Soil Erosion & Sediment Control
Internal Management Systems Review Tool
Step-by-Step Guideline
Overview
This document presents a step by step process that can be used within local government authorities (LGAs) to
assess the adequacy of internal programs (management systems) to manage erosion and sediment control
(ESC) on local developments and building sites. It focuses on the development assessment and compliance
process, however it could be adapted to review Council's own construction activities.
The aim of this review is to improve ESC across the LGA to reduce sediment discharge into drains and
waterways in order to protect the health of aquatic ecosystems and maintain stormwater infrastructure. In
most circumstances it will identify opportunities to improve the organisation’s ESC program, which should lead
to improvements in the way that ESC is implemented and managed. Ideally, this review would be requested by
the organisation’s CEO or Mayor.
This document outlines each step in the review process and provides templates and data recording forms as
attachments. A Council may choose to add or remove steps to suit the Council’s individual needs.
Aims
1. Gain managerial and internal support to improve ESC practices
2. Review current documents, processes, staff capacity and on-ground performance
3. Identify gaps in the process and barriers to ESC implementation
4. Develop an Action Plan to introduce improvements in the ESC management system
5. Build the organisations capacity to assess/audit own processes and undertake continuous improvement
How to use the tool
A process is outlined below that could be used within a typical LGA to use the review tool. We would strongly
recommend that this process be instigated at the most senior level (e.g. by the CEO or Mayor). The process is
as follows:
1. Commit to doing an internal review of the Council’s ESC Program at a senior level (e.g. at the CEO or
Mayoral level). This review should be a fair assessment of Council’s activities, with a focus on
identifying opportunities for improvement.
2. Assign an executive manager and project manager as being responsible for undertaking the audit and
reporting the results to Council’s executive management team and/or Councillors.
3. Get external assistance to conduct the audit if necessary (e.g. from Healthy Waterways, specialist
auditors or specialist ESC consultants). It is strongly recommended that someone with a high level of
ESC technical expertise (i.e. a ‘Certified Professional in Erosion in Sediment Control’; CPESC) be
involved.
4. Follow the Steps outlined in this document and record the findings, results and actions in the ESC
Report Template & Action Plan Document .
5. Ensure the results of the audit are reported at an executive and/or Councillor level, and include
specific recommendations to ways to improve Council’s performance in managing ESC.
6. Link approved recommendations to Council’s operational work plans.
7. Monitor the progress of implementing recommendations from the audit.
8. Conduct another audit in one year’s time to ensure progress has been made.
STEPS
Step 1: Gain Managerial Support &
Build an Internal Review Team (IRT)
Step 2: Rapid Desk Top Assessment
Step 3: ESC Policy Review
Step 4: ESC Plan Review
Step 5: ESC Compliance Process Review
Step 6: Staff Surveys
Step 7: ESC Score Card
Step 8: Develop an Action Plan
Step 9: Annual Review
Step 1: Gain Managerial Support & Build an Internal Review Team (IRT)
Gain Managerial Support
It is important to firstly gain management and internal support to undertake the review. This might involve
explaining the process to management, highlighting what resources will be required and what the outcomes of
the audit may be (eg updating guidelines, investing in staff training, increasing enforcement etc) so that a
commitment can be agreed upon from the start. Without managerial support, there is a risk that the
recommended actions may not be successfully up-taken. Ideally, this tool would be used as part of an internal
review/audit requested by the organisation’s CEO or Mayor.
At the end of the review process the results of the audit and an action plan should be reported at an Executive
and/or Councillor level to gain support and resourcing for implementation.
Build an Internal Review Team (IRT)
Building an internal review team with representatives from relevant departments will assist with gaining
internal understanding and support for the audit process. It is suggested that a mixture of managers and
officers be involved so that their different perspectives can be contributed to the project. This will also ensure
the needs of the different departments and management levels are understood and are considered
throughout the process. For example a team might consist of staff from: Planning Development Assessment,
Development Compliance, Strategic Planning, Engineering, Environment/Environmental Health.
