Sanchez Hacking (2002) - An Approach To Linking Environmental Impact Assessment and Environmental Management Systems
Sanchez Hacking (2002) - An Approach To Linking Environmental Impact Assessment and Environmental Management Systems
To cite this article: Luis Enrique Sánchez & Theo Hacking (2002) An approach to linking
environmental impact assessment and environmental management systems, Impact Assessment
and Project Appraisal, 20:1, 25-38, DOI: 10.3152/147154602781766843
Integrative management
T
The failure adequately to implement mitigation ODAY ENVIRONMENTAL PLANNERS
measures or monitor environmental impacts fol- and managers have access to a plethora of
lowing the approval of projects, is often cited as a tools conceived to respond to particular prob-
major shortcoming of the environmental impact lems and situations. Minimising impacts over the
assessment (EIA) process. The contents and rec- life cycle of a product, improving the eco-efficiency
ommendations of environmental impact statements of an industrial process and involving stakeholders
in the decision-making process are a few of the is-
(EISs) are often disregarded when environmental sues that these tools aim to address.
management systems (EMSs) are implemented. Many of the environmental management tools
This paper focuses on a possible means of linking now in use evolved from environmental impact as-
the EIA process to EMS implementation, by build- sessment (EIA) ideas and concepts but, in order to
ing a conceptual framework capable of serving the respond to specific needs, developed their own ap-
needs of both. A key feature entails relating the proaches, methods and terminology. Following the
project actions or activities to environmental im- world-wide dissemination of the ISO 14000 series of
pacts via interaction processes, defined as ‘envi- standards, environmental management systems
ronmental aspects’ by ISO 14001 sta ndard. The (EMSs) emerged as a cost-effective tool to, among
feasibility of constructing double-field matrices other things, help improve eco-efficiency and boost
that are able to summarise all the relevant linkages a company’s public image.
is demonstrated. Application to a hypothetical mine
illustrates the approach. Comparison between EIA and EMS
Impact Assessment and Project Appraisal March 2002 1461-5517/02/0010025-14 US$08.00 IAIA 2002 25
Linking EIA and environmental management systems
implement the necessary environmental manage- “What needs to be managed?” and “How should it
ment and to optimise day-to-day operations, thus be managed?”.
further reducing harmful consequences and maxi- A number of significant common tasks and some
mising benefits. fundamental differences are:
Despite the global dissemination of both EIA and
EMS as widespread environmental planning and • Impact identification is the initial step common to
management tools, their interrelationships remain both tools. However, an important difference is
poorly understood by many practitioners, proponents that in the EIS preparation potential impacts are
and regulatory officials (Ridgway, 1999). Hence, identified, while in an EMS both actual and po-
these two key tools often exist as ‘islands’ without tential impacts must be considered.
clearly defined bridges between them. • Both processes require the ranking of these im-
Table 1 compares the elements or components pacts according to their relative importance, but,
that comprise a typical EIA process and an EMS in EIA, ranking criteria will be submitted for pub-
based on the ISO 14001 standard (ISO, 1996). lic scrutiny. Although public input is also recom-
For the purposes of comparison, the EIA process mended in EMS, the decision whether or not to
has been simplified by ignoring, for example, the solicit and how to incorporate these views rests
iterative nature of a number of the components exclusively internally.
and their integration with the project planning life
cycle. A question that is emphasised in an EIA process, but
The table indicates that there is considerable which does not feature strongly in an EMS is: “What
common ground between the planning stage of the will be the environmental consequences of the pro-
EMS and a typical EIA process. This is not acciden- ject?” The EIS is the vehicle for seeking approva l
tal, since both aim to answer the same questions — for the project; hence the environmental conse-
quences of the project need to be considered in de-
tail. When an EMS is implemented at an operational
Table 1. Comparison between EIA and EMS
facility, the environmental consequences of the ac-
tivities are usually only considered in sufficient de-
Typical EIA process ISO 14001 EMS tail for management to be prioritised. The reason for
this is that, unlike in an EIS where the consequences
Project planning have to be justified to external parties, an EMS ‘au-
Screening and scoping 4.2 Environmental policy dience’ is primarily internal. The company’s own
4.3 Planning management can usually be persuaded by less rigor-
Describe project activities
ous arguments than would be required to convince
Obtain public comments external parties.
