The
E.M.P (Environmental Management Program/Plan)
The
EMP is commonly established to ensure prompt action on measures desired to achieve
or comply to certain environmental requirements or objectives. In
achieving environmental requirement, such as ‘Terms and Conditions’ of an E.I.A
approval, is widely seen in the construction industry involving mega projects
such as highways, railways, ports, land-reclammation etc. This serves as a
planning tool to execute those legally based specific requirements. On the
other hand, in ISO14001
Environmental Management System (EMS), clause 4.3.3 stipulates the
requirement to set objectives, targets and program (EMP) for any organization
which adopt the EMS, as means of environmental continual improvement. Hence,
the redundancy of this term seems to have confused several parties, except,
those who are in organizations subscribing to the EIA and at the same time
certified ISO14001. Also, the term EIA
is NOT referring to the Aspects’ Impact Evaluation task conducted
in screening for Significant Environmental Aspects as performed in establishing
ISO14001 EMS! So, in ISO14001 please use the term ‘evaluation’ and not ‘assessment’.
Delightfully, in this write-up I’ll discuss both EMPs; one for the EIA compliance
and the other for EMS ISO14001. Enjoy it.
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First of all, not all projects are subjected to
the EIA (Environmental Impact Assessment) requirement. The EMP is one chapter
of the EIA report. In general, an approved EIA report means that its EMP is
accepted by the governing agency. Nonetheless, additional requirement may be
imposed in the EIA Approval’s ‘terms
and conditions’ issued by the approving agency. Project activities that
requires EIA reports are listed in the law, namely; Environmental Quality (Prescribed
Activities) (Environmental Impact Assessment) Order, 1987; as
follows;
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Order-2, Environmental Quality (Prescribed
Activities) (Environmental Impact Assessment) Order, 1987. The ‘Schedule’.
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Agriculture
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a)
Land development
schemes covering an area of 500 hectares or more to bring forest land into
agricultural production.
b)
Agricultural
programmes necessitating the resettlement of 100 families or more.
c)
Development of agricultural
estates covering an area of 500 hectares or more involving changes in types
of agricultural use.
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Airport
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a)
Construction of
airports (having an airstrip of 2,500 metres or longer).
b)
Airstrip
development in state and national parks.
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Drainage and irrigation
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a)
Construction of
dams and man-made lakes and artificial enlargement of lakes with surface
areas of 200 hectares or more.
b)
Drainage of
wetland, wild-life habitat or virgin forest covering an area of 100 hectares
or more.
c)
Irrigation schemes
covering an area of 5,000 hectares or more.
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Land reclamation
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Coastal reclamation involving an area of 50
hectares or more.
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Fisheries
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a)
Construction of
fishing harbours.
b)
Harbour expansion
involving an increase of 50 percent or more in fish landing capacity per
annum.
c)
Land based
aquaculture projects accompanied by clearing of mangrove swamp forests
covering an area of 50 hectares or more.
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Forestry
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a)
Conversion of hill
forest land to other land use covering an area of 50 hectares or more.
b)
Logging or
conversion of forest land to other land use within the catchment area of
reservoirs used for municipal water supply, irrigation or hydro-power
generation or in area adjacent to state and national parks and national
marine parks.
c)
Logging covering an
area of 500 hectares or more.
d)
Conversion of
mangrove swamps for industrial, housing or agricultural use covering an area
of 50 hectares or more.
e)
Clearing of mangrove
swamps on islands adjacent to national marine parks.
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Housing
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Housing development covering an area of 50
hectares or more.
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Industry
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a)
Chemical
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Where production capacity of each product or of
combined products is greater than 100 tonnes/day
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b)
Petrochemicals
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All sizes
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c)
Non-ferrous
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Primary smelting;
Aluminium – all sizes.
Copper – all sizes.
Others – producing 50 tonnes/day and above of
product.
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d)
Non-metallic
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Cement
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For clinker throughput of 30 tonnes/hour and
above.
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Lime
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100 tonnes/day and above burnt lime rotary kiln
or 50 tonnes/day and above vertical kiln.
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e)
Iron and steel
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-
require iron ore as
raw materials for production greater than 100 tonnes/day or
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using scrap iron as
raw materials for production greater than 200 tonnes/day.
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f)
Shipyards
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Dead Weight Tonnage greater than 5,000 tonnes.
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g)
Pulp and paper
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Production capacity greater than 50 tonnes/day.
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Infrastructure
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a)
Construction of
hospitals with outfall into beachfronts used for recreational purposes.
b)
Industrial estate
development for medium and heavy industries covering an area of 50 hectares
or more.
c)
Construction of
expressways.
d)
Construction of
national highways.
e)
Construction of new
townships.
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Ports
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a)
Construction of
ports.
b)
Port expansion
involving an increase of 50% or more in handling capacity per annum.
