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CPCCBC5011-Learner Guide PDF
CPCCBC5011-Learner Guide PDF
CPCCBC5011-Learner Guide PDF
Learner Guide
Learning Program
As you progress through this unit of study, you will develop skills in locating and
understanding an organisation’s policies and procedures. You will build up a sound
knowledge of the industry standards within which organisations must operate. You will
become more aware of the effect that your own skills in dealing with people have on your
success or otherwise in the workplace. Knowledge of your skills and capabilities will help you
make informed choices about your further study and career options.
Flexible Learning
Studying to become a competent worker is an interesting and exciting thing to do. You will
learn about current issues in this area. You will establish relationships with other students,
fellow workers, and clients. You will learn about your own ideas, attitudes, and values. You
will also have fun. (Most of the time!)
At other times, studying can seem overwhelming and impossibly demanding, particularly
when you have an assignment to do and you aren’t sure how to tackle it, your family and
friends want you to spend time with them, or a movie you want to see is on television.
Sometimes being a student can be hard.
Here are some ideas to help you through the hard times. To study effectively, you need
space, resources, and time.
Space
Try to set up a place at home or at work where:
1. You can keep your study materials,
2. you can be reasonably quiet and free from interruptions, and
3. you can be reasonably comfortable, with good lighting, seating, and a flat surface for
writing.
If it is impossible for you to set up a study space, perhaps you could use your local library.
You will not be able to store your study materials there, but you will have quiet, a desk and
chair, and easy access to the other facilities.
An environmental management plan (EMP) sets out the potential impact of construction
activities on the natural environment and applies clear measures on how those impacts may
be mitigated (The Commonwealth of Australia, 2014). EMPs span the life cycle of a
construction building from the planning phase to the decommissioning phase. They consider
how construction operations contribute to long-term environmental sustainability and
positive impacts to the community. While EMPs may generate short-term expenses for the
construction firm, these are outweighed by benefits such as:
Cost savings
• Costs can be lessened by spending less on raw materials, energy, water and
waste management.
Business reputation
• People may be more likely to support a business that cares about its
impact on the environment.
Resource recovery
• Reducing, reusing and recycling is important for the environment and can
also be profitable.
• Reduced use of industrial chemicals and less waste can improve workplace
health and safety.
Legal compliance
Sourced from Environmental management and your business, used under CC BY 3.0.
business.gov.au. © Commonwealth of Australia 2020.
For EMPs to be effective, however, they have to be carefully designed. Because the natural
environment and legal standards governing its protection are ever changing, the EMP should
be continually adapted to suit changing contexts. For this reason, the design and
implementation of the EMP adhere to the standard process of continuous improvement
known as the Plan-Do-Check-Act (PDCA) cycle. This also serves as a suitable framework that
structures the discussion on managing an EMP.
Plan Do
Act Check
• Monitoring
• Reviewing the Organisational
EMP Legal Obligations
The first thing you will learn from this guide is the basics of environmental management
planning. This refers to developing the practices and processes in the EMP based on a
thorough study of the legal requirements and industry best practices in environmental
management. This is the first stage of managing an EMP and will be discussed in detail in
Chapter 1 where you will learn how to prepare an EMP.
Upon developing the practices and processes in the EMP, the next stage is actually doing the
practices set out in the EMP. Doing pertains to the actual application of the EMP in the
construction operations. This involves setting up the necessary communication channels,
reporting arrangements, and data gathering systems that would allow effective coordination
of the various tasks of different stakeholders in environmental management. Chapter 2
tackles these matters, at which point you will study how to manage the implementation of
the EMP.
Finally, having discerned the areas of improvement in your EMP, you have to begin
incorporating relevant feedback in the revision process and acting upon such feedback. This
will involve assessing the EMP from a long-term perspective, redrafting the EMP based on
the findings of the assessment, and properly communicating changes to all members of the
team. At this point, further planning and implementation may be done in light of the revised
EMP. This process is considered in Chapter 4 as you learn to review the environmental
management plan.
As you read this learner guide, you will learn more about the nuances of this process, how,
for example, the PDCA cycle is embedded in almost every process implemented in the EMP.
Crucial to such processes of continuous improvement is effective coordination among
internal and external stakeholders hoping to initiate change. That is why in addition to
studying the rigours of legal standards, industry benchmarks, and environmental sampling
techniques, you will also learn about communication channels which lie at the heart of a
well-functioning EMP. It is hoped that by studying this learner guide, you will become well-
equipped in developing an EMP that is not only legally and technically sound, but also
practicable in the organisational contexts of the construction firm.
Accounting for the impact of various legal standards keeps all environmental management
practices you implement within baseline environmental performance. It is important to
note, however, that laws and regulations are ever-changing due to the advances of scientific
research. A well-built regulatory framework, therefore, rests on a working-level knowledge
of the current shifts in environmental legislation or regulations. You will use this information
as you build your own regulatory framework when you prepare your EMP.
wetlands of
world heritage national heritage international
importance
nationally
threatened species Commonwealth
migratory species
and ecological marine areas
communities
water resource, in
the Great Barrier relation to coal seam
nuclear actions
Reef Marine Park gas and large coal
mining
Sourced from About the EPBC Act, used under CC BY 4.0. Department of Agriculture,
Water and the Environment © Commonwealth of Australia.