Describe the baseline 4.3.1 Identify environmental aspects Management measures and action plans are part
environment (and impacts)
Identify, predict and
of both processes, but these are much more detailed
assess impacts in EMS planning. Mitigation and other measures
Identify legal and other 4.3.2 Legal and other requirements arising from EIA are sometimes stated in vague and
requirements imprecise terms; hence they need to be ‘translated’
Develop management 4.3.3 Environmental objectives and and interpreted to become practical instructions for
plans (mitigation, targets implementation. This makes auditing the implemen-
enhancement and 4.3.4 Environmental management tation of management plans a difficult task. On the
compensation programme(s)
measures) other hand, EMS standards tend to promote the de-
Implementation and 4.4 Implementation and
sign of more detailed action plans capable of meet-
management phase operation ing clearly defined objectives and goals. Plans
4.4.1 Structure and responsibility
developed via the EMS approach are, therefore, usu-
4.4.2 Training, awareness and ally more auditable than those developed using tradi-
The adjacent EMS items
competence tional EIA methods.
4.4.3 Communication
may be conceptually
4.4.4 EMS documentation
Basically the implementation and operation,
covered in the EIA checking and corrective action, and management
management plans 4.4.5 Document control
4.4.6 Operational control review EMS elements focus on the institutional
4.4.7 Emergence preparedness and
respons e capacity (administration, resources and so on) re-
4.5 Checking and corrective
quired to implement environmental management, to
action confirm its effectiveness, and to ensure that im-
4.5.1 Monitoring and measurement
provements are made where this is possible or nec-
The adjacent EMS items 4.5.2 Non-conformance and essary. These items are usually only considered
may be conceptually corrective and preventive conceptually in an EIA process and some (for in-
covered in the EIA action stance, document control) are often not considered at
management plans 4.5.3 Records
4.5.4 EMS audit all, since they are regarded as dealing with issues
4.6 Management review that are only relevant once the project has been
implemented.
Linkage between EIA and EMS participated in the public consultation aimed at
identifying the consequences of the undertaking,
Project proponents, regulators and interested parties hence they would not be aware of the public per-
would benefit in many ways from greater EIA–EMS ceptions or of the reasons that led to the adoption
integration. This applies particularly to the process of a particular management measure.
of converting the management measures proposed in • Public debate during the approval process tends to
an EIS into enforceable commitments, which is concentrate on whether or not to grant permission
common practice in many jurisdictions where the for the project. Discussions are seldom directed
government authority incorporates terms and condi- towards the technical details of managing the
tions in their permits or licences. Such terms and project.
conditions are often derived from the pr oponents’ • The EIA process is often viewed by project
commitments described in the EIS, modified or proponents as a bureaucratic step to obtain a gov-
adapted to reflect public concerns so as to become ernment permit, rather than a useful planning
enforceable or legally binding requisites. Hence they process that will assist in the actual operation of
need to be considered under ‘legal and other re- the project.
quirements’ when implementing an EMS. The
EMS’s ‘environmental management programmes’
will then translate them into verifiable actions. Why EIA–EMS integration is beneficial
Another potential benefit of EIA–EMS integration
is that the effort to describe the affected environment A generally recognised shortcoming of the EIA
and to identify impacts during the EIA process process is poor implementation of mitigation meas-
would not be duplicated once the organisation de- ures and management plans. The reasons for this
cides to implement an EMS. include:
Of course, EIA and EMS do not aim to achieve
the same goal and this is why both are needed. Later • EISs often do not clearly provide a basis for the
in the paper it will be suggested that, for new pro- design of management plans.
jects, the initial EIA process should be designed to • The recommendations presented in EISs are
be compatible with the EMS planning requirements. generally stated in terms that are too broad and
In this way the EIA could provide a clear starting generic. In order to be implemented these recom-
point for the EMS. mendations need to be ‘translated’ into a set of
clear procedures and/or instructions.
