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CPCCBC5011

Learner Guide

Manage environmental management practices


and processes in building and construction
Table of Contents

This Learner Guide.............................................................................................................. 5


Introduction ..................................................................................................................... 12
I. Prepare an Organisational Environmental Management Plan........................................ 16
1.1 Analyse the Potential Impact on the Organisation of Current Shifts in
Environmental Legislation or Regulations .............................................................. 17
1.1.1 Key Legislation and Regulations in Environmental Management ........................ 18
1.1.2 Tracking Legislative and Regulatory Changes ....................................................... 21
1.1.3 Building Your Own Regulatory Framework ........................................................... 21
1.2 Determine Current Environmental Management Performance Using Best
Practice and Benchmarking Methods ...................................................................... 25
1.2.1 Environmental Management Practices and Methodologies ................................ 25
1.2.2 Benchmarking and the Establishment of Environmental Goals ........................... 30
1.3 Analyse Project Requirements in Relation to Environmental Obligations .......... 33
1.3.1 Deriving Work Packages from the Work Breakdown Structure (WBS) ................ 33
1.3.2 Identifying Potential Impacts of Work Packages on Environmental Obligations . 37
1.4 Prepare an Environmental Management Plan Using Available Information ...... 42
1.4.1 Content of the EMP ............................................................................................... 42
1.4.2 Competencies Required in Preparing an EMP....................................................... 44
1.5 Seek Senior Management Advice Concerning Implementation of the Plan as
Required ...................................................................................................................... 50
1.5.1 Develop a Stakeholder Register ............................................................................ 50
1.5.2 Consult with Senior Management......................................................................... 53
1.5.3 Incorporate Feedback ............................................................................................ 55
Classroom Activity for Chapter 1 ........................................................................................ 56
II. Manage Environmental Management Plan Implementation......................................... 57
2.1 Inform Staff and Contractors of their Obligations to Comply with the
Environmental Plan .................................................................................................... 58
2.2 Monitor Staff and Contractor Compliance with Implementing the Environmental
Plan .............................................................................................................................. 59
2.2.1 Conformance Reporting ........................................................................................ 60
2.2.2 Environmental Management Meetings and Briefings .......................................... 61

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2.2.3 Employee and Contractor Reports ........................................................................ 62
2.2.4 Statistical and Analytical Data ............................................................................... 63
2.3 Manage the Effectiveness and Accuracy of the Environmental Data Gathering
Systems ....................................................................................................................... 65
2.3.1 Assuring Sampling Integrity................................................................................... 66
2.3.2 Ensuring Proper Data Analysis and Reporting ...................................................... 68
2.4 Evaluate New Projects to Determine their Impact on Existing Environmental
Planning Obligations .................................................................................................. 70
2.5 Contact Local Authorities and Regulatory Bodies Where the Plan Requires
Ongoing External Monitoring or Overseeing .......................................................... 72
2.6 Communicate Information to Staff and Stakeholders Concerning Updates to
the Environmental Management Plan ..................................................................... 74
2.6.1 Informing Staff and Contractors ............................................................................ 74
2.6.2 Informing External Stakeholders ........................................................................... 75
2.7 Manage and Evaluate the Environmental Management Plan and Track
Changing Circumstances to Maintain Organisation Compliance......................... 78
2.7.1 Plan Internal Audit................................................................................................. 79
2.7.2 Conduct Internal Audit .......................................................................................... 80
2.7.3 Report Findings ...................................................................................................... 81
2.7.4 Complete Corrective Actions ................................................................................. 82
Classroom Activity for Chapter 2 ........................................................................................ 82
III. Monitor Organisational Legal Obligations.................................................................... 83
3.1 Manage Organisational Feedback Systems to Assist with Conformance of the
Plan .............................................................................................................................. 84
3.1.1 Formal Feedback Systems ..................................................................................... 85
3.1.2 Informal Feedback Systems................................................................................... 89
3.1.3 Feedback Documentation ..................................................................................... 90
3.2 Seek Regular Feedback Concerning the Operations of the Environmental
Management Plan to Assist the Organisation to Meet Its Legal Obligations ..... 92
3.2.1 Feedback From the Surrounding Community ....................................................... 92
3.2.3 Feedback From Environmental Agencies .............................................................. 94
3.3 Manage and Maintain Legally Required Auditing Practices to Ensure Probity
and Accountability towards Legislative Requirements .......................................... 96
3.3.1 Sourcing an Auditor ............................................................................................... 97

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3.3.2 Develop Audit Criteria and Methodology ............................................................. 98
3.3.3 Commence Audit ................................................................................................... 99
3.3.4 Seek Audit Approval ............................................................................................ 100
3.4 Maintain Contact with Contractors and Monitor their Compliance with
Environmental Management Requirements ......................................................... 101
3.4.1 Maintaining Contact ............................................................................................ 101
3.4.2 Monitoring Compliance .................................................................................... 102
3.5 Implement Emergency and Remediation Response Strategies as Necessary to
Assist Compliance with the Environmental Management Plan .......................... 104
3.5.1 Emergency Response Strategies.......................................................................... 104
3.5.2 Remediation Response Strategies ....................................................................... 106
Classroom Activity for Chapter 3 ...................................................................................... 108
IV. Review Environmental Management Plan ................................................................. 109
4.1 Review Environmental Management Plan to Identify Areas that Need Actioning
or Improvement ........................................................................................................ 110
4.2 Introduce Measures to Encourage Staff to Suggest Innovations to Improve the
Performance of the Environmental Management Plan ....................................... 113
4.3 Redraft Plans to Include Improvements or Address Deficiencies Found During
the Review Process ................................................................................................. 115
4.4 Submit Revised Plans for Endorsement by Senior Management and
Implement Reviewed Procedures .......................................................................... 117
Classroom Activity for Chapter 4 ...................................................................................... 119
References...................................................................................................................... 120

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This Learner Guide
CPCCBC5011 - Manage environmental management practices and processes in building
and construction (Release 1)
This unit of competency specifies the skills and knowledge required to plan and implement
effective environmental practices and processes and manage improvements of
environmental issues. It includes determining and managing energy efficient systems,
measuring and dealing with non-conforming practices and improving performance.
This unit of competency applies to builders, senior managers and other construction industry
professionals responsible for developing effective environmental management plans and
strategies to reduce environmental risk on building and construction projects.
Completion of the general construction induction training program specified by the model
Code of Practice for Construction Work is required for any person who is to carry out
construction work. Achievement of CPCCWHS1001 Prepare to work safely in the construction
industry meets this requirement.
No licensing, legislative or certification requirements apply to this unit at the time of
publication.
A complete copy of the above unit of competency can be downloaded from the TGA
website:
https://training.gov.au/Training/Details/CPCCBC5011

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About this Unit of Study Introduction
As a worker, a trainee, or a future worker, you want to enjoy your work and become known
as a valuable team member. This unit of competency will help you acquire the knowledge
and skills to work effectively as an individual and in groups. It will give you the basis to
contribute to the goals of the organisation which employs you.
It is essential that you begin your training by becoming familiar with the industry standards
to which organisations must conform.

This Learner Guide Covers


Manage Environmental Management Practices and Processes in Building and Construction
I. Prepare an organisational environmental management plan
II. Manage environmental management plan implementation
III. Monitor organisational legal obligations
IV. Review environmental management plan

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.

Additional Learning Support


To obtain additional support you may:
 Search for other resources. You may find books, journals, videos and other materials
which provide additional information about topics in this unit.
 Search for other resources in your local library. Most libraries keep information about
government departments and other organisations, services and programs. The
librarian should be able to help you locate such resources.
 Contact information services such as Infolink, Equal Opportunity Commission,
Commissioner of Workplace Agreements, Union organisations, and public relations
and information services provided by various government departments. Many of
these services are listed in the telephone directory.
 Contact your facilitator.

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Facilitation
Your training organisation will provide you with a facilitator. Your facilitator will play an
active role in supporting your learning. Your facilitator will help you at any time during
working hours to assist with:
 How and when to make contact,
 what you need to do to complete this unit of study, and
 what support will be provided.
Here are some of the things your facilitator may do to make your study easier:
 Give you a clear visual timetable of events for the semester or term in which you are
enrolled, including any deadlines for assessments.
 Provide you with online webinar times and availability.
 Use ‘action sheets’ to remind you about tasks you need to complete, and updates on
websites.
 Make themselves available by telephone for support discussion and provide you with
industry updates by email where applicable.
 Keep in touch with you during your studies.

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.

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Study Resources
The most basic resources you will need are:
1. A chair
2. A desk or table
3. A computer with Internet access
4. A reading lamp or good light
5. A folder or file to keep your notes and study materials together
6. Materials to record information (pen and paper or notebooks, or a computer and
printer)
7. Reference materials, including a dictionary
Do not forget that other people can be valuable study resources. Your fellow workers, work
supervisor, other students, your facilitator, your local librarian, and workers in this area can
also help you.
Time
It is important to plan your study time. Work out a time that suits you and plan around it.
Most people find that studying, in short, concentrated blocks of time (an hour or two) at
regular intervals (daily, every second day, once a week) is more effective than trying to cram
a lot of learning into a whole day. You need time to ‘digest’ the information in one section
before you move on to the next, and everyone needs regular breaks from study to avoid
overload. Be realistic in allocating time for study. Look at what is required for the unit and
look at your other commitments.
Make up a study timetable and stick to it. Build in ‘deadlines’ and set yourself goals for
completing study tasks. Allow time for reading and completing activities. Remember that it
is the quality of the time you spend studying rather than the quantity that is important.

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Study Strategies
Different people have different learning ‘styles’. Some people learn best by listening or
repeating things out loud. Some learn best by ‘doing’, some by reading and making notes.
Assess your own learning style and try to identify any barriers to learning which might affect
you. Are you easily distracted? Are you afraid you will fail? Are you taking study too
seriously? Not seriously enough? Do you have supportive friends and family? Here are some
ideas for effective study strategies:
1. Make notes. This often helps you to remember new or unfamiliar information. Do
not worry about spelling or neatness, as long as you can read your own notes. Keep
your notes with the rest of your study materials and add to them as you go. Use
pictures and diagrams if this helps.
2. Underline keywords when you are reading the materials in this Learner Guide. (Do
not underline things in other people’s books.) This also helps you to remember
important points.
3. Talk to other people (fellow workers, fellow students, friends, family, or your
facilitator) about what you are learning. As well as help you to clarify and understand
new ideas, talking also gives you a chance to find out extra information and to get
fresh ideas and different points of view.

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Using this Learner Guide
A Learner Guide is just that, a guide to help you learn. A Learner Guide is not a textbook.
Your Learner Guide will:
1. Describe the skills you need to demonstrate to achieve competency for this unit.
2. Provide information and knowledge to help you develop your skills.
3. Provide you with structured learning activities to help you absorb knowledge and
information and practice your skills.
4. Direct you to other sources of additional knowledge and information about topics for
this unit.

