Transcript Document

Module 6
Environmental Review
Project
ETIV – EMAS TECHNICAL IMPLEMENTATION
AND VERIFICATION
Prepared by:
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Module 6
Environmental Review
This project has been funded with support from the
European Commission. This publication reflects the views
only of the author, and the Commission cannot be held
responsible for any use which may be made of the
information contained therein.
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Objectives
The following Module is aimed at providing the student of
EMAS with an insight into the preparation of an integral
Environmental Review of a company’s activities at a
particular location, according to the Annex Vll of Regulation
(EC) No 761/2001
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Main steps of an Environmental Management System (EMS)
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Environmental Review
• Starting point for implementing of an EMS
• Allows the identification of all environmental aspects of
the organisation’s activities, products and services,
methods to assess these, its legal and regulatory
framework and existing environmental management
practices and procedures
• Used to inform and to revise the environmental policy
and help to set environmental objectives
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Principal Requirements of an EMAS Environmental Review
• Perform a technical (input-output) analysis of the organisation
• Identify environmental aspects related to past, current or future
operations
• Make a legal compliance assessment
• Evaluate the existing management practices
• Include the description of the following components of a specific
company:
- objectives and phases
- description of the organisation, its history, location, operational
processes, management
- environmental aspects (direct and indirect)
- significant aspects
- significance assessment criteria
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Step by step approach
• Identify the environmental aspects involved
• Define the criteria which are of significance for the
company’s environmental performance in terms of European
legislation
• Identify those environmental aspects that are related to
these significance criteria
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Data Collection & Assessment
Data collection procedures should include the following
points:
• Environmental indicators
• Basic data
• Data sources
• Conversion factors, if necessary
• Frequency of determining indicators
• Responsibility for collecting data
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Data Collection & Assessment
The Collection of Data will concern, among other issues:
• Power production and distribution
• Water consumption
• Natural resources consumption (including raw materials)
• Polluting emissions
• Waste management
• Emission of noise
• Check of possible use and contamination of the soil
• Emergency management
• Indirect environmental aspects, such as the use of products
and of services by users and consumers.
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Data Collection & Assessment
The process of evaluation will particularly concern:
• The definition of the criteria, in order to evaluate the relevance of
impacts
• The list of the most significant environmental aspects
• The choice of proper indicators which will provide for an accurate and
transparent evaluation of the organization and will enable easy
temporal and territorial comparisons
• The level of environmental efficiency of the activities realized in the
company, using proper environmental indicators for every
environmental aspect which has been considered.
• The individualization of the areas for the environmental performances,
from a technical and managerial point of view
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Environmental Review
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Assessment Subject & Phases (Screening)
The Environmental Review shall include effects arising, or likely
to arise, as consequences of:
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normal operating conditions;
abnormal operating conditions;
incidents, accidents and potential emergency situations;
past activities, current activities and planned activities.
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Assessment Subject & Phases (Screening)
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The Organisation: History, Location, Operation,
Management
Planning the process of the environmental review
Gaining Corporate commitment
Planning and assigning responsibilities
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Environmental Aspects (Scoping)
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Environmental Aspects (Scoping) – Documents to consider
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Relevant legislative regulations, laws and policies
Legal documents like permits, licences
Organisational records and documents
Organisational policies, procedures, charts
Existing environmental policies
Consumption and monitoring data, relevant contracts
Inventories
Material flow
Maps and surveys of site
Emergency plans
Health and Safety procedures
Incidents reports
Stakeholder analysis (if available)
Decide how to record this information (sample)
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Environmental Aspects (Scoping)
The impacts identification should include: emission to atmosphere;
releases to water; waste management; soil pollution; use of water,
fuels and energy and of the other natural sources; load by heat
energy, noise, odour, dust, vibration, and radiation; impacts on the
specific part of the environment
Sources of the significant impacts (environmental aspects) in the
organisation might be and are not limited to: emissions to the
Atmosphere (energetic, technology and transport); releases to
Water (wastewater - technologic, sewage, rain and cooling,
contaminated water pumped at the remedial works); waste
Management (by-products and waste disposal sites)
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Direct Environmental Aspects
Direct environmental aspects are associated with activities, products
and services of the organisation itself, over which organisation has
direct management control
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Environmental Aspects over which an organisation has control
Site, Footprint
Raw Materials, Energy
Product life cycle assessment
Emissions, Releases,
Disposal, Contamination
Material Flow & Recycling
Transport
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Environmental Aspects - Receptors
Receptors include all components and aspects of the
surrounding environment that could be directly and
indirectly damaged by any production and non-production
Activity, like: air, water, soil, landscape, cultural and
archaeological aspects, ecology and biota (biodiversity), noise
and vibration
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Environmental Aspects - Air
Main steps may involve:
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Assessment of Ambient Air Quality.