To determine whether your construction project will have a significant impact, you must
consider the quality (its cultural value, for instance) of the environment that will potentially
be affected and the extent of those effects.
Further Reading
The Department of Agriculture, Water and the Environment
has published a document detailing guidelines on how to
determine if an action has or will have a significant impact.
You may access it through the link below.
Matters of National Environmental Significance
At the minimum, complying with environmental laws will save you unnecessary operational
expenses in the long run. Doing so will spare you of penalties or administrative measures for
various breaches and non-conformity:
administrative responses, including warnings, notices or cautions
excluding individuals and companies from programs
seizing goods
suspending, varying or cancelling approvals, permits, licences or registrations
applying for injunctions
issuing remediation orders
negotiating enforceable undertakings
issuing fines
applying to the court for criminal prosecution and/or civil penalties
Sourced from Compliance Policy, Commonwealth of Australia 2019. Used under CC BY 4.0.
In addition, the person in charge should be able to fit such environmental legal standards
within wider government building legislation (see Further Reading at the end of Section
1.4.1). Finally, they should be able to keep relevant copies of updated and superseded legal
documentation, and duly inform the parties concerned. The main intention is to make sure
that the organisation’s environmental performance meets legal requirements.
1.1.3 Building Your Own Regulatory Framework
Having delegated the tasks for monitoring developments in legal standards, you are now in
a better position to build the regulatory framework for your EMP. The regulatory framework
is meant to define the environmental prohibitions and restrictions to be applied to your
project. Here are the general steps involved in this process:
1. Identify which laws are relevant to your project.
Consult with your construction team to come to a consensus on these laws. In
general, you must take into account how the following legal issues will be affected:
ambient air quality
protecting flora and fauna
managing weed infestation
soil quality and sediment
soil disturbance and vibration
water quality
waste management
hazardous resources
fuels and chemicals
cultural and historical heritage
Evaluate the impact of project for soil loss at the planning stage.
Requires contractors to introduce Strategise on erosion and sediment control before groundbreaking.
Soil Conservation and necessary measures towards preventing
Land Utilisation Act soil erosion and conserving and reclaiming Preserve as much top soil as possible so that it may be rehabilitated later.
soil Regulate the flow of water from the peak of the project area to minimise
erosion.
While legal research will help you achieve minimum environmental compliance, you must
also consider key industry standards to incorporate best practices applicable to your EMP.
Environmental best practices are those practices which have been found to be useful in
meeting environmental goals widely shared within the industry. They can be identified by:
consulting international standards references on environmental management; and
conducting research for benchmarking.
Environmental management
practices are measures and
activities that aim to
implement an environmental Environmental management
strategy. methodologies are sets of guiding
principles and processes for
managing environmental practices.
The following table compiles Australian and international standards useful for developing
the practices and methodologies of your EMP. The overarching standard for environmental
management is ISO 14001 which will help contextualise your EMP within the larger
environmental system of your construction firm. Complement ISO 14001 with other
standards tackling specific environmental performance issues such as noise and vibration
and soil sampling.
Relevant Industry Standards on Environmental Performance
AS/NZS (Australian
Standards/New Environmental Management Systems - Requirements with
Zealand Standards) Guidance for Use
ISO 14001: 2016
BS (British
Standards) 7385- Evaluation and measurement for vibration in buildings
2:1993
Code of Practice for Small On-Site Sewage and Sullage Treatment Systems and the
Disposal or Reuse of Sewage Effluent
Plan
Adapt Search
Plan
In the planning stage, you decide the parameters for benchmarking. What aspects of
environmental management performance do you need to benchmark? Normally, these will
be quantifiable characteristics such as air emissions of the site, turbidity of effluent released,
and soil loss due to excavation. You may consult ISO 14001 for more information on relevant
characteristics to be benchmarked. You will also design how these characteristics will be
measured and monitored. Several sampling and analysis strategies exist, and you must
decide the appropriate times in using them (discussed in Section 2.3). Finally, you will also
determine the personnel involved in the benchmarking process. You will need to deliberate
with your construction team on the delegation of research responsibilities and whether
certain aspects of research will be outsourced.
These goals and procedures should then be developed in the EMP and duly monitored.
Feedback from the monitoring and sampling process should then be used to continuously
improve the writing of future EMPs.
Having researched on relevant laws and industry benchmarks, it is time to delve into internal
project operations and analyse how such operations may affect environmental obligations.
At the end of this section, you will have created a table demonstrating how specific project
requirements relate to identified environmental responsibilities. In doing so, you will need
to (1) derive relevant work packages from the work breakdown structure (WBS) and (2)
identify relevant obligations based on these work packages.