How to Get the Most Out of Your Learner Guide


Some sections are quite long and cover complex ideas and information. If you come across
anything you do not understand:
1. Talk to your facilitator.
2. Research the area using the books and materials listed under Resources.
3. Discuss the issue with other people (your workplace supervisor, fellow workers,
fellow students).
4. Try to relate the information presented in this Learner Guide to your own experience
and to what you already know.
5. Ask yourself questions as you go. For example, ‘Have I seen this happening
anywhere?’ ‘Could this apply to me?’ ‘What if...’ This will help you to ‘make sense’ of
new material, and to build on your existing knowledge.
6. Talk to people about your study. Talking is a great way to reinforce what you are
learning.
7. Make notes.
8. Work through the activities. Even if you are tempted to skip some activities, do them
anyway. They are there for a reason, and even if you already have the knowledge or
skills relating to a particular activity, doing them will help to reinforce what you
already know. If you do not understand an activity, think carefully about the way the
questions or instructions are phrased. Read the section again to see if you can make
sense of it. If you are still confused, contact your facilitator or discuss the activity with
other students, fellow workers or with your workplace supervisor.

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Additional Research, Reading, and Note-Taking
If you are using the additional references and resources suggested in the Learner Guide to
take your knowledge a step further, there are a few simple things to keep in mind to make
this kind of research easier.
Always make a note of the author’s name, the title of the book or article, the edition, when
it was published, where it was published, and the name of the publisher. This includes online
articles. If you are taking notes about specific ideas or information, you will need to put the
page number as well. This is called the reference information. You will need this for some
assessment tasks, and it will help you to find the book again if you need to.
Keep your notes short and to the point. Relate your notes to the material in your Learner
Guide. Put things into your own words. This will give you a better understanding of the
material.
Start off with a question you want answered when you are exploring additional resource
materials. This will structure your reading and save you time.

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Introduction

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 Business reputation Resource recovery

Work health and safety Legal compliance

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These benefits are further explained below:

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.

Work health and safety

• Reduced use of industrial chemicals and less waste can improve workplace
health and safety.

Legal compliance

• Your business needs to meet certain environmental protection laws.

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.

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The PDCA is illustrated below:

• Preparing an • Managing EMP


Organisational Implementation
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.

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As you implement the EMP, it is important that you conduct a process of checking to see if
the EMP is indeed effective in reaching your environmental goals. Without which, your
environmental controls may be outdated and inappropriate given inevitable changes in
scientific research and in legislation. That is why it is important to set up systems by which
you will be able to gather and coordinate relevant feedback regarding your legal compliance.
Chapter 3 describes how such systems may be developed as you learn how to monitor
organisational legal obligations.

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.

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I. Prepare an Organisational Environmental Management Plan
Preparing an environmental management plan requires a lot of due diligence. At first, you
will need to systematically gather information about legal standards and industry best
practices related to your construction project. After which, you will have to incorporate such
information in the EMP as you develop the environmental management practices and
processes. Throughout this process, you will have to communicate with your team and
senior management team for necessary consultations in the suitability of the EMP.
This chapter will therefore discuss preparing an environmental management plan, including:
 analysing the potential impact on the organisation of current shifts in environmental
legislation or regulations;
 determining current environmental management performance using best practice
and benchmarking methods;
 analysing project requirements in relation to environmental obligations;
 preparing an environmental management plan; and
 seeking senior management advice concerning implementation of the plan as
required.

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1.1 Analyse the Potential Impact on the Organisation of Current Shifts in
Environmental Legislation or Regulations
One of the functions of the EMP is that it aids in maintaining compliance with relevant legal
and regulatory requirements. This is most evident in an element of the EMP known as the
regulatory framework. The regulatory framework enumerates all legal environmental
standards relevant to the construction project and describes their impact to project
activities. Legal standards include legislation and regulations:

• This pertains to the description of legal


Environmental legislation requirements and corresponding sanctions for
violating environmental laws.

 These specify how such legislation is enforced


Environmental regulations through appropriate enforcement and
monitoring procedure.

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.

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1.1.1 Key Legislation and Regulations in Environmental Management
The Environment Protection and Biodiversity Conservation Act of 1999 (EPBC Act) is the
central legislative piece of Australia which governs the protection of environmental
resources. This is supported by the EPBC Regulations 2000 which specifies legal and
administrative procedures on matters such as biodiversity conservation and impact
assessment necessary to achieve the principles of the EPBC Act.
As site manager, you must consider if your construction project would have significant
impact on matters of national environmental significance set out in the EPBC Act, namely:

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

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If you believe that your construction project is likely to have a significant impact after
undertaking a risk assessment (see Section 1.4.2), then you should refer your proposed
project to the Department through their online referral system.
As the EPBC Act is continually being reviewed, you must keep yourself updated with the
latest news on this piece whenever you create an EMP. You might also consider attending
training sessions or hire external consultants to brief you on the development of such
legislation and regulation.
In addition to the above commonwealth environmental legislation, territory-specific laws
must also be accounted for in the regulatory framework. These laws aim to address
particular environmental concerns of the said territory.
For example, the Northern Territory has 4 laws that may impact EMP measures on sacred
site protection namely, the Aboriginal Land Act, Heritage Act, Northern Territory Aboriginal
Sacred Sites Act, and Soil Conservation and Land Utilisation Act.
To organise your research, you may use the table below to identify the general
environmental legislation in your territory. Then, consult the accompanying online resource
which lists laws and regulations related or subordinate to the key legislation.
Here are the key pieces of environmental legislation per State/Territory:

State/Territory Key Environmental Legislation Relevant Online Resource

Australian Capital The Environmental Protection Act


ACT Environmental Laws
Territory 1997 (Australian Capital Territory)

The Waste Management and


Pollution Control Act 1998
Northern Territory (Northern Territory) & NT Environmental Laws
Environmental Assessment Act
1982 (Northern Territory)

The Protection of the


New South Wales Environment Operations Act 1997 NSW Environmental Laws
(New South Wales)

The Environmental Protection Act


Queensland QLD Environmental Laws
1994 (Queensland)

The Environment Protection Act


South Australia SA Environmental Laws
1993 (South Australia)

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State/Territory Key Environmental Legislation Relevant Online Resource

The Environmental Management


Tasmania and Pollution Control Act 1994 Tas Environmental Laws
(Tasmania)

The Environment Protection Act


Victoria Vic Environmental Laws
1970 (Victoria)

The Environmental Protection Act


Western Australia 1986 (Western Australia) WA Environmental Laws
(Western Australia EP Act)

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.

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1.1.2 Tracking Legislative and Regulatory Changes
Responsibility for monitoring developments with relevant laws should be clearly delegated
according to the organisational framework of your EMP (see Section 1.4.2). Usually, this
responsibility falls under the environmental management representative who is the
coordinator and spokesperson of the EMP. It can also be shared between managerial and
operational personnel, though if this is your chosen option, care should be taken to avoid
confusion by clearly defining responsibilities. The person responsible should maintain links
with local and national government environmental departments by:

regularly visiting relevant regularly contacting the subscribing to appropriate


web sites local council environmental newsletters

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

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 sacred site protection
 noise and vibration
 community viewpoints
 environmentally sensitive areas
 fire management
NOTE: Not all pertinent laws may be directly related to the environment; some may
be related to health, safety, and quality management. After deciding the relevant
laws, write accompanying brief summaries of each as they apply to your project.

2. Describe how such laws may apply to your project activities.


Subsequently, enumerate the measures you will undertake so that your project
activities adhere to the laws. Coordinate with your subcontractors to gain their
insights regarding these legal obligations.

3. Organise the information you have generated through a table.


The following shows an abbreviated example of a tabulated regulatory framework in
the context of Northern Territory legal standards. It is not meant to be used for actual
construction projects but should serve as a basis on how legal information may be
written and organised.

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Act/Regulation/Bylaw Description Applicability to Project and Mitigative Measures

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.

Identify weed species to be controlled and ways to manage them by


Mandates contractors to take reasonable consulting the Weed Management Handbook.
Weeds Management measures to prevent weed infestations Properly clean machinery when switching operational areas.
Act and observe statutory weed management
plans Refrain from driving machinery through germinating seeds.
Incorporate chemical control with slashing and burning procedures.

Determine the necessary licenses and permits necessary to conduct


Safeguards all identified Aboriginal and works in the construction area.
Macassan objects/places
Verify that registered heritage sites and items are listed in relevant risk
Heritage Act Addresses how unearthed artifacts of assessment documents, and adhere to the conditions protecting them.
potentially Aboriginal or Macassan origin
may be dealt with Cease all construction work when artifacts are encountered, and consult
specialists as necessary.

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Provides a systematic policy regarding
how water resources in the Northern Take baselines of flow rates, turbidity, and pH to be monitored and
Terrritory may be allocated, used, sampled later.
protected, controlled, managed and
administered. Introduce soil erosion controls such as pumps and covers so that water
Water Act
from the site adheres to relevant water quality standards
Provides regulatory mechanisms such as
the approval of permits and licences and Time properly works in waterways to reduce exposure to flood events,
the design and implementation of water and prevent water contamination
allocation plans

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1.2 Determine Current Environmental Management Performance Using Best
Practice and Benchmarking Methods

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.

1.2.1 Environmental Management Practices and Methodologies


Guidelines provided by organisations such as Australian Standards (AS) and the International
Organisation for Standardization (ISO) will help you recognise environmental management
practices and methodologies crucial in designing performance indicators in your EMP.

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Environmental management practices and methodologies are differentiated as such:

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

Industry Standard Title

AS/NZS (Australian
Standards/New Environmental Management Systems - Requirements with
Zealand Standards) Guidance for Use
ISO 14001: 2016

AS/NZS ISO 9001:


Quality Management Systems - Requirements
2016

AS 1319: 1994 Safety signs for the occupational environment

AS 1692: 2006 Steel tanks for flammable and combustible liquids

AS 2187.1: 1998 Explosives - Storage, transport and use - Storage

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Industry Standard Title

AS 2187.2: 2006 Explosives - Storage and use, Part 2: Use of Explosives

Guide to noise and vibration control on construction, demolition


AS 2436: 2010
and maintenance sites

AS 4373: 2007 Pruning of amenity trees

AS 4970: 2009 Protection of trees on development sites

BS (British
Standards) 7385- Evaluation and measurement for vibration in buildings
2:1993

Mechanical vibration and shock – Vibration of fixed structures –


BS ISO
Guidelines for the measurement of vibrations and evaluation of
4866: 2010
their effects on structures

ASTMD (ASTM Standard Practice for Classification of Soils for Engineering


International) 2487 Purposes (Unified Soil Classification System)

Standard Test Method for Determination of Temporary Ditch


ASTMD 7208-14e1 Check Performance in Protecting Earthen Channels from
Stormwater-Induced Erosion

Code of Practice for Small On-Site Sewage and Sullage Treatment Systems and the
Disposal or Reuse of Sewage Effluent

The Australian Dangerous Goods Code Edition 7.6 (2018)

There are many environmental management practices and methodologies. Examples of


methodologies that can be applied in a building and construction project are the following:
 aspects and impacts analysis
 risk assessment
 plan-do-check-act
On the other hand, environmental management practices that can be done on a building
and construction project are:
 prioritising the use of more durable building materials
 using digital files where possible and avoiding the use of printed documents
 implementing litter abatement strategies on the project
 applying demolition practices that increase material recovery

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One way you can integrate environmental management practices into conducting site
surveys is by making sure that site surveys include ecological data. This means gathering data
on things such as the different animal and plant species on the site, the habitats that will be
affected by the building and construction and how they will be affected, and if there are any
protected species that are present on the site.
The National Construction Code
Aside from the relevant standards above, you may also source best practices from building
and environmental codes and standards. In this regard, the National Construction Code
(NCC) prescribes the minimum specifications in promoting the construction of safe,
accessible, sustainable, and liveable buildings in Australia.
The scope of the NCC is described in the table below:

NCC Unit Subject Matter

Class 2 to 9 (multi-residential, commercial,


NCC Volume 1
industrial and public) buildings and structures
Building Code
of Australia
Class 1 (residential) and 10 (non-habitable)
NCC Volume 2
buildings and structures

Plumbing Code of Australia (NCC


Plumbing and drainage for all classes of buildings
Volume Three)

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Current Trends in Environmental Management and Controls
Current trends of environmental management must protect the environment and minimise
the impact of building and construction on nature.
On the other hand, current trends in environmental control measures must contain and
prevent further damage to the environment. Examples of control measures used in the
building and construction industry include:
 Erecting noise barriers
 Wetting the soil to prevent spreading dust
 Installing sediment traps
 Providing on-site spill kits
With the environmental effects of the industry in mind, the growing construction industry
must work to create and incorporate more environmental management and controls.
Although construction sites will have to strike a delicate balance between sustainability,
many of these current trends are actually improving the efficiency of construction overall.