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Characterisation of Stack Emission and Pollution Load Studies.
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Fugitive emissions and work zone Air Quality Studies.
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Performance evaluation of Pollution Control Systems. Boiler
Efficiency/Incinerator Efficiency.
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Micro-Meteorological data generation in respect of temperature,
humidity, solar radiation, wind speed, wind direction, rainfall etc.
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Study of Gaseous Pollutants, Organic Solvents, Pesticides and
Metallic Constituents and other Toxic Chemicals in Air, including
PAH.
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Particle size distribution, respirable dust and dust fall rate
studies.
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Data generation for EIA related studies
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Environmental Aspects - Water
Main steps may involve:
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Analyse raw and treated water to assess suitability of water for
specific end uses (domestic, irrigation, construction, potable,
recreation and industrial applications)
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Mineral water analysis and sourcing
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Domestic and trade waste water for conformity to relevant
standards for discharging
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Performance evaluation of water and effluent treatment plants,
water purification equipment and storage vessels
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Flow measurement and total discharge of canals, streams and
rivers etc.
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Ground water studies which include hydro geological survey,
water availability, water use-pattern, water evaporation rates etc.
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Consultancy services in the areas of waste water treatment and
pollution abatement.
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Environmental Aspects - Soil
Main steps may involve:
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Soil testing for physical and chemical analysis for engineering,
agriculture and horticulture applications
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Test for heavy metals, pesticides and soil microbes
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Soil reclamation, salinity studies and its remedial measures
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Suitability of soil for types of crops
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Characterisation of wastes and hazard identification
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Incineration studies
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Toxicity waste behaviour and its contribution to ground water
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Handling and disposal of waste. Suitability of waste for land-fill
or composting.
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Environmental Aspects – Ecology/Biodiversity
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Creation of industrial ecosystems: maximising use of recycled
materials in production, optimising use of materials and
embedded energy, minimising waste generation, and reevaluating "wastes" as raw material for other processes or
companies.
Balancing organisations input and output to natural ecosystem
capacity
Dematerialization of industrial output
Improving the metabolic pathways of production processes and
materials use
Systemic patterns of energy use
Policy alignment with a long-term perspective of company’s
management system evolution
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Environmental Aspects – Landscape Visual
Landscape planning design project and management includes:
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Urban Design
Landscape Design and Implementation
Landscape Appraisal and Visual Impact Assessment:
Landscape Planning: careful planning of existing landscape
resources and the establishment of new sites for housing,
industry, recreation and wildlife
Historic Landscape Research and Restoration: The assessment,
analysis, conservation, refurbishment and design of Historic
Landscapes require sensitive and specialist expertise.
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Environmental Aspects – Culture/Archaeology
The cultural heritage aspects include:
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Historical buildings and structures
Archaeological sites and structures
Palaeo-ontological sites
Other cultural features
Other cultural features are items of antiquities in very varied
forms
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Environmental Aspects – Noise/Vibration
The Environmental Review should include :
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Description of noise-vibration generating production processes
Identification of sensitive receptors in the vicinity (type and
distance from organisation)
Sound-vibration proofing methods planned or implemented
inside and outside the organisation;
Noise-vibration emissions at the site boundary and at sensitive
receptors
Company’s monitoring systems and frequency
Attachments: Prior environmental audits or investigations,
Site map, Site layout, Thematic maps, Noise and vibration level
measurements, Local Environmental law applicable
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Environmental Aspects – Stakeholders
Within the process of identifying stakeholders, social auditing
Provides new approaches to the underlined and the growing
importance of systematic stakeholder dialogue
Social auditing is a means of measuring an organisation's/
company’s social impact and ethical behaviour in relation to its
aims and those of its stakeholders
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Indirect Environmental Aspects
Indirect environmental aspects arise from activities, services
and products, over which organisation has no or limited
control on their impact on the environment. For non-industrial
organisations, such as local authorities and financial
institutions, it is essential that they also consider the
environmental aspects associated with their core activities. An
inventory limited to the environmental aspects of an
organisations site and facilities is insufficient.
