emitted under their cap
and a financial disincentive to those which have emitted over their cap. This mechanism is used for schemes such
as the EU emissions trading system where carbon emissions from energy-intensive organisations must be traded.

STUDY QUESTIONS
6. Define BPEO.

7. What strategy is used by the pollution prevention and control regime to prevent and minimise pollution?

(Suggested Answers are at the end.)

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4.3 Evaluation of Environmental Aspects and Impacts

Evaluation of Environmental Aspects and Impacts

IN THIS SECTION...
• Cost-Benefit Analysis (CBA) compares the value of costs and benefits in a single monetary unit of measure.
• CBA is seen by some as a prerequisite for sustainability; others believe CBA does not encourage sustainability.
• Models are used to test environmental systems that it may not be possible to field-test. Examples include air-
quality impact assessments, dispersion analyses and water-quality modelling.
• Conceptual models are written as diagrams and provide a compact visual statement of a problem.
• A quantitative model is a set of mathematical expressions, coefficients and data attached to a conceptual model.
• A life-cycle assessment is an assessment of the impacts of a product on the environment through its whole
life cycle, from ‘cradle to grave’. It consists of four stages: definition, inventory analysis, impact assessment and
interpretation.
• Ecotoxicology is the study of how chemicals affect the environment. Lethal Concentration (LC50) is one example
of a measure of ecotoxicity.

Cost-Benefit Analysis
Cost-Benefit Analysis (CBA) aims to translate all impacts into monetary
values. The aim is to help decision-makers by ‘translating’ environmental and
social costs into a single unit of measure - money - that they already use
to make decisions. In theory, this allows all impacts to be put on the same
footing. It is a general technique with no specific approach or methodology,
so, if asked to perform a CBA, one should always clarify what is needed or
expected.

Examples of cost-benefit analyses include:

• Environmental impact of an industrial plant.
• Convenience for users of a new railway.
The major constraint in applying CBA is that not all environmental changes
are readily amenable to economic valuation. As a result, hybrid approaches CBA translates all impacts into
have been developed. They generally take the economic valuation as far as is monetary values
credible and leave the remaining impacts in non-monetary terms.

CBA is an important tool to inform the decision-making process, but it does not by itself make decisions. One should not
automatically pursue the most economically efficient project, without weighing efficiency against the other important
criteria that affect overall social desirability.

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Cost-Benefit Analysis as Applied to Environmental Risks

There are several different CBA techniques that may be used to derive the monetary value of environmental and social
costs. These techniques are described in the table that follows.

Cost-Benefit Analysis techniques

Technique Description
Dose-response Determines the links between pollution (dose) and its impacts (response), and values the
approach final impact at a market or shadow price (e.g. cost of crop/forest damage from air pollution).
Replacement cost Ascertains the environmental damage done and then estimates the cost of restoring the
approach environment to its original state.
Avertive expenditures Measures expenditures undertaken by households that are designed to offset some
environmental risk (e.g. noise abatement).
Travel cost method A detailed sample survey of travellers to a site determines how they value the (mainly
recreational) characteristics of the site and the time spent travelling to the site (e.g. visiting
a nature area).
Hedonic price Applies to environmental attributes that are likely to be capitalised into the price of housing
methods (house and/or land. Involves assembling cross-sectional data on house prices, together with data
prices approach) on factors likely to influence these prices, and analysing these using multiple regression
techniques.
Contingent valuation Involves asking people for their willingness to pay and/or accept compensation for changes
in environmental resources.
Contingent ranking Individuals are asked to rank several alternatives rather than express a willingness to pay.

Application of CBA
CBA and Sustainability
Society as a whole prefers to receive goods and services now and defer costs to later. This ‘social time preference’ is
the rate at which society values the present with respect to the future. CBA calculates its results from the perspective
of the present generation.

Opinion therefore differs about the ways in which CBA can be made consistent with sustainable development:
• CBA is seen by some as a prerequisite for sustainability, since CBA is concerned with ensuring that actions are not
taken where costs exceed benefits.
• Others see CBA as not encouraging sustainability as a result of CBA giving cost in the future less weight than cost
incurred now. Therefore, there is a risk that this would lead to an emphasis on short-term gain over the needs of
future generations.

CBA and Stakeholder Analysis

Although in individual cases, overall policy benefits may exceed policy costs, the spread of those costs and benefits for
individual stakeholders may be very different. Stakeholder analysis enables the decision-maker to identify the potential
winners and losers. Losers may well block or delay a policy, even though the net societal benefits are positive.

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4.3 Evaluation of Environmental Aspects and Impacts

Environmental Modelling
This is a useful tool for understanding and predicting environmental changes over various times and areas.

TOPIC FOCUS
Models can be used to explore ideas regarding environmental systems that may not be possible to field-test for
logistical, political or financial reasons. Examples of scenarios where environmental models are commonly used
include:
• Air-quality impact assessments and dispersion analyses.
• Water-quality modelling.
• Groundwater risk assessments.
• Long-range and near-field pollutant transport investigations.
• Contaminated land studies.
The process of formulating a model can be extremely valuable for organising thought, identifying hidden
assumptions and identifying data needs.

In this course, you are not expected to be able to develop or use the models discussed below, but you do need an
understanding of what models are used for, their applications and some of their limitations.

Principles and Application of Environmental Modelling

Conceptual Models
These are generally written as diagrams with boxes and arrows, to provide a compact visual statement of the problem.
The model should incorporate sufficient detail to capture the necessary environmental structure and processes, and
still be simple enough to be useful. It should enable the analyst to formulate hypotheses, identify the available data and
what additional data is required.

Quantitative Models
A quantitative model is a set of mathematical expressions, coefficients and data attached to a conceptual model.

These enable predictions to be made for the values of stated variables under varying circumstances (e.g. differing
weather conditions, increase in river flow). Often, they are used to generate predictions for situations where actual tests
are impossible to run, owing to environmental, social or economic reasons, or where the timescales involved are too
long, e.g. impact over 100-year time span.

Sensitivity analysis of a quantitative model can identify which processes and coefficients have the greatest effect
on the results. It explores whether the conclusions would change if the parameters, initial values, or equations were
different.

Models can be based on:

• empirical (observed) data; or they can be
• mechanistic, being based on hypotheses regarding the processes involved.
They can become quite complex, particularly when they are used as a basis for policy and resource-management
decisions.

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Simplified, illustrative conceptual model for exposure to hydrocarbon fuels at petroleum retail sites
(Based on original source Guidelines for Environmental Risk Assessment and Management, DETR (now DEFRA),
2000)
The most recent government guidelines are available at:
www.gov.uk/government/uploads/system/uploads/attachment_data/file/69450/pb13670-green-leaves-
iii-1111071.pdf

Deterministic and Stochastic Models

Consider the following quantitative model types:
• A deterministic model has no random components and every time it is run with the same parameters and
conditions, the same results will be produced.
• A stochastic model has at least one random factor, so as to produce different results each time the model is run,
simulating environmental variability. The randomness can be introduced using probability distributions, by adding
random errors, or by using random number generators. Results are usually cast as probabilities.
Although stochastic models provide more information than deterministic models, they are not necessarily more correct
and they are certainly more work to create.

Scaling
Scientific knowledge of environmental processes has largely been developed by studying those processes at a local level.
Study at this level reveals the critical causes of environmental change and the processes can be accurately simulated.
However, the problems affecting us now are often expressed on regional and global scales.

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4.3 Evaluation of Environmental Aspects and Impacts

100 yrs
Global

Knowledge
Decrease
Regional

Time Catchment Ecosystem

Plot

Plant
Leaf

second
cm 1,000
space Km
Typical scales of environmental models

Some common scaling problems include:

• Difficulties in aggregation of large-scale behaviour from local processes due to spatial variation and non-linear
processes.
• Different processes predominate at different scales; correlations derived at one scale may not be appropriate at
another.
• The interaction between processes operating at different scales, e.g. small, fast local processes may be constrained
by large, slow ones.
• Emergent properties from mutual interaction of small-scale components.
• Time lags in the response of a system to change.

GIS and Environmental Modelling

As many environmental models involve a spatial component, they lend themselves to the use of GIS (Geographical
Information and Spatial Referencing Systems). The inputs and outputs can be stored in an efficient fashion and easily
related to information from other sources, e.g. farm boundaries or land use, and it is possible to link these to the high-
quality graphics and animation capabilities of GIS, in a way that makes it possible to convey abstract technical concepts
and modelling to a non-technical audience.

Example applications:
• Climate change.
• Surface water.
• Groundwater.
• Watershed/water catchment.
• Ecosystem.

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 Evaluation of Environmental Aspects and Impacts 4.3

Dispersion and Transport of Pollutants in the Atmosphere

A pollutant plume emitted from a single source will be transported in the direction of the mean wind. It is acted upon by
the prevailing level of atmospheric turbulence, which causes the plume to grow in size as it entrains the (usually cleaner)
air. There are two main methods of generating atmospheric turbulence: mechanical turbulence (generated as the air
flows over obstacles on the ground), and convective turbulence (associated with solar radiation).

Air Modelling - Use of Models

Models are used for regulatory purposes to show compliance with a given set of parameters, given as part of a legal
permit. They are also used for support of a given policy or course of action, for the provision of public information, or
for scientific research.

Dispersion models link measured air quality with emissions data.

DEFINITION
DISPERSION MODELS
Describe how pollutants are spread and mixed in the atmosphere. Mathematical procedures are used to
calculate pollutant concentrations based on emission rates (mass of pollutant emitted over time) and dilution
rates (the volume of surrounding air into which the pollutant is being mixed, per unit of time).

In air-pollution assessments, all parts of the cause and effect ‘chain’ have to be evaluated, and whereas air-quality
monitoring may be defined as the systematic collection of information from measurements and other means, monitoring
alone will not achieve the best possible description of the concentration or space/time relationships. Spatial scales may
vary from street level up to the global scale, and although measurements may form an important part of monitoring,
for many purposes, models are often needed to establish larger-scale average exposures or deposition fields.

The reasons for modelling include greater representation of effects under changing conditions, such as release
quantities, meteorological conditions, or to account for the local topography. Models can also be used to predict the
effect of various sources and emission scenarios.

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4.3 Evaluation of Environmental Aspects and Impacts

This figure shows some key results from climate change experiments conducted using Hadley Centre (part of the
Meteorological Office) computer models of the climate system. It is important to be aware that predictions from
climate models are always subject to uncertainty because of limitations in our knowledge of how the climate system
works, and in the power of the computing resources available. Different climate models can give different predictions.

Dispersion in Water
The impact of a discharge on any water body is dependent on discharge quality and quantity, and prevailing physical and
chemical conditions of the waters receiving the discharge. In contrast to a river, the physical and chemical conditions of
tidal waters are highly variable, both spatially and temporally, owing to tide and wind currents, the bathymetry of the
seabed and seasonal river flow and quality.