• In certain jurisdictions, the management measures
Obstacles to linking EIA and EMS proposed in EISs are modified by the permitting
authorities to accommodate the officials’ desire
In practice there is often poor linkage between the for ‘standardised’ management. In the process, the
EIS produced to gain approval for a project and the relevance of the management may be lost, since it
EMS that is implemented once the project is opera- is not clearly based on the outcomes of the EIA
tional. Reasons for this include: process. Operational staff are inclined to resist
management that appears to be merely a bureau-
• Insufficient interaction between the EIS consult- cratic requirement rather than justified on the
ant and the proponent project team. basis of thorough investigation.
• Operational staff are often a completely new team
that do not fully “buy into” the work undertaken Enhancing EIA usefulness to environmental man-
by the project team. In addition, the operational agement requires two sets of changes:
management team often would not have
• A change in attitude towards the EIA process.
Proponents need to recognise the potential con-
tribution that EIA can make to the ongoing
management of the project.
One benefit of integrating • The available ‘toolkit’ must be integrated. EIA
environmental impact assessment and and EMS are powerful tools. If integrated and ap-
plied by a competent team they could together
the environmental management system deliver enhanced and cost-effective solutions for
is that the effort to describe the better environmental outcomes.
affected environment and identify
This paper addresses the second challenge. It as-
impacts in the EIA would not be sumes that, by slightly adapting EIS preparation
duplicated once it is decided to methods or practices, it would be possible to deliver
a value-added product, that is, an EIS that is more
implement an EMS useful for management purposes, while maintaining
its other roles in the EIA process, namely a tool for
Causal mechanism separated out Hazardous waste disposal Contaminated seepage Groundwater pollution
Casual mechanism built into the activity Hazardous waste disposal site releases contaminated Groundwater pollution
description seepage
Casual mechanism built into impact Hazardous waste disposal Contaminated seepage causes groundwater pollution.
description
project planning, providing a basis for negotiating impact’ chain concept is not new and features in, for
with interested and affected parties, and informing example, an early work by Munn (1975). It has also
the decision-making process. been adopted by the ISO 14001 standard, which
largely evolved from an earlier British EMS stan-
dard, BS7750 (BSI, 1992). However, even though
Linkage between activities and impacts common ground exists, this is not always clear,
since different terminology and definitions are used
The core of any environmental planning or man- in the models. The examples in Table 3 illustrate this
agement tool is adequate identification of the key point.
issues. Many EISs do not correctly describe the ex- Of the examples given, only the ISO model
pected impacts and some even mistake an action (the explicitly separates out and defines the causal
cause) for the impact (the consequence). When pla n- mechanism as an ‘environmental aspect’. The term
ning an EMS, correct impact identification is essen- ‘aspect’ is sometimes confusing because it is widely
tial, since the establishment of objectives and targets used in everyday language. The ISO standard de-
and consequent management programmes will de- fines environmental aspect as “an element of an org-
pend on this identification. anisation’s activities, products or services that can
A number of techniques have been devised to help interact with the environment”. The key word here is
practitioners to identify environmental impacts. “interact”, as it suggests that an aspect is the linkage
Most of the techniques rely on a cause–effect model, between an activity, product or service and their en-
that is, project components, actions or activities (dif- vironmental consequences, or impacts.
ferent names are used with similar meanings) are the The manner in which the term ‘environmental ef-
cause of changes in the state of the environment. fect’ is defined and used in BS7750 indicates that
The changes may be harmful or beneficial and are they have basically chosen to merge the causal
often termed ‘impacts’. mechanism with the impact side of the chain. How-
The most successful models aim to identify the ever, the explanations and examples given (emis-
causal mechanisms responsible for ‘linking’ the ac- sions to atmosphere, discharges to water and so on)
tivities to environmental changes. Some models do indicate that their emphasis is on the identification
not explicitly separate out the causal mechanisms, of the causal mechanisms rather than on the detailed
but rather incorporate them into the description of assessment of the resulting environmental changes.
the activities or identification of the environmental (As previously mentioned, this is the appropriate
impacts. This can be illustrated as shown in Table 2. emphasis for an EMS, but would not be for an EIA.)
