Contractor Environmental Management Procedure

Transcription

1 PURPOSE To define the minimum environmental management requirements of any contractor working in any capacity on university grounds, plant or equipment. 1 SCOPE This procedure applies to all works performed by a contractor within areas controlled by the University of Canberra. All persons shall comply with the requirements of this procedure in respect to works performed by contractors within university grounds, plant or equipment. 2 PROCEDURE 2.1 Requirement for an Environmental Management Plan (EMP) The contractor shall submit an Environmental Management Plan (EMP) for both operational type contracts (OEMP) and construction type contracts (CEMP) during contract preliminaries. The contractor shall not commence works until an EMP has been submitted and reviewed by the University of Canberra (UC) Project Officer An EMP shall only be accepted if written specifically for the site and job AN OEMP or CEMP shall address all environmental risks specific to this work and shall also address all environmental risks listed within this procedure Contractors performing construction work where total cost is less than $ or where UC retains control of the construction project as principal contractor, or any contract not involving construction work may complete the EMP template provided as Appendix 2 of this procedure and submit to UC during preliminaries Principal contractors in charge of a construction project (worth more than $250,000) will be required to submit a CEMP that sufficiently covers all risks/hazards associated with this specific project and shall comply with: All requirements listed within this procedure The Guideline for the Preparation of Environmental Management Plans (DIPNR, NSW, 2004) AS/NZS ISO Environmental Management Plan Guidelines 2014, Department of Environment. PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 1 of 15

2 2.2 Schedule of WHS and Environmental Management Information within preliminaries The contractor will provide within preliminary documentation the following: Evidence of satisfactory WHS management performance. This can be achieved by submitting a WHS Management Plan or three Safe Work Method statements implemented on a previous project within the last twelve months Evidence of satisfactory Environmental Management performance. This can be achieved by submitting an Environmental Management Plan (EMP), or an environmental management procedure/ checklist, implemented on a previous project within the last twelve months Recent WHS or environmental prosecutions and/ or fines for the last two years. 2.3 EMP - Structure and Responsibility An EMP shall provide a clear organisation structure for the project including the names and positions of personnel responsible for environmental management. A description of the roles and responsibilities of each identified person shall also be documented within this plan. The roles and responsibilities of subcontractors shall also be identified and documented within this plan A person shall be nominated with the specific task of ensuring that the EMP is implemented and maintained. This is generally the contractor s project manager or environmental manager An approval or consent authority may require that an Environmental Management Representative (EMR) be appointed during large construction projects. The role of this EMR is to be specifically identified within the project s EMP. 2.4 EMP - Approval and Licensing Requirements A project s regulatory framework shall be identified. An EMP shall include relevant requirements to ensure they are considered, including: Listing the conditions of approval or consent. It may be useful to include these as a matrix indicating where in the EMP each condition of approval or consent is addressed. Provision of a table listing the legislation relevant to the project and any licences, approvals or permits required to be obtained under that legislation. The table should identify the relevant section(s) of the legislation and specific triggers. Identifying the person (or role) responsible for obtaining the licences, approvals and permits and when they should be obtained and renewed, and PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 2 of 15

3 Describing any other requirements that apply to the project e.g. voluntary agreements, stakeholder agreements, EMS requirements, etc. 2.5 EMP - Reporting Requirements A description of the reporting requirements for the project shall be provided and included within the EMP, including: A list of reports required, for example: o Construction monitoring o Non-compliance o Corrective actions o Auditing o Pre-construction and pre-operation compliance, and o Any reports required by government agencies A description of a typical report content Personnel responsible for preparing the reports and when they are to be prepared Communications protocols establishing who is responsible for distributing information, what is to be distributed, to whom, and at what frequency Document control procedures 2.6 EMP - Training Requirements All workers shall undergo general environmental awareness training and training about their responsibilities under the EMP. The training shall ensure that all workers onsite understand their obligation to exercise due diligence for environmental matters. A worker in this instance means any person performing any task for the contractor in charge of the work Environmental training shall include: Site induction Familiarisation with the requirements of the EMP Environmental emergency response training Familiarisation with site environmental controls Targeted environmental training based on specific role or task. For example, plant operators receive training on dust minimisation The need for additional or revised training should be identified and implemented from the outputs of monitoring and reviewing the EMP Records of all training shall be maintained and include: Who was trained When person was trained Name of trainer Training content PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 3 of 15