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Indirect Environmental Aspects
The main objectives of indirect environmental effects include:
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Product related issues (design, development, packaging,
transportation, use and waste recovery)
Financial issues: capital investments, loans, insurance
services
New markets issues
Choice and composition of services
Administration and planning decisions
Product range compositions
Environmental performance and practices of contractors,
subcontractors and suppliers
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Indirect Environmental Aspects – Financial Issues
Environmental Accounting (EA) is a method for evaluating the
true environmental costs of operating a business, so these
costs can be considered in business decisions. Environmental
costs should include:
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costs of resources in production,
cost of resources in general business operations,
waste treatment and disposal costs, and in some
situations:
cost of a poor environmental reputation,
environmental risk insurance premiums.
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Environmental Taxes (ET) are one of the tools of financial management
Problems of ET
It is difficult to set taxes at a level which reflect the real
environmental cost of an activity or product
If there is no alternative to a resource (say a fuel) higher
costs shift the burden to the consumer. This discourages
consumption of the resource but may not lead to cleaner
production
It is difficult to direct the revenue from an ET directly
towards renewing the correct resource - frequently the
revenue simply goes into a general fund. However,
directing the revenue very specifically may limit
government policy options
Environmental taxes can damage the competitive
advantage of a national industry unless a tax benefit is
directed to eco-efficient enterprises in the same industry
Benefits of ET
Some kinds of
environmental taxes (for
example, emissions taxes)
have been shown to
produce measurable
results
Proponents of green taxes
argue that employment
can be created, resource
use optimised and
pollution reduced by
increasing taxes on
resource use and
decreasing income taxes
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Indirect Environmental Aspects – New Markets
With the objectives of addressing the conflict between
protection of the environment and economic competitiveness
by turning environmental concern into competitive advantage,
the 5th European Action Programme included new economic
and fiscal tools such as eco-labelling, EMAS and the proposed
EU environmental taxation. The four categories of marketbased instruments identified are:
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charges and levies;
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fiscal incentives;
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state subvention (or subsidy) systems;
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environmental auditing
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Indirect Environmental Aspects – Services
The importance of moving beyond the production process is
particularly relevant in the context of service industries. In the
service sector, it is generally the case that direct, site-based
impacts are minimal and the most significant impacts are
associated with the policies or service 'products', so call
indirect impact.
Example: A bank has direct environmental impacts through
heating, lighting, transportation, office equipment and paper
use (so-called 'corporate ecology'), the indirect impact of its
products - its loans and investment portfolios, or 'product
ecology' - is likely to be by orders of magnitude more
significant.
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Indirect Environmental Aspects – Administration/Planning
Through their various roles and tasks, committees and
administrations make decisions and agree on various plans
with a number of consequences for the environment.
Planning is an important part of environmental management.
For the company’s environmental performance it includes:
environmental impact classification; legal and other
requirements; identification of the main objectives and targets;
environmental management programme; control/monitoring of
its implementation and operation
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Indirect Environmental Aspects – Contractors
A study-project of environmental performance of contractors
comprises principal phases:
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Formulation of environmental management concept for
the contractors.
Preparation of an environmental management policy and
its implementations.
Final testing in case companies according to the result of
policy implementation.
Completion of the environmental management system.
Marketing of the EMSA to the contractors.
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Indirect Environmental Aspects – Management
The main direction of internal environmental policy establishes
objectives for the internal environmental strategy located in
the following areas (integrated management within the
indirect environmental aspect issues):
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Employee’s involvement
Green Procurement
Transportation
Dissemination
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Significant Aspects – Key concepts
Significant environmental effect: environmental aspect of an
organisation activity that carries the potential to cause environmental
harm on the global, regional, and local environment and population
Environmental aspect - an element of an organisations activities,
products or services that can affect the environment,
Environmental impact - changes to the environment, whether adverse
or beneficial, that result from the organisations activities, products or
services
Evaluation criteria - has to be comprehensive, capable of independent
checking, reproducible, and made publicly available
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Significant Aspects – Key concepts
EMAS recommends four steps for the identification and evaluation
of significant environmental aspects:
1. Select an activity, product or service large enough for
meaningful examination and small enough to be sufficiently
understood
2. Identify direct and indirect environmental aspects of the activity,
product or service, i.e. how does it interact with the environment?