Using Building information modelling (BIM) to improve efficiency


Building information modelling (BIM) is a process that involves creating digital
representations of buildings and construction sites, allowing construction industry
professionals to plan for and manage projects more efficiently. While not specifically
advertised as a technology for sustainability, the use of BIM can lead to higher productivity
and shorter project timelines, which means construction projects spend less time on
activities that produce environmental waste.

Extending the lifespan of building materials


Relevant to the previous trend, some contractors turn to BIM to promote ‘circular
construction’. BIM designs allow contractors to see which parts of an existing building can
be used for a new construction project. Saving as much of this raw material as possible
reduces costs; in addition, recycled materials are often less costly than new materials, and
using them reduces the amount of greenhouse gases emitted when producing materials
such as construction-grade steel.

Moving Off-Site Construction


The use of prefabricated construction materials is increasingly becoming common. In
addition to maintaining tolerances close, having construction parts assembled off-site results
in less scrap and surplus of materials. Since prefabricated parts only have to be assembled,
the time it takes to complete a project is greatly reduced.
Based on Emerging Trends in Sustainable Construction. © 2020 VIATechnik

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1.2.2 Benchmarking and the Establishment of Environmental Goals
Another way by which you can identify current trends or best practices is through
benchmarking. Environmental benchmarking is the process of comparing your firm’s
environmental management plans and procedures with that of another firm or industry with
the goal of adapting best practices.
When you are developing an EMP, it is important to know what the relevant industry
benchmarks are so that you have an idea of what level of performance is fair to expect for
equivalent aspects of the EMP. If your initial expectations are too high or too low, you can
adjust them to be more realistic.
Benchmarking should be a cycle of continuous improvement as illustrated below:

Plan

Adapt Search

Analyse Collect Data

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.

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Search
Upon developing a plan of action for benchmarking, you will have to search for the firms and
industries you need to compare your firm to. Ideal benchmarking partners include those
who:
 are certified with relevant environmental management standards such as ISO 14001;
 produced innovations in environmental performance in construction; and
 have cost-effective measures for environmental management.
The output of the searching process should ideally be the consent of the prospective
benchmarking partners in the study.
Collect Data
In this stage, you will first need to assess the information needs of your benchmarking study.
You need to prioritise what aspects of the environmental performance of other parties you
need to observe.
Afterwards, you need to coordinate with these parties to gather the data you have
prioritised. The data gathering methodologies need to be rigorous and follow prescribed
industry standards (see Section 2.3 for more information).
Finally, the benchmarking partners should be debriefed on the results of the study so that
they too may learn information for their continuous improvement.
Analyse
At the minimum, your benchmarking study should be able to produce descriptive statistics
of relevant characteristics of the benchmarking partners. Examples of factors which could be
analysed in this manner include averages on number of inspections, frequency of reports to
relevant agencies, and rates of accidents and near misses, if any.
More comprehensive studies may require the use of statistical tests that make use of
correlation and regression. These tools will allow you to describe the relationship among
various environmental performance factors; for example, the relationship between the
turbidity of effluent discharged and the use of certain dewatering procedures or the
relationship between the use of certain rebar procedures and generated cutting waste.
Adapt
The findings of the benchmarking study should already give you a clear idea of the key
environmental benchmarks to be achieved in your EMP. These benchmarks should, on the
whole, consider:
 energy
 greenhouse
 water
 materials
 waste - solid and hazardous
 emissions and discharges to air, land and water
 biodiversity
 ozone-depleting substances

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 suppliers
 products and services
 compliance
However, the identified benchmarks should be contextualised in terms of geographical
location, size, structure, products, technology, economic activity, and organisational climate
(see Further Reading at the end of Section 1.4.1 for calculating and reporting on the above
benchmarks). This will enable you to localise these practices as appropriate to your own
construction firm.
Afterward, you should be able to identify what environmental goals you need to be
established. When you are developing an EMP, it is important to know what the
organisation’s environmental goals are because that will guide you in what to include in the
EMP. For example, if the organisation’s environmental goal is to reduce their carbon
footprint, then the EMP should include content geared toward reducing the organisation’s
carbon footprint.
The goals should be:
 Specific
The scope of the goal is well-restricted enough to avoid overlap. The responsible
parties and the nature of work to be done can be easily identified.
 Measurable
Progress towards the goal can be quantified. The steps taken to achieve the goal can
be monitored and audited.
 Attainable
The goal can be reasonably met given the limited resources. Concrete steps can be
easily planned to achieve the goal.
 Relevant
Goal is necessary to achieve the key environmental benchmarks. Criteria such as
time, cost and quality of construction work are well-considered.
 Time-bound
The goal should have set deadlines. It must be contextualised within the project
timeframe.
Examples of these goals should relate to the benchmarks as seen in the example below:

 Reduce air emissions by 25% of current emissions rate.


 Ensure all temporary site buildings have an energy performance
certificate (EPC) rating of A, B, or C.
 By the end of the year, ensure that 50% of construction materials
used are low-impact, opting for recycled or repurposed materials.

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.

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1.3 Analyse Project Requirements in Relation to Environmental Obligations

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.

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Below is a sample high-level WBS:

High-rise building
construction

1. Foundation 2. Structural 4. Project


3. Decorating
work construction management

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

2.3 Lifts 3.3 Furnishings 4.3 HR

2.4 Doors and 4.4 Contract


3.4 Signage
windows management

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.

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In fact, certain work packages can be further subdivided as shown in the example below:

1. Foundation
Work

1.1 Excavation- 1.2 Laying


related Works Foundations

1.1.1 1.2.1
Dewatering Formwork

1.1.2 Mass
1.2.2 Rebar
Excavation

1.1.3 Site 1.2.3 Concrete


Grading Placing

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.

Mutually exclusive: Each element at a certain level must be self-contained meaning no


work packages must be overlapping to avoid performing the same work.

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.

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After studying the WBS, you may generate a partial table of all the specific elements to be
considered and relevant environmental responsibilities. You may use the table below as an
example for the table you will make.

Relevant Environmental Applicability to Project and


Work Package
Concerns Mitigative Measures

1. Foundation Work

1.1 Excavation-related
Works

1.1.1 Dewatering

1.1.2 Mass Excavation

1.1.3 Site Grading

1.1.4 Shoring

1.2 Laying Foundations

1.2.1 Formwork

1.2.2 Rebar

1.2.3 Concrete Placing

4. Project Management

4.5 Quality Auditing

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1.3.2 Identifying Potential Impacts of Work Packages on Environmental
Obligations
Upon generating a list of work packages that need to be audited, you need to consider how
the operations involved in these packages may impact environmental concerns. This is done
through an aspects-and-impacts analysis and is already partly accomplished by the
regulatory framework. As the name suggests, this has two parts:

• Components of construction activities, products and


Aspects
services that interact with the environment

• Adverse and beneficial effects to the environment of the


Impacts
identified aspects

The process of aspects-and-impacts analysis can be summarised into three steps:

Identify aspects Identify impacts Set up controls

Step 1: Identify aspects.


Generate a list of activities, products and services that may impact the environment. Consult
your contractors and subcontractors for package-specific aspects.

Step 2: Identify impacts.


Determine the possible effects of these activities based on the legal issues identified in
Section 1.1.3. Cite any environmental prohibitions or restrictions involved.

Step 3: Set up controls.


Identify environmental controls to mitigate environmental impacts. Brainstorm with your
construction team to come up with cost-effective controls.

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The process of conducting an aspects-and-impacts analysis is best documented through a table. Below is an example of such a table in the
context of construction in the Northern Territory legislation.

Environmental Relevant Laws


Work Package Environmental Aspect Environmental Controls
Impact and Prohibitions

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

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EPBC Act Eliminate source of seeds
Use of land clearing equipment Proliferation of AS/NSZ ISO 14001 Implement weed hygiene by cleaning
displacing weeds weeds machines and avoiding traversing paths
Weeds
Management Act with germinating weeds
1.1.2 Mass
Excavation EPBC Act
(cont.) If artifacts or relics are encountered,
Compromising AS/NSZ ISO 14001
Use of excavation tools and contractor must cease all excavation
cultural and
equipment damaging Heritage work. Site manager must then arrange for
historical
underground artifacts Protection Act specialists and community
heritage
representatives to survey the site.
Heritage Act

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

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1.1.4 Shoring

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

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EPBC Act
AS/NSZ ISO 14001 Establish and use a concrete wash-down
Waste and area
Disposal of concrete waste resources Waste
management Management and All set and excess concrete should be
Pollution Control recycled
Act

EPBC Act Cover up all drains on a construction site,


1.2.3 Concrete
parking nearby pumps as necessary
Placing Disposal of concrete waste Water quality AS/NSZ ISO 14001
Collect and treat wastewater before
Water Act
discharging as effluent

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

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1.4 Prepare an Environmental Management Plan Using Available Information
At this point, you will have done your due diligence on the environmental obligations
relevant to your construction project. This includes having built a regulatory framework and
having identified best practices for the environmental performance of your team’s
operations. Now, you will incorporate all these necessary inputs to design your EMP.

1.4.1 Content of the EMP


The core of the EMP is the set of procedures on environmental management, monitoring,
and auditing designed to promote regulatory compliance. While necessarily technical, an
EMP should be both effective and user-friendly. Your EMP should be accessible not only to
internal stakeholders but also to community groups and approval authorities. It should
properly introduce stakeholders to the project, describe how the EMP is to be implemented,
and propose how environmental indicators are to be monitored. All EMPs should therefore
contain the following aspects:

Front Matter

• Cover Page and Declaration of Accuracy


• Document Version Control
• Table of Contents

Background

• Introduction
• Project Description
• EMP Context
• Objectives
• Environmental Policy

Environmental Management

• Environmental Management Structure and Responsibility


• Approval and Licensing Requirements
• Reporting
• Environmental Training
• Emergency Contacts and Response

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Implementation

• Risk Assessment
• Environmental Management Activities and Controls
• Environmental Management Plans or Maps
• Environmental Schedules

Monitor and Review

• Environmental Monitoring
• Environmental Auditing
• Corrective Action
• EMP Review

Sourced from Environmental Management Plan Guidelines, used under CC BY 3.0.