1.3.1 Deriving Work Packages from the Work Breakdown Structure (WBS)
The work breakdown structure (WBS) is a useful tool that illustrates how construction work
packages are broken down into smaller work components. It emphasises the relationships
among general areas and specific work packages of a given construction project. The WBS
should be accessible right after the contract negotiation phase when the scopes of work are
being finalised.
High-rise building
construction
2.1 Exterior
1.1 Excavation 3.1 Painting 4.1 Planning
framework
2.2 Interior
1.2 Laying 4.2 Project admin
structural 3.2 Carpets
foundations and reporting
columns
4.5 Quality
2.5 Utilities
auditing
As you can see, the upper levels of the WBS indicate the major deliverable work areas of the
project. On the other hand, the lower levels decompose these major areas such that they
can be scoped and managed more effectively.
1. Foundation
Work
1.1.1 1.2.1
Dewatering Formwork
1.1.2 Mass
1.2.2 Rebar
Excavation
1.1.4 Shoring
Studying the work breakdown structure will allow you to pull out the specific activities that
need to be considered further in light of environmental management concerns. In fact, you
may need to modify the existing WBS to achieve the level of specificity best suited for the
EMP. Just keep in mind the following principles of WBS construction when doing so:
Hierarchical: Each child level should be a strict subcomponent of its parent level.
Observes 100% rule: The sum of all child levels should constitute the whole of the
parent level.
Outcomes-based: Your WBS should emphasise the work deliverables rather than the
procedures involved. A tip is to use nouns rather than verbs when creating elements.
1. Foundation Work
1.1 Excavation-related
Works
1.1.1 Dewatering
1.1.4 Shoring
1.2.1 Formwork
1.2.2 Rebar
4. Project Management
1. Foundation
Work
1.1 Excavation-
related Works
EPBC Act
Use of pumps and dewatering Use artificial recharge and temporary
1.1.1. Compromising
equipment that may alter the AS/NSZ ISO 14001 cutoff walls to preserve water resources
Dewatering water quality
conditions of the water table after the project
Water Act
EPBC Act
Evaluate impact of dewatering for soil loss
Use of excavation equipment Soil erosion AS/NSZ ISO 14001
displacing topsoil and and sediment Conserve topsoil when possible by
Soil Conservation controlling the perimeter and marking off
subsurface soil control and Land no-go areas
1.1.2 Mass Utilisation Act
Excavation
EPBC Act Cover up all drains on a construction site,
Use of excavation tools altering parking nearby pumps as necessary
Compromising
the conditions of the water AS/NSZ ISO 14001
water quality Collect and treat wastewater before
table Water Act discharing as effluent
EPBC Act
Evaluate impact of dewatering for soil loss
Use of site grading equipment Soil erosion AS/NSZ ISO 14001
displacing topsoil and and sediment Conserve topsoil when possible by
Soil Conservation controlling the perimeter and marking off
subsurface soil control and Land no-go areas
Utilisation Act
1.1.3 Site
Grading EPBC Act
If artifacts or relics are encountered,
Use of site grading equipment Cultural and AS/NSZ ISO 14001 contractor must cease all excavation
damaging underground historical Heritage work. Site manager must then arrange for
artifacts heritage Protection Act specialists and community
representatives to survey the site.
Heritage Act
1.2 Laying
Foundations
EPBC Act
AS/NSZ ISO 14001
Waste and
When possible, opt for durable modular
Waste disposal resources Waste
Management and metal form systems
management
Pollution Control
Act
EPBC Act
AS/NSZ ISO 14001
1.2.1 Fire Cast reinforced conrete in vertical
Use of flammable materials Fire and
Formwork management formwork
Emergency Act
Bushfires Act
EPBC Act
AS/NSZ ISO 14001 Lay sandbags along bars’ lengths
Use of formwork equipment
Noise and
that generate high levels of AS 2436 Avoid dropping materials from height
vibration
noise BS 7385.2 Use mufflers and acoustic screens
BS ISO 4866
EPBC Act
Use of concreting equipment AS/NSZ ISO 14001 Avoid dropping materials from height
Noise and
that generate high levels of
vibration AS 2436 Use mufflers and acoustic screens
noise
Front Matter
Background
• Introduction
• Project Description
• EMP Context
• Objectives
• Environmental Policy
Environmental Management
• Risk Assessment
• Environmental Management Activities and Controls
• Environmental Management Plans or Maps
• Environmental Schedules
• Environmental Monitoring
• Environmental Auditing
• Corrective Action
• EMP Review
Further Reading
e Department of Infrastructure, Planning and Natural Resources has
compiled guidelines on the preparation of environmental
management plans. For more information on writing the content of
the EMP, check it out through the link below:
Guideline for the Preparation of Environmental Management
Plans
All personnel Carry out all activities in accordance with the EMP and
safe work method statements
Report any incidents of non-compliance with the EMP
Keep in mind key participants and their contact details,
and report relevant concerns to them
Be up-to-date with relevant environmental trainings
Delegating environmental responsibilities in this way also facilitates future consultation with
regard to the preparation and implementation of the EMP. For example, the table above lists
the key people to be consulted or included in decision-making, and certain aspects of the
EMP that they should have thorough knowledge of.