– Annex VI of the Regulation and the guidance provide some
useful ideas.
3. Identify environmental impacts, considering actual and potential,
positive and negative impacts associated with each aspect.
4. Evaluate significance of impacts
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Significant Aspects – Existing Data
The most important tool to manage and to estimate the existing
data on significant aspects of the company’s environmental
performance is the use of Indicators which provide a numerical
basis for evaluation of environmental performance, including the
significance of environmental impacts.
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Significant Aspects – Existing Data
Apart from the use as an internal instrument for measuring
significant aspects of the company’s environmental performance,
other possible applications for environmental indicators are:
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Benchmarking - Comparing your environmental performance
with other organisations
Internal communication - Illustrated performance indicators
provide feedback to employees on the results of their efforts,
and are therefore a valuable instrument for internal
communication
External communication - Data-supported reporting is the
best way to gain the trust of public administrations,
neighbours and environmental groups
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Significant Aspects – Regulated Activities
Monitoring and measurement is about controlling the significant
environmental aspects of the organisation
Three specific tasks shall be addressed under the Monitoring and
Measurement section of the regulation:
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Track the performance of the EMS with respect to the
significant environmental aspects (documented procedure,
records)
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Ensure accurate and reproducible measurements through
maintenance and calibration of monitoring equipment
(records);
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Evaluate regularly compliance with relevant environmental
laws and regulations (documented procedure).
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Significant Aspects – Material Flow
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Balance of material and energy flows is the creation of a
system where all material and energy flows going through the
production are taken in account
The balance is based on the law of conservation of mass and
energy, i.e.: the quantity of substances and energy entering
the company must leave the company or must be
accumulated within the company
Inputs and outputs of substances and energy are given in
physical units (for example in kg, t, GJ) and apply always to a
particular selected time period (year, month etc.)
The environmental accounting attaches to the identified
material and energy flows their monetary values, which has a
substantial importance for a correct determination of
environmental costs with respect to the significant impact.
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Significant Aspects – Stakeholders/Customers
Stakeholder groups are critical to the success of EMAS as a market
instrument; but in order to fulfil their respective roles in relation to
EMAS, they must:
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firstly, have access to appropriate information;
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secondly, be convinced of the legitimacy and credibility of the
EMAS process.
Public Environmental Reporting (PER) - also referred to as
Corporate Environmental Reporting - is a method by which
businesses report on their environmental progress to shareholders.
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Significant Assessment Criteria
The evaluation should consider the following criteria:
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the scale of impact on the environment
the severity of the impact on the environment
the scale and frequency of impact
accumulation aspect of impact
the probability of occurrence
the duration of impact on the environment
potential regulatory and legal exposure
difficulty of changing the impact
effect of change on other activities and processes
concerns of interested parties and interaction
effect on the public image of the company, stakeholders
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Classification of Environmental Aspects shall include:
(a) emissions to atmosphere;
(b) discharges to water or sewers;
(c) solid and other wastes, particularly hazardous wastes;
(d) contaminated of land;
(e) use of land, water, fuels and energy, and other natural
resources;
(f) discharge of thermal energy, noise, odour, dust, vibration and
visual impact;
(g) effects on specific parts of the environment and ecosystems.
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Classification of Environmental Aspects shall include effects arising,
or likely to arise, as consequence of:
(1)
(2)
(3)
(4)
normal operating conditions;
abnormal operating conditions;
incidents, accidents and potential emergency situations;
past activities, current activities and planned activities."
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Type & Location of Business/Industry
In relation to the type of business activity or branch of industry the
organisaton belongs to, this procedure consists of four stages:
(1) screening of all issues and activities;
(2) testing of significance/analysing effect risk;
(a) identifying environmental effects;
(b) testing each effort for its significance;
(3) prioritisation of effects (into improvement, control and further
analysis actions).