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Mining
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a)
Mining of minerals
in new area where the mining lease covers a total area in excess of 250
hectares.
b)
c)
Sand dredging
involving an area of 50 hectares or more
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Petroleum
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a)
Oil and gas fields
development.
b)
Construction of
off-shore and on-shore pipelines in excess of 50km in length.
c)
Construction of oil
and gas separation, processing, handling and storage facilities.
d)
Construction of oil
refineries.
e)
Construction of
product depots for the strorage of petrols, gas or diesel (excluding service
stations) which are located within 3 km of any commercial, industrial or
residential areas and which have a combined storage capacity of 60,000
barrels or more.
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Power generation and transmission
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a)
Construction of
steam generated power stations burning fossil fuels and having a capacity of
more than 10 megawatts.
b)
Dam and
hydro-electric power schemes with either or both of the following;
1) dams over 15m high and ancillary structures covering a total area
in excess of 40 hectares;
2) reservoirs with a surface area in excess of 400 hectares.
c)
Construction of
combined cycle power stations.
d)
Construction of
nuclear fuelled power stations.
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Quarries
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Proposed quarrying of aggregates, limestones,
silica, quartzite, sandstone, marble and decorative building stone within 3
km of ant existing residential, commercial or industrial areas, or any area
for which a license, permit or approval has been granted for residential,
commercial or industrial development.
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Railways
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a)
Construction of new
routes.
b)
Construction of
branched lines.
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Transportation
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Construction of Mass Rapid Transport projects.
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Resort and recreational development
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a)
Construction of
coastal resort facilities or hotels with more than 80 rooms.
b)
Hill station resort
or hotel development covering an area of 50 hectares or more.
c)
Development of
tourist or recreational facilities in national parks.
d)
Development of
tourist or recreational facilities on islands in surrounding waters which are
gazetted as national parks.
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Waste treatment and disposal
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a)
Toxic and hazardous
waste.
1)
Construction of
incineration plant.
2)
Construction of
recovery plant (off-site).
3)
Construction of
wastewater treatment plant (off-site).
4)
Construction of
secure landfill facility.
5)
Construction of
storage facility (off-site)
b)
Municipal Solid
Waste.
1)
Construction of
incineration plant.
2)
Construction of
composting plant.
3)
Construction of
recovery/recycling plant.
4)
Construction of
municipal solid waste landfill facility.
c)
Municipal Sewage
1)
Construction of
wastewater treatment plant.
2)
Construction of
marine outfall.
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Water supply
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a)
Construction of
dams or impounding reservois with a surface area of 200 hectares or more.
b)
Groundwater
development for industrial, agricultural or urban water supply of greater
than 4,500 m3 per day.
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Back to the EMP issue. So, how to develop an EMP after the EIA report
is approved by the Department of Environment? My professional advice is; to ‘slot-in’
the EIA terms and conditions or ‘mitigation measures’ into the project’s detailed
progress planning.
·
Let the overall project planning serves as a
base for the EMP formulation; Rationale: the EIA mitigation and the EIA’s ‘terms
and conditions of aproval’ don’t normally apply exclusively to each single
step of the project. Sometimes a single requirement may be applicable to
several phases, for example, as in the management of Scheduled Wastes, environmental
measurements, samplings, monitoring etc.
·
Study the EIA terms and conditions carefully
and classify each requirement according to the project’s phases;
·
Insert specific EIA terms and conditions into
the respective steps of the related construction phases.
·
Make sure the overall Project Progam addresses;
what to do, who does what, when, how, and how much cost, and current status;
·
In reality, we need to anticipate some ‘misses’
in adhering to these steps, so, a reliable contingency step or ‘Plan-B’ so to
speak, is useful.
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EMP compliance is all about prompt execution and implementation.
And, in many cases, at the end of each phase of the project, one or several Post EIA Audit
is required to justify the EMP’s fullfillment. A Competent Environmental Auditor who
are registered eith the DOE may be required to serve as a 3rd party to verify
this. In practice, they may conduct a site review and endorse your internal
report to serve this requirement, otherwise, they’d write an exclusive report.
I’d display an example of EIA aproval in my other post and explain this
further.
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In EMS ISO14001 an EMP is a sub-element of clause 4.3.3. An EMS has
no direction without it.
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What the
standard says:
The
organization shall establish, implement and maintain documented environmental
objectives and targets, at relevant functions and levels within the
organization.The objectives and targets shall be measurable, where
practicable, and consistent with the environmental policy, including the
commitment to prevention of pollution, to compliance with applicable legal
requirements and with other requirements to which the organization subscribe,
and to continual improvement. When establishing and reviewing its objectives
and targets, an organization shall take into account …the legal requirements
and other requirements to which the organization subscribe, and its
significant environmental aspects. It shall also consider its technological
options, its financial, operational and business requirements, and the views
of interested parties. The organization shall establish, Implement and
maintain a programme(s) for achieving its objectives and targets.
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An example of the
simplest EMP for ISO14001 is illustrated below. In practice I personally do
not recommend the use of percentages if a form of numbers is preferred.
Quantitative targets should consider the use of ‘normalized data’ as I
introduced in another post titled: ISO14001 Tips –
Environmental Aspects’ Data.
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Finally, I hope the
difference between the two kinds of EMPs are clearly understood.
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