National Environment

Management Council (NEMC)

MANAGING COMPLIANCE AND
OPERATIONAL RISKS

PRESENTED BY:
YOHANA MTONI, PhD,
PRINCIPAL ENVIRONMENTAL MANAGEMENT OFFICER (PEMO)
HEAD, MONITORING AND AUDIT DEPARTMENT, DECE, NEMC
HEAD, NEMC MONITORING TASK FORCE

15-17 MAR 2016

Outline of Presentation:
What is Risk?
Risk Management?
Sustainability & Environmental Risk
Environmental challenges
Environmental assessment of operations and
activities
 What is Risk?
Risk is present in everything we do.

ISO 31000 definition of risk:

Risk = the effect of uncertainty on objectives.

Risk can be a threat or an opportunity

Anything that could harm, prevent, delay or enhance
your ability to achieve your objectives = risk
 Enterprise Risk Management (ERM)?
Risk Management is a coordinated effort to direct
and control all activities related to risk.
Risk is the effect of uncertainty on objectives. It
therefore ties the management of risk to what is
most important to the organization.
The responsibility for managing risk is spread
across the organization to those who have
accountability and authority risk owners.
 Types or Risk Exposures in ERM
Hazard risk
risks related to accidental losses, such as workplace injuries, property
damage, and natural disasters.
Financial risk
risks related to financial activities, such as pricing, asset valuation,
currency fluctuations, and liquidity.
Operational risk
risks related to operations, such as supply chain, customer
satisfaction, product failure, or loss of key personnel.
Strategic risk
risks related with an organizations long-term goals and management,
such as partnerships, mergers, and acquisitions.
Compliance risk
risks related to violations of or nonconformance with laws, rules,
regulations, prescribed practices, internal policies, and procedures, or
ethical standards.
Reputational risk
risks related to the trustworthiness of business. Damage to a firm's
reputation can result in lost revenue or destruction of shareholder
value.
What is Sustainability?
What is Environmental Risk?

Environmental risk - arises from the relationship

between humans and human activity and the
environment

Ecological risk management - deals with risks

associated with past, present and future human
activities on flora, fauna and ecosystems. It is a sub-
set of environmental risk management
Types of Environmental Risk:
Risk to the environment - this type of risk recognises that activities of
an organisation can cause some form of environmental change
(Environmental risks can relate to flora & fauna; human health & wellbeing; human
social and cultural welfare; earth, air and water resources; energy and climate)

Risk to an organization from environment-related issues - this

includes the risk of not complying with existing (or future) legislation
(Associated risks include business losses an organization may suffer as a result of
poor management, such as loss of reputation, fines, costs of litigation, and from
failure to secure & maintain permission for development and operational activities

Both have environmental, legal, financial, reputational and operational impacts

Key Definitions (1):
Source of Risk all sources of a risk where there is a cause-effect
relationship
Hazard a source of potential harm
Environmental aspects elements of an organisations activities, products
or services that can interact with the environment
Incidents (aka Event) any occurrence that can have impact on the
environment (an incident releases the intrinsic potential of the hazard)
Impacts include, where relevant, effects and consequences
Consequence is the outcome of impact of an event
Environmental impact any change to the environment wholly or partly
resulting from an organisations activities, products ort services
Risk management structured, systematic approach to decision-making
Key Definitions (2):
Need to manage environmental risk but how?
Environmental management system (EMS) - refers to the
management of an organisation's environmental programs in a comprehensive,
systematic, planned and documented manner:
Serves as a tool to improve environmental performance
Provides a systematic way of managing an organisations
environmental affairs
Addresses immediate and long-term impacts of its products, services
and processes on the environment
Gives order and consistency for organisations to address
environmental concerns through the allocation of resources,
assignment of responsibility and ongoing evaluation of practices,
procedures and processes
Focuses on continual improvement of the system
An EMS follows a Plan-Do-Check-Act Cycle
Process flow for the management of an
audit programme
Key Elements of an EMS:
Policy Statement - a statement of the organizations
commitment to the environment
Identification of Significant Environmental Impacts -
environmental attributes of products, activities and
services and their effects on the environment
Development of Objectives and Targets -
environmental goals for the organization
Implementation - plans to meet objectives and
targets
Training - instruction to ensure employees are aware
and capable of fulfilling their environmental
responsibilities
Management Review
 Environmental Risk Assessment
Aspect
Identification UQ as an example
Established and mature system.
Hazard Evolved from a certified ISO 14001 system.
Identification
Recognises relationships with:
OH&S risk,
Risk
Assessment Legal risk, and
Financial risk.
Risk
Prioritisation
What is environmental management
and ISO 14001?
ISO 14001 is an internationally accepted standard
that outlines how to put an effective
environmental management system in place in
your organization.
It is designed to help businesses remain
commercially successful without overlooking
environmental responsibilities and impacts. It can
also help you to grow sustainably while reducing
the environmental impact of this growth.
 Aspects
Aspect
Identification
Purpose:
Complete understanding of impacts.
Hazard
Engage stakeholders.
Identification Raise awareness.
Review existing aspects.
Risk
Assessment