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Type & Location of Business/Industry
In relation to the location of the organisations, the procedure
reveal following significance criteria:
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extent of existing economic, social and environmental stress,
in affected areas;
direction of changes to base-line area conditions;
nature, order of magnitude, geographic extent and
reversibility / duration of changes;
regulatory and institutional capacity to implement measures
on the site.
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Legislation
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Each branch of industry should be provided with necessary
legislation updates and regulation on significant
environmental assessment to ensure that companies are kept
aware of any forthcoming legislation that will impact the
business
The updates of legislation must be reviewed by the
environmental representative and assessed to determine if
any requirements or changes are applicable to the company
The organisations own register should then be updated
accordingly
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Severity
Severity is one of the significance assessment criteria that reflect
the potentiality, power, weighing, scale or degree of the capacity
of the environmental impact
According to the logic consideration a combination of the
‘frequency’ with which the environment is affected by that activity
and the ‘severity’ of the effect when it does occur provides the
basis for general understanding of the degree of significant
environmental impact. Thus, the significance of an environmental
effect increases proportionately with the frequency and severity.
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Severity
The severity of an effect can be determined by considering a
number of components, including:
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Proximity to a regulatory standard.
Environmental impact (against recognised damage).
Significance and extent of the receptor (e.g. local, national or
global damage).
Longevity and reversibility of the effect.
Sensitivity of the public and press to the effect.
Sustainability of an effect.
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Scale/Frequency
Scale is a main factor in determining the type of environmental
measures and processes to use for the management of a particular
potential impact.
Frequency as a criterion of significance reflects the repeated in
time occurrence of the significant damages to the environment
from various types of activities and considers the necessity of
systematic (frequent) protective measures called to prevent those
events occur. Frequency is a systematic category and based in the
areas, such as quantitative measurement related to the activities,
health and safety.
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Accumulation
Environmental assessment significance are directed toward the
general purpose of protecting the environment. Usually this means
preventing and minimising adverse impacts on individual
environmental components and its cumulative effect. Cumulative
effects are addressed by aggregating individual effects (i.e. parts to
whole). The role of environmental management is to control
cumulative impacts.
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Interaction
Criteria of interaction within significant assessment criteria consider
a multiple level of activities that affect the significance of
environmental impact. Each level of interaction has its own
influence over the procedure of the assessment. From the point of
nature of the influence of criterion of interaction on significance
assessment there are following types of interaction:
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Interaction between the people is the basic level of interactive
activities.
Interaction within the company of industrial or non-industrial
sector of economy itself created the second level of
interactive activities
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Interaction
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The third level of relation concludes the interaction between
the companies: that belong to the same branch of industry;
that located in the same area; that produce the same types of
pollutions; that damages the same type of natural receptors;
that use the same natural resources for production cycle; etc.
As a sub-level of the third type of relation is interaction
between different companies that belong to different
industries, located in different areas, produce different type of
pollutions, damaged different receptors, use different
resources for their production, etc.
The fourth level of communication is the interaction between
industries within the governmental level.
The fifth level includes the interaction of the global scale
between the different countries, groups of the countries,
multinational companies, and continents.
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Stakeholders
To approach stakeholders’ objectives in environmental impact
assessment company needs to:
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Evaluate the consequences of inaccurate recording of financial
data
Recognise, complete and interpret complex business documents
and understand their interrelationships
Evaluate the significance of the final accounts to different
groups of stakeholders
Explain why ratios change over time and how this affects
different groups of stakeholder
Draw conclusions about the financial performance of the
business based on your use and understanding of a range of
financial data;
Justify changes to business practices to achieve required cash
flow and budget requirements .
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Risks
Significant Risk Assessment includes:
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Identification of significant risk must ensure that all significant
risks are captured
Risk analysis
Risk evaluation
Risk treatment
Risk monitoring and risk review
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Risks
There are three sides to environmental risk which a company must
consider:
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Risks to the environment from manufacturing processes
arising from normal routine process releases into the
environment or from accidents or incidents which give rise to
loss of containment and consequent release into the
environment.
Risks associated with purchase or inheritance of a
contaminated site.
Risks from the environment on a business arising from such
problems as extreme weather conditions or long term
environmental changes, for example, greenhouse effect and
climate
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