Therefore, in order to assess the impact of a discharge to a tidal water body, it is necessary to predict the duration over
which the pollutants may act, the area of impact and whether any other discharges (diffuse or point) might impact the
same area. This assessment is normally made with some form of predictive model to enable simulation of different
discharge quality parameters, in combination with the different physical and chemical conditions of the receiving waters.

Models vary greatly in type and complexity, but it is essential that the model chosen is appropriate to the situation in
which it is being used. It is also important that the model is properly calibrated and validated, in order to ensure that
the model output is reliable and accurate. This is a specialist area which requires an expert in the field to carry out the
modelling process.

In the case of water modelling, the amount of data and the complexity of the data will depend on whether the water
system is a river, an estuary, or coastal system. This is because tidal effects, mixing effects and degrees of salinity all affect
the behaviour of pollutants.

Limitations of Environmental Modelling

A single sample for one process will seldom be an adequate basis for control decisions.

The means of data collection, the accuracy of the data analysis, and the limits of accuracy of the test/detectable limits
and all the factors relating to the reliability of the information, must be sought. The relevant factors relating to the
monitoring and/or sampling must be recorded, along with the results as a reference. This information may include
nature of the sample, method of collection and analysis, relevant local conditions including meteorological conditions,
and time and temperature at the time of sampling.

Modelling, Monitoring and Control

Remember that monitoring is not a means of control - it is a means by which failure and defects in control are made
apparent, and a means of demonstrating the continued effectiveness of controls.

Life-Cycle Analysis
DEFINITION
LIFE CYCLE
Refers to the notion that accurate assessment of the impacts of a product on the environment should take
into account the effects of the product in its whole life cycle, including raw-material production, manufacture,
distribution, use and disposal.

The sum of these phases is known as the life cycle of the product.

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The theory may be used to improve the environmental performance of an individual product, or a whole organisation.
A classic application of Life-Cycle Analysis (LCA), for example, is to determine whether a milk bottle made of glass is
more or less burdensome than a plastic milk bottle.

LCAs may be carried out:

• By a sector of industry to highlight where environmental improvements can be made.
• To provide environmental data for the general public or government.
Major companies also use LCAs and they are often referenced in advertising campaigns to add value to claims of a
product being kinder to the environment.

Cradle-to-Grave Concept
The cradle-to-grave approach involves a full assessment of the impacts of a process or product.

It is often necessary to look beyond the immediate effects (say, of manufacturing) to study all the effects associated
with the process or product, starting with the raw materials and their production, and ending with the final disposal.
For example, it may be the case that the major effects of a washing machine are not in the manufacture but in its use.

The cradle-to-grave approach enables a ‘holistic’ view of the environment and would include:
• Extraction of raw materials.
• Transport of raw materials.
• Construction effects of the process plant.
• The production process.
• Use of the product.
• Disposal of the product.
• Demolition of the process plant.

Principles and Techniques of Life-Cycle Analysis

There are four key steps to LCA:
• Definition - defining the goal and scope of the study.
• Life-cycle inventory analysis - gathering data and making a model of Transport of raw materials
the product life cycle with all the environmental inflows and outflows.
• Life-cycle impact assessment - understanding the environmental relevance of all the inflows and outflows.
• Life-cycle interpretation - evaluating their relative importance.

Key Steps of Life-Cycle Analysis

Step 1 - Definition of Goal and Scope
The scope should be sufficiently well-defined to ensure that the breadth, the depth and the details of the study are
compatible and sufficient to address the stated goal.

One of the early problems with LCA was that it was almost impossible to make meaningful comparisons between
different materials or products. To help solve this, comparisons are now usually based on the function served by a
product or service. The functional unit sets the unit of comparison for two or more products fulfilling the same function.

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4.3 Evaluation of Environmental Aspects and Impacts

A functional unit must be measurable and may be, for example:

• The packaging used to deliver a given volume of toothpaste.
• The amount of detergent required for a standard household wash.
• For paint, the unit surface protected for a specified time period.
• For building insulation materials, the thermal insulation value of a kilogram, or one centimetre thickness of
material.
The functional unit is the pivot of the LCA study - it provides the reference to which inputs and outputs are related, and
helps make it easier to clearly compare LCA results.

The processes connected to the functional unit are generally referred to as the ‘product system’.

Product systems tend to be interrelated in a very complex way. For example, in an LCA on milk cartons, trucks are used.
However, trucks are also products with a life cycle. To produce a truck, steel is needed; to produce steel, coal is needed;
to produce coal, trucks are needed, etc. It is clear that one cannot trace all inputs and outputs to a product system, and
that one has to define boundaries around the system. It is also clear that by excluding certain parts as outside the system
boundaries, the results can be distorted. It is helpful to draw a diagram of the system and to identify the boundaries in
the diagram.

Simplified system for the life cycle of a plastic bottle, based on information supplied
by SmithKline Beecham; from IEM Journal, Vol. 5, June 1998

Step 2 - Life-Cycle Inventory Analysis

The most demanding task in performing LCAs is data collection. Depending on the time and budget available, there are
a number of strategies used to collect such data.

It is useful to distinguish two types of data:

• Foreground data - very specific data which you need to model your system. Typically, these data describe a
particular product system and particular specialised production system.
• Background data - for generic materials, energy, transport and waste management systems. These are typically
data you can find in databases and literature.
In many cases, you will have to collect foreground data from specific companies. One or more questionnaires usually
need to be developed to collect such data. It is important to establish good contacts with the people who are supposed
to fill in the questionnaire and to understand what they know, in what way data are available, and what terminology is
used.

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Often, 80% of the data you need is background information that you do not have to collect via questionnaires, as it is
readily available in databases, or can be found in literature or on the Internet (e.g. www.ecoinvent.ch).

Step 3 - Life-Cycle Impact Assessment

In this step, inventory results are linked to physical impacts on the environment. There are three phases to consider:
• Classification and characterisation.
• Normalisation.
• Evaluation or weighting.
In the classification phase, all substances are sorted into classes according to the effect they have on the environment.
For example, substances that contribute to the greenhouse effect, or ozone-layer depletion, are divided into two
classes. Certain substances are included in more than one class. For example, NOx is found to be toxic, acidifying and
causes eutrophication.

Characterisation provides a basis for aggregation of inventory results within each category. For example, many emissions
are thought to contribute to global warming. At the characterisation stage, the relative significance of each of the
contributors is calculated by converting to a common indicator.

In global warming, the Global Warming Potential in CO2 equivalents is the most common indicator. For example, if a
product results in the releases in column A, then the CO2 equivalent will be as shown in column B:

Substance A (kg) B (equiv./kg)

Carbon Dioxide 3.2 3.2
Nitrogen Dioxide 0.15 43.5
Tetrachloromethane 0.0003 0.6
Total GWP in CO2 equivalents 47.3

Environmental categories and common indicators used in LCA studies

Reserve depletion: Application of depletion factors for reserves to the inventory.
Greenhouse effect: Application of global warming potentials to the inventory.
Acidification: Application of acidification potentials to the inventory.
Nitrification: Application of nitrification potentials to the inventory.
Smog formation: Application of photochemical ozone creation potentials to the inventory.
Potential toxicity: Expert assessment based on potential for toxic effects. This includes both the risk of
uptake in the human food chain and phytotoxic effects.

In order to gain a better understanding of the relative size of an effect, a normalisation phase is required. Each effect
calculated for the life cycle of a product is benchmarked against the known total effect for this class. Normalisation
enables you to see the relative contribution from the material production to each already existing effect.

Normalisation considerably improves insight into the results. However, no final judgment can be made as not all effects
are considered to be of equal importance. In the evaluation phase the normalised effect scores are multiplied by a
weighting factor representing the relative importance of the effect.

Step 4 - Life-Cycle Interpretation

Interpretation is likely to involve a review of all elements of the LCA process, checking that these have been systematic
and that assumptions made are consistent.

Results should be structured to show inventory and assessment data associated with specific operations, with a view to
identifying areas of greatest environmental significance.

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4.3 Evaluation of Environmental Aspects and Impacts

It is likely that the methodologies used will be similar to those used to determine significant environmental aspects and
impacts in ISO 14001. Significance will be gauged with reference to both the operator (and its stakeholders) and the
environment.

Reporting the Findings

A full report will typically contain a clear statement of the study objectives; an explanation of the scope of the study;
a clear explanation of and the reasoning behind the drawing of the system boundary; flow diagrams which clearly
describe the system and all important inputs, outputs and products (the relationship between different diagrams should
be clear); and a description of the methodology used, with an explanation of value judgments and assumptions made.

The following International Standards apply to LCA:

• ISO 14040:2006 Environmental Management - Life-Cycle Assessment - Principles and Framework.
• ISO 14044:2006 Environmental Management - Life-Cycle Assessment - Requirements and Guidelines.
• ISO/TS 14072:2014 Environmental Management - Life-Cycle Assessment - Requirements and Guidelines for
Organisational Life-Cycle Assessment.

Circular Economy
A circular economy can be defined as an economy where resources are retained in use for as long as is possible. During
use the maximum value of the product is extracted and when the product comes to the end of its life then as much
material as possible is recovered. Such recovered materials can be used to make new products.

A circular economy differs from a linear economy, where the raw materials for a product are extracted, the product is
manufactured and then used. When the product comes to the end of its use phase it is disposed of either by landfill
or incineration without energy recovery. The difference between the two types of economy can be summarised in the
following two diagrams:

Example of a linear economy

Example of a circular economy

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 Evaluation of Environmental Aspects and Impacts 4.3

The benefits of operating a circular economy in comparison to a linear economy are:

• Resources are kept in use for as long as is possible.
• The maximum value of each resource is extracted while in use.
• Products are recovered or regenerated at the end of their life.
• Reduction in pollution and waste.
• Delivers a more competitive economy.
• Reduces the environmental impacts associated with resource extraction.

Assessment of Environmental Toxicity

The Meaning of Predicted No-Effect Concentration (PNEC)
Any concentration of a substance above the Predicted No-Effect Concentration
(PNEC) will cause harm. The PNEC is determined by applying an assessment DEFINITIONS
factor to the results of toxicity tests on a few specific organisms.
PREDICTED NO-EFFECT
CONCENTRATION (PNEC)
Ecotoxicity: Lethal Concentration and Effective Concentration of a substance
Concentration below which adverse effects are
We have already considered one method of determining ecotoxicology on not expected to occur.
organisms, the PNEC. ECOTOXICOLOGY
Other methods commonly used to assess the effects of chemicals on species The study of how chemicals
include: affect the environment and the
organisms living in it.
• Lethal Concentration (LC50)
The Lethal Concentration 50 (LC50) is a statistically-derived concentration of a test substance in water, which kills
50% of a test batch of organisms within a continuous period of exposure (usually 96 hours).