Risk
Prioritisation
 Aspects
Aspect
Identification
Common: Unusual:
Office and Transport.
administration. Sewage treatment.
Hazard
Identification Teaching. Incineration.
Laboratories & Farming.
Risk Research. Mine operations.
Assessment ITS.
Maintenance.
Risk
Prioritisation
 Environmental Hazards
Aspect Common: Unusual:
Identification
Chemicals. Nanoparticles.
Hazard Dust. Radiation.
Identification Fire. GMOs.
Noise. Clinical agents.
Risk Light. Biological.
Assessment
Waste. Explosives.
Gases.
Risk
Prioritisation
 Environmental
EnvironmentalHazards
Risks
Aspect Common: Unusual:
Identification
Chemicals. Nanoparticles.
Hazard Dust. Radiation.
Identification Fire. GMOs.
Noise. Clinical agents.
Risk Light. Biological.
Assessment
Waste. Explosives.
Gases.
Risk
Prioritisation
 Environmental Risks
Aspect Common: Unusual:
Identification
Legal. Climate change.
Hazard Pollution. Consumption
Identification Contamination. (i.e. non-renewable
resources).
Nuisance.
Risk Inadvertent harm.
Assessment

Risk
Prioritisation
 Prioritising
Aspect Common:
Identification
Prioritise by greatest risk.
Hazard
Identification
Complexities:
Intrinsic risk can be high risk.
Risk
Assessment Competing risks do not equal the
environmental risk.
Risk
Prioritisation
 Assessment Process
Aspect
Identification
Stakeholders

Hazard
Identification
Sustainability
Office
Risk
Assessment

Management
Risk
Prioritisation
 as an Example
Chemicals: Identification and Assessment.
Operation Activity/Aspect Risk Controls Legal
Bulk Flammable and Storing FCLs in rooms and Fire or spill causing contamination of receiving Must follow regulations Council bylaw.
Combustible Stores buildings. environment
Laboratories - daily Storing and using chemicals Spillage of chemical escaping to soil or receiving Must follow regulations OHS Regs
operations. within laboratories. waters

Fume cupboards Use of chemicals in fume Loss of volatile chemicals to atmosphere. Local procedures No
cupbords.
Fieldwork Use of chemicals in the Loss of chemicals to the receiving environment. Local procedures No
field.
Transporting Materials - Transporting chemicals by Loss to the environment by spilling. Follow regulations DGSM Act.
Chemicals vehicle between or around
campuses and sites.

Transport Use of chemicals during Loss to the evironment through spills and improper Areas bunded. Disposal systems provided. ERA
maintenance. disposal.
Waste Management - Disposal of sewerable Release to the environment by improper or non- EMS EPP Waste
Chemical chemicals. sewerable chemical disposal.

Waste Management - Disposal of non-sewerable Improperly disposed and being released to the EMS. Contractor for collection and disposal. EPP Waste
Chemical chemicals. receiving environment.

