EST 325/301: ENVIRONMENTAL IMPACT ASSESSMENT

PART C
This part of the course is aimed at introducing students to environmental
management systems, environmental management plans, environmental
monitoring and auditing and the variables associated with them. The role of the
environmental auditing is important to monitor projects that have been
developed and to seek ways of maintaining such systems through compliance
with legislative requirements and national or international standards. Finally,
the course provides a brief presentation on some EIA case studies.

Environmental Management Systems (EMS)

EMS is a tool for managing the impacts of an organization’s activities on the

environment. It provides a structured approach of planning and implementing
environment protection measures.

EMS is set of process that allow organization to reduce environmental impacts,

increase operation efficiency and achieve real cost saving while protecting the
environment.

An Environmental Management System is a framework that helps an

organization achieve its environmental goals through consistent review,
evaluation, and improvement of its environmental performance. The
assumption is that this consistent review and evaluation will identify
opportunities for improving and implementing the environmental performance
of the organization. The EMS itself does not dictate a level of environmental
performance that must be achieved. Each organization's EMS is tailored to its
own individual objectives and targets.

EMS integrates environmental management into an organization’s daily

operations.

EMS is, therefore, a tool to control, improve, manage and monitor the
environmental impacts and risks associated with a project or an activity.
Figure 1: Various processes involved in EMS
Figure 2: The EMS continuous improvement cycle
 The EMS: The Continuous Improvement Cycle

Policy: Top management commits to environmental improvement and

establishes the organization's environmental policy. The policy is the
foundation of the EMS.

Planning: An organization first identifies environmental aspects of its

operations. Environmental aspects are those items, such as air pollutants or
hazardous waste that can have negative impacts on people and/or the
environment. An organization then determines which aspects are significant by
choosing criteria considered most important by the organization

Implementation: An organization follows through with the action plan using

the necessary resources (human, financial, etc.). Other steps in the
implementation stage include documentation, following operating procedures,
and setting up internal and external communication lines.

Evaluation -A company monitors its operations to evaluate whether objectives

and targets are being met. If not, the company takes corrective action.

Review -Top management reviews the results of the evaluation to see if the
EMS is working. The plan is then revised to optimize the effectiveness of the
EMS. The review stage creates a loop of continuous improvement for a
company.

TYPES OF EMS
Several EMS have been put in place. The most popular ones are those
developed by the International Organization of Standardization (ISO).
ISO is a Worldwide Federation of National Standards Bodies (NSB) that develop
international standards required by the market for facilitation of trade, spread of
knowledge, sharing of technology and management practices.
Founded in 1946 by delegates from 25 countries, it offers a portfolio of 16,500
standards that cover product specification, services, tests methods, conformity
assessment as well as management and organizational practices.
Standards are developed based on set of rules that are determined by a standard
setting organisation (ISO). ISO issues certificates based on compliance to
established guidelines. Certification means that a qualified body (an “accredited
certifier”) has inspected the EMS system that has been put in place and has made
a formal declaration that the system is consistent with the requirements of the
ISO in operation.
The most popular standards are ISO 9000 and ISO 14000 series which are similar
in their processes but target different elements in a company or organization.

ISO 14001

ISO 14000 refers to a family of standards for the design, implementation, and
optimization of an environmental management system (EMS) for businesses
and organizations.

ISO 14000 is focused on the guidelines for setting up a successful

environmental management system based on a clear environmental policy and
a system of continuous improvement.

The ISO 14000 family was first developed due to a rising need for standard
operating procedures and policies for businesses to use to build their own EMS.

ISO 14000: A commitment to performance only

It is voluntary.

It does not require that companies adopt this standard.

Compliance with ISO 14001 does not by itself automatically ensure that an
enterprise will actually achieve improved environmental performance.

The standard requires that there be an environmental policy that “includes a

commitment to continual improvement and pollution prevention” and “a
commitment to comply with relevant environmental legislation and
regulations”.

The desirable approach would be for management to make a commitment to

specific environment performance improvements within a defined period and
then use ISO 14000 as the mechanism for demonstrating that it is complying
with that commitments.

A concern often expressed about the ISO 14001 system is the lack of a clear
commitment to improvements in actual environmental performance. The
whole EMS approach is designed to improve performance, but critics of the
rush to implement ISO 14001 argue that the standard can be misused.
Most Notable Standards in ISO 14000

ISO 14004 –General guidelines on principles, systems and support techniques

ISO 14006 –Guidelines for incorporating eco-design

ISO 14015 –Environmental assessment of sites and organizations (EASO)

ISO 14020 –Environmental labels and declarations

ISO 14031 –Environmental performance evaluation

ISO 14040 –Life cycle assessment

ISO 14050 –Vocabulary

ISO 14063 –Environmental communication

ISO 14064 –Greenhouse gases

ISO 19011 –Guidelines for auditing management systems

Limitations of ISO 14001

There are several reasons for companies not apply for ISO 14001 Certification.