4 2.7 EMP - Emergency Contacts and Response The EMP shall nominate a contact person(s) for emergencies that will be available 24 hours a day, seven days a week, and who has the authority to stop or direct works The EMP shall also document the procedures to be followed in the event of an environmental emergency. Where an environmental emergency is to be considered any event that causes or has potential to cause material harm to the environment. These environmental emergency procedures shall include: Then names and contact details (including all-hours telephone numbers) for the emergency response personnel Response personnel responsibilities Contact details for emergency services (ambulance, fire brigade, spill clean-up services) The location of on-site information on hazardous materials, including Material Safety Data sheets and spill containment materials. Steps to follow to minimise damage and control an environmental emergency, and Instructions and contact details for notifying government agencies, local councils and, if necessary nearby residents. 2.8 EMP Implementation Risk Assessment This section of the EMP shall follow the following steps. 1) Provide a list of the activities to be carried out. This should describe all project activates including those undertaken by subcontractors or suppliers together with ancillary works such as materials transport to and from site and site establishment. 2) Identify the actual and potential environmental impacts associated with each activity 3) Identify which environmental impacts are significant. Methods for risk assessment of these should be selected that are appropriate to the type of project. 4) Use this information to design the environmental management activities, controls and monitoring to prevent or minimise those environmental impacts appropriately, and 5) State how often, and when, this risk assessment will be carried out. PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 4 of 15

5 2.8.2 Environmental Control Plans or Maps Environmental control plans are a particularly useful on-site reference and should be included in every EMP. An example is a plan indicating the location of the following: Environmentally sensitive areas on and adjacent to the site Waterways including drains Erosion and sediment control measures Work areas, machinery or vehicle parking, spoil dumps, fuel and chemical stores Vegetation that requires protection Restrictions on traffic movement, and Monitoring locations Environmental Schedules Environmental management schedules are copies of forms, reports or registers used during a project s day-to-day environmental management and a copy of each is to be included within the EMP. Examples include: Environmental Inspection checklist Non-compliance and Corrective actions report Complaints report Environmental Incident Report Environmental Training Register Waste Register Monitoring Checklist 2.9 EMP Monitoring and Review Environmental Monitoring This section of the EMP shall explain how environmental management activities and controls shall be monitored. A monitoring checklist should be developed specifying when the environmental control activities need to be carried out, who is responsible and what methods will be used to measure effectiveness. It should include a space for sign-off to verify that the control action was undertaken and is working effectively. The checklist should specify if, when, follow-up action is required and who is responsible. Details of how monitoring records will be collated, distributed and stored should also be provided. PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 5 of 15

6 2.9.2 Environmental Auditing This EMP shall also describe the program and procedures for periodic auditing of the EMP s implementation and effectiveness. The audits should determine whether or not the EMP was properly implemented and maintained and provide information for the EMP review. The audit program and procedures should cover both internal and external auditing requirements, including scope, frequency and methods, as well as responsibilities and requirements for conducting audits and reporting results. The frequency of audits should reflect the level of significance of the environmental impacts and the results of previous audits Corrective Actions This EMP shall define procedures for dealing with non-compliance with environmental management controls, environmental incidents and emergencies. The procedures should also define who is responsible and has the authority for handling and investigating noncompliance, taking action and completing corrective and preventative action. Schedules should be developed for recording environmental incidents, non-compliance and corrective and preventative actions EMP Review This section should describe how the EMP will be reviewed; including looking at the environmental controls and procedures to make sure they are still applicable to the activities being carried out. It should include: When/ how often this is to be done Who will be responsible for reviewing the EMP, recording decisions and the reasons for them, and making subsequent changes How the site/project team will be informed of these changes, and When the reviewed EMP should be submitted to the approval or consent authority Project Size and Complexity influences presentation and detail required of an EMP Introduction The size and complexity of a project will influence how an EMP is presented, the format of the information and the level of information included. For small projects (for example projects small in area with no complex environmental issues and a total budget of less than $250, 000) the structure of the EMP may be organised using the UC Small Project EMP Template attached here as appendix 2. For large projects (for PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 6 of 15