• Effective Concentration (EC50)

The Effective Concentration is that concentration which has a harmful, but not necessarily lethal, effect on a test
batch of organisms (e.g. immobilisation of daphnia, or reduction in growth of test algae).

• Lethal Dose (LD50)

The Lethal Dose 50 (LD50) is the quantity of a substance that will kill 50% of a batch of test organisms in a single
oral administration.

Ecotoxicity has been assessed using data from many sources, including commercial databases:
• The ECOTOXicology database (ECOTOX) produced by the US Environmental Protection Agency provides a
source for locating single chemical toxicity data for aquatic life, terrestrial plants and wildlife.
• Hazardous Substances Data Bank (US National Library of Medicine).
• CHEMBANK - hosted by the Broad Institute of Harvard University and Massachusetts Institute of Technology.
• Dictionary of Substances and their Effects (Royal Society of Chemistry).
• Handbook of Environmental Data on Organic Chemicals, 4th edition, by K. Verschueren.

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4.3 Evaluation of Environmental Aspects and Impacts

The following terms are used:

Classification LC50 or EC50

Very High Ecotoxicity <1mg/litre
High Ecotoxicity 1-10 mg/litre
Moderate Ecotoxicity 10-100 mg/litre
Low Ecotoxicity >100 mg/litre
No effects in acute test No toxicity in tests

MORE...
The ECOTOX website (http://cfpub.epa.gov/ecotox/) provides ecotoxicology values for a range of species
and chemicals.

Principles of Environmental Toxicity and Ecotoxicity Testing

Risks from Chemical Substances
In the European Union the evaluation of the risks from all chemicals is now largely covered by the European Regulation
(EC 1907/2006) on Registration, Evaluation, Authorisation and Restriction of Chemicals (abbreviated to
REACH). REACH also deals with other things, such as the requirement to provide safety data sheets, previously covered
by other legislation.

Because it is a very far-reaching piece of legislation, REACH is being phased in over a long transition period. REACH now
deals with so-called “new substances”. New substances are defined as those that are not already listed in the European
Inventory of Existing Commercial Chemical Substances (EINECS). From 1 June 2008, these have been brought within
the scope of REACH, replacing requirements under the Notification of New Substances Regulations 1993 (as
amended), abbreviated to “NONS”.

From 1 June 2008 under REACH, all substances that have not been previously manufactured must be registered
and are not eligible for the ‘phase in’ scheme for existing substances. Registration involves collecting and collating
information regarding the properties of a substance. The amount of information required is dependent on the hazards
and tonnage of the substance that will be registered. This information is then required to be used to undertake a risk
assessment that will identify how potential risks from the substance can be controlled. The assessment and collected
information must then be submitted to the European Chemicals Agency (ECHA) in Helsinki.

For many common hazardous chemicals, available data have already been evaluated and a harmonised, European-wide
classification adopted. Classification and labelling data for these chemicals are published as Table 3.2 of Annex VI to
the Regulation (EC) No. 1272/2008 on Classification, Labelling and Packaging of substances and mixtures, and
amending Directive 67/548/EEC and the REACH Regulation.

MORE...
For further information on REACH, see the relevant part of the HSE’s website available at:
www.hse.gov.uk/reach/index.htm

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STUDY QUESTIONS
8. What is an environmental model?

9. When might you use an environmental modelling technique?

10. Outline what is meant by the ‘cradle-to-grave’ concept.

11. When might you use the technique of life-cycle analysis?

(Suggested Answers are at the end.)

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4.4 Environmental Impact Assessments and Statements for Large Developments

Environmental Impact Assessments and Statements for Large

Developments

IN THIS SECTION...
• Planning Environmental Impact Assessments (EIAs) are required to ensure that the environmental impacts of
developments are considered in the planning stage, to comply with legislation and to ensure that the public's
views are taken into account at an early stage.
• The stages of an EIA are screening, scoping, baseline studies, impact assessment significance, mitigation,
application environmental statement and monitoring.
• Common environmental issues considered within an EIA include, where relevant, air pollution, land
contamination, effects on the communities, water pollution, effects on ecosystems, archaeology and the built
heritage and noise and vibration.

Planning Environmental Impact Assessment (EIA)

DEFINITION
ENVIRONMENTAL IMPACT ASSESSMENT (EIA)
As defined in planning law is an assessment of the impacts of a specified major industrial or civil engineering
project on the environment as a whole. It is undertaken during the planning phase of a project.

The Purpose of a Planning EIA

From a planning viewpoint, the broad impact of a project must be determined, examining every aspect of the project,
as certain developments may impose adverse environmental impacts in terms of land usage, pollution or infrastructure
stress. Very few projects will be wholly beneficial; there will be losses as well as gains. In the case of the impact of large
development projects, statutory control can be exercised by planning control legislation.

An EIA also considers the views of the public, ensuring that they are informed of the development at an early stage and
have the ability to be involved in the decision-making process.

Planning EIAs are often required by law. In the EU, for example, Directive 2011/92/EU on the assessment of the
effects of certain public and private projects on the environment (as amended by Directive 2014/52/EU)
requires an impact assessment of developments likely to have significant environmental impacts, prior to them being
granted consent by local and/or national authorities. The documentation that is submitted to relevant regulators is
usually known as an environmental statement.

DEFINITION
ENVIRONMENTAL STATEMENT (ES)
A document or series of documents assessing the likely environmental impact of a development proposal and
the significance of the effects arising from its impact.

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 Environmental Impact Assessments and Statements for Large Developments 4.4

Often the following types of project will require an EIA to be developed and
submitted with a planning application:
• Crude-oil refineries.
• Coal gasification or liquefaction plants.
• Major power stations.
• Iron and steel plants.
• Chemical installations.
• Hazardous and radioactive waste-disposal facilities.
• Major roads, railway lines and ports.

Preparing an EIA
The process of preparing an EIA is usually defined in law which will vary Power stations require an EIA
around the world. However, common stages of an EIA will often include:
• Screening.
• Scoping.
• Baseline studies
• Impact assessment significance.
• Mitigation.
• Application environmental statement.
• Monitoring.
Process and stages of environmental impact assessment
1. Screening This stage is a formal decision about whether the development requires an EIA or
not.
2. Scoping Decide which environmental impacts are to be considered in detail. This will depend
on the type of development, for example:
• Air emissions?
• Noise emissions?
• Discharges to water?
3. Baseline Studies For the impacts selected above: determine the current status. For example, what is
the current air or water quality like?
4. Impact Assessment Consider whether your proposed or existing development will have a significant
Significance impact. For example, will your development cause the air quality to deteriorate
significantly?
5. Mitigation If there will be a significant impact, what can you do to reduce it? For example, can
you fit abatement technology to control air emissions, or not operate at night to
prevent noise nuisance to residents?
6. Application and Development of an environmental statement (different terminology may be used,
Environmental Statement but this is essentially a report) to document the EIA.
7. Monitoring All developments or existing industries will need to monitor their significant impacts
to ensure mitigation measures remain effective.

To support the preparation of an Environmental Impact Assessment and Statement many individual assessments may
have to be carried out. Among them will be the effects on the air or water, flora and fauna, or the interaction of
emissions from the project. They may require in-depth modelling to predict effects or events (such as may occur in
emergencies), which may not be possible to measure by any direct monitoring. Predictions will also be made for a plant
that is still on the ‘drawing board’.

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4.4 Environmental Impact Assessments and Statements for Large Developments

Environmental Considerations
An environmental statement will often be required to cover the following:
• A description of the development.
• A description of the measures required to avoid or reduce significant environmental impacts.
• The data needed to identify and assess the significant impacts which a development is likely to have on the
environment.
• An outline of the key alternatives to mitigate significant environmental impacts and the main reasons for the
choice made.
• A non-technical summary of the environmental statement.
The current and future environmental issues that are included in an EIA will vary depending on the type of development
and its location. However, current and future environmental considerations will cover, where relevant, the following:
• Air pollution.
• Land contamination.
• Effects on the communities.
• Water pollution.
• Effects on ecosystems.
• Archaeology and the built heritage.
• Noise and vibration.

STUDY QUESTIONS
12. Identify the stages of an environmental impact assessment.

13. Identify the content of an environmental statement.

(Suggested Answers are at the end.)

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 Summary

Summary

Key topics covered in this element:
• An environmental aspect is an “element of an organisation’s activities or products or services that interacts or can
interact with the environment”.
• An environmental impact is a “change to the environment, whether adverse or beneficial, wholly or partially
resulting from an organisation's environmental aspects”.
• The Source-Pathway-Target model is a way to model environmental risks.
• Key environmental issues include climate change and depletion of the ozone layer.
• Nuisance (from noise, odour, premises, etc.), visual impacts and transportation can affect people’s quality of life.
• Environmental impacts can be determined by selecting an activity, determining the aspects and impacts of that
activity and evaluating significance.
• Best Practicable Environmental Option (BPEO) and Best Available Techniques (BAT) describe the extent to which
control measures are implemented.
• When choosing control measures, factors such as long/short term, applicability, practicability and costs should be
considered.
• Ways to evaluate risks to the environment from workplace activities and substances released to the environment
include:
–– Cost-benefit analysis (a comparison of monetary values and costs).
–– Environmental modelling (representation of an environmental system that can be used for predictive
purposes).
–– Life-cycle analysis (assessment of the environmental impacts of a product from ‘cradle to grave’).
–– Assessment of environmental toxicity (indicators such as LC50 or PNEC can be used).
• An Environmental Impact Assessment (EIA) must be undertaken for specified large developments.

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ES Exam Skills

Exam Skills

QUESTION
Describe a methodology for the identification and assessment of environmental aspects and impacts for
compliance with the ISO 14001:2015 environmental management system standard. (20)

Approaching the Question

• Read the question.
• Consider the marks available - there is one question worth 20 marks which should take no more than 36 minutes
to answer.
• An outline plan might include select activities, determine the aspects and impacts of the activities, evaluate
significance, record aspects and impacts, monitor and review.
This question focuses on describing a methodology to identify and assess environmental aspects and impacts. There are
many methodologies that could be considered, in addition to the ones covered earlier in this element.

Suggested Answer Outline

Now you have completed your answer, compare it to the following suggested answer.

A methodology to identify and assess environmental impacts can be described as consisting of the following.

The activity, product or service selected should be large enough for meaningful examination and small enough to be
sufficiently understood; e.g. an organisation may have many different compressors that use energy on-site, so depending
on the size of the site, the energy use for compressors may be identified as one aspect. A process-flow diagram is often
developed to identify activities on a site (from goods in to despatch) and ancillary activities that are not part of the main
process should not be forgotten (e.g. maintenance, fuel storage, office activities).

Following determination of activities, the next stage is to work out the aspects and impacts of the activity. A simple way
is to consider the inputs and outputs from the activity - these are the environmental aspects.