➢ Limited direct economic incentive for participating companies (eg,

EMS Certification is not required when companies apply for contracts)

➢ A general lack of public recognition for participation in voluntary

approaches.

➢ Lack of consistency between ISO 14001 requirements and other

industry and government programmes.

➢ Standards are sometimes weak, not properly enforced, lack of

credibility and transparency.

➢ Critics note that ISO 14001 is often used as a label for image building
and does not necessarily result in superior performance.

➢ Costs of implementation and certification are not trivial.

➢ ISO 14001 is not a performance-based standard, it focuses on processes

that help firms to achieve their environmental objectives.
ISO 9000

ISO 9000 is a group of standards for the development and continuous

improvement of a quality management system (QMS).
OVERALL IMPORTANCE OF ENVIRONMRNTAL MANAGEMENT
SYSTEMS (EMS)
The importance of an effective EMS are, but not limited to:
1 Protecting the environment.

2 Mitigating the adverse impacts of a “proposed” project on the environment.

3 Improving the environmental performance of an organization.

4 Ensuring of the firm’s compliance obligations.

5 Achieving benefits resulting from the implementing environmentally sound

alternatives that strengthen the organization market’s position.

ENVIRONMENTAL MANAGEMENT PLANS (EMP)

EMP provides a delivery mechanism to address adverse impacts, to enhance

project benefits and to introduce standards of good practice to be adopted for
all project activities. It is a plan that covers all stages of the project
development, from initial establishment of logistics facilities, through site
preparation, construction, operation to decommissioning and abandonment.

At each stage of the project, the EMP lists the requirements to ensure effective
mitigation of potential adverse impacts on the natural, social and health
environments identified in the EIA. After EIA regulatory permit is obtained,
the EMP becomes the reference document with which the regulatory
authorities and the general public will assess proponent’s level of compliance
with regulatory provisions. Therefore, an EMP should be clear, concise,
practicable and cost-effective. In addition, it should provide:
 a) Clear program of actions for the maintenance of high environmental
performance throughout project development phases.

b) Include both mitigation and monitoring measures for continuous control of

environmental effects.

c) Serve as an effective tool to enhance the environmental sustainability of the

project by the project managers and subsequent implementation by the project
management team. An EMP is mandatory for all EIA and a core deliverable
from an EIA process.

EMP FORMAT AND PRESENTATION

A comprehensive EMP document should contain the following:

1 Detailed Design Guidelines

The design guidelines should spell out strategies to ensure that detailed design
complies with conceptual design, on which the EIA study was based, as well
as the mitigation measures defined in the EIA.

2 Construction Guidelines

The construction guidelines are prepared for pre-construction and construction

activities. It would detail out the procedures for tree clearing, the use of public
right of way, handling of archeological sites, accident prevention, pollution
control, waste management, prevention of erosion, health and safety of
construction workers, etc. It also contains guidelines on hiring of labor and
safeguards for public health. Additionally, it provides clear instructions on pre-
construction, construction and abandonment of permanent and temporary
structures.

A good example of a construction guideline is: expressly stating that clearing

of sites be undertaken when immediately required and that clearing of
extensive areas in advance of construction works should be avoided. Also, the
maximum permitted elapsed time between site clearing and the initiation of
construction should be stated.

3 Operations and Maintenance Guidelines

This guideline stipulates the manner in which pollution from gaseous

emissions, liquid effluents and noise will be controlled and how non-hazardous
wastes will be collected and disposed off. The appropriate procedure for
ensuring non or minimal environmental impacts should be stated under this
guideline.
4 Site Inspection Procedure

Inspection of site by officers from the regulatory bodies and operation helps to
ensure compliance with regulations. Access to the site by these authorized
officers should be allowed at all times. The procedure and frequency for the
inspection, including the examination of equipment, collection of samples of
pollutants emitted into the environment and the examination of record book
should be properly outlined.

5 Monitoring Programme

Detailed monitoring programme of environmental quality parameters (natural,

social and health aspects) should be spelt out in this section. Such monitoring
is required at every stage of the project. Environmental components to be
specified for monitoring include ecology (plant species, plankton, fisheries and
wildlife), surface water, ground water, air, noise, diseases prevalence, income
and quality of life. The indicator parameters, locations and monitoring
frequency should be specified. The result from the monitoring programme
would be compared with acceptable standards in order to evaluate performance
of mitigation measures.