© Department of Agriculture, Water and the Environment 2020.

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

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1.4.2 Competencies Required in Preparing an EMP
1.4.2.1 Delegating Environmental Responsibilities
The Environmental Management Structure and Responsibility section of your EMP lists all
key participants in the EMP preparation and implementation process, and their
corresponding responsibilities. Normally, information about each participant’s
responsibilities is organised through a table. The process of delegating environmental
responsibilities in this way offers two key functions:

clarifies and reinforces accountability

facilitates future consultation and decision-making

Key participants may be identified by consulting with the management team or by


developing a stakeholder register (discussed further in Section 1.5.1). Responsibilities may
be assigned on the basis of the general functions of each member based on the
organisational chart and how these functions may contribute to implementing the EMP.
Below is a sample table of key stakeholders to be included in decision-making and
consultation as well as their responsibilities:

Key Stakeholder Responsibilities

 Approves and endorses EMP


Senior management
staff  Communicates general environmental policy of
construction firm to stakeholders

 Implement all activities and controls in the EMP


 Audit sub-contractors’ environmental performance on a
confidential and strategic basis
Head contractor  Provide environmental management training
 Manage complaints
 Notify relevant agencies of any non-conformances with
the EMP

 Implement relevant sub-plans within the EMP


 Administer the environmental performance of each task
Sub-contractor(s) against the EMP
 Notify head contractor of any non-conformance with
the EMP

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 Comply with the standards set forth in the regulatory
framework including approval and licensing
requirements
 Carry out all activities in an environmentally responsible
way

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

Department of the  Audit construction site if necessary and evaluate


Environment and compliance of EMP with Commonwealth approvals
Energy
(Commonwealth)  Appraises annual monitoring reports

Territory-specific  Audit construction site if necessary, and evaluate


environmental compliance of EMP with Commonwealth approvals
protection authority  Appraise annual monitoring reports

Independent auditor  Appraise annual monitoring reports

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.

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Severity

Catastrophic Critical Moderate Marginal

Frequent High High High Medium

Probable High High Serious Medium

Likelihood Occasional High Serious Medium Low

Remote Serious Medium Medium Low

Improbable Medium Low Low 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:

the measures and the performance trigger values for


the description of commitments to objectives and additional action,
the risk minimise and monitoring review and
manage the risk programs reporting

Sourced from Environmental Management Plan Guidelines, used under CC BY 3.0.


© Department of Agriculture, Water and the Environment 2020.

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When deciding what aspects of construction to subject to risk assessment and future
evaluation or monitoring, it is useful to refer to the following areas of risk and associated
activities:

Area of Risk Associated Activities

Use of jackhammers, cement cutters, cement mixers,


Noise electric saws, tamping machines, dump trucks, welding
machines, sledgehammers, and drills

Land clearing, operation of diesel engines, demolition,


Air quality (dust)
burning, and using toxic materials

Water quality (chemical and Use of diesel and oil, paints, glues; cement cutting and
biological) mixing

Sediment controls, silt


Excavation, dewatering, concreting
fences, and traps

Discharge from retention


ponds, artificial wetlands Dredging, dewatering
and sediment dams

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.

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1.4.2.3 Proper Timing and Scheduling

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.

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Below are some common examples of hold points and witness points.
Common Hold Points:
 Submission of the EMP
 Submission of Permit to Survey Land
 Clearance from cultural and heritage councils
 Submission of permissions to clear vegetation
 Submission of camp site permission
 Submission of approvals for stockpile management
 Submission of water extraction licenses and approvals
 Submission of Permits to Extract Water from Bores
 Submission of Permits for Surface Water Extraction
 Approval by Site Superintendent of Dewatering Activities
 Notice of Discovered Threatened Species on Site
 Notice of Threatened or Nesting Animals
 Notification of the Transport and Deposit of Waste

Common Witness Points:


 Demarcation of Site and Marking Off No-Go Areas
 Establishment of Ancillary Areas (e.g. detours and turnarounds)
 Cleaning of Equipment and Plant
 Notice of Pets
Be sure to describe the procedures and key monitors involved in the Environmental
Schedules section of your EMP. For example, should endangered species be encountered
during construction, the EMP should indicate that:
 consultations should be arranged with relevant environmental agencies
 temporary barriers should be mounted to protect the fauna
 all construction work should be ceased until recommendations have been sought
from appropriate authority
Note that such hold points and witness points should be integrated into the master
schedules of the construction project. This will allow all members of the construction team
to observe the monitoring and inspection requirements accordingly.

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1.5 Seek Senior Management Advice Concerning Implementation of the Plan as
Required
Stakeholder consultation is an essential step in crafting EMPs. Expert judgement will help
you determine the feasibility of your EMP. In particular, senior management team members
will help in appraising whether your EMP is economical and may suggest cost-effective
measures. Senior management also offers organisational perspective and may help identify
the potential factors and barriers to promoting compliance with the EMP among team
members. Since senior management advice is crucial input in EMPs, it is best to adopt a
standard procedure for the consultation process as shown below:

Develop stakeholder register

Consult with senior management

Incorporate Feedback

1.5.1 Develop a Stakeholder Register


The stakeholder register is a management tool used to enumerate all identified key
stakeholders and lay out their various competing interests. This contains all details related
to the identified stakeholders including, but not limited to:
 Identification information. Name, organisational position, location, role in the
project, contact information
 Assessment information. Major requirements, main expectations, potential
influence in the project, phase in the life cycle with the most interest
 Stakeholder classification. l/external, supporter/neutral/resistor, etc.
More details on these classifications below:

Location Level of Engagement

Unaware. Uninformed of project and potential impacts


Internal. Stakeholders Resistant. Aware of project and potential impacts and
within the organisation resists change
such as senior
management Neutral. Conscious of project yet is indifferent to the project

External. Stakeholders Supportive. Conscious of project and potential impacts and


outside the organisation supportive to change
such as subcontractors Leading. Conscious of project and impacts and actively
taking steps to ensure project success

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).

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Several stakeholders exist, including:
 the management team;
 the head contractor; and
 the subcontractors.
However, this section will focus on the senior
management.
You can use the information derived from the
stakeholder register to prepare for your
consultations with them, making initial
assessments on their level of engagement with
their current roles.

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An abbreviated example is shown below:

Identification Information Stakeholder Classification

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

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1.5.2 Consult with Senior Management
Once you have prepared an initial profile of the senior management team members through
the stakeholder register, you must use the appropriate techniques to facilitate productive
discussions with them. These may be done through the following techniques:

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

Surveys whereby overall attitudes, perceptions and other characteristics are


quantified and summarised

For a more detailed discussion regarding how these techniques are used, see Section 3.1.
Best practices during consultation include the following:

Furnishing senior management with proposed EMP

 This allows your participants to prepare for the consultation and formulate
insights that can be discussed further during data collection.

Taking notes during the consultation

 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.

Updating participants on relevant outcomes

 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.

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Feedback may also be gathered through informal means as through chance conversations
and anecdotes from senior management. These may be touched upon during meetings or
even minutes after the formal consultation process, so be sure to be alert and ask follow-up
questions.
The advantage of using informal means is that participants feel less pressured to respond
appropriately to facilitative questions. Hence, more authentic viewpoints steeped in
organisational realities can be obtained in addition to the on-the-record accounts.
Be sure to document these anecdotes through daily job site diaries alongside your formal
data gathering documentation.

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1.5.3 Incorporate Feedback
Your consultations with the senior management team are likely to generate significant
revisions in your EMP. To organise the responses you gain from senior management, you
must make use of documentation mechanisms to summarise feedback given and how it was
incorporated in the EMP. Such mechanisms are shown below:

 a register listing the key issues identified during


Issue log consultation and whether or not they have been
resolved
 a form which details the proposed changes, corrective or
Change Requests preventive actions of a stakeholder to the project, in this
case the EMP
 a section within the EMP which lists all official versions
EMP Version
of the EMP and the changes in content and form that
Control
took place per version
 documentation that explains the root cause analysis of
problems encountered, rationale behind remediations
Lessons learned undertaken, and other kinds of lessons learned through
documentation consultation. Such lessons are documented and
distributed and are incorporated in the historical
database of the project and the organisation
 includes other relevant documents to be updated such
Other Project as the stakeholder register, specifically the level of
Document engagement and updates of each stakeholder, and
Updates project records such as memos, minutes, status reports
and presentations

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.

Checkpoint! Let’s Review


1. What is the difference between a legislation and a
regulation?
2. What is the overarching standard of ISO for environmental
management?
3. What is the difference between an aspect and an impact?
4. List key people to be consulted in drafting and
implementing the EMP.

5. Why is it important to have the EMP signed off by senior


management?

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Further Reading
The EPBC Act is the central legislative piece on environmental
protection in Australia. Read the resource below for more
information on the EPBC Act, documenting all relevant
amendments and appraisals of the said law.
Environment Protection and Biodiversity Conservation Act 1999
(EPBC Act)

In addition to the environmental legal standards mentioned, you


should also take time to study the general legislation on building
and construction so that you will be able to contextualise your EMP
within fair work practices. You can read overview of relevant
legislation through the link below.
ABCC Legislation

Calculating and reporting against environmental indicators


demands precision and thoroughness. You can read technical
guidelines on how these may be accomplished through the link
below.
Triple Bottom Line Reporting in Australia

Classroom Activity for Chapter 1


Well done completing this chapter. You may now proceed to your
Classroom Activity Booklet (provided along with this Learner
Guide) and complete the classroom learning activities associated
with this chapter.
Please coordinate with your trainer/training organisation for
additional instructions and guidance in completing these
practical activities.

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II. Manage Environmental Management Plan Implementation
It is time to translate the EMP you have developed into practice. Implementing the EMP is
no easy task. At the heart of the EMP are the environmental controls and activities that will
mitigate the environmental impact of your project. For these to work, you have to coordinate
technical information from various communication channels and data gathering systems.
In light of this, this chapter will discuss the basics of managing the environmental
management plan implementation, including:
 informing staff and contractors of their obligations to comply with the environmental
plan;
 monitoring staff and contractor compliance with implementing the environmental
plan;
 managing the effectiveness and accuracy of environmental data gathering systems;
 evaluating new projects to determine their impact on existing environmental
planning obligations;
 contacting local authorities and regulatory bodies where the plan requires ongoing
external monitoring or overseeing;
 communicating information to staff and stakeholders concerning updates to the
environmental management plan; and
 managing and evaluating the environmental management plan and tracking
changing circumstances to maintain organisation compliance.

