Preparatory Environmental Review

Preparatory Environmental Review (PER) or GAP Analysis

A preparatory environmental review is an investigative exercise,a structured piece of detective work, which identifies all of the organization’s environmental aspects. Preparatory environment review is not mandatory and cannot be audited during the assessment and yet, if it is not performed, the whole environmental management system may not be soundly based. It is suggested that an organization with no pre-existing environmental management system should establish its current position, with regard to the environment, by a review An organization may have a clear vision of where it would like to be in terms of future environmental performance. Unless  ‘snapshot’ of current performance is undertaken,  the organization may act in an unfocused manner and not achieve this goal. So unless an organization knows where it is now with regard to its interaction with the environment, it may not be able to move in the correct direction in controlling and minimizing its environmental impacts. It is only after performing a preparatory environmental review that a meaningful environmental policy, with proper and relevant objectives and targets, can be set out. The preparatory environmental review may not be an auditable item on the external auditor’s checklist but, by examining the review, the auditor will get a measure of the environmental competence of the organization and an indication of the level of understanding of environmental issues by the organization. In short, a level of confidence will be gained which can only assist in the smooth conduct of the assessment process. If an organization decides to undertake this preparatory review, there are two options open:

1. Perform the preparatory environmental review using internally available resources.
2. Perform the preparatory environmental review using external consultants.

These options are considered below.

Internally available resources

Performing the preparatory environmental review using internally available resources has its merits in that the organization can use personnel experienced in the operations of its processes and, of some importance costs can be somewhat better controlled. Several options exist for this approach. One option is to send out questionnaires to each department head, requiring those individuals in charge to complete a series of questions, including, for example:

• What materials are used
• What quantities of materials are used
• How much energy is used
• The amount and type of waste streams
• Possible emergency situations
• Abnormal situations (frequency of start-ups and shut-downs, maintenance, breakdowns and incidents)
• Any history of ‘out of the ordinary’ incidents
• Any areas of training required

This will form a meaningful exercise by establishing the baseline to work from after analysis by management. Possible flaws in this approach are that staff employed to perform this task may not have the necessary expertise to carry out a meaningful review. In fact, Careful review of the answers in these completed questionnaires will indicate the level of training required in the person completing them. Management tools such as ‘brainstorming’, although they are of value, will not give the same answers as hard data collection and some investigative detective work. On occasions, organizations have made the mistake of basing their preparatory review on environmental projects that are currently up and running. The rationale is that if such projects are current, then they must be important, must focus on the significant environmental impacts of the organization and, therefore, must be a sound basis to start from.

Unfortunately, although such projects may have been started with the best of intentions, they may be based upon previous initiatives (for example, a project that was topical at the time, or a project that looked easy to fulfil). The project may have been used to give credence to an individual or the organization during a marketing initiative at that time. Or again, it may have been a project which tied in with everyone’s work schedules and was easy to manage, and with which everyone was comfortable because of the feeling that ‘they were doing something for the environment’. Such projects may well have been reducing environmental impacts and this is no reason to abandon them. Unfortunately, because of the haphazard nature and methodology of such projects, they will, in all likelihood, not be focusing on significant impacts – fundamental to ISO 14001 philosophy. It is essential if following this option that at least one senior manager in the organization has environmental expertise. If the expertise is not available within the organization, suitable existing staff might be trained by external consultants.

External environmental consultants

Quite often the individual chosen to lead the environmental management team and implement ISO 14001 is the quality assurance manager. The reasons for this choice are not always valid. Those quality assurance managers who have taken on this task invariably perform well, but usually after a painful and steep learning curve. Just because the two Standards, ISO 14001 and ISO 9001 are now very much aligned, ISO 9001 implementing experience may not bridge the shortfall in the required environmental knowledge required by the individual tasked with implementing ISO 14001. There are of course commonalities between quality systems and environmental systems and a quality manager will certainly be comfortable in the areas of operating to documented management systems: the concept of objectives and targets and continuous improvement; the requirement for self-policing (auditing); the value of reviews; and a corrective and preventive action system to allow improvements to occur. But this does not necessarily equip the manager in question with the knowledge and skills in environmental issues required for ISO 14001. That said, the requirement for in-depth environmental knowledge from within the organization need not be onerous, and much of course depends upon the complexity of the organization’s environmental aspects.  However, to commence from a standing start into the complex world of environmental issues and perform a meaningful preparatory review is something not to be undertaken lightly. In such cases, the organization is well advised to use the services of a consultant and ask them to perform a preparatory review prior to ISO 14001 implementation. A well-executed preparatory environmental review will generate a ‘specification’ for the organization in the form of a report setting out very clearly what steps are required. This will form the foundation for deriving a meaningful environmental policy and developing a robust EMS, capable of demonstrating environmental performance improvement. A typical format of a preparatory review is outlined below.