The ‘activity–causal mechanism–environmental Munn chose to emphasise that environmental
changes result from human-induced actions, which natural scientists, who are often involved in EIS
modify one or more processes (environmental ef- preparation and review.
fects). Such modifications can affect environmental Regardless of the terminology used, the concept
quality, thus causing an environmental impact. He of linking an activity or action (cause) to an envi-
illustrates that human-induced actions can modify ronmental change (a consequence) via the causal
(by intensification or reduction) or even initiate mechanism should be the thrust of correct impact
natural or social processes. Water erosion, for ni - identification and, hence, of successful environ-
stance, is a natural process occurring all over the mental management. Management can only be fo-
Earth’s surface. Therefore, stating that that the cused if what needs to be managed is understood.
construction of a road causes erosion is not strictly Since the purpose of this paper is to find ways of
correct, it is more correct to say that a road intensi- linking EIA and EMS, the terminology adopted by
fies erosion. the ISO series of EMS standards will be favoured in
Munn’s work was clearly an attempt to under- the remainder of the text. This can be illustrated as
stand the mechanisms by which environmental shown in Figure 1.
changes are caused by human actions. Munn tended
to focus on the environmental change side of the
chain, which is not uncommon when the outcome is An approach to linking EIA and EMS
intended to be an EIS, as opposed to an EMS.
Yet another attempt to describe environmental in- In order to prepare an EIS and to implement an EMS
teractions is the concept of ‘processes’ used by natu- a number of common tasks must be fulfilled. By fo-
ral scientists. Erosion is, once again, a convenient cusing on these common features it is possible to
example to illustrate this concept. It is a natural find synergies. This primarily involves ensuring that
process, which can be modified by human action. the EIA methodology sets the stage for the subse-
Mining, road building, forestry, and a number of quent EMS planning stage. This can be achieved
other undertakings change natural erosion patterns: utilising an ‘EMS friendly’ approach during the EIA
sheet erosion can be intensified, gullies can develop process. The pivotal concept is the use of the activ-
and even mass movements (such as landslides) can ity–aspect–environmental impact linkage promoted
occur as consequences of human activity. in the ISO14001 standard.
Many biophysical interactions can be described in The approach is described below and is illustrated
terms of processes. Fornasari et al (1991), in an at- by means of a hypothetical gold mine. The general-
tempt to improve and facilitate EIS preparation and ised EIA sections listed below are considered. For
review, systematically described 20 geological pro- each one, it is shown how a link can be made to the
cesses that can be affected by engineering projects. EMS process, thereby adding value to the EIA.
Ecologists also describe several interactions as
processes, such as succession, eutrophication and • Description of the project activities
pollutant bioaccumulation. • Public consultation
An environmental effect (in Munn’s terms) is a • Description of the baseline environment
modification in a natural process. An environmental • Impact identification, prediction and assessment
aspect (in ISO 14001 terms), for instance, the dis- • Legal and other requirements
charge of contaminated effluent, is the ‘mechanism’ • Management plans
that can modify a natural process; for instance, water
pollution can reduce the productivity of a river Description of the project activities
system.
Natural scientists are familiar with natural pro- To be able to predict the environmental changes that
cesses, while engineers are more familiar with a proposal can cause it is necessary to understand the
industrial processes. Aspects are outcomes of indus- mechanisms by which the project activities can
trial processes. Since people coming from the interact with the environment. In ISO 14001 EMS
business/industrial sector have largely developed the terminology this is referred to as “identifying the
ISO 14000 series of standards, they employ their environmental aspects”. As illustrated by the
terminology and concepts rather than those used by examples given in Table 2, this step is not always
explicit in EIA processes. However, the transition Table 4. Main activities in an hypothetical gold mine
from an EIA to an EMS is greatly facilitated if the
causal mechanisms (environmental aspects) are Green Mountain Gold Mine
clearly identified during the EIA process.