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2.1 Inform Staff and Contractors of their Obligations to Comply with the
Environmental Plan
Everybody in the team should be aware of their roles in managing the environmental impact
of their construction operations. The primary way by which you can inform staff and
contractors of their environmental obligations is through training sessions identified in the
EMP, such as:

• orients staff and contractors to the physical and


environmental layout of the construction site
Site induction
• briefs staff and contractors on the general
environmental risks inherent to the site

• trains all relevant personnel in handling oil spills, fire


Emergency accidents and hazardous substances
response and
preparedness • informs them of preventive measures to reduce the
incidences of environmental emergencies

• briefs staff and contractors to checklists, inspection and


Familiarisation test plans, regular audits, and work method statements
with
environmental • details their corresponding roles and responsibilities in
controls relation to complying with the above environmental
controls

• informs staff and contractors on their specific role in


implementing the EMP based on the nature of their task
Task-specific
training • trains relevant staff on installing sedimentation and
erosion controls, regular checks to maintain controls,
cleaning up spills, and minimising material waste

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.

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2.2 Monitor Staff and Contractor Compliance with Implementing the
Environmental Plan

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:

conformance reporting employee and contractor reports

environmental management
statistical and analytical data
meetings and briefings

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2.2.1 Conformance Reporting
You must assign relevant construction personnel to report on how the construction team
has performed against set environmental performance indicators. These are called
conformance reports and should be accomplished by key people in the team such as
subcontractors and the environmental management representative. A conformance report
should include:
 environmental outcomes to be achieved
 response indicators, which are the environmental characteristics that tell of the
environmental impact of construction operations
 response criteria, which are the threshold or trigger levels in relation to the indicators
 corrective or preventive actions, if necessary
Based on content from Instructions on how to prepare: Environmental Protection Act 1986 Part IV,
Environmental Management Plans. Used with permission from EPA Western Australia.

An example of conformance reporting is shown below:

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.

The sample process of conformance reporting is complete. It clearly identifies its


environmental outcome as maintaining the seagrass communities in the nearby lagoon. It
sets out the appropriate response indicator and criterion (i.e. chlorophyll a concentration
should be below the 80th percentile of initial data gathering). Furthermore, it briefly
describes an investigation procedure that should be done when the response criterion is not
met.
The above example focuses on discharge monitoring. In general, though, you should ensure
that you get conformance reports from your staff and contractors on the following
environmental concerns:

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Soil and Weed Hazardous Waste
Air emissions reporting
Management Reporting Reporting

Discharge Monitoring
Toxic Release Inventory
Reporting

2.2.2 Environmental Management Meetings and Briefings


You should also ensure that your
construction team meets regularly to
discuss key issues in environmental
management. In addition to the
conformance reports which detail the
compliance of specific aspects of
construction with the EMP, the meetings
and briefings should provide a big
picture of environmental performance.
In particular, you should organise your
meetings with these key points in mind:
 attendance of members and roles
 agenda last meeting and matter arising
 summary of results from inspections and audits
 summary of communications from external parties, including complaints
 current and recent environmental performance of the organisation
 status of corrective and preventive actions
 follow-up actions from previous meetings
 changing circumstances, including shifts in legal and other requirements related to
environmental management
 actions for continuous improvement
Be sure to document the proceedings of the meeting through meeting minutes so that
personnel can continually refer to issues discussed when planning ongoing and future
operations.

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2.2.3 Employee and Contractor Reports
You should also take advantage of progress reports from your employees and contractors.
Progress reports are meant to summarise what has been done to meet requirements on
speed, cost, quality and safety. However, it is ideal that there be a section in the progress
reports on environmental performance, if not a dedicated report as such.
In particular, this section or report should include:

Date of the report

Relevant personnel involved and their responsibilities

Recent performance on identified environmental indicators

Issues identified and problems encountered

Strategies and solutions applied to problems encountered

Implications of current environmental performance on construction operations

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.

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2.2.4 Statistical and Analytical Data
Some of the most reliable monitoring systems you can implement in your EMP are statistical
and analytical data gathering systems. A main advantage of data gathered from such systems
is that they are generalisable. This means that just a small data sample can already tell you
a whole lot about the environmental system you are concerned about.
Consider the previous example on ‘chlorophyll a’ concentration. It would be ridiculous for
you or your EMR to monitor the ‘chlorophyll a’ concentration levels on every section of the
lagoon every day. In fact, it may be more practical to just take several vials of water from the
lagoon at key moments during construction – one week after excavation, for example – and
at strategic sections – nearby waterway channels, for instance – and send those water
samples for analysis. You may decide that the level of ’chlorophyll a’ concentrations from
these samples relative to samples in the past would already be enough in determining the
health of the lagoon.
The above scenario describes the process of sampling. In general, sampling is the
procedure of taking a small portion of a whole system and drawing conclusions about that
system based on just the small portion you have taken. This process is illustrated below:

Assumption: The ‘chlorophyll a’ concentration of this water


sample is about the same as that of the whole lagoon.

Near-perfect conclusion: ‘Chlorophyll a’ concentration of the


whole lagoon is about 17% higher after construction
operations.

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Because you are just taking a small portion of the whole system, you might be concerned
that the data you have gathered is not representative. This means that the small data sample
you have does not really mirror the true state of the whole environmental system. This is
why there needs to be strict procedures on the types of sampling that can be performed.
This is more thoroughly discussed in Section 2.3 which emphasises maintaining the accuracy
and effectiveness of environmental data gathering systems.
In general, there are four components of a statistical or analytical data gathering system. As
site manager, it is your responsibility to ensure that the four components work harmoniously
in monitoring environmental performance through conformance reports, progress reports,
and meetings. These components are summarised below:

• 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

Data gathering • environmental management representative


and analysis • outsourced lab technicians
administrators • head contractor

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2.3 Manage the Effectiveness and Accuracy of the Environmental Data
Gathering Systems

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:

• Environmental data gathered are correct, or captures the


true impact of environmental operations
Accurate • Environmental data gathered are representative, or
reflects the state of the whole environmental system or
subsystem in concern

• Methods for data gathering are cost-effective, requiring


only specialised equipment if necessary
Effective
• Methods for data gathering are efficient and can be
consistently performed

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.

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In particular, it becomes your responsibility to manage two distinct components of such a
system, namely:

Data collection and sampling Data analysis and reporting

2.3.1 Assuring Sampling Integrity


Sampling enables you to achieve an accurate and effective data gathering system. If
performed correctly, it allows you to accurately estimate the value of an environmental
indicator. It is also convenient because you only need to collect a few samples to generate
findings.
However, sampling is quite technical. You may outsource lab technicians to collect and
analyse data for you. However, as site manager, you are expected to demonstrate working
familiarity with how data are gathered so that you too may verify the reliability of data.
Below are four of the most common types of sampling techniques used in environmental
data gathering:

• samples are collected at the same time to represent


Grab Sample
conditions at a certain time

• multiple grab samples gathered over an interval and


mixed together
Composite Sample
• stands for the average conditions of a system over a
period of time

Continuous
• samples are measured in increments
Sample

• samples taken at fixed-time intervals of substantial


Periodic Sample duration to produce a representative estimate of
emissions across a full range of environmental condition

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

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These sampling techniques are used to gather data from a variety of environmental
subsystems such as soil, stockpile, air, water, weather, noise and odour. Specific ways on
how these techniques are applied per subsystem may be studied further through the
references listed in the table below. They address topics such as proper handling of sampling
equipment, the types of sampling applied, and how to analyse results. You will be able to
assess your environmental data gathering system based on these authoritative references.

Subsystem Relevant Reference

AS 4482.1–2005 Guide to the investigation and sampling of


sites with potentially contaminated soil, Part 1: Non-
Soil volatile and semi-volatile compounds
AS 4482.2-1999 Guide to the Sampling and Investigation of
Potentially Contaminated Soil, Part 2: Volatile Substances

Environmental Guidelines: Use and Disposal of Biosolids


Stockpile Products – Schedule 1: Biosolids Sampling & Analysis
Procedures

AS/NZS 3580.10.1:2016 Methods for sampling and analysis of


Air ambient air - Determination of particulate matter –
Deposited matter – Gravimetric method

Water AS/NZS 5667.1-1998: Water Quality-Sampling

AS 2923–1987: Ambient Air – Guide for measurement of


horizontal wind for air quality applications
Weather
AS/NZS 3580.1.1 2007: Methods for sampling and analysis of
ambient air – Guide to siting air monitoring equipment

NSW Industrial Noise Policy 2000


AS/NZS IEC 61672.1:2019: Electroacoustics - Sound level
Noise meters Specifications
AS/NZS IEC 61672.2:2019: Electroacoustics - Sound level
meters Pattern evaluation tests

Approved methods for the sampling and analysis of air


Odour
pollutants in NSW

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2.3.2 Ensuring Proper Data Analysis and Reporting
Statistical analysis methodologies are processes that allow your data to be transformed
from raw sample data into findings about your system as a whole. These methodologies
include:

Estimating the value of an environmental indicator at a specified time (e.g.,


estimating air pollutant concentration last week)

Comparing the values of an environmental indicator at settings (e.g., determining if


air pollutant concentration is the same across project sites)

Generating trends regarding an environmental indicator over a period of time (e.g.,


tracking air pollutant concentration across the construction life-cycle from
construction planning to the use of the building)

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

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 the details of the sample (properties of the sample, location where it was taken, etc.)
 Units of measurement (e.g. 'mg/kg dry weight' or 'mg/kg as obtained' not only
'mg/kg'); specific statements must be made for soils if the sample is not in the usual
'land moist' state (e.g. 'already dried and sieved','freeze-dried', etc.)
 a description of the test method used
 equipment and analytical method used
Based on Laboratory Analysis, used under CC BY 4.0. ©Ministry for the Environment
Based on Strategic Environmental Compliance and Performance Review. Department
of Environment, Climate Change and Water NSW © State of New South Wales
through the Environment Protection Authority

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.

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2.4 Evaluate New Projects to Determine their Impact on Existing Environmental
Planning Obligations

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.

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Step 2: Update the Environmental Management Activities and Controls section of your
EMP.
Consider if:
 Some environmental controls may need to be added to suit the context of incoming
projects and/or improve environmental management of existing projects.
 Some environmental controls may need to be modified to accommodate all
incoming and existing projects.
 Some environmental controls may need to be deleted due to outdated controls in
light of the firm's new portfolio.
Incorporate the above considerations as necessary.

Step 3: Properly communicate the updates to the EMP.


Document updates in the Version Control section of the EMP. Have Senior Management
sign off the revised EMP, if updates materially impact construction operations.
Announce the updates to relevant stakeholders, using:
 Memos and meetings for employees (see Section 2.6.1)
 Press releases and annual reports for external stakeholders (see Section 2.6.2)

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2.5 Contact Local Authorities and Regulatory Bodies Where the Plan Requires
Ongoing External Monitoring or Overseeing

There may be times when local authorities and regulatory bodies need to monitor your
project:

when there is a need for assistance in assessing a priority environmental risk

when there is a need to assist with the management of an environmental risk

Sourced from Regulatory Monitoring and Testing – Monitoring Plans Requirements,


used under CC BY 4.0. EPA South Australia Copyright © 2020 EPA

Construction projects with a high environmental risk usually require monitoring from
external agencies.

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The table below lists the relevant environmental authorities per state or territory and the
webpages leading to their contact details.