Issues that are commonly addressed include:

• Emissions to air.
• Releases to water.
• Waste management.
• Contamination of land.
• Use of raw materials and natural resources.
Following the aspects identification, the next stage is to determine environmental impacts that the aspects cause or
can potentially cause. Research of what impact is caused by the aspect may be required. An aspect can also have more
than one impact on the environment.

Environmental impacts are usually considered within a number of contexts:

• Direct/indirect: impacts can arise as a direct result of an organisation’s activities. For example, in the case of a
coal-fired power station, the operator of the power station clearly has management control and responsibility
for the facility. The environmental impacts associated with the power station are therefore the operator’s direct
environmental impacts.

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 Exam Skills ES

Indirect environmental impacts are associated with many goods and services. For many organisations, especially in
the service sector, indirect environmental impacts may therefore have a very high significance in their environmental
programme.
• Normal/abnormal conditions: all planned activities need to be considered. These will include not only those
associated with normal running but also those associated with the non-routine (‘abnormal’), such as maintenance
and cleaning.
• Accidents/incidents/emergencies: reasonably foreseeable incidents should also be considered, e.g. fire or
chemical/oil spillage.
• Past/future activities: you should consider the impact from past and planned activities. For example, past land
contamination has impacts that continue into the present. Business plans, such as increasing production, will also
have future impacts that should be taken into account.
The next stage is to determine the significance of the list of aspects. There are many ways of doing this and ISO 14001
does not provide guidance as to which technique should be used.

Two ways to evaluate significance are with simple questions or by using risk assessment.

• Simple Questions
For each aspect and associated impact the ‘yes or no’ answer to a set of questions may be used; e.g. a ‘yes’ answer
to any of the following questions will mean that an aspect is significant:
–– Compliance obligations - is there a general legal requirement, policy commitment, or corporate/office-
specific requirement?
–– Risk - does the activity present a significant risk to the environment, local or global?
–– Customers - is the aspect of concern to customers, visitors or members of the public?

• Risk Assessment
A scoring system can be developed that looks at the likelihood and consequences of an aspect (as is often used for
general health and safety risk assessment).

The following process is used to assign a priority rating for each environmental aspect:
1. Likelihood scored according to previously identified criteria.
2. Consequences scored according to previously identified criteria.
3. Calculate a rating score:
Rating Score = Likelihood × Consequence
4. Those with a rating score greater than a predetermined value are identified as significant.
Environmental aspects and impacts and associated information are often recorded in the form of a register. Although
there is no set format for an aspects and impacts register, as a minimum it will often contain the following information:
• Activity that has been assessed.
• Environmental aspects associated with the activity.
• Environmental impacts associated with each aspect.
• Identification of whether the aspect is from normal, abnormal, or emergency context.
• Identification of the results of the assessment against significance criteria - e.g. likelihood, consequence and total
scores if using a semi-quantitative method to assess significance.

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ES Exam Skills

An aspects and impacts assessment may need to be reviewed if monitoring or other forms of performance evaluation
identify the following:
• An incident relevant to the assessment has occurred, particularly if there appear to be inadequate controls.
• Processes and/or equipment changes.
• Staff changes, particularly if there is a loss of experience and/or historical knowledge.
• Legislation changes, imposing more onerous or new requirements.
• There has been a lapse of time since the last review - technology moves on and what is considered the best
available technique or best practicable environmental option today, may not be in the future.

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 Element 5
Environmental Performance Evaluation

Learning Outcomes

Once you’ve read this element, you’ll

understand how to:

 Explain appropriate indicators that may

reflect an organisation’s environmental
management performance.

 Outline appropriate monitoring

techniques and differentiate between
active (proactive) monitoring and reactive
monitoring.

© RRC International © RRC International Unit ED1 - Element 5: Environmental Performance Evaluation 5-1
 Contents

Performance Indicators 5-3

Environmental Management Performance Indicators 5-3
Study Questions 5-7

Monitoring Techniques 5-8

Active and Reactive Monitoring 5-8
Workplace Inspections 5-14
Auditing 5-22
Study Questions 5-27

Summary 5-28
Exam Skills 5-29

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 Performance Indicators 5.1

Performance Indicators

IN THIS SECTION...
• Environmental Performance Indicators (EPIs) are developed depending on the risk level and environmental
issues relevant to a company.
• Common EPIs include those for incidents, emissions, waste, water, energy, transport and travel, carbon dioxide
and carbon (measurement conversion).

Environmental Management Performance Indicators

The international standard ISO 14031 gives guidance on Environmental
Performance Evaluation (EPE). This uses the Plan - Do - Check - Act model DEFINITION
to identify and collect information on environmental performance indicators:
ENVIRONMENTAL
• Plan - mainly consists of the selection of indicators - either those that PERFORMANCE
are new, or those that are currently being tracked. INDICATORS (EPIs)
• Do - collecting information that is required by indicators, analysing and
converting the data, assessing the information against the organisation’s Are a business tool for the
environmental performance objectives, and communicating the measurement of environmental
information that identifies the organisation’s environmental performance. They should
performance. be quantifiable metrics that
identify the environmental
• Check and Act - a periodic review should be carried out to determine
performance of a business,
opportunities for improvement of the EPE system. Recommendations
e.g. tonnes of waste sent to
should be considered in the management review process.
landfill per tonne of product
The standard suggests the use of two main types of environmental produced.
performance indicators (EPIs):

• Management Performance Indicators (MPIs)

These provide information regarding the efforts of management in relation to environmental performance.

The standard gives examples of MPIs being set in the following categories:
–– Management policies and programmes.
–– Regulatory compliance.
–– Financial performance correlated with environmental performance.

• Operational Performance Indicators (OPIs)

These provide information regarding the environmental performance of operations and are measures of the
environmental inputs and outputs from an organisation’s activities.
Categories where these could be set include:
–– Inputs:
–– Materials.
–– Energy.
–– Physical facilities and equipment.

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5.1 Performance Indicators

–– Outputs:
–– Products.
–– Wastes.
–– Emissions.
Combined indicators are also identified in the standard. These are indicators that may provide information on more
than one issue, e.g. by collecting information on fuel usage per mile, information on the emissions of greenhouse gases,
particulates and other emissions can be derived.

The standard suggests that all types of indicators are relevant, complete, consistent, accurate and transparent.

Examples of these types of EPIs are provided in the table that follows.

Management Performance Indicators (MPIs) Operational Performance Indicators (OPIs)

Number of achieved objectives and targets Quantity of material used (per unit of product)
Level of compliance with environmental regulations Quantity of energy used per year
Number of audits completed in comparison to planned Average fuel consumption per vehicle
Quantity of implemented pollution prevention initiatives Number of products that are/can be recycled
Number of audit findings per period Rate of defective products

Total waste for disposal

Each company will develop its own OPIs depending on the most relevant issues associated with its activities and the
level of risk. OPIs are almost always numerical and should be capable of being used to indicate performance trends
over time. Numerical OPIs can be either absolute or normalised measures. Absolute measures usually express an overall
total - total energy consumption in kWh, for example. Absolute measures may not, however, accurately express an
organisation’s performance over time. A decrease in an organisation’s total energy consumption, for example, may
simply reflect the disposal of certain assets, rather than a genuine improvement in energy efficiency. It is good practice,
therefore, to relate whatever is being measured to a normalising factor - for example, energy consumption per tonne
of product, or per employee, or per m2 of floor space.

The standard also identifies the use of Environmental Condition Indicators (ECIs) - these provide information about
the condition of the ambient environment surrounding the organisation, which might be affected by its activities. ECIs
are usually established by governmental organisations and regulators, and the areas covered include:
• Air quality.
• River quality.
• Bathing-water quality.
• Global climate change.
• Concentration of specified contaminants in living tissue in the local population.
Legislation covering financial reporting by companies requires specific environmental performance information to be
included. The EU Accounts Modernisation Directive, for example, has requirements for companies to include a
balanced and comprehensive analysis of the development and performance of the business in their Directors’ Report.
The analysis should include both financial and, where appropriate, non-financial key performance indicators relevant
to the particular business, including information relating to environmental and employee matters.

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 Performance Indicators 5.1

Incidents
As we will consider in more detail later, indicators of performance might
include incident and near-miss frequencies and complaints.

Business may also accrue fines and costs as a result of regulatory actions.
These can be associated with EPIs, which will ensure that financial
information is reported to stakeholders. Costs can be allocated to a specific
EPI, such as wastes, and, in such cases, should be reported alongside the
relevant EPI. Other costs are more difficult to allocate to a specific EPI and
should be reported individually. Businesses are under a duty to comply with
environmental law and any breaches must be reported including the number
of prosecutions, the amount of any fines and any costs accrued.

Emissions
EPIs that identify emissions from a company are often used by organisations
wanting to report environmental performance. Performance indicators often Incidents are an indicator of
reported include emissions of greenhouse gases (see below), acid rain and performance
smog precursors, such as sulphur dioxide (SO2), nitrous oxides (NOx), ammonia (NH3) and carbon monoxide (CO).

Noise may also be reported.

Waste
Wastes produced by an organisation can be measured relatively easily, e.g. by estimating the number and weight of
waste items that leave a site for disposal or treatment. Waste is often reported in tonnes per annum. Waste should be
measured by individual types (e.g. glass, wood, metal) and the final waste management option (e.g. landfill, recycling)
should be recorded. In some cases this may need to be carried out for regulatory reasons.

Water
Common indicators used for discharges to water include discharges of nutrients, organic substances and metals.

Organic matter is present in groundwater and surface water and may cause widespread pollution when it is found in
large quantities (usually from human activities). Discharges of sewage and from industry that consist of a high level of
organic material, such as nitrogen and phosphorus, can cause eutrophication. This is when organic materials cause
aquatic plant life to flourish, which, following death and decomposition, deplete oxygen, causing adverse changes to
the ecosystem. Other organic materials include Polychlorinated Biphenyls (PCBs), Polycyclic Aromatic Hydrocarbons
(PAHs) and Hexachlorocyclohexanes (HCHs), which can have significant effects on watercourses.

Parameters that are commonly used to estimate the potential effect of eutrophication of wastewaters include Biological
Oxygen Demand (BOD), Total Organic Carbon (TOC) and Chemical Oxygen Demand (COD). Effluent discharges are
often reported in cubic metres per annum.

It is also common to record spillages (amount, substances, etc.) of organic pollutants if these contribute significantly
to pollution.

Metal and metal compounds are other relatively common aquatic pollutants. Commonly reported metal discharges
include mercury, cadmium, arsenic and zinc. Metals can be found in cooling water and industrial discharges. Metal
may affect the aquatic ecosystem in many ways. Some metals, e.g. cadmium, can biomagnify - their concentration can
increase as they travel up the food chain.