6 Audit programme

An audit scheme should be drawn up, with stress on areas having highest
environmental risk. Auditing should examine compliance, identify current and
potential environmental problems, check EIA predictions and make
recommendations for improvement. At least, one audit should be carried out
on each major facility in use during construction phase. A good example is the
camp site, processing and storage facilities. During operation, all major areas,
including fuel handling and storage, operation units and maintenance facility
should be subjected to annual audit, as a minimum.

Other components of a typical and detailed EMP include mitigation plan,

training and programme of action, emergency response plan, role of project
owners and contractors and decommissioning plan.

MONITORING AND AUDITING OF IMPACTS

The proper implementation of EMP depends on how the monitoring and
auditing of identified adverse impacts and other cognate activities are
effectively carried out. This is because the life cycle of a project may cover
very long period for construction, operation and decommissioning activities.
This shows that EIA should not just stop at the approval of the EIA report and
EIS or at decision-making, or obtaining permit to execute the project, but
should last throughout the life cycle of the project. Monitoring and auditing
programmes should, therefore, be an important component of EMP
implementation.

Environmental Monitoring

The term environmental monitoring has been defined in several ways. Two of
such definitions are presented below.

This is defined as the activities carried out to provide specific information on

the characteristics and functioning of environmental variables in space and
time.

Environmental monitoring also refers to the tools and techniques designed to

observe an environment, characterize its quality, and establish environmental
parameters for the purpose of accurately quantifying the impact an activity has
on an environment in order to prevent pollution.

Environmental monitoring, therefore, involves the systematic measuring,

collecting and recording of physical, socio-economic and health variables
associated with impacts resulting from an activity over a long period of time.
The information collected should be properly analysed, stored and
communicated with relevant participants in the EIA process.

Key questions that monitoring seek to answers

✓ Are the pre-identified outputs being produced as planned and

efficiently?

✓ What are the issues, risks and challenges that are faced or foreseen that
need to be taken into account to ensure the achievement of results?

✓ What decisions need to be made concerning changes to the already

planned work in subsequent stages?

✓ Will the planned and delivered outputs continue to be relevant for the
achievement of the envisioned outcomes?
✓ Are the envisaged outcomes relevant and effective for achieving the
overall national priorities, goals and impacts?

✓ What are the lessons learned?

Types of Monitoring
Many types of monitoring exist. Among them are:
self-monitoring,
online monitoring
Discontinuous monitoring
effect monitoring
compliance monitoring

Self-monitoring by industry: this is a way of monitoring where the industry

itself is responsible for collecting and submitting information on relevant
emissions and discharges to the authorities.

Online (or continuous) monitoring (by means of sensors) give the authorities
immediate information of breaches of the environmental license(s) granted to
industries.

Discontinuous monitoring can be used in case of emissions which are

classified as “less critical”. For this kind of monitoring, samples can be taken
(according to a sampling protocol), to assess if an industry stays within the
limits of permitted emissions or discharges.

Effect monitoring
This is a continuous observation of environmental effects resulting from the
implementation of a project. It is carried out after the implementation of a
mitigation measure. Effect monitoring helps to test the validity of major
assumptions formulated during EIA study. Activities under effect monitoring
are carried out for years to draw reasonable conclusions with respect to the
implemented project.

Importance of effect monitoring

➢ It helps to understand if the mitigation measures have achieved their
expected results.
➢ Help to improve EIA methodologies and in designing future EIA
studies.
➢ Data from monitoring exercise can be compared with baseline data to
determine the margins of predicted levels of impacts.
 ➢ It provides information that helps minimize uncertainty in the future
prediction of impacts.

Compliance monitoring
This type of monitoring is carried out during site clearing, construction and
operation stages of the project. Compliance monitoring is very essential
because it ensures that all mitigation measures outlined in the EIA for the
purpose of remedying adverse impacts from a project activity are properly
enforced by the owners of the project and also the regulators.

Requirements for effective compliance monitoring

➢ Specifying who is responsible for the monitoring activities.
➢ Defining the proposed mitigation, and also compensatory measures.
➢ Including the implementation of mitigation measures in contract
specification.
➢ Making environmental competence one of the selection criteria for
contractors.
➢ Briefing, educating and training contractors in environmental protection
methods.