A coordinator should also be chosen to initiate the process, bring relevant staff together, organise meetings,
record minutes, facilitate the review process, engage expert consultants (if needed), collate data and report on
outcomes. This person should have a good understanding of ESC management systems and processes, and will
need to be resourced appropriately to undertake the role. The involvement of an executive manager to
oversee the project and report the results back to Council’s executive management team and/or Councillors
would be beneficial to give authority and weight to the review process and its conclusions.
It is recommended that either an internal staff member with appropriate qualifications and experience or an
external expert consultant (i.e. a ‘Certified Professional in Erosion in Sediment Control’; CPESC) be engaged to
review Council documents and procedures and recommend improvements in accordance with ESC best
practice standards.
Step 2: Rapid Desk Top Assessment
To get an overview of Councils current ESC Management Systems, the Internal Review Team (IRT) should first
fill out the Rapid Desktop ESC Audit Tool (add download link). The tool summarises the features of a ‘best
practice’ ESC program within a local government authority. These features reflect relevant research and the
views of experienced ESC practitioners. This tool could be used as a checklist to assess whether each feature is
present and strong within the LGA, and if not, identify some actions to strengthen relevant features.
The Council may choose to stop the audit process at this point if the team has sufficient information to be able
to answer the questions accurately and if the Council scores highly in majority of categories.
However if the IRT finds the questions in the checklist difficult to answer, for example if they do not have
enough information, or if the Council scores quite low in majority of categories, then the remaining Steps
(Steps 3-7) are recommended for a more thorough investigation of Council’s ESC processes. The following
steps will help Council to measure the current situation, map its current processes and identify areas for
improvement. To undertake this process download the ESC Report Template & Action Plan Document. This
document can be used to record data collected throughout the review and provide a template for the final ESC
Review Report and Action Plan. For information on how to populate this document follow the remaining steps.
Step 3: ESC Policy Review
Policy and Guidelines
Best practice ESC may not be being implemented on the ground for a number of reasons. One of the reasons
may be that the Council’s ESC Planning Scheme policy and guidelines do not reflect current best practice
(current best practice is regarded as the International Erosion Control Association - Best Practice Erosion &
Sediment Control Manual and can be found on the following website: http://www.austieca.com.au/). If this is
known to be the case or if policy documents have not been reviewed for some time, this audit could provide a
timely opportunity for such a review to occur.
The ESC Report Template & Data Collection Document provides a list of ESC documents Council may hold
(Table 3.1). These should be reviewed and the associated questions on the form answered by an appropriately
qualified person. It is recommended that the IRT first discuss the documents and questions on the list and add
questions as needed to meet the individual requirements of the Council.
Training and Education
The provision of training to staff and industry is a feature of a best practice ESC program. This is an opportunity
to review and document staff and local industry qualifications and identify where further training is required.
An example Register of ESC Suitably Qualified Persons is provided (Table 3.2)
Step 4: ESC Plan Review
Submitted Plans and Conditions of Approval
Recently submitted and approved ESC Plans and their associated conditions should be reviewed to determine
whether they are compliant with the Council ESC policy, guidelines and best practice standards.
To ensure a representative sample, several ESC plans should be reviewed. It’s recommended that the sample
include a mixture of large scale developments, high erosion risk sites (eg steep sites, dispersive soils, acid
sulphate soils), and medium scale developments. The plans should be no older than 12 months and the
development should be in the construction phase, so that site inspections can be undertaken in Step 6.
So that the review is impartial, it is recommended that it be undertaken by a suitably qualified person who
does not typically assess plans for Council. This may be an external consultant or an internal staff member
outside of the development assessment unit, for example a suitably qualified EHO, Environmental Officer or an
Engineer.
While going through the review, try to quantify the findings as much as possible so they can be summarised,
reported on and remeasured at a later date. An example data collection sheet is provided (Table 4). The IRT
may wish to make additions or adjustments to this sheet to reflect the needs of Council.