Ensure that all responsibilities are properly indicated in respective documentation such as
contracts and work statements for regular reference. You may also document the contact
details of each key participant in the EMP to promote ease in coordination and reporting.
1.4.2.2 Evaluating Risk
Risk is a central aspect of environmental management. It indicates how seriously you should
take a potential environmental impact based on its severity and likelihood. To gain an initial
understanding on construction activities that have significant environmental impact, consult
the aspects-and-impacts analysis that you have conducted. These activities should then be
properly accounted for in the Environmental Management Activities and Controls section
depending on their level of perceived risk in your project. You can use the risk rating table
on the following page to determine whether your risk level is high, serious, medium, or low.
Legend:
Likelihood: Severity:
Frequent – will almost certainly Catastrophic – profound and
happen/continue to happen potentially irreversible environmental
destruction
Probable – likely to happen
Critical – profound environmental
Occasional – may happen under special
damage which may be remediated
conditions
through intensive efforts
Remote – not likely to happen
Moderate – significant environmental
Improbable – will almost certainly not happen damage which may be manageably
offset through reasonable efforts
Marginal – little environmental
damage which may be avoided through
standard procedures
In general, potential impacts with higher risk ratings deserve increased attention and should
have more detail regarding:
Water quality (chemical and Use of diesel and oil, paints, glues; cement cutting and
biological) mixing
Pumping contaminated
water to the stormwater Excavation, dewatering, concreting
system or natural waterway
Based on the content from Environmental Guidelines for Major Construction Sites,
used under CC BY 4.0. © EPA Victoria
Further Reading
n example of a comprehensive environmental risk assessment may be
accessed in the Draft Environmental Impact Statement of Tellus
Holdings Table 6-10.
Draft Environmental Impact Statement
Risk evaluation is generally qualitative and has a degree of subjectivity to it. It should
therefore be conducted by several members of the management team to achieve consensus
on the appraisal of risk. As an exercise, check to see if the risk assessment of Tellus Holdings
matches your own perceptions of risk with the potential environmental impacts they have
enumerated.
One of the key qualities of an effective EMP is that it is proactive. This means that imminent
environmental problems are spotted and addressed before they happen. To achieve this,
the timeframes of your EMP should be properly structured by making use of hold points and
witness points. Hold points and witness points are defined as such:
Hold points are key events during the project beyond which construction cannot
proceed unless proper inspections have been made.
Witness points are similar events requiring inspections but need not suspend
operations.
Incorporate Feedback
Based on the content from: 13.2 Plan Stakeholder Management. For more information, please consult the
Guide to the Project Management Body of Knowledge (PMBOK Guide 2008).
Organisati
Contact Internal/ Engagement
Name onal Location Project Role Major requirements Main expectations
Details External Level
Position
Understand
Project completion
financial benefits of
Sylvia Chairpers Senior 0X-XXXX- by June 2021 in
Adelaide EMP Internal Supportive
Reyes on Management XXXX accordance with
Align EMP with
contract
other goals of firm
To find suitable
Project completion
Chief annual
Frank O’ Senior 0X-XXXX- by June 2021 in
Executive Adelaide environmental Internal Supportive
Hara Management XXXX accordance with
Officer auditor and EMP
contract
representattive
Accurate and
Karen Prime 0X-XXXX- complete project Easy-to-follow EMP
N/A Gawler External Leading
Anders Contractor XXXX plans and controls
specifications
Accurate and
Proper waste
Andre Demolition 0X-XXXX- complete project
N/A Adelaide management plan External Neutral
White Subcontractor XXXX plans and
in place
specifications
Interviews whereby personal insights and experiences are gathered through key
facilitative questions
Focus groups whereby a range of opinions are gathered from members of the
management team through key facilitative questions
For a more detailed discussion regarding how these techniques are used, see Section 3.1.
Best practices during consultation include the following:
This allows your participants to prepare for the consultation and formulate
insights that can be discussed further during data collection.
Noting down key insights allows you to keep track of issues that may need to be
incorporated in the EMP or discussed further during consultation. Further, taking
notes lets your participant know that you are paying attention and would promote
better collaboration in the future.
After data collection, you must let your participants know of the outcomes of
consultation. You must provide them a copy of the revised EMP, as well as keep
track of any document changes that took place as a result of consultation through
the version control.
Once you have finalised the EMP, it is best practice to have senior management sign it off.
This will mark the EMP as a board-level priority and promote compliance among members
of your team.
No matter how general or specific the training may be, it should continually remind
personnel of their specific environmental obligations. During trainings, this may be
accomplished by:
continually referring personnel to the environmental structure and responsibility
section of the EMP;
contextualising broad environmental impacts and legislation within the construction
site and within the nature of each worker’s tasks; and
relating roles and responsibilities to incidences of non-compliance observed during
construction operations.
