Environment protection principle 1: do no harm
This Good Practice
Note is for DFAT
staff, delivery
partners and
environment
specialists
involved in
delivering
Australia’s aid
program. It is one
of a series of notes
which explains the
principles of the
aid program’s
Environment
Protection Policy
and how they
should be
addressed. The
notes complement
the Operational
Procedures of the
Environment
Protection Policy.
This Good Practice
Note should be
read in conjunction
with the
Department of the
Environment
publication: Actions
on, or impacting
upon
Commonwealth land
and actions by
Commonwealth
agencies Significant
Impact Guidelines
1.2.
1.2 How to manage pollution and
emissions
1. Why is it important to manage pollution?
Pollution can degrade natural resources such as soils and water quality,
affect quality of life and impose costs on communities and businesses.
Pollution of water, air and land is a source of health risks and costs to
health systems in developing countries and emerging economies. It affects
poor people disproportionally. Diarrhoea related to water quality is a
primary cause of death in children aged under five in developing countries,
and a major contributor to poor maternal health, sickness and loss of
schooling and productivity in poor communities. Air pollution is now a major
cause of respiratory disease worldwide.
2. What are the legal obligations?
All aid program activity implemented is subject to a range of environment
laws and multilateral agreements including:
1. Partner country laws
2. The Environment Protection and
Biodiversity Conservation Act
1999 (EPBC Act)
3. Basel Convention on the Control
of Transboundary Movements of
Hazardous Wastes 1989
4. Waigani Convention 1995
5. Stockholm Convention on
Persistent Organic Pesticides
2004
Stockholm Convention 2004
Includes: the requirement that
developed countries provide financial
resources and measures to eliminate
production and use of persistent
organic pesticides, and manage and
dispose of their wastes in an
environmentally sound manner.
At 2014, 23 chemicals were listed as
eliminated or restricted.
To help meet these obligations, the potential impacts of aid activities on the
environment, including biodiversity and ecosystems, need to be assessed
and managed.
The aid program must comply with the domestic laws of the countries in
which it operates- you will need to check with partner country environment
agencies regarding their environmental laws.
The EPBC Act requires DFAT to obtain and consider the advice of the
Minister for the Environment before it authorises any aid project that will
have or is likely to have a significant impact on the environment anywhere
in the world.
Environment protection principle 1: do no harm
Multilateral agreements protect certain high-value conservation areas and listed
threatened and listed migratory species, including from the impacts of development.
3. What you must do
DFAT’s Environment Protection Policy (EPP) describes its environmental obligations
and principles for environment protection. Operational Procedures have been
prepared to assist compliance with the EPP, setting out the environment protection
measures that need to be taken at each stage of the aid management cycle. These
measures include:
1. environment risk screening and categorisation;
2. environment risk assessment; and
3. managing environmental risks.
If, after measures to manage risks are taken in to account, you think that an activity
is likely to result in pollution which has a significant impact on any aspect of the
environment, you should contact environment@dfat.gov.au to discuss whether it
should be referred under the EPBC Act for advice from the Minister for the
Environment and for potential further assessment.
You should refer to other Good Practice Notes including 2.1 How to comply with the
EPBC Act.
1. Consider the potential for pollution in environment risk screening and
categorisation
All aid activities and investments are screened for potential environmental risks at the
concept stage.
If environmental screening identifies a potential risk, you will need to assess whether
the activity is likely to have a significant impact on the environment. In assessing the
likelihood of a significant impact occurring, you should consult the Actions on, or
impacting upon, Commonwealth, land and actions by Commonwealth agencies
Significant impact guidelines 1.2.
An activity could present pollution risks if it involves any of the following: for example:

Construction of infrastructure such as roads, bridges, ports or dams;

Large-scale clearing, conversion or intensification of agricultural or aquaculture
production, or disturbance of acid sulphate soils;

A significant increase in the use of pesticides or other hazardous substances;

Construction of medical facilities, waste management facilities or the installation of
sanitation facilities (such as toilets);

Generation of wastes that could harm people or the environment;

Shipping and transportation of hazardous substances;

Manufacturing and waste production; and
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Environment protection principle 1: do no harm