State/Territory Contact Webpage of Environmental Authority

Australian Capital Environment, Planning and Sustainable Development Directorate


Territory - Environment

Northern Territory Northern Territory Environment Protection Agency

New South Wales Environmental Protection Authority – New South Wales

Queensland Queensland Environment Department

South Australia South Australian Environment Protection Authority

Tasmania Environment Protection Authority Tasmania

Victoria Environment Protection Authority Victoria

Western Australia Environmental Protection Authority of Western Australia

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2.6 Communicate Information to Staff and Stakeholders Concerning Updates to
the Environmental Management Plan
Updates to the EMP happen for a variety of reasons, including:

Shifts in legislation and regulations

Trending best practices in environmental performance

Interventions proposed by local authorities and regulatory bodies

New environmental conditions discovered during construction work

Changes as a result of the continuous improvement process

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:

briefly summarise the changes in the EMP

refer to the EMP’s version control which indicates the specific sections
where significant changes took place

motivate your staff to implement the changes and undertake a process of


continuous improvement

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.

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2.6.1.2 Meetings
Meetings, on the other hand, should serve as a forum for discussing the changes in the EMP.
They should be opportunities for:

staff to ask questions and clarifications about how the changes would affect the day-to-
day operations of each staff member

site managers to reinforce understanding of the changes

site managers to promote teamwork among staff members in coordinating their


individual environmental obligations

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:

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briefly describe the contextual shifts that led to the changes in the EMP

present summary bullet points of changes in the EMP

include quotes from senior management staff endorsing the changes

include contact details of relevant personnel who administer the EMP

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:

the wider history of significant changes to the environmental management plan

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)

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In essence, such reports take a long-term view of environmental management and projects
the impact of the EMP and its changes on the financial and operational conditions of the
firm.

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2.7 Manage and Evaluate the Environmental Management Plan and Track
Changing Circumstances to Maintain Organisation Compliance
As you execute your environmental management plan, you must manage and evaluate its
processes and outcomes as they relate to your wider environmental goals. This can be done
through auditing. Auditing is the formal examination of your EMP’s legal compliance.
Compared to inspections, auditing focuses on the root causes of potential problems for
broader environmental performance and is performed by high-level personnel.
There are two types of auditing, namely:

• undertaken by construction firm to perform its own due


Internal diligence on its environmental performance
• usually voluntary

• undertaken by a regulatory body or a certified


environmental auditor engaged by the construction firm
External
• usually mandatory, for example, as part of licensing
arrangements

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

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2.7.1 Plan Internal Audit
To make the audit as thorough and as systematic as possible, you have to create an audit
plan. An audit plan contains:

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.

Logistics of conducting the audit


• This specifies any potential barriers to the audit process such as safety
requirements and weather conditions.

Audit timetable
• This details the date and places where on-site activities will be
conducted, and the expected time and duration of each activity.

Roles and responsibilities


• This delegates the responsibilities during the audit process—whether it
will be conducted by one person or a team, and what the duties of each
party are.

Allocation of appropriate resources


• This guarantees that all inspection equipment and administrative tools
are available during the audit process.

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.

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2.7.2 Conduct Internal Audit
Based on the audit criteria and checklist, the auditor assigned in the EMP shall examine
evidence of conformances and non-conformances. Evidence may be gained from the
following methods:

• pertains to getting verbal evidence from


individual staff members at all levels of the
hierarchy either based on random selection
or on their responsibility
Interviewing
• may point the way to other audit trails that
will escalate to problems
• gives a profile of the general perceptions
around the construction site

• becoming observant and taking note of


details of operations currently happening, as
well as past and imminent problems
Viewing
• involves using the five senses to apprehend
the qualitative aspects and issues of
environmental management

• relates to studying documents and records,


and monitoring data
• provides a summary of current and past
operations
Reviewing
• may reveal inconsistencies between what is
on the paper work and what happens in
practice revealed through interviews and
observations

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.

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s

2.7.3 Report Findings


After gathering evidence from the audit, the auditor must then generate the findings of the
audit through an audit report. The audit report must contain:

The specific industrial process or activity, waste, substance or noise in respect of which
the environmental audit was conducted

The name of the person engaged as an auditor

Signature of the auditor

Results of the environmental audit

Sourced from 952.5: Preparation of environmental audit reports on risk


to the environment, used under CC BY 4.0. © EPA Victoria

Part of the results of the environmental audit should be whether the firm tracks changing
circumstances with regard to environmental management. Such circumstances include:

Shifts in legislation or regulation

New environmental conditions discovered on site

Changes recommended by community stakeholders and regulatory bodies

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.

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2.7.4 Complete Corrective Actions
It important to gather environmental data after the implementation of an EMP because
environmental data is one way that you can measure the effects of the EMP. Depending on
what the data is about, values should consistently increase or decrease while the EMP is in
place. For example, if the environmental data is about carbon emissions from buildings, then
ideally, you would see emissions go down over time. If values stay the same (or increase),
then that means that something is wrong with the EMP or its implementation and that
corrective action needs to be made.
Before implementing the corrective actions, you must consult with your construction team
regarding necessary strategies to do so. The proceedings for coming up with strategies
should be documented through meeting minutes and daily job site diaries. As strategies are
agreed upon, corresponding changes should be made by revising the EMP (see Section 4.3).
Afterwards, you should coordinate with your staff and contractors with regards to
subsequent changes in safety precautions, standard operating procedures, and work
instructions. Having accomplished this, you should communicate all changes in
environmental responsibilities through a memo referring members of your construction
team to the revised EMP and operational procedures.

Checkpoint! Let’s Review


1. What are the different kinds of training involved to inform
your staff and contractors regarding their environmental
obligations?
2. What are the four monitoring systems you can use to
monitor staff and contractor compliance?
3. What are the four common types of sampling?

Classroom Activity for Chapter 2


Well done completing this chapter. You may now proceed to your
Classroom Activity Booklet (provided along with this Learner
Guide) and complete the classroom learning activities associated
with this chapter.
Please coordinate with your trainer/training organisation for
additional instructions and guidance in completing these
practical activities.

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III. Monitor Organisational Legal Obligations
As you implement your EMP, you have to keep track of your firm’s corresponding legal
obligations. The regulatory framework of your EMP forms a strong foundation for this task.
However, it is not enough that you rely on this for the rest of the EMP implementation phase.
For one thing, the interpretation of legal standards by staff and contractors along the chain
of responsibility may lose consistency. As site manager, you will have to regularly check on
your construction team’s legal compliance through effective internal and external feedback
systems.
This chapter will discuss the essentials of monitoring organisational legal obligations,
including:
 managing organisational feedback systems to assist with conformance of the plan;
 seeking regular feedback concerning the operations of the environmental
management plan to assist the organisation to meet its legal obligations;
 managing and maintaining legally required auditing practices to ensure probity and
accountability towards legislative requirements;
 maintaining contact with contractors and monitoring their compliance with
environmental management requirements; and
 implementing emergency and remediation response strategies as necessary to assist
compliance with the environmental management plan.

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3.1 Manage Organisational Feedback Systems to Assist with Conformance of
the Plan

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

• Surveys • Meeting Points


• Interviews • Conversations
• Focus Groups

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3.1.1 Formal Feedback Systems
Formal feedback systems are those systems in which feedback is prepared beforehand and
scheduled into the official processes of the firm. They are also related to required
communication and routines from the hierarchical relationships between and among site
managers, contractors and subcontractors. Chief techniques used in such systems and ways
of managing them are described below:
 Surveys
A survey is a list of questions whose aim is to extract the attitudes of your
construction team, in this case, attitudes about the legal compliance of the EMP. The
advantage of using surveys is that they allow you to gain a general idea regarding the
environmental compliance of your team members.
When you construct a survey, you will make use of numerical scales to assess your
team member’s attitudes in the following manner:

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

Proper waste management

Water quality management

Noise management

Fire emergency response

Oil spill remediation response

Some guidelines on administering surveys include:


o Administer the surveys regularly, perhaps monthly or biannually (depending
on the scale of your project) to track the general compliance of your team
throughout time.
o Put optional fields for names and other identifying details. This allows your
respondents to maintain their privacy and, at the same time, give them the
opportunity to disclose their identity for context-sensitive feedback.
o Consider adding open-ended questions at the end of subsections of your
survey in case your respondents may want to add qualitative comments
regarding their scores.

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 Interviews
An interview is a structured conversation whereby one party asks questions and the
other gives answers. Compared to surveys, interviews allow you to probe deeper into
the opinions offered by your participant. In the context of your construction firm,
there are several avenues for interviewing, including performance reviews or actual
sit-in interviews. No matter the reason for the interview, it is crucial to incorporate
matters on environmental performance. The best way to do this is to ask about their
experiences of implementing the EMP using ‘what/why/how’ questions rather than
‘yes/no’ questions meant for surveys. That is why you need to prepare a set of
questions beforehand which will serve as starting points for conversation about the
topic. Then you may ask follow-up questions based on your participant’s answers.

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A sample topic and set of questions is shown below:

Topic Recent Changes in the Waste Management Plan

Interviewer Joe Teluk, Site Manager

Interviewee Theo Johnson, Concreting Contractor

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?

Some guidelines on administering interviews include:


o Keep the interview a two-way conversation. Include opportunities for the
interview to ask questions from you too.
o Document the interview. Take notes on the answers offered by your
interviewee alongside the questions. Not only will this help summarise key
points, it will also help you form follow-up questions during the interview. You
may also record the interview, provided that you seek permission from the
interviewee.
o Close the interview on a proper note. Thank the interviewee for sharing their
insights and assure them that their insights will be considered in the
management review (see Section 4.3) of the EMP.

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 Focus Groups
Focus groups are essentially group interviews used to gather a range of opinions from
different members of the company and of the project teams. They focus on how the
different members within a department, trade, or construction firm coincide with or
differ from each other in terms of interpreting or practicing EMP obligations.
As site manager, you may be tasked to facilitate focus groups. All this really involves
is the capacity to facilitate a discussion and a set of questions to drive the discussion
forward. Focus group questions are like interview questions in that they should ask
‘what/how/why’ questions but they are structured in a way that tries to pool the
opinions of everyone.
Questions for focus groups should be structured in a way similar to those below:

Topic Sourcing an EMR

Interviewer Joe Teluk, Site Manager

Participants

Thea, Concreting Contractor; Julio, Excavation Contractor; William, Plumbing


Contractor; Carla, HVAC subcontractor; Lemuel, Landscaping Contractor; Tricia,
Rebar Subcontractor; Andre, Demolition Subcontractor; Rafael, Painting
Subcontractor

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?

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Some guidelines on administering focus groups include:
o Set the number of participants to 8-10 so that facilitating the focus group is
more manageable. This means that you should invite only the necessary
representatives from each department or subcontracting trade who will have
relevant experiences and insights on the topic at hand.
o Promote open discussion. It is your responsibility to create an environment
that respects differences in interpretation and does not coerce them to reach
consensus or definitive stances. You may do so by ensuring your questions
are broad and open-ended, and not biased.
o Document the focus group. Take notes on the answers offered by your
participants alongside the questions. Not only will this help summarise key
points, it will also help you form follow-up questions during the interview. You
may also record the interview, provided that you seek permission from the
participants.