Once you have briefed staff and contractors regarding their environmental obligations, you
must design systems which would enable you to monitor compliance. If you do not brief
them, the environmental controls may not be executed reliably, if at all.
There are four monitoring systems you can implement in your EMP, including:
environmental management
statistical and analytical data
meetings and briefings
One of the goals of WeBuildIt Construction Corp. is to maintain the population of seagrass
in the lagoon nearby its construction site.
To do so, the EMR closely monitors the concentration of “Chlorophyll a” in the lagoon.
‘Chlorophyll a’ is known to be an indicator of the amount of photosynthetic plankton
present in bodies of water. Discharge from the construction site elevates nutrient levels
and subsequently the phytoplankton population. Ultimately, this promotes the growth of
microscopic algae on seagrass leaves resulting in shading effect. This may slow down
photosynthesis and lead to the dwindling of seagrass meadows.
WeBuildIt sets a monitoring threshold for ‘chlorophyll a’ concentration. In particular, it
decides that concentration levels should not exceed the 80th percentile concentration
reported during initial data gathering, beyond which a formal investigation should be
undertaken to identify and resolve root causes. The EMR includes in their monthly
conformance reports the levels of ‘chlorophyll a’, accounting for the surges in
concentration levels and what can be done to reduce the impact of present operations on
‘chlorophyll a’ concentration.
Discharge Monitoring
Toxic Release Inventory
Reporting
Be sure that key issues from the progress reports are brought up during regular meetings.
This will allow fellow construction team members to know the impacts of such issues on their
operations and propose strategies accordingly. Having discussed such issues, you can ask
your personnel to report on the status of proposed follow-up actions in their next progress
report.
• soil
• stockpiles
• water
Environmental
• air
subsystem
• weather
• noise
• odour
• Grab sampling
Sampling • Composite sampling
procedures • Continuous sampling
• Periodic sampling
• water bottles
Sampling • dust depositional gauges
equipment • sound level meters
• clamshell
As you begin to collect data about your environmental performance, you must ensure that
your data gathering system is both accurate and effective. In a nutshell, accuracy pertains to
how correct the data gathered is while effectiveness refers to how well the data is collected.
This distinction is summarised below:
As site manager, you will be able to assess your environmental data gathering system based
on accuracy and effectiveness. You have considerable control over ensuring that your data
gathering system meets the above conditions.
Continuous
• samples are measured in increments
Sample
Based on the content from Strategic Environmental Compliance and Performance Review.
Department of Environment, Climate Change and Water NSW © State of New South Wales
through the Environment Protection Authority
The specific techniques on performing statistical analysis are covered in the table in Section
2.3.1. As site manager, it is not expected that you master the mentioned resources, but be
sure you at least know what resource to use when analysing results for a particular
subsystem. This way, you have some working knowledge when you consult your samples
with lab technicians. Ensure that the laboratory which will conduct data analysis is one that
is accredited by a credible testing agency, such as the National Association of Testing
Authorities, Australia.s
After conducting analysis on the various environmental subsystems, sampling reports must
be created to summarise the environmental findings. Whether the reports will be created
by an environmental management representative or department in your firm, or by an
outside laboratory, you will have to assess if the reports are complete. In particular, the
reports should at least contain the following information:
name of representative, department or laboratory selected
date and time the report was issued
accreditation number of the laboratory, if NATA-accredited
By following standards on data gathering and data sampling, it is expected that you will be
able to maintain the high quality and effectiveness of your environmental data gathering
system.
A construction firm will typically service incoming and existing projects running at once.
Therefore, some of the provisions of the EMP may no longer apply to new projects and may
need to be updated. To make this process as systematic as possible, you have to conduct
another aspects-and-impacts analysis (see Section 1.3), and incorporate changes in your
EMP.
The process for doing so is detailed below:
Step 1: Evaluate each project through an aspects-and-impacts analysis.
Identify aspects and impacts of each project.
Take note of the proposed environmental controls.
Take note of relevant legislation and regulations.
Refer to the proposed environmental controls and relevant legislation and
regulations in your aspects-and-impacts analysis.
There may be times when local authorities and regulatory bodies need to monitor your
project:
Construction projects with a high environmental risk usually require monitoring from
external agencies.
In such cases, it is necessary to inform staff and other stakeholders of the changes in your
EMP.
2.6.1 Informing Staff and Contractors
It is important to communicate the updates of the EMP to your staff and contractors so that
they can make changes in their implementation of environmental controls accordingly. An
equally compelling reason, however, is that a well-informed construction team reinforces
the credibility of your EMP. Treat each individual member as a spokesperson of your EMP.
Remember that they will also interact with external stakeholders, and how well they
communicate your firm’s environmental vision speaks volumes about your commitment to
environmental performance.
The two primary ways by which you can update your staff regarding the changes in the EMP
include memos and meetings.
2.6.1.1 Memos
Use memos as formal, written documentation of communication of updates to your staff.