Step 5: ESC Compliance Process Review
On-site Assessment and Review of Compliance Records
Good policy and ESC plan production are important to have in place in order to provide clear direction for onsite ESC management. Without these policies and plans in place it will be difficult to measure whether or not a
site is compliant. However, even sound policies and plans do not always translate to on-ground
implementation and compliance. A recent investigation by Healthy Waterways found developer compliance in
SE Queensland to be quite poor. Therefore compliance is an important process to review and it is
recommended that the review be undertaken in a quantitative and measurable way so that improvements (or
declines) in performance can be measured and reported on.
To measure on-ground implementation of ESC, field inspections should be undertaken of the same
developments that were assessed in the ESC Plan Review Section (Step 4) for continuity. The inspections
should be completed by Compliance Staff with the option of seeking a third party to provide an independent
assessment and potentially also provide training to staff (eg Expert Consultant, EPA Officer).
It is recommended that a site inspection checklist be used to collect data on compliance and non-compliance
and to assist with quantifying the degree of compliance across the LGA. Council may wish to use its own
checklist or take this opportunity to develop one. A suggested list of elements to include in a Checklist can be
found on the IECA Website (www.austieca.com.au/documents/item/373). Remember to take photographs of
the site for record keeping purposes and to illustrate compliant and non-compliant practices. At the end of this
process collate the information and fill out Table 5.1 with the number of developments that are currently
compliant and non-compliant. There is also room in the document to insert photographs demonstrating
compliant and non-compliant practices.
Desk-Top Compliance Records Review
Previous compliance records of the same developments should also be reviewed. The review could examine
the quantity and quality of information typically collected about ESC compliance, and to gain an understanding
of how enforcement tools are applied. Table 5.2 outlines questions that can be used as a guide to collect this
information.
Step 6: Staff Surveys
Survey Purpose
A staff survey is recommended to uncover staff knowledge and understanding of Council policy and
procedures relating to ESC, and to help identify gaps and areas needing improvement. Surveys can also seek
staff input and ideas. These recommendations could form the basis of an Action Plan (to be completed after
the review process, Step 8). Survey templates with example questions have been developed for DA Officers
and Compliance Officers. Once again, the IRT should review the questions on the forms and make
adjustments/additions as needed. Some of the questions are quite detailed and involved so it should be made
clear to those being surveyed that they can put in as little or as much detail as they like, and that the survey is
a chance for them to have input into the ESC Plan Assessment / Compliance process.
So that participants feel comfortable answering the questions, survey results should remain anonymous and
should only appear in reports as pooled statistical results or as anonymous comments and ideas.
The following are Staff Survey Templates that can be used to collect data from DA Assessment and Compliance
Officer Staff on the topic of ESC assessment and compliance.
Survey Delivery
There are a number of ways the survey could be delivered to staff, however it is recommended that a survey
delivery and collation program such as Adobe FormsCentral or Survey Monkey be used so that the results can
remain anonymous, be automatically collated, easily downloaded and analysed. The following Staff Survey
Templates can be downloaded from the WbD website in the Adobe FormsCentral Format. If you have the
FormsCentral Program, use it to open the files, edit the survey content as needed and distribute the survey to
relevant staff. Once the staff have completed the survey their responses will be automatically collated by the
program and can then can then be downloaded into excel or pdf for further analysis. The FormsCentral
Program can be downloaded from
http://success.adobe.com/en/na/sem/services/1109_5958_formscentral.html for a nominal fee of $15 per
month.
If you do not wish to use a survey collation program you could alternatively cut and paste the survey text from
the Report Template & Action Plan (pg 11+) into a separate word document and deliver it to staff via email or
hardcopy. Responses can then be manually collated and analysed. However if this method is chosen, consider
how the anonymity of the survey will be maintained, and factor in the length of time data collation may take.
Once collated, the responses can then be summarised and inserted into the Report Template & Action Plan.
You may like to present summarised data in graphs and/or tables, and extrapolate key ideas and anonymous
comments.
Step 7: ESC Score Card
Once Steps 1-6 have been completed, compile the information gathered and fill out the ESC Score Card. The
Score Card aims to summarise Council’s current performance in the three main areas – Policy, Assessment and
Compliance, and measure internal support for and awareness of ESC.
Once completed follow the next step to develop an Action Plan for ESC process improvement.