Aspects can be conceptualised by regarding an The operational phase of the Green Mountain Gold Mine
organisation as a ‘black box’. If a project involved a involves the following main activities:
completely self-contained ‘black box’, environ- · Open pit mining
mental impacts could only result from the fact that · Disposal of overburden at dumps
the ‘black box’ will occupy space. Additional im- · Metallurgical processing to extract the gold
pacts would only result if there were inputs to or · Tailings disposal
outputs from the ‘black box’. Therefore, the identif i-
· Support services (workshops, water and energy supply,
cation of aspects associated with project activities waste recovery etc)
involves:
· Materials transport to site
the site. Note: For a full and detailed assessment, these activ ities should
• Identifying the inputs and outputs. be further divided into other component activities. Thus
open pit mining would include, for example, vegetation
removal, topsoil removal and storage, overburden removal,
This can be illustrated as shown in Figure 2. rock drilling, rock blasting, ore hauling, groundwater
An understanding of the activities that take place pumping
within the ‘black box’ is required to identify the as-
pects that are (or could be) associated with them. facilitate the process of screening out the aspects
This can best be illustrated by an example, such as that require further consideration.
that given in Table 4. If public consultation is undertaken, it is conven-
The inputs and outputs are best identified by a ient to ‘unpack’ the comments that are recorded in
process flow diagram (Table 5). Possible inputs or accordance with the ‘activity–aspect–environmental
outputs due to adverse operating conditions or as a impact’ model. By doing so, the comments can be
result of incidents should also be considered. clearly linked to the analysis presented in the EIS.
The success of aspect identification is greatly de- Table 6 furnishes an example of how public con-
pendent on appropriately subdividing the project cerns can be understood in terms of this model.
into its component activities. At one extreme the This can be used during the preparation of the
entire mine could be considered as an activity and, at EMS to help develop operational procedures, the
the other, every process unit could be treated as a environmental management programme and the
separate activity. The most appropriate level of de- community liaison/consultation programme.
tail of subdivision is usually the same as would be
used for overall project planning or for line man- Description of the baseline environment
agement responsibility during the operational phase.
A description of conditions prevailing prior to pro-
Public comments ject implementation is a standard component of EIS
preparation. It is the background against which pro-
Identifying the aspects of concern should form part ject actions will be analysed and impacts will be
of the EIA scoping phase. During the scoping phase identified, predicted and assessed. When considering
certain aspects can be eliminated ‘by inspection’ or impacts, the environment is usually (for clarity and
from preliminary technical investigations. It is also convenience) divided into a number of separate ‘en-
generally accepted good practice to undertake public vironments’. The most appropriate subdivision
consultation as part of the scoping phase although in varies and depends on the environmental setting and
many countries this is not a legal requirement. The
views/concerns/suggestions obtained by consulting
with the interested and affected parties can greatly
Social
Appropriate subdivision of the project
into component activities is important:
the most appropriate level of detail is
Outputs
usually the same as for overall project
Inputs Incidents
planning or for line management
Land
transformation
responsibility during the operational
phase
Figure 2. A representation of a project's interaction with its
environment.
Dust
In-pit/process water Overburden
Noise
(dust suppression) disposal
Runoff from dumps
Electricity Tailings
Chemicals Metallurgical Recovered water Runoff from plant site
In-pit/recovered/ processing Reject chemicals Dust, gases and fumes
return/process water Chemical spills?
Dust
Tailings Surplus water
Return water
Process water Tailings disposal Runoff from dam sides
Tailings spills?
(irrigation) Seepage from dam
Tailings spills?
Electricity
Scrap metal
Chemicals Electricity
Electricity (from grid) Reject chemicals
Equipment and spares
Support services Process water Used oils
Water (from river) Used tires
Chemical spills? General waste
Damaged equipment
Sewage
Reject chemicals
Diesel
Diesel
Explosives
Transport to site Chemicals Chemical spills?
