Environmental Audits Adil Daniel Marhaba Niazi Naima Farooq

What is an Environmental Audit? EA is a management tool comprising a systematic, documented periodic and objective evaluation of how well environmental organization, management and equipment are performing, with the aim of helping safeguard the environment by: (i) facilitating management control of environmental practices and (ii) assessing compliance with company policies which would include meeting regulatory requirements.

Objectives of Environmental Auditing determine how well the environmental management systems and equipment are performing verify compliance with the relevant national, local or other laws and regulations minimize human exposure to risks from environmental, health and safety problems.

Origins of Environmental Auditing Environmental safety and health auditing developed in the early 1970 s, largely among companies operating in environmentally intensive sectors such as oils and chemicals. Since then environmental auditing has spread rapidly with a corresponding development of the approaches and techniques adopted. Several factors have influenced this growth. Industrial accidents. Major incidents such as the Bhopal, Chernobyl and Exxon- Valdez disasters have reminded companies that it is not sufficient to set corporate policies and standards on environmental health and safety matters without ensuring that they are being implemented. Audits can help reduce the risk of unpleasant surprises. Regulatory developments. Since the early 1970 s regulations on environmental topics have increased substantially. This has made it steadily more difficult for a company to ascertain whether a specific plant in a particular country is complying with all of the relevant legislation.

Public awareness. The public has become increasingly aware of, and vocal about, environmental and safety issues. Companies have had to demonstrate to the public that they are managing environmental risks effectively. Litigation. The growth of legislation has led to a corresponding explosion of litigation and liability claims, particularly in the United States. In Europe and elsewhere, there is growing emphasis on the responsibilities of individual directors and on making information available to the public.

Benefits OF EA Benefits vary depending on the objectives and scope of the audit. Environmental auditing benefits include: Organisations understand how to meet their legal requirements; Meeting specific statutory reporting requirements; Organisations can demonstrate they are environmentally responsible; Organisations can demonstrate their environmental policy is implemented; Understanding environmental interactions of products, services & activities, Knowing their environmental risks are managed appropriately; Understanding how to develop and implement an ISO 14001 EMS; and Improving environmental performance and saving money.

Criteria—what do you audit against? An essential step in establishing an audit programme is to decide the criteria against which the audit will be conducted and to ensure that management throughout the organization knows what these criteria are. Typically criteria used for audits are: 1. company policies and procedures on environmental matters 2. applicable legislation and regulations 3. good environmental management practice.

The Typical Audit Process An audit is usually conducted by a team of people who will assemble factual information prior to and during a site visit, analyse the facts and compare them with the criteria for the audit, draw conclusions and report their findings. These steps are usually conducted within some kind of formal structure (an audit protocol), such that the process can be repeated reliably at other facilities and quality can be maintained. To ensure that an audit is effective, a number of key steps must be included.

Basic Steps: Pre-audit The pre-audit steps include the following: • setting overall goals, objectives, scope and priorities; • selecting the personnel for the audit team • preparing the audit protocol used by the organization • obtaining background information about the facility.

On-site on-site audit steps include the following: • Assessing strengths and weaknesses of internal controls, • Gathering audit evidence, • Recording audit findings, • review of documents and records; • review of policies; • interviews; • site inspection;

Post-Audit Post-audit is mainly done to draft a report which includes recommendations. This is used for future audits as well as for verification. The steps include: • evaluation of findings; • reporting with recommendations; • preparation of an action plan; and • follow-up

Environmental Management Systems (EMS) An EMS is a tool designed to enable organisations to target, achieve and demonstrate continuous improvement in environmental performance. It is one integrated management process with a number of stages, which includes an environmental audit. There a number of standards (e. g. the British Standard BS 7750 (BS 11992). many companies have set up internal environmental standards which are applied world-wide. These may be more stringent than local legislation

Elements of EMS: adopt an environmental policy to confirm and promote commitment to continual improvement in environmental performance; undertake an environmental review to identify significant environmental issues and effects; set up environmental programmes of objectives, targets and actions; establish an environmental management system to ensure the implementation of the necessary actions to achieve these objectives; undertake periodic environmental audits to assess the performance of such components;

Public sector environmental auditing Increasingly, public sector bodies and local authorities are adapting auditing methods to establish baselines of environmental performance. These then inform management action. The scope of public sector audits is different from that of the industrial sector in that the effects of service provision are considered as well as the direct effects of the activities of the local authority: Direct effects - environmental impacts that result from the way in which day to day activities are undertaken. Direct effects are covered by internal management audit. Service effects - environmental impacts that result from the organisations efforts in implementing environmental policies and objectives.