Step 8: Develop an Action Plan
Action Plan Development
Now that the review process is complete the Internal Review Team will have a good understanding of the
weaknesses and strengths of current internal processes. It would be timely to re-group with relevant staff and
management to workshop methods for improvement. The more the staff are involved in developing the
actions for improvement, the more likely it will be that the improvements will be implemented. An Action Plan
Template is provided with suggestions for typical actions that could be taken to improve ESC management
processes. Note that each action must have the approval and support/sign-off from management.
A communications strategy should also be developed alongside the Action Plan that details how the changes
will be communicated to staff and industry, and how the improvements to ESC implementation will be
reported.
Consider strategies Council could use to increase the rate of uptake by staff, for example Link approved
recommendations to Council’s operational work plans, and maybe offer recognition/incentives/rewards to
staff and/or departments who have successfully implemented the actions outlined in the plan.
Communication and Implementation
Now that the ESC Review and Action Plan are complete, communicate findings and recommendations to
management and Council. The Report Template & Action Plan can be used as a template for communication.
Overall the final document should highlight the positives and negatives of current practices, identify any gaps
and barriers, include staff suggestions for improvement (as obtained through the staff surveys), and a plan for
action. Once again it is important to highlight to management the benefits of implementing the Action Plan
and the resources that will be required for success.
Once implementation of the Action Plan has commenced, consider sharing good-news-stories with the Council
and the public to help generate ongoing support for change and to publicly demonstrate the benefits of
effective erosion & sediment control.
Step 9: Annual Review
It’s important to review and report on any improvements to the ESC management process as a result of
implementing the Action Plan. Results of the review should be compared with previous findings to help
determine if the changes have resulted in an increase in ESC implementation. A review could be undertaken by
repeating the Steps outlined in this document, or by just concentrating on the main focus areas of the Action
Plan.
A good time to do this would be about 12 months after implementation to keep the momentum of the project
going and to maintain support for positive change.
A local press release to publically advertise improvements in ESC and the flow-on benefits this has for the
environment and economic savings for rate payers would help to communicate the importance and success of
the project.
Lessons learned throughout the process could also be shared with other Councils.
Further Information
For more templates, ESC designs, and technical specifications relevant to Queensland please refer to:
•
•
IECA Best Practice ESC Manual and other ESC information :
–
http://www.austieca.com.au/ ;
–
http://www.ieca.org/
Catchments and Creeks – has great free resources with plenty of pictures:
–
Website- http://www.catchmentsandcreeks.com.au/
–
Field guidehttp://www.catchmentsandcreeks.com.au/esc_field_guide.html
•
Healthy Waterways - Water by Design - http://waterbydesign.com.au/
•
Legislation –
–
http://www.austlii.edu.au/
–
https://www.legislation.qld.gov.au/OQPChome.htm
Acknowledgement:
This document was developed by Healthy Waterways, through funding from the Australian Government Reef
Programme and in collaboration with the Reef Urban Stormwater Management Improvement Group
(RUSMIG).
RUSMIG represents the key urban stakeholders in the Great Barrier Reef catchment, including Local
Governments, Regional Natural Resource Management bodies, the Queensland Department of Environment
and Heritage Protection, and the Great Barrier Reef Marine Park Authority. The principal role of RUSMIG is an
information exchange forum to share experiences and knowledge about urban stormwater management and
associated topics.
Water by Design is a program of Healthy Waterways Ltd. For further information about Healthy Waterways,
please email hwwinfo@healthywaterways.org or telephone (07) 3177 9100.
Disclaimer:
The material contained in this publication is produced for general information only. It is not intended as
professional advice on specific applications. It is the responsibility of the user to determine the suitability and
appropriateness of the material contained in this publication to specific applications. No person should act or
fail to act on the basis of any material contained in this publication without first obtaining specific independent
professional advice. Healthy Waterways Limited and the participants of the Healthy Waterways Network
expressly disclaim any and all liability to any person in respect of anything done by any such person in reliance,
whether in whole or in part, on this publication. The information contained in this publication does not
necessarily represent the views of Healthy Waterways Limited or the participants of the Healthy Waterways
Network.