Chemicals
Equipment and spares
Equipment and spares
Table 6. Example of ‘unpacking’ public comments the nature of the organisation’s activities, and on the
standard practice and legal requirements of each
Comments Activity Aspect Environment jurisdiction. ‘Environments’ that lend themselves to
of concern fairly general application are defined in Table 7,
which also contains examples of the criteria that
Mr Brown Open Contaminated Groundwater could be used to ‘measure’ environmental value.
(Farmer): pit seepage
“Seepage from The level of detail provided in the description of
the pit will the various environments in the EIS must be prior i-
contaminate my tised in relation to their sensitivity to the project.
borehole”
Often voluminous descriptions are provided for
Ms Jones Tailings Land Habitats and environments that will be virtually unaffected by a
(Conservationist): dam occupation biodiversity
“The tailings project because the information happens to be easily
disposal site will available, while those that may be significantly af-
occupy a wetland fected are only described superficially.
area”
When developing an EMS, significant aspects are
Bio-physical
Soil and land capability The inherent value (agriculture, conservation etc) of the land Agricultural potential
Ecology/fauna and flora/ Plants and animals and their inter-relationship Biodiversity
plants and animals/sensitive Rarity or endangered status
landscapes Uniqueness
Conservation value
Surface water Rivers, streams, dams, pans etc Usefulness (recreation, industry,
drinking, agriculture or environment)
Value as natural habitat
Groundwater Underground water Usefulness (recreation, industry,
drinking, agriculture or environment)
Ocean Salt water bodies (oceans, seas and estuaries) Usefulness (recreation and environment)
Value as natural habitat
Atmosphere/air Ambient air quality/noise levels/radiation levels Hazard or nuisance levels (to humans or
the bio-physical environment)
Contribution to climate change
Earth’s resources The earth’s finites stock of non-renewable resources Available reserves
Human
Neighbours/communities Individuals or groupings of people Lifestyle
Standard of living
Health and welfare
Cultural/historical sites Archaeological sites, palaeontological sites, graves, national Age and rarity
monuments etc Cultural significance
Aesthetics/visual Appearance of the landscape Sense of place
Compatibility with surroundings
Regional economy Production systems, consumption patterns and public sector Gross domestic product
identified on the basis of the significance of their determine whether a particular aspect is significant.
impacts on the environment. By assessing the im- This process is not well defined in the EMS stan-
pacts during the EIS stage and creating the linkage dards. Therefore, a fair degree of iteration is un-
with the responsible environmental aspects it will be avoidable during the assessment process.
possible to have the justification required to deter- Criteria used to determine the significance of en-
mine the significance of the impacts identified vironmental impacts should be defined and used
during EMS implementation. consistently during EIS preparation. If these are
clearly defined and documented at the EIS prepara-
Impact identification and scoping tion stage, the same criteria could later be employed
in planning an EMS for the project, thus assuring
An appropriate technique to identify environmental that public concerns expressed during the project
impacts in order to integrate EIA and EMS is to ap- approval phase will also be considered for manage-
ply the activity–aspect–environmental impact model. ment purposes.
Once project activities have been described, every The aspect identification and ranking process is
relevant aspect needs to be associated with each largely a scoping exercise. Aspects that do not have
activity and environmental impacts need to be asso- the potential to cause significant impacts are ranked
ciated with each aspect. Table 8 contains a list of ‘low’ and do not warrant further attention. Aspects
the typical categories of environmental aspects and causing impacts ranked in categories such as ‘high’
impacts usually encountered in many industrial pro- and ‘moderate’ are significant and will require op-
jects. The ‘Nature of interaction’ column refers to erational control. The significance of the aspects
Figure 2. should be ranked on the assumption that the
If an environmental aspect is present, it does not management measures that are recommended in the
necessarily mean that significant environmental im- EIA will be in place. This represents the scenario
pacts will result. For example, a project may require that the proponent wishes to have considered for
effluent to be discharged. However, if the effluent is approval. The influence of various project alterna-
of the same quality as the river water and is of such tives on the significance of the aspects must be
a small volume that it will not measurably alter the considered.
