Terry Dowson

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Evaluation of Environmental Impacts --- The Improvement Process

Evaluation of Environmental Impacts

At this stage, a reasonably detailed description of the environmental aspects of the organisation should have been established, conveniently evaluated by department. The task now is to convert the data into an objective appraisal, and this can be done with numbers. The benefit of taking a slightly longer route initially, and assessing all environmental aspects by department, should begin to pay off.

For every aspect identified at the company, consideration must be given to any corresponding environmental impacts. This is best achieved using a pre-determined set of criteria, including emissions to atmosphere, discharges to sewer or controlled waters, contamination of the land, associated issues of waste production and disposal, types and volumes of substances used in the processes, storage and handling requirements, fuel and energy consumption, types and volumes of raw materials used, transport and shipping and current controls. It is also essential to identify all relevant, environmental legislation relating to the company' activities, and to include this in the assessment of environmental impacts.

Devise a scoring system that can be applied uniformly, then evaluate each of the environmental impacts, awarding collective scores for each department. Use a hierarchy of criteria on which to base scores, for example any activity that is covered by legislation would score highly, due to the potential consequences of failing to comply with the law; consider the actual or potential level of environmental damage e.g. toxicity, greenhouse gas emissions, ozone depletion; what would be the reaction of interested parties such as local residents, neighbouring companies, employees, shareholders, environmental interest groups and enforcement agencies; what quantities are used and what is the frequency of use/discharge etc.

Three categories may be employed to classify the severity of the actual or potential impact; Only slight or temporary environmental impact or deterioration in environmental quality; Some deterioration and/or public concern in environmental quality, such as noise, smoke, odours and emissions; High risk to environmental quality and/or public safety, potential/actual breach of legislation.

Use three similar categories to determine the likelihood of occurrence; Activity or aspect is well controlled by documented procedures, monitors are in place which result in only remote likelihood of an incident occurring; Activity is under general control although documented procedures are not in place, there is a history of incidents occurring on a regular basis, and these are not always brought under control quickly resulting in noticeable environmental damage; Activity has no formal controls in place, resulting in a frequently volatile process with the potential to cause serious and possibly irreversible environmental damage.

Finally, and again based on the use of three categories, determine the likelihood of failure associated with each impact; Controls in place will almost certainly detect a failure almost immediately, and in time to prevent any serious or lasting environmental damage; Controls may detect a failure, but are unlikely to prevent some environmental damage on each occasion of failure; Controls have little or no chance of detecting failure and would virtually never prevent releases to the environment, resulting in serious and lasting environmental damage.

Each impact would have to be evaluated against all these criteria, under two, separate sets of circumstances; normal operating conditions, and abnormal operating conditions. The eventual scores awarded under each set of operating conditions would be aggregated to give a total environmental impact rating, which would then determine the degree of significance for each of the identified environmental impacts. Develop a threshold for the points scoring system, and any impacts awarded scores greater than the threshold, would qualify for improvement project status, and be automatically included in the Management Improvement Programme.

Based on the scores awarded, the organisation's available resources and ability to take corrective actions, produce a register of significant environmental impacts. The results of this exercise are entirely dependent upon the nature of the business, and the controls in place to reduce the significance of the environmental impacts of its activities. However, it should now be possible to objectively determine how the company's activities impact on the local, regional and global environment.

The Improvement Process

This is a suitable time to consider developing an environmental policy statement, which must be appropriate and scaled according to the size and complexity of the business. The policy should be endorsed by a senior member of the management team, preferably the Managing Director, and include certain commitments to eliminating and/or reducing environmental pollution. The document must also make unambiguous references to continuous improvement, outline the company's objectives and targets, be available to the public, and be subject to regular reviews.

The next step is to consider the development of a series of objectives and targets, based on the evaluation of significant environmental impacts. Providing that the theme of evaluating all these impacts by department has been maintained, the Register of Significant Environmental Impacts, should be a descending list rating each department on its overall potential to cause environmental damage.

This provides a logical and progressive platform for developing a series of improvement projects built around the departments with the highest overall impact rating. The scoring system, and points awarded, can be compared against the threshold set, with those departments awarded the highest scores developed into projects, with targets set for improvement. Ownership of the improvement projects goes directly to the management team of that particular department, and there are no conflicts of interest. The progress of each project is reviewed on a quarterly basis, with each department head, and significance scores re-assigned according to the effectiveness of any corrective actions.

A management system provides the framework in which tangible and practical improvements can be made. The whole process should be kept as simple as possible, implementing only those procedures that are necessary to maintain the integrity of the EMS. Thoroughly develop the training and communication aspects of the system, and support this with a comprehensive set of procedures. A technically sound environmental management system is ineffective if people are unaware of its existence, or not trained in its disciplines.

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