3.1.2 Informal Feedback Systems


Informal feedback systems are those systems in which feedback take place in day-to-day
interactions, as an unplanned event. They are also related to feedback that are unsolicited
or voluntarily provided. Primary avenues for informal feedback and ways of managing them
are detailed below:
 Meeting Points
At this point, it is crucial to discuss the fact that the formality or informality of
feedback systems exist as a continuum. For example, meetings are formal events to
discuss the progress of the project and of environmental performance. However, in
the context of feedback systems, they are informal because meetings are not
designed primarily to provide feedback, and feedback provided may be incidental. In
this sense, meetings are informal relative to surveys and interviews.
In this sense, the best way to capture feedback during meetings is to provide a
separate agenda for feedback on environmental performance. This way, there will be
an opportunity for construction team members to share their insights regarding
insights and challenges in environmental compliance. As always, you should
document the meeting points raised through the meeting minutes so that
participants may follow up on any feedback they have given.

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 Conversations
Chance conversations and anecdotes from key people such as foremen and
subcontractors are vital sources of feedback often left undocumented. They provide
rich, informal accounts regarding how environmental obligations are actually
performed that may not be covered during formal interviews. For example, a
foreman may reveal that he actually does not know the relevance of updated
legislation in his environmental management sub-plans but could not bring it up
during structured interviews. In such cases, it may be necessary to record relevant
feedback as an entry in your job site diary. The entries should contain relevant
information such as:
o the names of the people who corresponded
o date and time of correspondence
o project involved in
o location
o summary of feedback

3.1.3 Feedback Documentation


You can only make use of the feedback you have gathered if you have documented them
properly. The table below summarises the documentation that you must keep per feedback
source:

Form of
Type of Feedback Documentation
Communication

Survey Duly accomplished survey form

Interview questions
Interview
Formal Interview notes

Focus group questions


Focus Groups
Focus group notes

Meeting agenda
Meeting Points
Informal Meeting minutes

Conversations Job site diary entry

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To make it more convenient for you, you may opt to use spreadsheet programs as aid in
analysing and summarising survey and interview data (see Further Reading at the end of this
chapter). This will also allow you to store the relevant data for easier access and over a longer
period of time.
One of the reasons for properly keeping feedback documentation is that you will use this as
you revise your EMP during the management review (see Section 4.3). The management
review is the stage of the environmental management process which allows you to fully
consider the feedback provided by your construction team members and incorporate them
into the revised version of the EMP. Therefore, throughout the feedback-gathering process,
you should assure your participants that their insights are accounted for and follow them up
on changes in the EMP.

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3.2 Seek Regular Feedback Concerning the Operations of the Environmental
Management Plan to Assist the Organisation to Meet Its Legal Obligations
Because your construction project ultimately impacts the surrounding community and
environment, it is also important for you to engage externally. This means seeking regular
feedback from external stakeholders such as:

the community

regulatory bodies

3.2.1 Feedback From the Surrounding Community


As site manager, you will need to seek feedback from the surrounding community regarding
your environmental impact. Remember that community engagement is not only the right
thing to do but is also strategic. Productive relations among community members contribute
to smooth operations which leads to project success. Stakeholders may include the
following:

Civic organisations

Resident associations

Local businesses

Local residents

Town or parish councils

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There are several methods for garnering feedback from the above stakeholders, including:
 Printed materials
These are used to lay out information for proposals such as event invitations relevant
to the construction project to presenting information about a project. Questionnaires
may also be included to gather initial feedback regarding such events and the project
in general. Ensure that the population is carefully considered so that enough
stakeholders are contacted about the proposals.
 Meetings
These are avenues for local residents and interest groups to voice their concerns and
proposals on a large-scale basis. Remember though that larger meetings may not
provide the opportunity for all stakeholders to input their concerns due to time and
logistical constraints. In this case, smaller-scale meetings may be better for more in-
depth conversations with specific groups on defined issues.
 Digital Media
This method makes use of a dedicated website or social media page to provide an
online presence enabling people to review information on a proposed project.
Feedback may be gathered through online feedback forms, comments, and private
messages. This allows different groups of people to share and debate on ideas and
maintain project transparency.

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

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3.2.3 Feedback From Environmental Agencies
If your construction firm is generally compliant with environmental regulations, you can
simply rely on the built-in feedback of the compliance mechanisms of regulatory bodies.
These include:
 Annual compliance statement
These are annual reports required by environmental protection agencies (e.g. EPA
Victoria, EPA South Australia) that report on:
o the environmental performance of the construction firm
o how the construction firm complied with the minimum standards set out by
the regulatory body
After being accomplished, annual
compliance statements should be
duly signed by the senior executive of
the company. In doing so, the
construction firm is testifying to the
accuracy and credibility of the
statement.
Should they find non-conformance in
your compliance statement or find
discrepancies between your
compliance statement and the
intelligence they have gathered
through community reports and
compliance audits, the regulatory
body may provide feedback through:
o advisory letters
o formal warnings
o show cause letters
o official cautions
Severe non-conformances may be issued with more stringent measures such as:
o pollution reduction programs
o variations, suspensions and cancellations of regulatory instruments
o notices, directions and orders
Ensure that the feedback received from regulatory authorities are summarised in
lessons learned documentation. This will be used when making revisions to the EMP.

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 Compliance audits
As part of their compliance policy, regulatory bodies will generally conduct
announced and unannounced audits on firms and individual which own licenses to
operate. Audits are formal examination of the environmental compliance procedures
of individuals and business entities. Regulatory bodies use a variety of methods to
assess compliance such as interviewing staff, analysing documents, and observing
work site processes. Findings are then generated in an audit report to summarise
how the entity fared with enumerated environmental requirements. You should
analyse the audit report to inform the improvement process of your EMP. Audit
reports will usually make use of the following legend to recap findings:
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.

‘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

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3.3 Manage and Maintain Legally Required Auditing Practices to Ensure Probity
and Accountability towards Legislative Requirements

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:

by attaching conditions to an approval requiring an environmental audit of the approved


action to be carried out under section 134 of the EPBC Act

by directing the holder of an environmental permit or approval to carry out an


environmental audit under section 458 of the EPBC Act

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.

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Having been compelled to undertake an independent audit, you have to follow a strict
process that will ensure a comprehensive, well-documented, and successful audit, as
illustrated below:

Source an auditor

Develop audit criteria and methodology

Commence audit

Seek audit approval

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

3.3.1 Sourcing an Auditor


You need to search for a third-party auditor who is capable of assessing your EMP. You may
search for suitable environmental auditors through the Internet. Here are the criteria you
may use to determine if an auditor is trustworthy:
 accredited by certification organisations like Exemplar Global, the Environment
Institute of Australia and New Zealand (EIANZ), or other equivalent organisations
 is able to present relevant credentials through curriculum vitae and other audit
qualifications
 has no previous engagements with your firm (e.g. consultancy) that may compromise
independence
Once you have engaged a suitable auditor, you must ask them to provide a written
declaration of their independence. The declaration of independence should state that the
auditor has no conflict of interest and will be diligent in maintaining their independence.
After which, you need to submit the independence form and relevant documentation on
qualification and accreditation to the regulatory body. A delegated official will review the
nominated auditor and check if there are any problems with independence or lack of
qualifications.

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If the regulatory body is satisfied with the requirements submitted, it will give your firm a
notice to carry out the audit. It may require you to provide further evidence for the suitability
of your nominated auditor or search for another auditor that satisfies the requirements. The
process of sourcing an auditor normally takes two months.

3.3.2 Develop Audit Criteria and Methodology


When you are authorised to proceed with the audit process, you can now begin developing
the audit criteria and methodology. Specified matters to be covered during the audit may be
found in the notice to carry out the audit or accompanying documents.
The approved auditor must create the audit criteria and methodology based on the approval
conditions stated in the approval notice when the EMP was submitted to the regulatory
body. To be precise, the criteria and methodology must:
 be founded on the relevant approval
 include subsequent variations on the approval
 address all approval conditions such as elements of conditions and controls required
by management reports, plans, or programs
After development, the proposed criteria and methodology must be submitted to the
regulatory body. They must provide a high-level view of how the audit is to proceed.
The regulatory body will then evaluate the proposal on the basis of its compliance with the
approval conditions. Only proposals sufficiently covering the approval conditions will be
approved.

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3.3.3 Commence Audit
After receiving the written approval from the regulatory body, the audit can commence. The
audit can be conducted using a variety of methods, as summarised in the table below:

Method of Audit Description

 pertains to getting verbal evidence from individual staff


members at all levels of the hierarchy either based on
random selection or on their responsibility
Interviewing  may point the way to other audit trails that will escalate
to problems
 gives a profile of the general perceptions around the
construction site

 becoming observant and taking note of details of


operations currently happening, as well as past and
imminent problems
Viewing
 involves using the five senses to apprehend the
qualitative aspects and issues of environmental
management

 relates to studying documents, records, and monitoring


data
 provides a summary of current and past operations
Reviewing
 may reveal inconsistencies between what is on the
paperwork and what happens in practice revealed
through interviews and observations

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.

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3.3.4 Seek Audit Approval
The auditor must furnish the approval holder a signed
audit report with letterhead detailing the audit results.
Afterwards, you need to submit the duly accomplished
and signed audit report to the regulatory body within
the specified timeframe.
Then, the regulatory body will review the audit report. If
the regulatory body finds that the report addresses all
requirements and approval conditions, a delegated
officer will give a notice of approval. Otherwise, the
regulatory body will set out the details of the matters
that need further explanation. In this case, the regulatory body will communicate both with
the approval holder and the auditor to ensure that proper corrections are made.
The audit report is submitted again with the mandatory changes highlighted in track
changes. Once approved by the regulatory body, a digest of the results should be published
in hard copy and/or on the regulatory body’s website. Be sure to maintain official copies of
the audit report, sending them to appropriate stakeholders such as your EMR and staff, for
future reference and review.

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3.4 Maintain Contact with Contractors and Monitor their Compliance with
Environmental Management Requirements

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.

3.4.1 Maintaining Contact


Your primary point of contact with your contractors is through meetings. Require your
contractors or their assigned representatives to attend regular meetings whose agenda
include coordinating efforts in the EMP. In these meetings, you must inform and remind your
contractors of:
 the environmental management sub-plans (e.g., Waste Management Sub-plan,
Weed Management Sub-plan, Air Quality and Ambience Sub-plan) that concern each
subcontractor
 the respective roles and responsibilities of each contractor in the EMP and their
corresponding sub-plans
 procedures to monitor their compliance with the EMP and their corresponding sub-
plan

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An example of what you might plan to discuss in such a meeting is shown below:

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.