flow of the river, then no significant impacts will Although many organisations prepare EMSs dur-
result from this aspect. In some cases it will be ing the operational phase of an undertaking, EMSs
necessary to undertake the impact assessment to could also be used to manage a project during its
Table 8. Typical categories of environmental aspects and impacts associated with projects
construction phase and during decommissioning. the level of detail will be determined by how the
Most EIA regulations require proponents to identify team decides to divide up the project into its compo-
impacts and mitigation measures for each major nent actions. Variations of this matrix may be con-
phase of a project. Thus to fully integrate both tools, ceived. For example, Figure 4 shows the impacts as
the aspects and impacts of each phase should be descriptive statements instead of classifying them
identified and analysed. The impact of various pro- according to environmental ‘compartments’. Addi-
ject alternatives should also be considered. tional matrices can be prepared for the construction,
The aspects and impacts associated with the vari- decommissioning and post-closure scenarios.
ous project activities can be summarised using a
matrix format. The aspects and impacts due to the Impact prediction and assessment
operational phase of the hypothetical Green Moun-
tain Gold Mine are shown in Figure 3 in the form of Impact prediction is key to EIA. After potential
a double -field matrix. The matrix should be read as impacts have been identified, appropriate indica-
follows: tors should be selected. Predictions about the future
behaviour of the indicators can then inform decision-
• The left-hand side shows the environmental as- makers as well as interested and affected parties
pects that are associated with each of the project about the future state of the environment, if the
actions (activities, products or services). Each proposal were approved.
action may cause one or more aspects. Impact prediction is usually not the main focus of
• The right-hand side shows the environmental an EMS because, in most cases, it is possible to de-
impacts anticipated to arise from each environ- termine (through an appropriate monitoring system)
mental aspect. the actual impacts of the activities, products or
services. Impacts that could result from accidents of
The double -field matrix thus provides a means of abnormal operating conditions will, of course,
linking a particular project action to its impacts (via always need to be predicted, since they will not fea-
the interactions mechanisms or aspects). Notice that ture in the normal monitoring record.
Figure 3. Operational phase of Green Mountain Gold Mine classifying impacts by environmental compartments
Figure 4. Operational phase of Green Mountain Gold Mine classifying impacts as descriptive statements
Typical Influence the location, appearance, Governs the quantity and/or quality of Restricts damage to the environment
requirements characteristics etc of the infrastructure inputs and outputs; nature and extent
and equipment of land use and the and/or
characteristics of social aspects
Hypothetical
examples
Administrative Open pit: Written approval must be Releases to air: Dust fall out Ecology: Written approval is required
requirements obtained before mining commences monitoring results must be submitted from the Forestry Department before
every three months trees greater than 200mm in diameter
are removed
Performance Tailings dam: Side slopes may not Releases to water: Effluent quality Air quality: particulate matter
requirements exceed 35° must comply with the standards concentration may not exceed daily
contained in Schedule X peaks of 240ug/m3; annual average
may not exceed 80ug/m3
Surface water: Effluent may not be
discharged into a Category I river
The lack of a baseline against which to compare the severity, spatial extent, duration of the impact
actual (and predicted) impacts is extremely common and its probability of occurrence.
because of inadequate EIA prior to the implementa-
tion of the project. If an EIA is properly undertaken, Legal and other requirements
the baseline should be well established when com-
mencing with the implementation of the EMS. This Legal reviews undertaken as part of EIA processes
is another example of the advantage to be gained may fulfil different functions, such as providing one
from integrating EIA and EMS. set of criteria for judging the significance of impacts
Impact assessment is a requirement for both EIA and providing an input for the scoping phase. When
and EMS. Where signific ant environmental aspects reviews are undertaken as part of EMS implementa-
are present (‘high’ or ‘moderate’), significant tion one of the main purposes is to identify the
environmental impacts may result. The significance minimum performance requirements.