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5.1 Performance Indicators

Energy
Most electricity is produced from fossil-fuel combustion. Industry and commerce have a significant impact on climate
change, being indirectly responsible for emissions of large quantities of carbon dioxide and other greenhouse gases.
Emissions of greenhouse gases can be determined by contacting the relevant electricity supplier, or using a standard
factor for electricity. Those companies that have a non-typical combination of electricity supplies (e.g. purchase energy
from renewable sources) should contact their supplier, whereas organisations with a standard supply may use the
standard generation factor to determine carbon emissions.

Transport and Travel

Transport has a key role in a much wider environmental agenda. For example,
the impact of global warming is becoming more accepted as a critical risk,
and a continued rise in CO2 concentrations means that a catastrophic change
in the Earth’s temperature cannot be discounted.
• Traffic impacts on the environment through pollution from engine
exhaust gases, particularly in urban areas. However, pollutant
concentrations have fallen owing to cleaner fuels and new technologies.
• Plants, animals and habitats are sensitive to the vehicle pollutants.
For example, nitrogen oxides from exhausts form acid rain in the
atmosphere, which can damage trees and soil.
• Transport affects the environment in other ways. Land and habitats Oil slicks damage the
are lost when new roads are built. Oil slicks from wrecked tankers can marine environment
damage the marine environment.
Transport can also affect human health. Consider the following:
• Vehicle emissions release potentially harmful substances, such as MORE...
nitrogen oxide, carbon monoxide and fine particles into the air. These Further information on
pollutants can reach high levels of concentration in towns and cities. environmental performance
• Air pollution triggers asthmatic attacks. Fine particles, in particular, may indicators is available in the
have long-term health effects, especially for those with heart and lung DEFRA guide Environmental
problems. Key Performance Indicators:
• Lead used to be added to petrol to give it more power. The UK Reporting Guidelines for UK
Government reduced the amount of lead allowed in petrol in 1985 and Business at:
banned it in 2000. Lead emissions have decreased by about 98% since
www.gov.uk/government/
1980.
publications/environmental-
EPIs used for travel and transport could include: key-performance-indicators-
• Vehicle miles per average weekday. reporting-guidelines-for-uk-
business
• Number of journeys undertaken by sustainable modes (cycling, walking
and public transport).
• Total number of Green Travel Plans and School Travel Plans implemented in a borough.

Carbon Dioxide and Carbon (Measurement Conversion)

Many organisations report on the emissions of Greenhouse Gases (GHGs). Different GHGs, however, have different
potential to cause global warming - this is known as Global Warming Potential (GWP). The GWP used in the Kyoto
Protocol is defined as the warming caused over 100 years in comparison to carbon dioxide. For example, methane has a
GWP of 21 and nitrous oxide 310. GHG measurement may be directly at source by monitoring, or the amounts emitted
can be estimated by using activity data (e.g. fuel consumption) and conversion factors.

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 Performance Indicators 5.1

STUDY QUESTIONS
1. Name five impacts where indicators can be set to track environmental performance.

2. What are the environmental reporting requirements in the EU Accounts Modernisation Directive?

3. Identify a possible environmental performance indicator for travel and transport.

(Suggested Answers are at the end.)

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5.2 Monitoring Techniques

Monitoring Techniques

IN THIS SECTION...
• Active monitoring is a means of identifying environmental problems before they happen and includes
environmental audits and workplace inspections.
• Reactive monitoring is a means of identifying loss incidents, such as near-misses, complaints or regulatory action.
• Environmental auditing is a systematic, documented, periodic and objective evaluation of how well the
organisation’s management systems are performing.
• Undertaking an audit consists of the following stages: pre-audit preparations; information gathering (opening
meeting, information collection, closing meeting); and report writing.
• There are numerous types of environmental audits - examples include corporate audits, compliance audits and
due-diligence audits.

Active and Reactive Monitoring DEFINITIONS

No single measure, by itself, will effectively measure the performance of the
organisation. While we will be favouring the use of active monitoring, there is ACTIVE
still a role for the reactive monitoring of accidents, spillages, etc.
Means ‘before it happens’.
The essential element is to find some factor that can be measured which will
REACTIVE
relate directly to some specific objective in the environmental policy.
Means ‘after it has happened’.
Active Monitoring Measures
ENVIRONMENTAL
Objectives of Active Monitoring AUDIT
The purpose of active monitoring is to check that the environmental plans Is an in-depth, systematic,
have been implemented and to monitor the extent of compliance with: critical investigation into all
• The organisation’s systems and procedures (check that practice reflects aspects of environmental
the written procedures). management. It needs to
include management systems,
• Legislation and technical standards.
policy, attitudes, training and
By identifying non-compliances, steps can be taken to ensure that any practice.
weaknesses are addressed, thus maintaining the adequacy of the plans, and
helping to avoid any incidents. WORKPLACE
INSPECTION
Measurement Techniques Involves someone walking
These include environmental audits and workplace inspections. round a part of the premises,
looking for environmental
Active Monitoring Data aspects and impacts, or non-
compliance with legislation,
This should determine the extent to which plans and objectives have been set rules or good environmental
and achieved, and includes: practice, and taking notes. The
• Staff perceptions of management commitment to environmental task is made easier and more
management. methodical if some form of
checklist is used.
• Whether a director for the environment has been appointed.

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 Monitoring Techniques 5.2

• Whether environmental-management specialist staff have been appointed.

• The extent of influence of environmental specialists.
• Whether an environmental policy has been published.
• Whether the environmental policy has been communicated adequately.
• The effectiveness of environmental training.
• Number of risk assessments completed as a proportion of those required.
• Extent of compliance with risk controls.
• Extent of compliance with statutory requirements.
• Staff attitudes to risk and risk controls.
• Staff understanding of risk and risk controls.
• Frequency of environmental audits.
• Frequency and effectiveness of environmental committee meetings.

Monitoring of Performance Standards and Criteria

The basis of planning the arrangements for environmental management
is the risk, or aspect, and impact assessment. Risk assessment provides the
means for identifying new issues for control and ensuring that the existing
measures are effective. The controls that are put in place may be specified
as written ‘performance standards’ comprising, for each risk, a statement of:
• What has to be done:
–– Physical aspects of the working process (such as noise/dust/
light levels, containment measures) and/or certain actions that
are required to be taken at predetermined intervals (such as
maintenance checks, health surveillance).
–– Physical or chemical monitoring of the quality of emissions to Records are maintained
atmosphere, or discharges of effluent to sewer, or controlled waters.
• Who does it, how often and with what equipment.
• What records should be created and maintained.
We can assess performance by measuring how well the stated standards are being achieved, e.g. the level of accident
rates, numbers of environmental failures identified on inspection, degree of compliance with the requirements in
respect of who does what, when and with what result.

This measurement should be set against the ‘levels of acceptability’ built into the standard, in respect of what is deemed
an acceptable level of performance. It could be argued that there is no leeway in this - that 100% effectiveness is
required in all cases and at all times. However, in all but the most high-risk operations, there is likely to be some degree
of tolerance of imperfections. Thus, a single incidence of a failure to maintain noise levels below the stated level may
not be of great consequence, but several would. The important thing is that we know what is happening and can make
a judgment as to its adequacy.

This approach to measuring performance can also be applied successfully across the various elements comprising the
environmental management system. Performance standards can be stated in terms of who does what, when and with
what result in respect of the organisational arrangements for:
• Conducting risk assessments, including frequency, suitability and involvement of different personnel.
• Preparation of rules, procedures and documentation.
• The active involvement of senior managers in environmental matters, including tours, incident investigations, etc.
• Specifying the key environmental posts and roles, and ensuring that they are filled at all times.

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5.2 Monitoring Techniques

• The structure and functioning of consultation processes, including

membership of environmental committees, the frequency of meetings
and the distribution of minutes, etc.
• How incidents are to be reported, investigated and acted upon.
• Collection and dissemination of information from external sources.
• Audit and review.
It is important that monitoring takes in the whole range of arrangements,
not just the actual control measures. The effectiveness of those measures
- in terms of both how comprehensive they are in protecting against risks
and how well they operate in practice - is a management responsibility. If
Effectiveness of control measures is
there are failings in that responsibility, the result may well be an accident. Not
management responsibility
only is the avoidance of that outcome a moral duty but it is also a statutory
requirement, so a failing may result in criminal prosecution, or civil liability.

Thus, active monitoring is concerned with the totality of performance standards for environmental management at
work.

Assessing effectiveness of environmental performance implies that we must first have something that can be measured,
and some goal or standard against which to judge that measurement.

Systematic Inspection of the Workplace

In the same way that health and safety inspections are a useful tool so, too, are environmental inspections. In some
organisations, it is possible to combine environmental inspections with health and safety inspections, which allows a
more holistic approach to the management of both disciplines.

Inspections are the least formal activities out of all the environmental improvement tools. However, if carried out
conscientiously in a positive and proactive manner, they can have an immediate impact on the effectiveness of the
organisation. Inspections are scheduled checks on premises, activities or equipment carried out by personnel within
that organisation. In some cases, particularly with respect to plant and equipment inspections, they are carried out by
external specialists. An example of this is the Local Exhaust Ventilation (LEV) inspection on equipment carried out by
an external surveyor.

Use of Environmental Inspections

To be effective, inspections should be planned according to a published schedule and have the full support of senior
management. However, ad-hoc inspections are also valuable - for example, when used to enforce EMS procedures.
Any non-conformance to plans and specifications should be formally noted and suitable corrective actions applied and
monitored.

While it is recognised that the use of a checklist is not always practicable, it is recommended that checklists are used
to facilitate the inspections. This has the added bonus of providing evidence to any auditor or interested party that
inspections are a formal part of company procedures.

Inspections can also be used to monitor performance through the use of an end-of-shift checklist, e.g. for housekeeping,
to ensure that company standards of tidiness are maintained, recording the results as a tick list. A check sheet is a
valuable tool, which can aid the more formal audits at a later stage.

Role within a Monitoring Regime

Systematic active monitoring, involving inspections and other forms of examining environmental arrangements and
control measures, will be based on the nature and severity of the risks.

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 Monitoring Techniques 5.2

High-risk situations will require a greater depth and frequency of monitoring than situations of lower risk. Thus, some
measures may need to be checked on a daily basis, or even before any work activity. Others may only need examining
every week or month, and others every few months or every year.

There is a variety of means of doing this, including:

• Workplace inspections - the systematic examination of the controls in operation, such as the condition of
secondary containment and the level of compliance with environmental procedures, and the effectiveness of the
level of information, instruction, training and supervision.
• Performance review - the systematic collection and review of information drawn from inspections, interviews/
consultation and reports, etc. to assess the achievement of the organisation’s objectives in respect of
environmental management.
• Environmental audits - the regular, comprehensive review of all management systems that support the
procedures and measures for ensuring effective environmental management in the workplace.