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In general, inspection reports should include:

Name of the inspector

Name of the contractor

Date and time of the inspection

Description of the work inspected

Description of non-compliant work (if any)

Documentation of non-compliant work (e.g. photographs, statements from other


contractors)

Corrective action required

Date of follow up

Based on Assuring environmental compliance: A toolkit for building better environmental


inspectorates in Eastern Europe, Caucasus, and Central Asia. Organisation for Economic
Co-operation and Development. ©OECD 2004

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3.5 Implement Emergency and Remediation Response Strategies as Necessary
to Assist Compliance with the Environmental Management Plan
3.5.1 Emergency Response Strategies
Even with the most secure EMP, there may be times when there are unforeseen incidents
that pose significant risk to the environment. In this case, you have to implement the
necessary emergency response strategies to address these incidents.
Three common incidents are fire, oil leakage, and chemical/hazardous material spillage.
Their corresponding response strategies are described below. These are general rules of
thumb and must be contextualised within your construction project.

• Follow the fire evacuation procedure as detailed in the


EMP.
• Contact the fire service immediately.
Fire • Report the presence, kind, quantities, and location of
flammable objects within the construction site.
• Report any special handling and other precautions to be
considered.

• Retain the oil leakage within the surrounding bund or


secondary containment of the tank.
• If the leak escapes, seek help from the fire service.
Oil leakage • For leased premises, inform the landlord and local
authorities immediately.
• Seek intervention from a soil or contaminated water
contractor, and request clean-up if appropriate.

• Identify the substance (e.g. solvent, conditioning fluid,


remover fluid, electrolyte, tin powder)
• Create a zone of exclusion and consider evacuating.
• Wear personal protective equipment if appropriate.
Chemical/ • Seek help from contact workshop maintenance
hazardous personnel for the spill containment and clean-up.
material spillage • Store empty containers for hazardous substances in the
designated storage area before authorised collection and
disposal.
• Once the spill has been cleaned up and the residue may
be disposed of, contact a contractor for the collection.

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Once the incident has been addressed, you have to document any action that required
external assistance or aid from spillage response personnel through an incidence report and
identify it as a non-conformity. Accomplishing the incident report will help in determining
the cause of the incident and introducing any corrective actions.
The incident report should contain:
 the date and time of the incident
 the type of the incident (e.g. fire, spill)
 description of the environmental impact, including:
o general environmental and social effects
o contamination of water, land, and air
o noise, dust, vibration and odour
o solid waste
o impact on the natural environment
o use of natural resources
o legal concerns
o media relations

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 number of people impacted by the incident, including:
o employees
o subcontractors
o trespassers
o general public
o property owners
o others
 details of the incident, including
o potential causes identified
o procedures for containment and clean upi
 severity of incident
 involvement of local enforcement or emergency services, and details
 whether work improvement, rectification, retraining issues have been issued
 cost breakdown of the incident
3.5.2 Remediation Response Strategies
Remediation refers to the process of removing polluted wastes or hazardous materials.
Unlike emergency responses, remediation is not limited to incidents only. It is undertaken
on an existing construction site or building to adequately prepare it for demolition or start
of a new project. It may also be undertaken prior to or due to industrial activities.
Remediation ensures that the environmental concerns and conditions stated in your EMP
are met so that risks to the environment and human health are reduced.
Examples of what needs to be remediated include:
 contaminated groundwater or surface water
 contaminated soil
 asbestos
 chlordane
 lead
Your remediation response strategy varies depending on the following factors:

interior building exterior building


site conditions
conditions conditions

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Environmental remediation uses a wide range of tools and techniques for cleaning up
polluted areas. The approaches used at a specific site rely on the form and nature of the
contamination, as well as the site's own characteristics. There are different methods of
remediation, and new technologies are being introduced constantly. General steps
undertaken in environmental remediation include the following:

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

Remediation is about handling the pollution, which will be undertaken by remediation


specialists. Different forms of pollution need different methods to address the issue.

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

Checkpoint! Let’s Review


1. How do you document feedback from informal feedback
systems?
2. What are the characteristics you should look for a
prospective third-party auditor?
3. What is an inspection in the context of the EMP?

4. What documentation should be accomplished after a fire or


spillage incident?

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Further Reading
Microsoft Excel offers a lot of opportunities for analysing and
summarising survey and interview data. Check out the following
resources for more guidance:
How to Analyze Survey Data in Excel
Using Spreadsheets as a Qualitative Analysis Tool

Classroom Activity for Chapter 3


Well done completing this chapter. You may now proceed to your
Classroom Activity Booklet (provided along with this Learner
Guide) and complete the classroom learning activities associated
with this chapter.
Please coordinate with your trainer/training organisation for
additional instructions and guidance in completing these
practical activities.

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IV. Review Environmental Management Plan

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.

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4.1 Review Environmental Management Plan to Identify Areas that Need
Actioning or Improvement
Since the management review is an important event which typically happens once per year,
it has to be thoroughly planned for. The actual process for conducting the management
review varies depending on the firm’s culture and resources. However, there are main
elements in any management review that have to be addressed.
Below is the general procedure to ensure adequate preparation and implementation of the
review process:

Gather
information

Prepare
briefings

Review
presentation

Update
presentation

Consider
findings

Act on findings

There are, at minimum, two parties involved in the management review:

the environmental monitor(s) the senior management team

The environmental monitor(s), usually the environmental management representative(s)


and the site manager, are responsible for reporting on the firm’s environmental
performance. On the other hand, the role of the senior management team is to consider and
act on the findings presented.

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Their roles become more detailed in the procedure below:
Step 1: Gather information.

The environmental monitors will gather information regarding the environmental


performance of the firm in the current cycle. Such information should include:
 The procedures used to identify the firm’s environmental aspects and impacts,
hazards and risks, legal and other requirements, goals, targets, and programs
(discussed in Section 1)
 The degree of success in meeting the goals and targets
 Previous meetings with senior management regarding the success and direction of
the system
 After-action reports on incidents and interventions
 Outcomes of past audits and compliance assessments
 Current status of corrective/preventive actions

Step 2: Prepare briefings.


Prior to the actual review, the environmental monitors will compile key points on the
information gathered. Such information will include:
 Outcomes of previous audits and compliance assessments
 Outcomes of participations and consultations
 Correspondences with relevant parties (e.g. complaints)
 Overall health and safety performance
 The degree of success in meeting the goals and targets
 Current status of incident reviews and corrective/preventive actions
 Recommendations and actions from past management reviews
 Changing contexts that may impact the scope of the EMP
 Suggestions for improvement

Step 3: Review presentation.


Having summarised the environmental data and information gathered, the environmental
monitors shall conduct a review of the management review presentation to evaluate the
adequacy, appropriateness, and effectiveness of the EMP and generate recommendations.

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Some guide questions are presented below:
 Are the procedures used to identify the firm’s environmental aspects and impacts,
hazards and risks, legal and other requirements, goals, targets, and programs
adequate enough to the firm’s environmental policy and its activities, products, and
services?
 Has the EMP been properly prepared, maintained, and used to guarantee successful
completion of goals and targets?
 Have the environmental controls in the EMP been sufficient in guaranteeing long-
term compliance with all relevant regulatory requirements?
 Do all operating procedures in the EMP give enough structure, guidance, and
accountability?
 Are the levels of internal and external communication enough in attaining the desired
degree of awareness, collaboration, and consultation?

Step 4: Update presentation


After the review of the presentation, the environmental monitors shall make the necessary
changes in content covered. The management review will then be scheduled when at least
50% of the Senior Management team is available. It is also usually scheduled during the last
month of the firm’s cycle.

Step 5: Consider findings.


During the actual review, the senior management team will contemplate upon the findings
presented, make inquiries to assess if the EMP is appropriate, adequate, and sustainable,
and propose recommendations they feel are appropriate for the firm to meet its long-term
environmental and business goals. The meeting shall be documented through the meeting
minutes.

Step 6: Act on findings.


Should the senior management team require corrective or preventive actions, all relevant
contractors and subcontractors should be duly informed via established lines and
mechanisms of communication based on the organisational structure of the firm. All parties
with assigned responsibilities shall give regular progress reports on the status of the
recommendations.

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4.2 Introduce Measures to Encourage Staff to Suggest Innovations to Improve
the Performance of the Environmental Management Plan

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?

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 Wrap-up questions should include suggested innovations, and what operations
should be continued or stopped.
Focus Groups
 Used to gather a range of opinions from different members of the company using
group interview sessions
 Focuses on how different members within a department, trade or construction firm
coincide with or differ from each other in terms of EMP evaluation
Example: What do you all think are the qualities that should be possessed by our new
environmental management representative?
 Concluding questions should also include suggested innovations. Highlight
differences during the discussion and negotiate ways by which consensus can be
arrived at on the proposed suggestions
All feedback should be properly documented. Outcomes of surveys may be compiled and
analysed through spreadsheet programs and summarised through illustrative bars and
charts. On the other hand, interviews and focus groups may be recorded and transcribed for
future reference. Taking interview notes will also help in generating key insights and is useful
when redrafting the EMP.

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4.3 Redraft Plans to Include Improvements or Address Deficiencies Found
During the Review Process

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:

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Addressed
Feedback EMP Section Actions Required at sign-
off?

Put earlier and stricter schedules


Delayed responses in this section. ☐ YES
Environmental
from regulatory
authorities
Auditing Document correspondences with ☐ NO
authorities as needed.

Lack of coordination Include an additional section on


Environmental how these two plans may be
between soil ☐ YES
Management coordinated.
management plan
and cultural heritage
Activities and ☐ NO
Controls Alternatively, integrate these
plan into a single plan

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.

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4.4 Submit Revised Plans for Endorsement by Senior Management and
Implement Reviewed Procedures

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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The presentation should cover the following things:

 Has the review ensured relevance of the


Policy
environmental policy to the firm?

 Have the legal approaches of the EMP changed


Legal matters
due to changing shifts in legislation?

 Have necessary changes been made to ensure


Assessing compliance minimum compliance with relevant legislation
and regulations?

• Which among the firm’s objectives and targets


Objectives and targets have been changed? What new goals have been
set for the firm?

• What are the general environmental impacts of


construction activities? How are these to be
Identifying and evaluating
managed in light of the revision, and how
impact
effective are the proposed management
procedures projected to be?

 What are the common incident or system


failures in the firm?
Incident/system failures
 What lessons were learned, and what measures
were proposed in light of these lessons?

 How have the auditing, monitoring, and review


Monitoring failures
systems of the firm been made more reliable?

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Once the EMP has been made effective, you have to implement the procedures accordingly.
You have to issue a memo to all staff members and subcontractors, detailing the significant
changes in the EMP and how it may be accessed. Since a large part of environmental
management procedures and controls rests on the performance of your subcontractors, as
site manager, you have to coordinate with them during the implementation stage. This will
require:
 updating their knowledge of specific environmental management subplans as
necessary through meetings and conversation logs (as in Section 2.1)
 monitoring their environmental performance through regular progress reports (as in
Section 2.2)
 auditing the actual environmental subplans based on self-performed inspections and
their feedback (as in Section 2.3)

Checkpoint! Let’s Review


1. What is the EMP management review?
2. What measures can you introduce to encourage staff to
suggest innovations in the EMP?
3. What topics should the presentation of the EMP revision
cover when asking for endorsement from senior
management staff?

Classroom Activity for Chapter 4


Well done completing this chapter. You may now proceed to your
Classroom Activity Booklet (provided along with this Learner
Guide) and complete the classroom learning activities associated
with this chapter.
Please coordinate with your trainer/training organisation for
additional instructions and guidance in completing these
practical activities.

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