These memos should:
refer to the EMP’s version control which indicates the specific sections
where significant changes took place
The last point emphasises that communication should not only inform but also encourage
staff to contribute to the better environmental performance of the firm. In general, this can
be done by framing their individual contributions as crucial towards successful
implementation of the changes. For this reason, you may opt to send personnel-specific
memos in addition to the general memo to outline the changes in responsibilities of each
staff member in relation to the changes in the EMP. Doing so would reinforce the sense of
responsibility of each staff member, and promote better compliance.
staff to ask questions and clarifications about how the changes would affect the day-to-
day operations of each staff member
everyone to propose follow-up actions on environmental controls for each member given
the changes in the EMP
As always, you should document the points and questions that were raised during the
meeting through meeting minutes. Meeting minutes would serve as evidence of your staff
members’ understanding of the changes and of follow-up actions required from each
member. The important issues and questions during this meeting should be continually
addressed and referred to in subsequent meetings to ensure continuity in the
implementation of the changes.
2.6.2 Informing External Stakeholders
Other important stakeholders include
customers, shareholders and the media.
Such stakeholders can shape your company
image and impact the success of your
construction business dealings in the long
run. There are a variety of ways to
communicate your EMP updates to these
stakeholders including press releases and
annual reports.
2.6.2.1 Press Releases
Press releases are brief documents that share significant updates on your construction firm
through various channels such as industry publications, local newspapers, and general news
sites. In the case of large and complex construction projects with substantial environmental
implications, it is crucial that you take advantage of these channels to let the public know of
changes in your EMP. These press releases should:
Your role as site manager is to oversee your public relations (PR) personnel in writing and
distributing the press release. This means that you should properly brief your public relations
(PR) staff on the corresponding EMP changes and the implications on particular stakeholders
such as customers and trade alliances. At the end of the briefing, you and your PR staff
should come to a shared understanding on what the key take-away of the reader of the press
release should be.
2.6.2.2 Annual Reports
Annual reports, on the other hand, are comprehensive publications that describe the
company’s significant activities throughout the year. Part of this is its environmental
performance as manifested in the EMP. It may be that a section of the annual report is
intended for environmental management, or a dedicated environmental management
report is released annually as well. Whatever form it may take, this is an important avenue
for presenting the changes in the EMP to shareholders and other relevant parties. Compared
to press releases, such reports are allowed to be more technical by way of facts and figures
to capture the essence of the changes.
Basically, the report on the construction firm’s environmental performance should cover:
facts and figures detailing how present changes in the EMP have affected or will affect
large-scale operations of the firm
facts and figures detailing how present changes in the EMP have affected or will affect
the financial state of the firm (e.g. environmental management costs to sales ratio)
This section will discuss internal auditing, the process of conducting self-performed
assessments of your construction project’s environmental performance (see Section 3.3 for
external auditing). The steps involved in undertaking this process is illustrated below:
Complete
Plan internal Conduct
Report findings corrective
audit internal audit
actions
Audit objectives
• These pertain to the goals that must be established at the start to
establish the methods for the audit. These define what the audit is
supposed to achieve in terms of management priorities and regulatory
requirements.
Audit criteria
• These are the standards against which the in-house auditor checks your
environmental performance including regulatory requirements,
standards and codes of practice.
Audit scope
• This limits the boundaries of your audit in terms of locations,
organisational units, activities, processes and time period.
Audit timetable
• This details the date and places where on-site activities will be
conducted, and the expected time and duration of each activity.
Audit checklist
• These are the specific elements pooled from the audit criteria that need
to be checked for compliance.
Based on the content from Compliance Audit Handbook, used under CC BY 4.0. NSW
Department of Planning, Industry and Environment © State of New South Wales
(Department of Planning, Industry and Environment) 2006.
It is hoped that by using a variety of methods, the auditor can arrive at a more holistic
account of environmental performance of your construction firm.
The specific industrial process or activity, waste, substance or noise in respect of which
the environmental audit was conducted
Part of the results of the environmental audit should be whether the firm tracks changing
circumstances with regard to environmental management. Such circumstances include:
If ever these circumstances are not accounted for, this should be viewed as an opportunity
for corrective action. Corrective actions are those actions which have been found by the
auditor to be suitable in addressing issues or violations involving environmental legal
compliance, which would be implemented in the next stage.
Monitoring legal obligations, first and foremost, requires internal activities that enable the
firm to self-monitor compliance. These are primarily accomplished through organisational
feedback systems.
In the context of environmental management, an organisational feedback system is a
control loop between environmental goals and measured performance. As your construction
firm sets goals as detailed in the EMP Objectives section, it has to measure the extent to
which your construction team meets those goals through the implemented activities and
controls.
On the other hand, the measured performance may help inform you if goals are appropriate
or need to be changed. As site manager, it is your responsibility to manage such feedback
systems to facilitate the exchange of ideas regarding the legal compliance of the EMP.