Reactive Monitoring Measures

The objective of reactive monitoring is to analyse data relating to:
• Accidents.
• Other loss-causing events.
• Any other factors that degrade the system.
It is obviously preferable to identify, and address, any potential problems by
means of active monitoring, rather than waiting for an event to happen to
highlight any shortcomings in the systems. Hopefully, accidents are very rare
occurrences. This means that there are not many cases to count, and the
numbers may not be regarded as statistically significant.

Variations from year to year might be due to pure chance rather than any Reactive monitoring looks at
accident reduction measures that we have introduced. This is why we often accidents and other loss-causing
events
have to resort to national statistics, or even international data in order to find
significant numbers to target environmental programmes. If we keep data for many years, it is possible to iron out these
fluctuations by finding the moving average. As we get another year’s, or month’s, figure we are able to enter this into
the average and so determine a trend.

Accident statistics tend to reflect the results of actions that were taken some time ago, so that there is not a rapid cause-
and-effect situation. It is also unfair to blame a manager for accident situations when the present situation is to some
extent dependent on actions taken some time ago, and the present actions will take some time to show.

Accident data is relatively easy to collect. There are a number of standard calculations of accident rate, which are fairly
easy to understand. Management can easily link accidents with environmental performance, so it is easy to discuss
accident reports, and get management to take action.

Accident recording has some value, therefore, but it is of limited use in relation to assessing future risk. There are
problems with under-reporting of minor accidents. Also, if the staff are made aware of environmental matters, they
tend to report more accidents. The picture may then look worse when, actually, the environmental culture is improving.

Reactive Monitoring Data

• Incidents.
• Near misses.
• Reportable emissions (i.e. those over an emission limit value).
• Monitoring of water, energy, waste, etc.
• Complaints.

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5.2 Monitoring Techniques

• Criticisms from regulatory agency staff.

• Regulatory agency enforcement actions.

Incidents
The likelihood of an incident can be minimised by effective planning through the development of site pollution incident-
response planning. The plan needs to identify on-site risks and appropriate responses. Suitable equipment, such as spill
kits, should be held at appropriate locations on site. An effective pollution incident-response system relies on the following
elements:
• Effective pre-planning (e.g. use of drip trays, bunds, etc.).
• Identification of contact numbers.
• Definition of personnel responsible.
• Appropriate training.
• Dry running of an incident scenario - spill drills.
• Availability of suitable spill kits at appropriate locations on the site.

Near-Misses
As with health and safety, it is important that a company has a system in place
to record near-misses and ensure that they do not occur again, as the next DEFINITION
time they may turn out to be accidents that have a significant impact on the
environment. NEAR-MISS

Examples of environmental near-misses include: Is defined as an incident that

could have resulted in an
• An oil drum falling from a forklift truck, which spilled oil onto a roadway. accident.
The oil was, however, prevented from entering a surface-water drain by
a quick-thinking employee, who temporarily capped the drain.
• An item of hazardous waste was disposed of in the general waste skip prior to being taken by the waste contractor
from the site. The item of hazardous waste was seen by an employee before collection and removed from the
skip.
• A tanker containing diesel almost colliding with a car while undertaking a delivery to an industrial site.
An effective near-miss reporting system will include both mandatory and voluntary reporting. A key to near-miss
reporting is to learn lessons so that remedial actions can be implemented to prevent the situation from occurring again.
Root-cause investigation should be undertaken on all near-misses to determine the errors in the system that may
have occurred, leading to the incident.

Emissions
As we saw earlier, greenhouse gas emissions may be determined by using conversion factors or direct monitoring. Metal
discharges to water can be determined by using emissions estimation methods.

Waste
Processes that produce large and variable amounts of waste can often benefit from improved process control. The first
step is to identify the parameters affecting the amount of waste. An effective process control system typically consists
of a method of measuring key parameters, with a controller and a control device (e.g. a valve) linked in a feedback loop.
The controller can range from manual monitoring to a fully automated system.

Legal requirements often specify that a system should be in place and maintained that records the quantity, nature and
origin of any waste that is disposed of or recovered - and also, where relevant, the destination, frequency of collection,
mode of transport and treatment method for those wastes.

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 Monitoring Techniques 5.2

Water and Energy

Water and energy consumption can be monitored by using varyingly complex methods depending on the specific
requirements of an organisation. Methods commonly used include:
• Viewing and recording energy/water consumption from bills received by an organisation. Commonly, such
information is recorded on a spreadsheet, allowing graphs of water/energy consumption over a set period to be
produced.
• Recording meter readings on a regular basis (daily, weekly or monthly), allowing an organisation to identify trends
in water/energy consumption.
• Sub-metering systems, which allow an organisation to measure energy or water consumption within particular
areas of a site, or by particular items of equipment. This technique allows much more specific identification of
saving opportunities than is possible by using data from the primary utility meter. Sub-metering is appropriate for
energy- or water-intensive organisations and those that are already familiar with basic energy/water-management
practices.
• Online monitoring for water, which involves the fitting of a remote data-logging device to the existing water
meters on a site, which then records flow readings at programmed intervals and sends this information daily
to your water company. The customer can then access this data via a secure website in graphical, summary,
or individual-value formats. Similar systems are also available to monitor effluent production and energy
consumption.

Complaints by Workforce and Neighbours

Complaints and suggestions are likely to be a good indication of the
adequacy of environmental measures. These opinions may be voiced through
the normal consultative channels - environmental/employee representatives
and the environmental committee - or may be individual issues raised with
management.

Generally, the fact that employees have seen fit to raise an issue, in whatever
form, may be taken as an indication of a failure in the current arrangements.
This may be because there are actual physical failings in the control systems Complaints and suggestions may be
that are in place. Alternatively, it may indicate a lack of understanding of raised with management
the control systems, so that they feel there is a risk, even though the risk is
actually properly controlled. Either way, there is a need to address the issue.

If concerns are raised, it is important that they are acted on. This not only demonstrates management commitment
but also encourages a positive environmental culture in which the contribution of employees is valued.

Additionally, complaints from interested parties, such as members of the public residing in housing surrounding a site,
should be recorded. They provide a useful indicator of the success of measures to reduce environmental impacts of an
organisation and identify when corrective actions need to be undertaken to reduce certain types of impacts.

Enforcement Action
Regulatory authorities usually have a statutory right to inspect premises at any time, particularly where a breach of
statutory duty is suspected.

Any indication by an enforcement officer that standards of the existing arrangements are deficient must be taken
seriously. In the case of the issuing of notices, action is required immediately (or within a defined timeframe), but any
advice about improvements that should be made will be indicative of a failure of the existing system, which needs to
be remedied.

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In some cases, the issuing of advice may be on a technical issue and there may be no underlying problem - indeed,
the seeking of external advice may be seen as a demonstration that the management system is working effectively.
However, where a notice is issued, this is clear evidence that management controls are not effective.

Workplace Inspections
Role of Inspections
Workplace inspections are concerned with ensuring that the control arrangements specified in the environmental
policy statement and associated procedures are operating effectively and that they cover all the risks. As such, they
are the foundation of systematic environmental monitoring. They demonstrate management’s commitment to the
environment, and afford an opportunity to involve employees, thereby giving them ownership of environmental
concerns. By identifying problems, making recommendations, and eliminating or controlling the risk before an accident
happens, the morale of employees is raised.

There are a variety of types of inspection, as discussed below, but they all comprise the same three basic elements:
• An assessment of the standards of the workplace against the specified performance standards and risks.
• The identification and reporting of any deficiencies.
• The identification of causes and of action to be taken to remedy the problem.
In addition, the inspection should be carried out by a competent person, i.e. someone with the knowledge and skills to
appreciate the requirements of the performance standards and assess the actual situation against them.

Factors Governing Frequency and Type of Inspection

The frequency of the inspections will be determined by the nature of the risks and the importance of the measures
required to ensure their control. However, workplace inspections also provide an active demonstration of commitment
to environmental management and, as such, should be a sufficiently regular occurrence to assure the workforce that
environmental issues are important and demand constant vigilance.

The types and frequency of inspections will reflect the nature of the risks in the workplace and the methods used to
control them. There is, therefore, a range of inspection regimes designed to ensure the effectiveness of control systems:

• Routine Inspections
The first level of inspections is those that are carried out as a matter of
routine at all times, or at very frequent intervals.

Some precautions needed to control a particular risk may need to be

monitored on an almost continuous basis to ensure their effectiveness,
e.g. air-abatement systems to remove toxic fumes. Others need to
be checked on a regular, scheduled basis, e.g. that required spillage
equipment is present.

The requirement to carry out such inspections will be written into Any deficiencies must be reported
environmental procedures, or work instructions for the particular operation, and it will be the responsibility of the
operator and/or the immediate supervisor to ensure compliance.

It will not generally be necessary to document that routine inspections have been carried out, although where
they form part of a health and safety permit-to-work system this will be required. However, any deficiencies must
be reported to a supervisor or manager immediately and work should not commence before the issue has been
resolved.

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 Monitoring Techniques 5.2

• Maintenance Inspections
Many physical control systems, or items of plant, machinery and equipment, need to be checked on a regular basis
to ensure that they remain fit for purpose. These inspections will involve examining, testing and making repairs/
adjustments to such items as secondary containment (e.g. bund walls), flooring, vehicles, etc. This should be done
in accordance with a maintenance schedule, which is designed to ensure that all items are checked within defined
periods, depending on the rate at which they may be expected to deteriorate and thus present a risk in their use.
Thus, for vehicles, the requirement may be that they are inspected every six months or after having travelled 10,000
miles, or for air-abatement equipment it may be every two weeks.

The maintenance schedule is very often specified by the manufacturer or supplier of the plant and machinery, etc.,
and, in some cases, it is reinforced by legal requirements (as in the case of fire-fighting equipment).

Maintenance inspections will normally need to be documented and the record should include the general state of
repair of the item, results of any tests, and what repairs/adjustments were made, if any.

• One-Off Equipment, etc. Inspections

There will always be a need to specifically inspect particular items of plant, machinery and equipment in certain
circumstances, such as:
–– After a breakdown, accident or other incident affecting the item.
–– After a period of non-use, e.g. on resuming operations after a weekend or holiday period.
–– After resetting the equipment, e.g. checking the positioning of the fixed guard that had been removed to allow
for the changing of a grinding wheel.
The circumstances in which any items of plant, machinery and equipment will need to be inspected will generally
be stated in procedures.

Such inspections will normally be documented.

• Environmental Inspections
These are formal inspections of a whole area or section of the workplace to check on either all the environmental
measures applicable, or particular aspects of them. They are often combined with safety inspections. This will
include such issues as:
–– General maintenance, including the condition of floors, work surfaces, etc.
–– Compliance with procedures.
–– Housekeeping and cleanliness.
–– Condition of information and warning signs.
–– Fire precautions.
These inspections are usually conducted by a team of people, including the workplace supervisors, section manager
and safety representative. Depending on the level of technical detail or complexity, an environmental officer may
also be involved. Such inspections may also include examination of documentation, such as maintenance records,
and discussions with workers about the general approach to environmental issues and any particular concerns they
may have.