of the impacts associated with the significant aspects It is sometimes difficult to link legal requirements
can be determined by considering the risk: directly to management actions, but this difficulty
can be addressed by clearly structuring the review
Significance of environmental impact (risk) results in accordance with the activity–aspect–
= probability × consequence environmental impact model. The examples given in
Table 9 illustrate this approach. Some legal require-
ISO 14004 standard (the companion to ISO 14001, ments may regulate or restrict activities (for
providing guidelines for EMS implementation) instance, pr ohibition of underground storage tanks),
draws on EIA experience to recommend criteria for others may set performance standards for environ-
ranking impacts according to their significance. It mental aspects and yet others may limit the nature or
suggests that impacts can be analysed by considering magnitude of environmental impacts.
‘Capacity’ management
Impacts
Activities Aspects
‘Preventative’ To control the organis ation’s Re-circulate process water so as to reduce water consumption and effluent
or activities, products or discharge and, hence, minimise impacts on surface water
‘proactive’ services so as to influence
Implement a community liaison programme so as to improve communication
management the potential of the aspects and, hence, improve relations with neighbouring communities
to cause impacts
Develop, implement and rehearse emergency plans that equip employees to
responds to incidents
‘Curative’ To mitigate or remediate Rehabilitate the land disturbed by the organisation’s activities in order to restore
or impacts, which are the land capability of the area
‘reactive’ unavoidable, unforeseen or Pay compensation to landowners for crop damage caused by chemical spills
management accidental
‘Capacity’ To set in place the Allocate accountabilities and responsibilities
management resources, skills etc required
Provide adequate financial and other resources
for effective ‘preventative’
and ‘curative’ management. Implement training and awareness-raising programmes
Maintain health, safety and environment records
impacts (‘curing’) rather than Water consumption: Water collected in the in-pit sump will be
used for haul road dust suppression
endeavouring to design and manage b) Tailings dam
the project activities so that they do Water consumption/releases to water: Construct paddocks
around the tailings dam to trap silt eroding from the sides
not result in impacts in the first place
c) Metallurgical plant
(‘preventing’) Water consumption/releases to water: The tailings thickener over-
flow water will be recirculated to the ore washing facility
with the project activities. However, this layout is practical difficulties in integrating the two tools, it is
not ‘user friendly’ for the operational staff, since proposed in this paper that EIS preparation should
their day-to day responsibilities will be managing be structured around the activity–aspect–impact
the activities. It is for this reason that the manage- model. Information regarding impact identification
ment contained in an EMS is usually presented and classification can be organised and presented
activity-by-activity. Once again the transition to the using double -field matrix diagrams to highlight the
EMS format can be facilitated by explicitly adopting linkages between activities and their associated as-
the activity–aspect–environmental impact model at pects and to link these aspects to the environments
the EIA stage. Following the model, the same exam- on which they impact.
ple is reworded and shown in Table 12.
References
Conclusion
BSI, British Standards Institution (1992), BS 7750: Specification
EIA and EMSs are two of the tools used to plan and for Environmental Management Systems (BSI, London).
Fornasari, N et al (1991), Physical Environment Changes Result-
manage human activities so as to reduce their nega- ing from Engineering Works (Boletim 61, Instituto de Pes-
tive environmental and social impacts. Many practi- quisas Tecnológicas, São Paulo, in Portuguese).
tioners are specialised in one tool and often ISO, International Organization for Standardization (1996),
14001:1996: Environmental Management Systems – Specifi-
misunderstand or simply neglect the other. As a re- cation with guidance for use (ISO, Geneva).
sult, EMS does not build on existing EIA docu- Munn, R E (1975), Environmental Impact As sessment. Princ iples
ments; conversely, EIA is not designed to provide and Procedures (John Wiley and Sons, Toronto).
Ridgway, B (1999), “The project cycle and the role of EIA and
useful input for the EMS. EMS”, Journal of Environmental Assessment Policy and Man-
As a contribution to overcoming some of the agement, 1(4), pages 393–405.