Public Sector Audits Typically public sector audits cover a number of target areas such as: 1. energy use; 2. recycling; 3. hardwoods from sustainable sources; 4. environmental education; 5. habitat conservation and creation; 6. green purchasing; and 7. traffic calming.

Pakistan Environmental Protection Act, 1997 The key features of the law that have a direct bearing on the proposed subproject relate to the requirement for an initial environmental examination (IEE) and environmental impact assessment (EIA) for development subprojects. Section 12(1) requires that: “No proponent of a subproject shall commence construction or operation unless he has filed with the Federal Agency an initial environmental examination [IEE] or, where the subproject is likely to cause an adverse environmental effect, an environmental impact assessment [EIA], and has obtained from the Federal Agency approval in respect thereof”

IEA • An environmental impact assessment is a formal process used to predict the environmental consequences (positive or negative) of a plan, policy, program, or project prior the implementation decision, it proposes measures to adjust impacts to acceptable levels or to investigate new technological solution. IEE • Initial environmental examination is intended as a low-cost environmental evaluation that makes use of information already available

Scope of the audit The greater the scope of the audit, the greater will be the size of the audit team, the time spent onsite and the depth of investigation. The scope of an audit can vary from simple compliance testing to a more rigorous examination, depending on the perceived needs of the management. The technique is applied not only to operational environmental, health and safety management, but increasingly also to product safety and product quality management, and to areas such as loss prevention. Although some companies have a regular (often annual) audit cycle, audits are primarily determined by need and priority. Thus not all facilities or aspects of a company will be assessed at the same frequency or to the same extent.

Scope of environmental audit

A case study: Effluents from selected sugar mills in Pakistan’s sugar industry, considered to be one of the best organized industrial sectors in the country, is also among the country’s leading economic enterprises

Overview of the sugar industry directly or indirectly employing over 10 million people. (Hagler Bailley, 1999). Comprising 77 mills, 38 in the province of Punjab, 32 in Sindh, six in the North West Frontier Province (NWFP), and one in Azad Jammu and Kashmir (AJK) produced nearly 4 million tons of sugar during 2003 -04 and has a full production capacity estimated at 5 million tons, well exceeding the estimated domestic demand of 3. 6 million tons

Issue The sugar production process is known to produce substantial levels of solid waste, water and noise pollution. The highly polluted wastewater from sugar mills, in particular, poses a substantial danger to health and environmental quality. Pollution control measures for such a large-scale industrial operation must be carefully planned to minimize risks to health and environment.

The case study states that health and environmental impacts of waste water released from the sugar industry, particularly in terms of pollutant parameters that are found to exceed NEQS (National Environment Quality Standards) ; The amount of pollution charge, as calculated under the notified government environmental rules and regulations, which the industry will have to bear over the years if it fails to comply with NEQS; and the international trade implications of not meeting environmental standards. In technical and regulatory issues, wastewater problem may be tackled, discussing existing environmental policies and legislation and available options including technologies for the reduction of wastewater volume and pollution load, end of pipe treatment, and recycling/reuse of waste water.

Recommendations To enhance the identification and implementation of appropriate control measures, industry should consider carrying out periodic “waste audits”, particularly for water use, to identify the level of waste discharge Government can encourage compliance with environmental standards by fostering favorable regulatory and financial conditions Government agencies can also facilitate domestic initiatives and cooperation by providing forums and opportunities for stakeholders to come together and tackle environmental issues in collaborative processes, such as the one effectively executed for the determination of the pollution charge system and self-monitoring and reporting /SMART programme