Note that the whole workplace does not necessarily have to be inspected, nor all the items included in an inspection
checklist (see below) covered, during each inspection. Selection of certain activities, priority lists and discussions on
specific topics can often be far more beneficial than a tedious ‘walk-through’ survey of the whole department. It is
vital that enthusiasm and interest are maintained.

Environmental inspections should be fully documented and any problems encountered reported.

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• Environmental Tours
These are generally unplanned inspections by an environmental officer,
environmental representative and/or manager designed to observe
the workplace in operation without any prior warning. Again, these are
often combined with health and safety inspections. They will not be as
thorough as a full inspection, but have the advantage of being quick, easy
to organise and relatively informal.

Tours usually follow a predetermined route through the area or workshop,

which is designed to cover the main environmental measures applicable.
They are relatively short - say, just 15 minutes - and can be conducted at
regular intervals to keep workers on their toes.

They are a particularly effective method of checking that standards An environmental survey
of housekeeping are acceptable and that gangways and fire exits are
unobstructed.

Environmental tours will not generally be documented in detail, except in so far as any deficiencies are found.
These will need to be reported and follow-up action checked (perhaps on the next tour or, if urgent, by a special
inspection).

• Environmental Surveys
These are a narrower, more in-depth examination of specific issues or procedures following such events as the
introduction of new equipment, or changes in working practices. They may also be initiated after problems have
been highlighted by other monitoring techniques, e.g. where there has been a rise in particular types of accident, or
a deficiency has been disclosed by an environmental audit.

Environmental surveys are conducted by the managers responsible for the workplace(s) being inspected, together
with environmental officers. The findings will be fully documented in the form of a formal report to management.

In the case of environmental inspections and surveys, the length of time allocated to the inspection can be crucial in
maintaining a good standard of observation and interest. Inspections should not generally take more than two hours. It
may be necessary, then, to allocate time to discuss the findings and the construction of the report.

Competence of Inspector
The person responsible for conducting the inspection must be competent to carry out all the necessary checks
and draw the correct conclusions from them in terms of deficiencies in any aspect of the workplace environmental
arrangements. This will involve reporting problems in the appropriate form to the appropriate person, and may involve
identifying causes and remedial action.

The extent of knowledge and skills necessary to demonstrate competence will, obviously, vary with the extent of
the responsibilities involved in the inspection. The more detailed and extensive the inspection, and the wider the
implications of deficiencies, the greater the competence required.

Environmental inspections, tours and surveys will invariably involve the environmental officer. In addition, inspections
carried out under specific statutory requirements must usually be led by a person with specific competence in that area
of work.

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 Monitoring Techniques 5.2

Use of Checklists
In order to ensure a consistent and comprehensive approach to checking all the environmental elements to be covered
during an inspection, it is usual to develop a checklist or inspection form, which covers the key issues to be monitored.
This will identify all items that need to be inspected in that particular type of inspection - i.e. pre-operational checks,
maintenance checks for particular types of equipment, items to be covered in a full departmental environmental
inspection, etc.

Checklists should also be structured to provide a coherent approach to the inspection process. This aids monitoring
the process of inspection and analysing the results, as well as simplifying the task of actually carrying out the inspection
itself.

While checklists are often included in procedures and manuals, they should not be seen as set in tablets of stone.
In particular, in terms of maintenance and environmental inspections, the list should not act as a constraint on the
inspector(s) identifying other potential problems or hazards. Checklists should also be reviewed from time to time to
take account of recent or proposed developments in environmental issues in that particular workplace.

In order to get maximum value from inspection checklists, they should be designed so that they require objective
rather than subjective judgments of conditions. For example, asking the people undertaking a general inspection of
the workplace to rate housekeeping as good or bad begs questions as to what good and bad mean, and what criteria
should be used to judge this.

Allocation of Responsibilities and Priorities for Action

Since there is a general duty on employers to ensure the competence of their employees to carry out their workplace
roles effectively, this means that appropriate instruction and training must be provided.

The various persons involved in inspections are as follows:

• Individual Employees
Although there is no direct legal requirement under environmental law, the environment can be affected by their
acts and omissions. Therefore, operators must make sure, for all appropriate inspections, that their work area is free
from environmental hazards, e.g. all hazardous-liquid containers are placed on a drip tray.

• Supervisors
They have greater responsibilities, involving ensuring that operators under their control are operating in a manner
that prevents or limits impact on the environment, in accordance with environmental procedures. This applies to
the operation of all control measures. Supervisors have specific responsibility for ensuring routine inspections are
carried out and for leading maintenance and one-off inspections. They will also be involved in all other inspections
affecting their own work areas.

• Environmental Officers
They have a much wider role in inspections, particularly with regard to the identification of causes of problems and
identifying remedial actions. They will be involved in all environmental inspections, tours and surveys, in some cases
leading them.

• Management
Middle and senior managers, while not having any specific front-line responsibility for the more regular inspections,
must ensure that supervisors are fulfilling their responsibilities. Part of this will be the review of inspection reports,
particularly where action is required. Section/departmental managers are responsible for environmental inspections
covering their entire work area and are likely to be involved in safety tours and surveys as well. Visible management
participation in all types of inspection, from all levels of management and from the environmental committee, is
valuable in demonstrating commitment to the environment and is an essential element in promoting a positive
environmental culture.

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5.2 Monitoring Techniques

• Enforcement Authority Inspectors

Enforcement authorities usually have statutory rights to inspect
workplaces where a breach of statutory duty is suspected. They will
normally be accompanied by a member of management.

As a general point, inspections are not designed to provide a problem-solving

mechanism at the very instant an environmental aspect or risk is identified.
It would normally be more appropriate to analyse any deficiencies in the
environmental arrangements during a post-inspection discussion. However,
action may need to be taken if there is an immediate risk to the environment.

The purpose of inspection is, though, to identify remedial action to be taken

in respect of deficiencies. This needs to be based on an assessment of the Any results should be communicated
causes of the problem - immediate and underlying. Priority should be given to all personnel
to remedying any immediate causes of risk, since they may have the potential to cause accidents, and action should
be taken at the earliest opportunity. Other underlying causes also need to be addressed, but these are likely to involve
further investigation and consultation with management to identify the roots of the problem. They must not, though,
be overlooked.

It is also useful to rank the outstanding issues - i.e. those that are not earmarked for immediate action - so that priority
can be given to those deficiencies that appear to present the greatest risk.

It is important, too, that the outcome of any environmental inspection, tour or survey is communicated to all personnel
involved - whether the results are positive or negative. This will help improve environmental awareness and develop
the environmental culture.

Summaries of the findings, using graphical presentation where appropriate (e.g. simple graphs and bar charts, etc.),
may be displayed on noticeboards or in environmental bulletins, and comparisons drawn with previous inspections
and other similar workplaces. Discussion could be held to consider the outcomes and encourage involvement in the
identification of improvements.

The Requirements for Effective Report Writing

There are three main aims to the writing of reports and they are all about good communication. A good report should
aim to:
• Get the message through to the reader.
• Make the message and arguments clear and easy to understand.
• Make the arguments and conclusions persuasive.
Communication starts with trying to get into the mind of the reader, imagining what would most effectively catch the
attention, what would be most likely to convince, what would make the report stand out among others. A vital part of
this is presentation, so while a hand-written report is better than nothing, a clearly organised, typed report will be much
clearer. To the reader, who could be busy with a lot of written information to consider, a clear, well-presented report will
produce a positive attitude, with immediate benefits to the writer.

Style
Style means the tone of language you use to address the reader. There are the following points to consider:

• Clear
Clarity is achieved through the use of the right language - words that the recipient will understand, set out in a
logical order with appropriate structuring of the information. Take your reader through the points you want to
make one by one, so that each leads on to the next.

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 Monitoring Techniques 5.2

You need to use meaningful language that avoids ambiguity and puts your points across in a way that can be easily
understood by the reader - words and phrases need to be chosen with care, unavoidable jargon, terms and lesser-
known concepts and procedures need to be explained. Short, simple, structured sentences help, as do headings and
graphical forms of presentation such as diagrams, etc.

One problem often encountered is the need to refer to other documents or extracts from them, or to detailed
background information, say about particular measurements. The inclusion of such material in the body of a report
can upset the flow and be quite confusing as the reader feels they have to read through and understand it. Such
material, if it is necessary at all to getting your points across, should be placed in appendices, or attached as a
supporting document. This helps keep the main communication to the point throughout.

• Concise
Being concise means keeping the report as short as possible. You do not want the reader to have to wade through
vast amounts of material to find the key points, nor do you want your arguments or points to get lost in a clutter
of waffle.

Being concise does not necessarily mean simply stating the bald points. The use of explanations and examples
contributes to clarifying the key issues and should be employed where appropriate. However, the essence is to stick
to the point and not over-elaborate or wander off into other areas that may confuse the issue or lose the reader.

Brevity, compatible with the complexity of the information to be conveyed and the necessary style and tone, is of
the essence. Thus, it is better to say ‘Unfortunately ...’ rather than ‘I regret that I have to say that ...’. One of the
trends in report writing has been to be more direct and use less of the rather obtuse and long-winded language of
formal business communications from the past. That tendency has not disappeared completely, particularly from
some formal, old established organisations, but where the flow of language is not damaged, every effort should be
made to cut down on the number of words used to say something.

• Correct
The information conveyed must be as accurate as possible at the time of presentation - a seemingly obvious point,
but one which has a number of implications.

In order to be truly accurate, it may seem necessary to use incredibly complicated language, particularly legal
language, e.g. when explaining the limitations of what you were able to observe (such as not being able to check
the condition of certain measures because, say, they were not operational at the time or you lacked the necessary
testing equipment for one reason or another). This may be very off-putting or difficult to understand for many
recipients and needs to be avoided. (It clashes with C for clear.) In most circumstances, some degree of absolute
accuracy may be sacrificed for clarity.

All reports should be dated. This sets the information in a particular timeframe and allows for variations to be made
to reflect new information at a later date.

Being accurate is not always easy. In many situations, the information being conveyed is not precise or complete,
and this needs to be openly recognised where the reader needs to be aware of any limitations.

• Courteous
It pays to consider a report as a personal address to the reader(s). Therefore, in trying to be brief, do not be curt - be
polite and use friendly language rather than formal ‘officialese’.

• Complete
The report should contain everything you want to say - nothing more and nothing less. As far as possible nothing
should be left out, although you may have to say that certain points cannot be covered at this particular time and
will be dealt with later. In that way, the reader will be aware that they have everything they need.

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This may mean going beyond what were the original terms of the inspection when writing the report - additional
information may need to be brought in, in order for the complete picture to be presented.

