Diploma of Environmental Monitoring & Technology
Study module 6
Environmental Management Plans
Environmental
management systems
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EMS Study module 6
Environmental Management Plan
INTRODUCTION
2
ENVIRONMENTAL MANAGEMENT PLANS
2
What is an Environmental Management Plan?
The purpose of an EMP
Consultation
Review of EMP’s
Types of EMPs
2
2
3
5
5
EMP STRUCTURE
6
Background
Environmental management
Implementation and operation
Monitoring and reviewing
6
6
6
6
IMPLEMENTING AN ENVIRONMENTAL MANAGEMENT PLAN
7
Where is the EMP?
Project management
Project staff
The role of the environmental field technician
7
8
8
9
ASSESSMENT
12
Required knowledge questions
Assessment & submission rules
References & Resources
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Introduction
Thus far into our journey of Environmental Management Systems we have discussed a
variety of topics including;
◗ defining environmental management in general
◗ why our society needs it
◗ the role of environmental planning
◗ the role of environmental protection, and,
◗ environmental management systems themselves
We are now at the ‘business end’ of the journey, which, in relation to the job role of an
environmental technician, all relates to the implementation of an Environmental
Management Plan (EMP).
Environmental Management Plans
What is an Environmental Management Plan?
An Environmental Management Plan (EMP) is a site or project specific plan developed to
ensure that appropriate environmental management practices are followed during a
project’s construction and/or operation.
It results from a once common criticism of the overall Environmental Impact Assessment
(EIA) process which claimed that once approval for a project had been given, proponents
turned a ‘blind eye’ to the environmental management of the project. The EMP became part
of the EMS and also, in NSW, part of the planning system, which has since given rise to
better environmental management of projects both during the assessment period and the
overall operating period of the project.
The purpose of an EMP
Project proponents, including government agencies, are often required to prepare a project
specific EMP as a condition of approval or consent. There is a reliance on the EMP to ensure
that a project’s actual environmental impacts are consistent with those evaluated in the
environmental impact assessment (EIA) process. The EMP is therefore fundamental to the
EIA process and should ensure that commitments given at a project’s planning and
assessment stage are carried out in the construction and/or operation stage.
An effective EMP should ensure:
◗ application of best practice environmental management to a project
◗ the implementation of a project’s EIA including its conditions of approval or consent
◗ compliance with environmental legislation, and
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◗ that environmental risks associated with a project are properly managed
EMPs are valuable tools to:
◗ define details of who, what, where and when environmental management and
mitigation measures are to be implemented
◗ provide government agencies and their contractors, developers and other
stakeholders better on-site environmental management control over the life of a
project
◗ allow proponents to ensure their contractors fulfil environmental obligations on
their behalf, and
◗ demonstrate due diligence
In addition, EMPs are often required as part of tendering for projects and are essential for
some types of government projects. In NSW, Parts 4 and 5 of the EP&A Act 1979 are all
relevant to the implementation of an EMP
A construction EMP is generally developed about the same time as the detailed design and
related activities are undertaken. Each process should influence the other. An operation
EMP should be developed before commencing operation of an activity or development.
The broad steps for the preparation of an EMP in relation to the post-approval process are
illustrated in the flowchart contained in Appendix A. The flowchart summarises the
implementation of environmental requirements for a project from approval or consent
through to construction, operation and decommissioning.
It is important to note that an EMP is a “living” document that should be focused on
continual improvement and should be updated as necessary.
Consultation
Specific impacts and associated environmental control measures may not be fully described
at the EIA stage of a project. For this reason, government agencies that have environmental
protection responsibilities may need to be consulted as part of an EMP’s preparation.
Any agency consultation undertaken at this stage should be limited to that required by
specific conditions, or clarify specific issues, or obtain other approvals, licences or permits.
Authorities that typically need to be consulted include:
◗ The Department of Environment and Heritage
◗ The Department of Primary Industries
◗ Department of Trade and Investment
◗ NSW Heritage Office, and
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◗ Local Councils
As well as any of the specific agencies related to the mentioned departments such as;
◗ NSW EPA
◗ NSW Office of Water
◗ Office of Resources and Energy
During the preparation of an EMP, all relevant parties should be consulted as early as
possible to facilitate a reasoned response. Community involvement in the EMP may also be
appropriate, depending on the type of project. Community liaison groups are often
established for larger projects.
These groups may comment on the specific environmental management measures to be
considered in an EMP. In all cases, the specific requirements arising from environmental
assessment and consultation should be established and defined as early as possible for
inclusion in the EMP.