Gathering feedback from personnel directly affected by an EMP is one way to assess the
EMP. Personnel directly affected by the EMP are in the best position to know if the EMP is
performing as desired or if any unforeseen issues have arisen. They can also help identify
areas of improvement. For example, if the EMP is effective at controlling carbon emission
but makes daily work more difficult for affected personnel, management can work on
coming up with a solution to the problem.
In general, there are two broad types of such systems, and several techniques by which each
is implemented:
Formal Informal
On a scale of 1-10 (1 - no capacity; 10 - perfect capacity), how would you rate our
capacity to meet legal obligations on the following activities:
Activity Score
Noise management
1. What are the ways, if any, in which you have contributed to the recent changes
in the Waste Management Plan (WMP)?
2. Do you feel satisfied in the proposed changes in the WMP? Why or why not?
3. What have you been doing so far to comply with the recent changes?
4. What have you been doing so far to comply with the recent changes?
5. Do you have any suggestions by which we could increase the capacity of the
WMP to meet legal obligations? What are these?
Participants
1. Given the complexity of our project, what do you all think are the tasks and
responsibilities which will be assigned to our new environmental management
representative (EMR)?
2. Given these tasks and responsibilities, what do you all think are the qualities
that should be possessed by our EMR?
3. What are the ways in which we can make the tasks and responsibilities of our
EMR more manageable given our project schedule?
Form of
Type of Feedback Documentation
Communication
Interview questions
Interview
Formal Interview notes
Meeting agenda
Meeting Points
Informal Meeting minutes
the community
regulatory bodies
Civic organisations
Resident associations
Local businesses
Local residents
On the other hand, this form of consultation may sometimes be difficult to manage given
the number of users who may participate in sharing ideas in your site.
In addition to the environmental concerns raised in Section 1.1.3, topics which may be
addressed in community engagement include:
nuisance reports and concerns about the project
construction site housekeeping
local and business activities that may be impacted by the project
accessibility of information regarding the project
offering site visits for the local community
meetings and events that should be attended by construction firm representatives
Based on content from Consultation process. Designing Buildings Wiki. © Designing Buildings Ltd. 2020
‘N’ and ‘O’ ratings will inform what controls in your EMP need to be subject to
improved monitoring procedures. ‘Y’ ratings tell of what environmental controls
need to be maintained. However, controls rated as ‘Y’ should be subject to
continuous improvement especially if your firm seeks to go above and beyond
regulatory compliance.
The two compliance mechanisms described above are mandatory and may be
enough for the purposes of a typical construction project. However, if you suspect
that your project site has environmentally significant impacts requiring further
consultation, do not hesitate to contact your relevant regulatory body as detailed in
Section 2.5
Auditing is the formal examination of your EMP’s procedures and processes to determine
whether they achieve legal compliance. Conducting audits regularly is considered to be best
practice because it serves as a check-up of the health of your EMP. However, there may be
times when managing and maintaining audits are legally required. For instance, your
construction project may pose significant risks to an environmentally threatened area and
has to be monitored closely. In this case, the Department of Agriculture, Water and the
Environment and/or a territory-specific regulatory agency may require you to submit your
EMP to make sure you have the proper controls to manage environmental risk.
If your EMP meets the requirements of the regulatory body, your EMP will be approved, and
your firm shall become an approval holder. Normally, the approval comes with approval
conditions that have to be met and are subject to statutory auditing. In general, a regulatory
body may ask you to undertake an independent environmental audit in one of two ways:
Sourced from Environment Protection and Biodiversity Conservation Act 1999 Independent Audit
and Audit Report Guidelines, used under CC BY 4.0. Commonwealth of Australia 2019.
Source an auditor
Commence audit
Sourced from Environment Protection and Biodiversity Conservation Act 1999 Independent Audit and Audit
Report Guidelines, Commonwealth of Australia 2019. Used under CC BY 4.0
The findings of the audit should then be written in an audit report. The audit report must:
contain details on measurements, sample sizes, evidence of representativeness or
data and records, and other evidences
not report by exception and cover all details of findings checked against each
criterion
establish no conflict of interest, in that findings are founded on independently
verifiable third-party evidence and must not be unduly influenced by the approval
holder or their representatives.
Contractors perform the majority of work in construction projects and are able to observe
how the EMP plays out in the day-to-day operations of the site. Therefore, you will need to
maintain contact with them to monitor the compliance of their activities with the EMP.
For this next couple of months, you crew will already begin undertaking the work packages
for concreting and subcontracting. You know full well that concreting and dredging
subcontractors have differing environmental responsibilities. The concreting
subcontractor will have to manage the concrete waste and the noise from use of
concreting machinery. On the other hand, the dredging contractor will have to prevent
contamination of the ground water and surrounding bodies of water. With this, you know
that you will have to remind your concreting subcontractor of the Waste Management
Subplan and Noise Management Subplan, and the dredging subcontractor of the Water
Quality Management Subplan. While the subcontractors have different subplans,
however, their environmental performance are both subject to inspection. At the end of
the agenda on environmental performance, you will announce that surprise inspections
will take place once per month to check their compliance with these subplans.