7 example involving multiple sites and /or complex environmental issues or where total budget is more than $250, 000) there are a range of EMP formats that could be used based either on each stage of the project or each location. Whichever format of EMP is used the documentation should be as short and simple as possible, to facilitate ease of use, and provide practical and accessible information. Wherever possible, plans or checklists should be used instead of a written description. Templates are provided as appendices for use with small and large projects Specific Sub-Plans to be addressed within the EMP. Issue specific sub-plans should contain information relevant to key environmental management issues and include the following: Erosion and sedimentation Water quality Ground water Air quality Flora and fauna Rehabilitation Indigenous heritage Non-indigenous heritage Noise and vibration Waste Hazardous materials Traffic Construction Method Statements Shall be prepared for specific construction sites or activities that may have specific impact on the environment (examples include tunnelling, rock breaking, etc.) These statements shall include relevant information from the above sections on Environmental Management, Monitoring and Review and Implementation. PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 7 of 15

8 3 ACCOUNTABILITIES Role Responsibilities General Managers Ensure compliance with the requirements of this procedure within their Department or school Maintain and support a risk management culture by endorsing the risk management requirements within this procedure Ensure adequate resources are provided to meet the requirements as defined within this procedure Estate and Facilities Management Manager Ensure systems are established and maintained to support the requirements of this procedure Department Managers Ensure systems are established and maintained to support and comply with the requirements of this procedure within their department Ensure adequate resources are provided to meet the Departments requirements as identified in this procedure Ensure that all new items of plant, equipment or systems shall be designed and installed with the ability to be isolated in accordance with this procedure Ensure Training programs applicable to the task being peformed on the job are recorded appropriately in Training Plans / Role Requirements Ensure appropriate Training programs exist applicable to the tasks being performed Workplace Supervisor, Workers and Contractors Ensure the requirements of this procedure are met during daily work activities. Report any potential new risks or hazards that are identified during work activities Participate in risk management activities as and when requested within this procedure PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 8 of 15

9 4 REFERENCES Aboriginal and Torres Strait Islander Heritage Protection Act 1984 Environment Protection and Biodiversity Conservation Act 1999 AS/NZS ISO 14001:2004 Environmental Management Systems - requirements with guidance for use AS/NZS ISO 14004:2004 Environmental Management Systems - general guidelines on principles, systems and support techniques Guideline for the Preparation of Environmental Management Plans (DIPNR, NSW, 2004) Environmental Management Plan Guidelines 2014, Department of Environment PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 9 of 15

10 Appendix 1: Checklist of an EMP s adequacy (FRM-1121) The following table provides a summary of the factors considered important components of an EMP. Indicator Check (Y/N) EMP Structure A management tool showing how environmental impacts will be controlled? Well defined, clear document structure? Clearly and Concisely written? Prescriptive? Realistic? Written for its users (i.e. construction personnel)? Site specific? Easy to update? A dynamic assessment tool? Auditable? Prepared in parallel with detailed project plans and design? EMP as a Management Tool Reflect level of available information? Contains an environmental risk assessment? Use plans to illustrate requirements e.g. sensitive sites and location of controls? Identify areas of uncertainty and contain contingency plans to cover uncertainty? Does the EMP Contain? Yes No Background Introduction PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 10 of 15

11 Project Description EMP Context EMP Objectives Environmental Policy Environmental Management Environmental Management Structure & Responsibility Approval and Licensing Requirements Reporting Environmental Training Emergency Contacts and Response Implementation Risk Assessment Environmental Management Activities and Controls Environmental Control Plans or Maps Environmental Schedules Monitoring and Review Environmental Monitoring Environmental Auditing Corrective Actions EMP Review Note: This checklist highlights the main components of an EMP. It is not an EMP Template. PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 11 of 15

12 Appendix 2: Small Project EMP Template FRM-1122 (as per of this procedure) Project Name: Location of Project: Contractor Company: Commencement Date: Responsible Manager: ABN: Expected completion date: Signature: (person accepting responsibility for this Environmental Management plan) (By signing this plan I accept responsibility for ensuring all aspects of this project abide by all legislative requirements for environmental protection.) Phone number: Emergency Contact person: Position in Company: Phone number: Environmental Management Control Person Responsible Timing / Frequency Completed/ Actioned on (Initials and Date) General Site Issues Site Induction Training for all personnel. Includes: alerts personnel to sensitive work areas, explains the requirements of the EMP, outlines individual s responsibilities, informs workers of emergency response procedures. Documentary evidence of such training will be maintained and is available for review. All workers are inducted prior to of any form of work on-site. Compliance: Ensure all work is performed in compliance with Environmental protection legislation and this EMP. All site personnel Emergency Procedures: Ensure all required emergency procedures exist and are displayed in a prominent position within the site working area. Before any work on project Dissemination of Information: A contact person has been identified and a contact number is provided here for the receiving of comments or complaints from the community. Name: Phone: Register of Complaints: A register will record details of any complaints, complaint contract details and action taken to rectify. Audits of the EMP: A review of all documents, records and monitoring results to ensure compliance with this EMP. Site Manger Monthly PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 12 of 15