Other stakeholders
Stakeholders are people who have some involvement or interest in the project being
managed. Obviously the stakeholders involved in a project depend on the project but
include;
◗ The community
◗ Contractors (which can be many, and might be you if you are a consultant)
◗ Landholders surrounding the site
◗ Utility companies
There could be many more. The consultation with stakeholders is very important as they
can often contribute to the collection of information relevant to the project, or provide
details about potential problems that you could encounter, and as such, you should engage
in thorough stakeholder consultation.
Contributors
A project’s proponent has the responsibility for the environmental performance of its
projects or activities. As such, the proponent is responsible for ensuring the preparation,
certification, approval and implementation of an acceptable EMP whether for construction
or operation.
During a project’s construction and/or operation the preparation and implementation of an
EMP is often passed onto a consultant. While an EMP might be prepared and implemented
by a consultant, the responsibility for implementing the EMP lies with the proponent.
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Conditions of approval or consent generally require that an EMP be approved before
commencing construction and operation. The time required to obtain an approval often
depends on the quality of the documentation provided. The certification and approval
requirements for an EMP should be recognised before the document is prepared.
Review of EMP’s
An EMP is not static. It is a working document that requires review and amendment during
the life of a project. Making changes to an EMP is an important aspect of improving a
project’s environmental management.
The EMP review process is also a valuable means of continually improving the effectiveness
of current and future EMPs. Review timings depend on the nature and scale of the project
but would typically be undertaken:
◗ when there is a change in the scope of the project
◗ following significant environmental incidents
◗ when there is a need to improve performance in an area of environmental impact
◗ at the completion of environmental audits, and
◗ at the end of a project (to allow for improvements in subsequent projects).
The review process should include looking at the environmental controls and procedures in
use to make sure they remain effective. Reasons for making changes to the EMP should be
documented. A copy of the original EMP document and subsequent versions should be kept
for the project records.
The EMP should state under what circumstances an updated EMP should be resubmitted to
an approval or consent body, for review and approval. A requirement to submit updated
EMPs to the relevant authority may also be stipulated in conditions of approval or consent.
Types of EMPs
EMPs can be prepared at different times in a project’s life. Usually these are prepared as:
◗ Construction EMPs (CEMPs)
◗ Operation EMPs (OEMPs)
CEMPs are developed to ensure that appropriate environmental management practices are
followed during a project’s construction. OEMPs are developed to ensure that appropriate
environmental management practices are followed during a project’s operation and
decommissioning.
Refer to Figure 6.2 for a breakdown of the workings and differences of C & O EMPs.
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EMP Structure
The exact structure of an EMP will be determined by the project’s potential size and impacts
on the environment. The basic structure of an EMP would be to include all temporal aspects
from the background or planning phase right through to continuous operation of shutdown
and rehabilitation (if the project has a known deadline). DIPNR (2004) suggest that the four
elements of the EMP structure would include (but not restricted to) background,
environmental management elements, implementation and operational elements, and
finally monitoring and reviewing programs.
Background
The background information collected would provide introductory information about the
project and possibly about the EMS as well in general, a detailed description of the project,
the scope and context of the EMP, a clearly stated set of EMP objectives and include an
environmental policy which explains the projects or proponents charter for the
environment.
Environmental management
This section would detail the management structure, roles and responsibilities of the key
personnel, a detailed statement of environmental compliance and licensing arrangements,
all significant internal and external reporting requirements including incidents, aspects of
environmental training for staff and contractors training or skill requirements, as well as an
environmental emergency management plan including key contacts and response
procedures.
Implementation and operation
During the implementation and operation of the project a focus on environmental hazard
identification, risk assessment & control (HIRAC) is required, procedural management
activities and controls, environmental monitoring plans, maps and procedures are required
as well as any scheduling information contained therein. This is paid particular attention in
the next section.
Monitoring and reviewing
All of the above aspects require procedural and activity based reviews and audits to identify
problems and provide mechanisms for corrective action to be taken, as per the Australian
Standards for Environmental Management Systems (refer to Study module 5).
The monitoring and reviewing mentioned here is different to the fieldwork version of
monitoring. This is referring to the process of auditing.
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Implementing an Environmental Management Plan
So what is the relationship between an EMP and the work that an environmental technician
does for a living? The answer is simple, the EMP outlines how a an organisation will manage
and mitigate environmental harm, which needs to be monitored, which requires data, which
the environmental technicians collect through sampling and testing of environmental
samples.
The specific role of the technician depends on the company. Some will focus on air, water
and soil, whilst others can focus on ecology, biodiversity and heritage issues. Our focus is on
the air, water and soil side as this course is based on environmental technology.
Environmental technicians don’t simply go to work, grab an EMP and then go sampling. As a
matter of fact, most technicians would not have even seen an EMP, and that’s the problem
– how to relate the EMP with the work performed, so now we need to position the EMP in
context to the technician.
How an EMP is implemented depends on the organisation it belongs to, and as such is a
difficult thing to explain. What follows is a brief explanation of the implementation process,
you will actually learn how it is done by an assignment.