Steps to take – a checklist approach for a PER

The approach taken in PER should consider four key areas:

1. Legislative and regulatory requirements
2. Identification of significant environmental aspects
3. Examination of existing environmental practices and procedures
4. Assessment of previous incidents

Legislative and regulatory compliance

A fundamental requirement of ISO 14001 is that the organization complies with environmental law as a minimum standard. The review should identify which areas of the organization are covered by which laws. Any areas where there are breaches of legislation should be set as priority action areas.

Typical questions to ask are:
a) Is all existing legislation and other requirements being adhered to? Invariably there will be legislation relating to pollution or contamination of the three mediums air, land and water. Thus:

• Air emissions: If there is an authorized process, are the requirements for measuring, monitoring and recording being complied with?
• Solid waste to land: Is a waste management licence required for the site? If solid waste is taken away to the landfill, do the operators of the landfill site have a licence? Does it cover the particular waste that is being removed? Does the carrier of the waste need a licence?
• Water: Is there any groundwater extracted on-site? Is a licence required for this? Is any effluent discharged to streams, rivers, local authority sewage systems?  Is a licence to discharge required? If so, are the conditions being met?
• Other requirements: For example, does the site have any obligations to comply with any town and country planning consents or building regulations?

b) Is there any forthcoming legislation which may affect the business? For example, there may be legislation in the draft stage that, if enacted, could put the organization under heavy financial strain to comply. Therefore some investigative work is required.

c) Have there been previous incidents of breaches of legislation? Has the organization been prosecuted for any breach of environmental legislation? This may point to areas of weakness in the management system.

Evaluation of significant environmental aspects

An examination of an organization’s environmental aspects is a key requirement of an EMS because unless all are identified, a potentially significant impact may be overlooked. Thus the use of a checklist plus identification of the inputs and outputs of processes will be invaluable. Using an input-output type of diagram can assist in quantifying amounts of raw materials being used, energy consumption, levels of waste, etc. The input-output diagram could be performed for each office, each department or each process as appropriate.

Examination of existing environmental practices and procedures

There are many aspects to environmental management within an organization, especially management commitment. Such commitment is demonstrated in the environmental policy and documented procedures which are necessary to ensure such policies are known, understood and followed throughout the organization. The checklist illustrates the scope of the documented management system that needs to be in place, with some typical records that need to be retained to demonstrate a minimum level of an EMS.

Assessment of previous incidents

The preparatory environmental review should also include an assessment of previous incidents – under both abnormal and emergency situations.

• Abnormal conditions generally include unexpected events and startup and shut-down of continuous processes.
• Emergency conditions include fires, floods, chemical spillage and fugitive emissions of gases.

Therefore, typical questions to ask are:

1. Has a formalized risk assessment been carried out?
2. Are there emergency plans in place – especially concerning a major spillage or fire?
3. Are staff trained in operating such plans?

The outcome of the inputs and outputs exercise and the review checklist can be in the form of a report to the senior management of the organization.

The preparatory environmental review report

Preparatory Environmental Review Report Executive Summary P=priority C=possibility of environmental complaints G=best or good practice
Emissions: P- Comply with the requirements of the coating process permit. P- Maintain documented monitoring requirements of visual and of factory survey as required by the permit to operate. P- Compile register of legislative and regulatory requirements. C- Continue to research and review the potential use of alternative coating processes to reduce VOC emissions by using water-based paints and inks. C- Develop codes of practice for sub-contractors arriving on site for the proposed extension to the factory to reduce fugitive dust emissions. G- Monitor and control external noise emissions and intrusive lighting as appropriate, to reduce disturbance to adjacent sensitive amenity areas.
Discharges: P- Ensure continual compliance with trade effluent consents to discharge. C- Determine the precise route and discharge outfall of the surface water drainage system in order to establish if there is a pathway for solvent spillages from the main chemical stores. C- Ensure that all site drains are mapped and covers to the surface water and foul sewer are painted different colours to aid identification. G- Carry out regular inspection and maintenance of surface water interceptors and draw up an operational control to manage this.
Waste management: P- Monitor and ensure regulatory compliance with regard to maximum allowable storage requirements of dry wastes. P- Ensure all waste disposal facilities are appropriately licensed. G- Clearly label all waste collection areas to assist in the segregation of waste.
Storage facilities: P- Establish whether bunds at the tank farm have 110% capacity. G- Provide adequate labelling of hazardous raw material stores. G- Investigate the feasibility of storing chemical drums undercover to prevent water ingress and reduction of risk of damage by vandals. G- Perform regular inspections and maintenance of bulk storage tanks. G- Perform an energy audit and draw up measures for heat conservation in warehouses. G- Limit the variety of packaging used to facilitate easier segregation of waste.
Suppliers: P- Increase the environmental awareness of key suppliers through questionnaires and assistance with ISO 14001 implementation where appropriate.
Customers: G- Provide customers with environmental performance criteria of finished products; increase their understanding of their duty to inform end-users of the safe and appropriate disposal at end of life of products.