13 Evaluating Risk Each risk listed in this plan is to have a risk rating applied; the risk rating methodology to be used is listed below. Each environmental risk is to be given a rating in terms of likelihood and consequence using the criteria in the table below. These ratings are combined using the matrix provided to generate a risk rating of low, medium, high or severe. Likelihood (how likely is it that this event/ issue will occur after the listed control strategies have been put in place). Highly Likely Likely Possible Unlikely Rare Is expected to occur in most circumstances Will probably occur during the life of the project Might Occur during the life of the project Could occur but considered unlikely or doubtful May occur in exceptional circumstances Consequence (what will be the likely consequence / result if this issue does occur). Minor Moderate High Major Critical Minor incident of environmental damage that can be reversed. Isolated but substantial instances of environmental damage that could be reversed with intensive efforts. Substantial instances of environmental damage that could be reversed with intensive efforts. Major loss of environmental amenity and real danger of not containing this damage. Severe widespread loss of environmental amenity and irrecoverable environmental damage. Consequence Minor Moderate High Major Critical Highly Likely Medium High High Severe Severe Likelihood Likely Low Medium High High Severe Possible Low Medium Medium High Severe Unlikely Low Low Medium High High Rare Low Low Low Medium High PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 13 of 15

14 Environmental Management Control Person Responsible Timing / Frequency Completed/ Actioned on (Initials and Date) Indigenous Heritage Risk Rating: Any Aboriginal archaeological or significant site or artefact discovered during any works will result in immediate cessation of all works and the EPA will be contacted for further advice and action. Ensure Protective fencing is placed around any historically significant places or items potentially affected by the project. Air Quality Risk rating: Prevention of dust emissions: Vehicles entering or leaving sites and carrying a load that may generate dust are covered to prevent dust emission at all times, except during loading or unloading. Install, operate and maintain dust control measures: including: - On all internal haul roads - Truck loading areas - All stockpiles including: raw materials, topsoil and overburden. Unsealed road dust suppression: Ensure a mobile tanker equipped with a pump and sprays is used to supress dust on unsealed roads in use., with frequency based on activity. Flora and Fauna Risk Rating: Boundary and vegetation protection fencing. To prevent plant and equipment entering adjacent vegetated areas. Before work. Restriction of tree and vegetation removal. Removal of vegetation is kept to a minimum and only within the UC approval process. Rehabitate and revegetate. Will be employed to return the site to pre-works condition. Establish a riparian zone. Revegetated with local species, along the length of the reconstructed waterway. PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 14 of 15

15 Environmental Management Control Person Responsible Timing / Frequency Completed/ Actioned on (Initials and Date) Water Quality Risk Rating: Prepare a Soil and Waste Management Plan before work, that includes: - Drainage and sediment control around areas of ground disturbance or stockpiling of products - Provision of sediment and filter traps in advance of any earth works to prevent contaminated run-off leaving site. - Scour protection measures below all drainage outlets. Before work. Install erosion and sediment control measures before any land disturbance. Before work. Ensure drainage through any areas of ground disturbance is designed to minimise surface flow velocities. Including: Before work. - Surface water flows from disturbed areas or stockpiles will be directed into a sediment control facility. - Run-off from outside the work area is diverted around the disturbed catchment, or through the area without being able to mix with site-run-off to prevent overloading of erosion control structures. Discharge of stormwater from the site is ensured to be clear of any sediment and pollution. Before work. Noise Risk Rating: Work activities are restricted to the following hours: - 7:00 am to 6:00 pm Monday to Friday - 8:00 am to 1:pm Saturday - No work on Sunday or public holidays. Before work. Waste Management Risk Rating: Ensure waste is disposed in compliance with all legislative requirements PRO 1120 V1.0 Contractor Environmental Management Procedure.doc Page 15 of 15