Where is the EMP?
That is best introduced by the use of an image. Figure 6.1 below shows how the work that a
technician does can relate to different aspects of a job.
An explanation of the above flowchart is required. The flowchart is an attempt to relate the
work done by field technicians to the various phases of development and is structured as
follows;
◗ The top row is the phase of development
◗ The second row is the key legislative triggers
◗ The third row is the key reporting or management documents used
◗ The fourth row shows key licences that commonly apply to a project
◗ The last two rows show data analysis and the sampling and testing
Most assessors would be very impressed if the technician could draw an accurate flowchart
showing the precise documents that were involved from the sampling to the phase of the
project simply because everything in the first three rows is usually ‘invisible’ to the
technician. The purpose of this study module is to make these visible.
As can be seen, the precise location of the EMP depends on the phase of development being
considered at the time, but the implementation of an EMP is essentially the same
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regardless.
Also remember that by the time an EMP is being implemented, all of the background work
has been done, so the knowledge of the environment surrounding the project is extensively
understood. All that is required is for the work outlined by the EMP to be started.
Project management
The Project Manager is the person or team of people who run the project from the top.
They make strategic decisions based on overall project requirements.
These people deal with their counterparts in government and industry, and as such can be
involved with several high ranking people. The strategic decisions they make can have
massive impacts on the ground, such as whether a project continues or not.
Management work is that work undertaken by the project managers and includes;
◗ Requesting or submitting tenders for work
◗ Determining project staff requirements
◗ Communicating with stakeholders at higher levels
◗ Drawing up timelines for actions
◗ Ensuring quality
Generally speaking, following the PDCA cycle as outlined in the Australian Standards for
Environmental Management Systems (EMS). We won’t speak any more of the project
manager’s job role here.
Project staff
The role of the project staff is to act as middle men for the project implementation. These
people (which usually range in experience and qualification from senior technicians to
project specialists such as managers, scientists and engineers) are the coordinators of action
and perform functions that include;
◗ Determining the internal project requirements (i.e. equipment, vehicles etc)
◗ Drawing up management documents such as Sampling & Analysis Plans
◗ Communicating directly with stakeholders such as laboratories and landholders
◗ Organising GIS and mapping information
◗ Keeping all information up-to-date for audits
And the list goes on. The project staff will typically be the supervisors of the field technicians
and the people the technicians go to when they require further information or explanation
on a particular issue.
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The role of the environmental field technician
The fieldwork is obviously different, and effectively forms the basis of this entire course. The
implementation role of the field technician is quite simply to perform all outlined fieldwork
in accordance with the organisational or enterprise requirements to an acceptable level of
quality and do so safely. To do this effectively, this requires;
◗ Determining all statutory requirements
◗ Initial site visits to identify sites and field conditions
◗ Ensuring transportation capabilities
◗ Organising (client side) or participating in (consultant side) inductions
◗ Responding to incidents (client side, who may/may not contact consultants)
◗ Collecting sample bottles and ensuring laboratory requirements are met
◗ Undertaking fieldwork on a routine basis
◗ Collecting sample, site and field test data
◗ Performing data techniques related to DQO
◗ Completing all reporting requirements
Depending upon the project, this will also require any other specialist activities related to
specific work.
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An overview of Environmental Management in NSW
DEVELOPMENT PHASE
PLANNING
CONSTRUCTION
OPERATION
SHUTDOWN
REMEDIATION
Legislative triggers >>
LEP's, SEPP's, EP&A Act, EPBC
Act, POEO Act, Specific
industry Acts
EP&A Act, POEO Act
NEPMs, POEO Act
EP&A Act, POEO Act amongst
others
EPBC Act, SEPP 55, NEPMs,
EP&A Act, CLM Act, amongst
others
Licenses & Conditions >>
Planning consent conditions
EPL & consent conditions
EPL, TWA, amongst others
EPL, planning consent
conditions
Consent conditions (hihgly
variable)
Management Plans >>
SEE, REF, EIS, SIS & other
environmental assessments
(C)EMP, PIRMP
(O)EMP, PIRMP
(C)EMP, PIRMP
RPA, MREMP, Rehabilitaiton
Plans
Implementation >>
Fieldwork >>
Laboratory Analysis >>
Data Treatment >>
Data Quality Objectives (DQO), Workplace Health & Safety (WHS) requirements, Sampling plans, laboratory requirements and Chain of Custody (CoC) etc,
Stakeholder consultation, Staffing requirements, Time management.