Resettlement and housing development (which could affect water quality for
example).
These activities would normally be classed as medium to high risk. In assessing
the likelihood of a significant impact occurring, you should consult the Department of
the Environment publications: Actions on, or impacting upon, Commonwealth, land
and actions by Commonwealth agencies Significant impact guidelines 1.2.
2. Consider pollution in environmental assessments
If an activity has a medium or high likelihood of a significant impact on the
environment, an Environmental Assessment and Management Plan should be
completed.
The assessment should be conducted in line with any partner country and
international pollution and emissions standards and good practice guidelines,
primarily the World Bank Environmental Health and Safety Guidelines.
The World Bank Guidelines provide general guidance, covering environmental,
occupational health and safety, community health and safety, construction and
decommissioning, and industry sector guidelines for over 60 different industries and
project activities. It also references other useful sources of good practice guidance
for assessment of emissions and likely pollution risks. Additional sources include:

Asian Development Bank Environmental Safeguards: A Good Practice
Sourcebook Draft Working Document, 2012

Intergovernmental Panel 2006 on Climate Change Guidelines for National
Greenhouse Gas Inventories.
The assessment should take account of:

The environmental values and assets that could be impacted by the activity

Existing levels of pollution and emissions in the environment (receiving
environment standards for water, air, soil, sea)

Additional sources that could result from the activity.
The risk assessment process should include an assessment of whether a significant
impact is likely as defined by the EPBC Act, identifying impacts on biodiversity and
natural resources that are potentially significant and could trigger a referral.
3. Manage risks of pollution and emissions
Activities assessed as having medium to high risks of pollution must include an
environmental management plan and environmental indicators in the monitoring and
reporting frameworks.
It is good practice for management measures to aim for no net increase in existing
levels of pollution, and to avoid further reduction in the quality of air, water, soil,
seas or food.
How to manage pollution and emissions | 3
Environment protection principle 1: do no harm
Measures to prevent pollution must be considered in the first instance. Where
prevention is not possible, measures must be developed to manage pollution and
emissions. Measures commonly used to prevent and manage pollution include:

Location to avoid emissions that could impact on high quality and high value
environmental assets including water resources, food production systems, natural
environments and protected areas;

Avoiding use of pesticides listed under the Stockholm Convention;

Measures to comply with international Integrated Pest Management standards;

Measures to comply with global standards for transboundary movement of hazardous
wastes and their disposal under the Basel Convention;

Avoiding importation of hazardous wastes listed under the Waigani Convention into
Pacific Forum island countries;

Avoiding use of hazardous substances that are banned or are being phased out
nationally or internationally;

Resource use efficiency to minimise emissions from all sources;

Control of drainage and erosion from construction sites and in the design of roads,
dams, bridges and ports;

Suppression of dust and minimisation of noise on construction sites; and

Process modification, selection of materials and application of pollution control
technology according to World Bank Environmental Health and Safety Guidelines and
World Health Organization Air Quality Guidelines.
Wastes are a major source of pollution. Measures used to avoid and manage wastes
that are potentially harmful and could lead to pollution include employing technology
and processes to:

Reduce production of wastes by using materials more efficiently;

Reuse materials and products where feasible;

Recycle materials that can’t be reused; and

Treat and dispose of wastes that can’t be reused or recycled using appropriate good
practice disposal methods to meet health and safety standards, specifically World
Bank Environmental Health and Safety Guidelines.
4. You are following good practice if the activity:

Is assessed for risks of pollution in the design stage and incorporates measures
to manage the risks in implementation, monitoring and reporting frameworks of
delivery contracts;

Prevents emissions in legally protected or high conservation value environments and
productive natural ecosystems;

Prevents or manages pollution, wastes and emissions to meet national standards,
World Bank Environmental Health and Safety Guidelines and World Health
Organization Air Quality Guidelines;
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
Avoids the use of harmful substances;

Does not raise pollution levels in water, air, soil or sea above existing levels;

Provides for the safe disposal of waste; and

Builds capacity in local environment agencies and civil society groups.
6. Penalties could apply if emissions and pollution are significant
If an aid activity leads to significant harmful emissions and pollution, penalties could
include:

Penalties under partner country laws;

An injunction under the EPBC Act, which could halt an aid activity; and

Contract penalties for entities administering Australian aid activities which fail to fulfil
the environment provisions of their contracts.
Get help if you are unsure
Contact the Environment Safeguards Section: environment@dfat.gov.au
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