As always, you have to document the proceedings of such meetings through meeting
minutes. This will serve as evidence of the contractor’s participation in discussing the EMP
and can be used to follow-up on affirmed preventive or corrective actions.
3.4.2 Monitoring Compliance
Upon informing and reminding your contractors of their environmental responsibilities, you
need to monitor their compliance with such responsibilities. Compliance monitoring is
primarily done through inspections. In the context of the EMP, an inspection is a formal
examination or investigation of construction works to see if they meet prescribed standards
on environmental management. They can be conducted by key personnel such as the
environmental management representative or the head contractor.
Inspections are conducted frequently and can be announced or unannounced. At the end of
such an exercise, an inspection report summarising the findings of the inspection should be
produced. Should non-conformances be found, appropriate corrective actions should be
identified and followed up to the contractor during meetings.
Date of follow up
Site Assessment
In site assessment, the whole region is evaluated for the level of pollution. Samples from
materials like soil and groundwater may be taken to assess the pollution level.
Remediation
Community Protection
With community protection, rezoning will occur to prevent members of the community
from being affected.
Final Assessment
Final assessment is just a final examination of the contaminated site. If there is pollution
left in the area, further remediation will be done.
Based on Environmental Remediation: What Is It & How Does It Work?. © A-OTC 2021
Continuous improvement is a vital element of any management plan, and is all the more so
for the EMP. By this time, you will have learned about the various ways of assessing the
implementation of your EMP such as inspections and audits. However, these methods assess
the EMP in the medium-term only. At some point, you will need to take a longer-term
perspective to measure how much your EMP has met its organisational goals and adjust
these goals as necessary. This is achieved through the last step of EMP management known
as the management review. The management review enables senior management and staff
to collaborate to generate areas of improvement regarding the EMP.
This chapter will discuss the essentials of reviewing the environmental management plan,
including:
reviewing environmental management plan to identify areas that need actioning or
improvement;
introducing measures to encourage staff to suggest innovations to improve the
performance of the environmental management plan;
redrafting plans to include improvements or address deficiencies found during the
review process and;
submitting revised plans for endorsement by senior management and implement
reviewed procedures.
Gather
information
Prepare
briefings
Review
presentation
Update
presentation
Consider
findings
Act on findings
Members of the construction team at the lower levels of the organisational framework—
middle management, contractors and subcontractors—often have more on-site knowledge
of how the EMP plays out in practice. Their experiences and insights regarding how the EMP
may be improved are invaluable input when redrafting the EMP.
Following are several measures you can implement to gather suggestions on innovating the
EMP:
Surveys
Used to assess general attitudes regarding the EMP using numerical scales
Topics for the scales include perceived relevance, efficiency and effectiveness of the
EMP
Example: On a scale of 1 - 10, how would you rate the cost-effectiveness of the EMP?
Open-ended questions may be added as follow-up to the numerical scores and as a
way to ask for suggestions.
Interviews
Used to pool subjective insights regarding the EMP using semi-structured interview
questions.
Focuses on how the experiences of the interviewee coincide with or differ from the
expectations set out in the EMP. May utilise management review pointers (see
Section 4.1) and survey results as sources of topics.
Example: How does the weed management plan affect your current workflow in
preparing machinery?
Upon summarising relevant staff feedback, it is time to incorporate them in your revised
EMP. The first step in the revision process is to prioritise the feedback you have gathered.
You have to classify your feedback as either for preventive/corrective action or for
continuous improvement.
Feedback for preventive/corrective action are those proposals which have been identified
as crucial given present or imminent violations of the EMP with regard to legal obligations.
Hence, such feedback should be tagged as high priority. In this case, it is useful to refer to
the risk analysis matrix illustrated in Section 1.4.2.
On the other hand, feedback for continuous improvement are those suggestions which
would help in optimising the EMP in terms of effectiveness and efficiency. While not as
urgent as preventive/corrective actions, these should also be taken seriously especially if the
feedback is prevalent and would help reduce risk in the future. Decide with the rest of the
management team on which feedback should be included, prioritised, or deferred.
Afterwards, you should keep close at hand the finalised list of feedback and deficiencies
identified in the review process. This may be as easy as keeping a checklist or tabulating the
feedback. For easy reference, you may use a table to track the status of the deficiencies
identified. An example is shown below:
Upon organising the feedback in this way, you are in a better position to redraft your EMP.
Remember that you can always consult with your subcontractors and fellow team members
regarding your proposed changes in the EMP.
As you write, ensure that the changes that took place in the document are clearly reflected
in the Document Version Control Section. This should include a list of key details of your
modifications which will orient stakeholders regarding the necessary updates in the EMP.
It is crucial to seek endorsement from senior management regarding the revised EMP.
Having senior management sign off the document will promote further compliance among
team members.
There is no strict way in submitting the revised plans to senior management. However, it
would be wise to inform senior management of the revisions through brief points. You have
already accomplished this if you had updated the version control section of the document.
However, it is just as ideal to hold a presentation regarding the EMP.
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End of Document