AIR (Dust gauges, TSP, PM10, PM2.5, Odour), STATIONARY SOURCES (particulates and gases), WATER (grab, depth and composite for surface, groundwater
sampling & testing), SOILS (Contaminated site and natural resources sampling of pits, cores), BIODIVERSITY (Fauna and flora surveys and assessments), NOISE
(Environmental and occupational noise and vibration assessment),
Cations (Na, K, Ca, Mg), Anions (NO 3-, SO42-, PO43-, Cl-, CN-) Heavy metals and metalloids (Pb, Hg, Cd, Sn, Cr, As), NOM, BOD, COD, TSS, TDS, TPH, BTEX, PAH,
PCBVOC, Pesticides and herbicides, other regulated organics
Data cleaning (to match DQO), Descriptive statistics, graphical techniques, ANOVA, ARIMA, ecological and biodiversity statistics and indices, incorporation into
GIS systems and displays
Checklists and matices(scaled
Impact Assessment >> and weighted), modelling and
GIS
MANAGEMENT PHASE
ENVIRONMENTAL IMPACT
ASSESSMENT
Compartitive techniques against impact baselines and licence condition criteria. EPA will be
Load and Risk based as of June 2015
Measured against planned
targets and objectives
ENVIRONMENTAL PROTECTION COMPLIANCE
ENVIRONMENTAL
REHABILITATION
Figure 6.1 – An example of environmental management in NSW, relating the implementation of various EMPs to the ‘bigger picture.
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Figure 6.2 – Post approval EMP flowchart from the DIPNR EMP Guidelines (available from the cffet website)
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Assessment
Required knowledge questions
This section provides formative assessment of the theory. Answer all questions by typing
the answer in the boxes provided. Speak to your teacher if you are having technical
problems with this document.
◗ Type brief answers to each of the questions posed below.
◗ All answers should come from the theory found in this document only unless the
question specifies other.
◗ Marks shown next to the question should act as a guide as to the relative length or
complexity of your answer.
1. What is the purpose of an EMP? [2mk]
Click here to enter text.
Assessor feedback
2. Why are EMP’s required? [2mk]
Click here to enter text.
Assessor feedback
3. What key considerations are required to ensure an effective EMP? [2mk]
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Assessor feedback
4. Why is stakeholder consultation important when developing an EMP? [2mk]
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Assessor feedback
5. Think about the work a field technician performs. Identify three types of stakeholders
you think they would need to consult with. What communication techniques would they
typically use for each stakeholder? [3mk]
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Assessor feedback
6. Who has the responsibility to write the EMP? [1mk]
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Assessor feedback
7. Who has the responsibility to implement the EMP? [1mk]
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Assessor feedback
8. What are the two types of EMP and how do they differ? [3mk]
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Assessor feedback
9. Identify the basic structure of an EMP (bullet points only) [1mk]
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Click here to enter text.
Assessor feedback
10. Provide a brief description of the differences in the roles that project management,
project staff and field technicians play in implementing EMPs. [6mk]
Click here to enter text.
Assessor feedback
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Assessment & submission rules
Answers
◗ Attempt all questions and tasks
◗ Write answers in the text-fields provided
Submission
◗ Use the documents ‘Save As…’ function to save the document to your computer
using the file name format of;
Yourname-EMS-SM6
◗ email the document back to your teacher
Penalties
◗ If this assessment task is received greater than seven (7) days after the due date, it
may not be considered for marking without justification.
Results
◗ Your submitted work will be returned to you within 3 weeks of submission by email
fully graded with feedback.
◗ You have the right to appeal your results within 3 weeks of receipt of the marked
work.
Problems?
If you are having study related or technical problems with this document, make sure you
contact your assessor at the earliest convenience to get the problem resolved. The contact
details can be found at;
◗ www.cffet.net/env/contacts
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References & Resources
References
You are not required to read these references unless the question you are answering
requires it. Note that some of these resources might be available from the links provided in
the resources (below), your teacher or the library.
Bates, G. (2010). Environmental Law in Australia. Australia: LexisNexis-Butterworths.
EDO, NSW. (2005). Environmental law Toolkit - NSW. 5th Ed. Sydney, Australia: The
Federation Press.
Farrier, D. (. (2011). The Environmental Law Handbook. Sydney: Thomson Reuters.
Fisher, D. (2010). Australian Environmental law: norms, Principles and Rules. Australia:
Lawbook Company.
Lipman, Z. E. (2009). Environmental and Planning Law in New South Wales. Sydney,
Australia: The Federation press.
StandardsAustralia. (2004). AS/NZS ISO 14001:2004 Environmental Management Systems:
Requirements with guidance for use. Australia: Standards Australia.
Resources
◗ Information on environmental law can be found at the EDO here.
◗ Current Commonwealth legislation can be found here.
◗ Current State legislation can be found here.
◗ NSW environmental planning materials can be found here.
◗ NSW environmental protection information (EPA) can be found here.
◗ Commonwealth EPBC Act website is here.
◗ Local Government information can be found here.
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