How big are your environmental risks?
By Andrew Balch
Every business has the best intentions to be good corporate, social and environmental community members. But in reality, timeframes, budgets and a risk-taking attitude to regulatory compliance mean that many do not live up to that promise. This article is part of an expert series by Andrew Balch on avoiding the pitfalls that commonly befall businesses that fail to effectively manage their environmental responsibilities.
Do you understand your impact?
Once your project gets approved by the relevant planning authority, environmental operating conditions are set as part of their EA or EPL. Sometimes, but not always, source emissions monitoring is part of the license conditions. Rarer still, ambient air monitoring is prescribed.
However, without monitoring your emissions and the ambient air surrounding your site, you will never gain a thorough understanding of your environmental impact.
Are you adaptable?
If you have source emissions monitoring as part of your license conditions, it is typically reserved only for scheduled sources that emit criteria pollutants such as NOx, SOx, CO, fine particles and a few trace products of combustion.
Scheduled sources typically comprise power generation units, boilers, engines and perhaps air pollution control units like baghouses. But there is often a myriad of other sources from industrial activities that generate dust, odour and other hazardous air pollutants. These are often overlooked by both the business and the regulator, meaning that you never gain a true understanding of your environmental risks and how to manage them.
All too often I work with businesses that believe that their activities do not generate air pollution impacts, or that the controls that were put in place when the facility was built are still working as intended. They may hold the belief that the controls were designed correctly to handle the load asked of them in the first place. Ultimately, we are called in when it becomes obvious that these beliefs are no longer true.
Do you have a plan?
To manage compliance with their EA or EPL a business should have an environmental management plan. However, this is often not the case, or the document is light on detail and prescribed actions for managing pollution episodes.
Businesses may try to follow that plan, but some don’t. They claim to comply with their Environmental Authority, but if they never measure anything, how would they actually be sure of their compliance?
An environmental management plan should be a living document that tracks a business’s environmental performance and provides for constant improvement of processes and management procedures.