Importance of monitoring in general

➢ Monitoring enables environmental problems and risks to be anticipated
and responses planned.
➢ Through feedbacks, it demonstrates that an organization is aware of its
impact upon the environment.
➢ It ensures compliance not only with laws, regulations and standards,
but also with company policies and the requirements of an
environmental management system (EMS) standard if adopted.
➢ Monitoring leads to increased awareness amongst stakeholders.
➢ Constant monitoring could lead to more efficient resource use and
financial savings.
➢ Environment friendly technology (adopted) often save money in the
long run.

Environmental Auditing
“Environmental audit” (EA) means a systematic evaluation of activities and
processes of a project to determine how far these activities and processes
conform with the approved environmental management plan of that specific
project and sound environmental management practices and applicable
environmental standards. It is an attempt to provide information on the
environmental performance of company, and thus include environmental
issues in the decision making process. A typical environmental audit assesses
the nature and extent of injury/harm to the environment caused by the
activities, wastes or noise from a particular company.

The Benefits of auditing

➢ Ensuring compliance, not only with laws, regulations and standards, but
also with company policies and the requirements of an Environmental
Management System (EMS) standard if adopted.
➢ Enabling environmental problems and risks to be anticipated and
responses planned.
➢ Ensures improved environmental practices
➢ To demonstrate that an organization is aware of its impact upon the
environment through:
• providing feedback;
• Increased awareness among stakeholders; and
• More efficient resource use and financial savings.

Principles functions of an Environmental Audit

a) prevent damage and the tendency for environmental damage.

b) improve resource use through reduction in material use, to minimize wastes

and to identify recycling opportunities.

c) actions undertaken or needing to be undertaken by an organisation or activity

to meet environmental goals such as sustainable development, recycling and
efficient use of resources.

d) improve an organization or activity’s compliance with environmental

legislation and regulations such as air emission standards, effluent standards,
waste management standards, and standard operating procedures.

e) document an operation or activity’s current environmental performance of

operation and environmental management procedures, including emergency
response planning, monitoring and reporting system and planning for future
environmental performance.

Three main Phases to an Environmental Audit are:

• Pre-audit
• On-site audit
• Post-audit

Pre-Audit: This is the audit preparation phase before the site visit by an
audit team. Pre-audit stage entails:

• Obtaining full management commitment;

• Setting overall goals, objectives, scope and priorities;
• Selecting a team to ensure objectivity and professional competence;
• Sending out a prepared pre-audit questionnaire to facility management
• Reviewing background and operational information with facility
management or factory/plant manager;
• Conducting an initial site visit at the facility to be audited; and
• Reviewing audit plan and arrange logistics.

On-site Audit
The purpose of the on-site audit phase is to collect verifiable evidence to
determine whether audit criteria are being complied with. This entails well
defined and systematic use of protocols or checklists which should start with:

• Conducting opening meeting with an office manager and site personnel

• Identifying areas to be inspected
• Outlining procedures
• Outlining schedules
• Identifying records and document to be reviewed during audit
• Reviewing of health and safety requirements
• Reviewing how confidential data will be handled
• Collection of information in line with relevant audit protocols, personal
observations, collection of relevant samples and taking measurements, etc

Undertaking a review of relevant documents such as the following:

• Corporate or/and management policy;

• Facility Environmental Management Plan (EMP);
• Management system documentation;
• Operational procedures and records;
• Records (inventory, utility, monitoring, transportation, training);
• Environmental monitoring/quality records;
• Correspondence on environmental issues;
• Environmental committee /team meeting minutes; and
• Previous Environmental Audit Report (if any).
 Post Audit Activities
The objectives are to produce an Environmental audit report with audit findings
and recommendations and to contribute toward the formulation of an Action
Plan for continuous improvement of operations of the facility.

Actions required in post audit phase include:

• Collation of information and follow up on outstanding issues;

• Evaluation of findings including the outcome of material balance and impact
evaluation of facility process on the environment;
• Preparation of the draft audit report in the approved presentation format;
• Circulation of draft audit report for comments to management and audit team;
• Incorporate or resolve all comments;
• Preparation of an action plan in consultation with the facility management to
incorporate:

1. A list of recommended actions, in terms of increasing cost-

effectiveness in addressing the facility’s critical environmental issues.
2. Interim and long term targets/objectives and a timetable for achieving
them for environmental improvement in the facility.
3. An indication of investments and other resources (human &
information) that would be required at the facility without
compromising their commercial confidential information.

• Produce a report for client and regulatory agency;

• Facilitate the Implementation of an Action plan at the facility level.

EIA CASES IN NIGERIA

The KOKO incidence