• Consistent
The flow of language is considerably aided by consistency in its use, such as standardising the use of person and
tense in verbs, and sticking to a particular style and tone throughout. A number of problems arise from this:
–– Adopting a consistent and clear usage of non-gender-specific phrasing (to avoid the use of ‘he’ all the time
which you will find in most older texts) can mean using rather convoluted phrasing or an overuse of ‘he/she’
or ‘(s)he’, which can look and sound clumsy.
–– The convention of writing reports in the passive tense (‘it may be seen that ...’) can give rise to phrasing
difficulties and also conflicts with the more direct and courteous use of active tenses (‘you will see that ...’),
but it can be confusing to switch between the two too often.

• Convincing
This last point is often overlooked. It is very important to show confidence and commitment in what you write,
even though there may be times when you do not actually feel that in what you have to do at work. Doubt,
ambiguity and vagueness come through very clearly in all forms of communication. Messages need to be conveyed
with conviction or they will not be taken seriously.

Structure
A written report needs to say what you have done and what you have found out. It needs to make a clear distinction
between what is factual and what is opinion. Perhaps most importantly the report needs to be written in a style that
is easy to read and understand, and it should only include text that is relevant (sometimes “less is more” - try to
avoid ‘waffling’). The audience that it is aimed at should also be considered: non-technical people will not understand
technical wording or jargon, so this should be avoided; the managing director doesn’t have time to wade through a
huge report, so either a short report or a good summary at the front of the report should be provided.

TOPIC FOCUS
Report formats vary depending on the audience. Scientific reports typically adopt a far more formalised
approach (with many more sections). Below are the typical components of a workplace report (such as the
project required for this course):

• Title and Author

The title should be as short as possible and make it clear what the report is about. You should give your name.

• Abstract or Short Summary

This is a short summary which the reader can use to decide if they want to read the report.

• Introduction
This sets the scene and gives the reason for the piece of work, as well as background and basic methodology.

• Main Body of Report

This is where you include the main presentation of results, together with an analysis and discussion. To aid
the flow of the report, some large sets of data, tables and figures, etc. might be relegated to an appendix and
just summarised in the main body.

(Continued)

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 Monitoring Techniques 5.2

TOPIC FOCUS
• Conclusions
This is a brief statement of what your report has discovered.

• Recommendations
This is where your suggested course of action will be outlined. Recommended actions should be clearly stated
and will often be accompanied by appropriate timescales, as well as the responsible person for completing
the action. Recommendations should be numbered and, where appropriate, priority should be indicated.

• References
Where you have made use of other people’s publications or data then you will need to acknowledge this.
Usually, the references are put in alphabetical order by author surname. The title, date of publication and the
publisher involved should be included.

• Appendices
There is often material that might be of use to others, but which would only confuse the more casual reader.
Tables of raw data, forms used for collection of data and statistical calculations would come into this category.

Emphasis
As report writers using computers today have access to a wide variety of fonts and textual effects, they are no longer
limited to underlining to show emphasis.

Visual text devices for adding emphasis:

• Italics or underlining are often the preferred ways to emphasise words or phrases when necessary. Writers usually
choose one or the other method and use it consistently throughout an individual report.
• Overuse of various emphatic devices like changes of typeface and size, boldface, all-capitals, and so on in the text
of a report creates the impression of a writer relying on flashy effects instead of clear and precise writing to make
a point.
• Boldface is also used to show emphasis, as well as to highlight items in a list.
• Some report writers use all capital letters for emphasis, but they are usually unnecessary and can cause writing to
appear cluttered and ‘loud’. In e-mail correspondence, the use of all caps throughout a message can create the
unintended impression of shouting and is therefore discouraged.

Punctuation Marks
• Some punctuation marks prompt the reader to give a word or sentence more than usual emphasis. For example, a
command with a full stop does not evoke the same emphatic response as the same command with an exclamation
mark.
• A dash or colon has more emphatic force than a comma.
–– The employees were surprised by the decision, which was not to change company policy.
–– The employees were surprised by the decision - no change in company policy.
–– The employees were surprised by the decision: no change in company policy.

Choice and Arrangement of Words

The simplest way to emphasise something is to tell readers directly that what follows is important by using such words
and phrases as: especially, particularly, crucially, most importantly, and above all.

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Sentence Arrangement
• An abrupt, short sentence following a long sentence or a sequence of long sentences is often emphatic.
• Varying a sentence by using a question after a series of statements is another way of achieving emphasis.

Persuasiveness
The goal of the report is to convince the reader to accept the writer’s point of view. To accomplish this, the report
needs to be persuasive. Building a reasoned argument is more complex because more is involved. Five features of a
good argument are as follows:
• Evidence consisting of facts, opinions (ordinary and expert), and material things is absolutely essential when
building an argument. Statements of evidence should be:
–– Reliable: reliability means that the writer has the facts right so that, while different individuals may draw
different conclusions from the facts, there can be no disagreement over the facts of the situation.
–– Precise: a common error is lack of precision in statements, which emasculates the persuasiveness of an
argument. Specificity shows that the writer appreciates the situation in all its subtleties.
–– Realistic: shocking statements are avoided because they only provoke the reader’s distrust and suspicion.
• Arguments are built using as much observable evidence as possible.
• Assumptions about probable relationships, quantities or results are made and stated when needed to carry the
reasoning further. Stating assumptions means the reader has critical information created by the writer when
developing the argument.
• Arguments are built by tying pieces of evidence and assumptions together and drawing inferences from them.
• Shortcomings, weaknesses and limitations are admitted when the arguments are presented. Dealing with both the
positive and the negative suggests objectivity and treats the reader as a mature, informed individual. Doing so also
makes the reader feel that the writer has performed a thorough analysis.

Auditing
Scope and Purpose of Auditing Environmental Management Systems
Auditing is a long-established tool originating in financial management,
and subsequently adapted for monitoring quality, environmental and DEFINITION
safety performance. It provides a systematic, documented, periodic and
objective evaluation of how well the organisation’s management systems are ENVIRONMENTAL
performing by a critical examination of each area of activity. AUDIT

ISO 19011:2011 provides guidance on the management of audit programmes, "Systematic, independent
the conduct of internal or external audits of quality and/or environmental and documented process for
management systems, as well as on the competence and evaluation of obtaining audit evidence and
auditors. It provides a useful source of information on auditing and should be evaluating it objectively to
consulted for further information regarding this topic. determine the extent to which
the audit criteria are fulfilled."
Although this International Standard is applicable to the auditing of quality (ISO 19011:2011)
and/or environmental management systems, the user can consider adapting
or extending the guidance provided within the standard to apply to other types of audits, including safety management
system audits.

The purpose of an environmental audit defines what is to be accomplished by the audit and may include:
• Determination of the extent of conformity of the auditee’s management system, or parts of it, with audit criteria.
• Evaluation of the capability of the management system to ensure compliance with statutory, regulatory and
contractual requirements.

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• Evaluation of the effectiveness of the management system in meeting its

specified objectives. DEFINITION
• Identification of areas for potential improvement of the management
AUDIT CRITERIA
system.
The audit scope describes the extent and boundaries of the audit, such as: Are used as a reference
against which conformity is
• Physical locations. determined and may include
• Organisational units. applicable policies, procedures,
• Activities and processes. standards, laws and regulations,
management system
• The time period covered by the audit.
requirements, contractual
Difference between Audits and Inspections requirements or industry/
business sector codes of
In relation to environmental management, the term auditing is sometimes conduct.
used loosely for describing various monitoring activities, such as workplace
inspections. This should be avoided.
• Monitoring is principally a line-management role, undertaken
continuously or frequently to ensure compliance with the organisation’s
adopted standards and procedures.
• Auditing is a more fundamental examination undertaken by people
outside the line-management structure, challenging whether the
standards and procedures are appropriate, as well as their application.
Auditing usually requires some sampling and selectivity, and is undertaken
periodically. It includes checks on the monitoring programme. Just as an
annual financial audit is a check on the company’s solvency (that the business
has been managed prudently and cash has not been misappropriated), so Auditing involves sampling
an environmental audit is a check on the management of environmental and selectivity
impacts.

Pre-Audit Preparations, Information Gathering, Notifications and Interviews

TOPIC FOCUS

Pre-Audit Preparations
Prior to the on-site audit activities the auditee’s documentation should be reviewed to determine the conformity
of the system, as documented, with audit criteria.

The documentation may include relevant management system documents and records, and previous audit
reports. The review should take into account the size, nature and complexity of the organisation, and the
objectives and scope of the audit.

In some situations, this review may be deferred until the on-site activities commence, if this is not detrimental
to the effectiveness of the conduct of the audit. In other situations, a preliminary site visit may be conducted
to obtain a suitable overview of available information. If the documentation is found to be inadequate, the audit
team leader should inform the audit client, those assigned responsibility for managing the audit programme,
and the auditee. A decision should be made as to whether the audit should be continued or suspended until
documentation concerns are resolved.

(Continued)

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TOPIC FOCUS
The audit team members or individual auditor should review the information relevant to their audit assignments
and prepare work documents as necessary for reference and for recording audit proceedings.

Such work documents may include:

• Checklists and audit sampling plans.
• Forms for recording information, such as supporting evidence, audit findings and records of meetings.
The use of checklists and forms should not restrict the extent of audit activities, which can change as a result of
information collected during the audit.

Information Gathering
When on the site, an opening meeting should be held with the auditee’s management or, where appropriate,
those responsible for the functions or processes to be audited.

The purpose of an opening meeting is to:

• Confirm the audit plan.
• Provide a short summary of how the audit activities will be undertaken.
• Confirm communication channels.
• Provide an opportunity for the auditee to ask questions.
During the audit, information relevant to the audit objectives, scope and criteria, including information relating
to interfaces between functions, activities and processes, should be collected by appropriate sampling and
should be verified. Such sources of information may include:
• Interviews with employees and other persons.
• Observations of activities and the surrounding work environment and conditions.
• Documents, such as policy, objectives, plans, procedures, standards, instructions, licences and permits,
specifications, drawings, contracts and orders.
• Records, such as inspection records, minutes of meetings, audit reports, records of monitoring programmes
and the results of measurements.
• Data summaries, analyses and performance indicators.
• Information on the auditee’s sampling programmes and on procedures for the control of sampling and
measurement processes.
• Reports from other sources, e.g. customer feedback, other relevant information from external parties and
supplier ratings.
• Computerised databases and websites.
Only information that is verifiable may be audit evidence. Audit evidence should be recorded. The audit evidence
is based on samples of the available information ,therefore there is an element of uncertainty in auditing, and
those acting on the audit conclusions should be aware of this uncertainty.

The auditor or audit team should determine prior to the closing meeting the conclusions of the audit.

(Continued)

5-24 Unit ED1 - Element 5: Environmental Performance Evaluation © RRC International