Printery Use of volatile chemicals Release to the environment None ERA

and solvents
Disaster Management Fire in a chemical store or Chemicals volatilised and released to the atmosphere. Fire protection. Response processes. Stored in Council bylaw.
location accordance with code and Act
Disaster Management Fire in a chemical store or Chemicals washed to Brisbane river in fire water Fire protection. Response processes. Stored in Council bylaw.
location accordance with code and Act
Central Chemical Store - Decanting Chemicals Spillage of chemical escaping to soil or receiving Bunding. Drainage to sewer. Council bylaw.
Daily Operations waters
Chemical Waste Store - Storing waste chemicals. Loss of chemicls to the Brisbane river through spill or Bunded. Small containers. Frequently cleared. No
Daily operations leak.
Chemical Waste Store - Flood inundating the store. Loss of chemicals to the Brisbane River. Containers small. Volumes kept low. Can be No
Incident cleared with warning.
Cleaning - Daily Use of chemical cleaners Spills of chemicals to receiving environment. Cleaning rooms bunded and plumbed to sewer. No
operations
Disaster Management Release of fire water from Release of chemicals to receiving waters None No
site.
Workshop - chemical Storing chemicals in the Spills being released to the creek. Spill kit. No
storage workshop.
CAAS - Chemical Storage of bulk volumes of Leaks being lost to receiving environment. Bunded. Spill processes ERA
Treatment Facility NaOH
Chemical Waste Store - Fire Release to the Brisbane River in fire water. Containmanet tank. Volumes kept low by weekly No
Incident pick up.
Chemical Waste Store - Fire Release to atmosphere in smoke plume Volumes kept low by weekly pick up. No
Incident
Swimming Pool - Daily Use of chemicals in Contamination of surface waters in the event of a spill None EPP Water
Operations maintenance
Washing up with detergents Release of chemicals to sewer and receiving waters All such sinks are connected to sewer. Plants are No
tertiary treated.
Tea Rooms
Use of chemicals in Contact with incompatible materials. Spill kit. Training None
Swimming Pool - Daily
maintenance
Operations
Traffic and Parking Deterioration of paint used Entering natural water bodies. None None
for line marking.
 as an Example
Chemicals: Identification and Assessment.
Operation Activity/Aspect Risk Controls Legal
Bulk Flammable Storing FCLs in Fire or spill causing contamination of Must follow regulations. Council bylaw.
and Combustiblerooms and receiving environment
Stores buildings.
Laboratories - Storing and using Spillage of chemical escaping to soil Must follow regulations. OHS Regs
daily operations.
chemicals within or receiving waters
laboratories.
Fume cupboards Use of chemicals Loss of volatile chemicals to Local procedures. No
in fume cupboards. atmosphere.
Fieldwork Use of chemicals Loss of chemicals to the receiving Local procedures. No
in the field. environment.
Transporting Transporting Loss to the environment by spilling. Follow regulations. DGSM Act.
Materials - chemicals by
Chemicals vehicle between or
around campuses
and sites.
Waste Disposal of Release to the environment by EMS. EPP Waste
Management - sewerable improper or non-sewerable chemical
Chemical chemicals. disposal.
Waste Disposal of non- Improperly disposed and being EMS. Contractor for collection EPP Waste
Management - sewerable released to the receiving and disposal.
Chemical chemicals. environment.
Printery Use of volatile Release to the environment None. ERA
chemicals and
solvents
 as an Example
Chemicals: Risk Management.
 2009 Risk Assessment
Aspect
= 126 Aspects Environmental Aspects Against Risk
Identification
200

160

#of Aspects
Hazard 120
= 72 Hazards
Identification 80

40

0
Risk
= 290 Risks
Assessment
Risk

Risk = 34 Unacceptable Risks

Prioritisation = 10 Different Hazards
 2009 Risk Assessment
Aspect Historic Environmental Risks
Identification
100

75
Hazard Percentage (%)
Identification
50
"Acceptable"
"Unacceptable"
Risk 25
Assessment
0
2005 2006 2007 2008 2009

Risk Year
Prioritisation
 Prioritising
Aspect Common:
Identification
Prioritise by greatest risk.
Hazard
Identification
Complexities:
Intrinsic risk can be high risk.
Risk
Assessment Competing risks do not equal the
environmental risk.
Risk
Prioritisation
Project Scope:
Identify the current and potential environmental issues and
liabilities at University
Determine and assess the level of environmental risk
associated with activities undertaken at the University
Ascertain the adequacy of control measures associated with
current and potential environmental issues and liabilities
Conduct environmental legal compliance assessment in order
to evaluate compliance with environmental legal obligations
Conduct a gap analysis against the International ISO 14001
Standard in order to facilitate the development of an EMS
Identify and recommend measures for improvement
Overview:
Methodology:
Identification of Environmental Activities &
Risk Assessment
Legal Compliance Assessment
ISO 14001 Gap Analysis
Results:
Identification of Environmental Activities &
Risk Assessment
Legal Compliance Assessment
ISO 14001 Gap Analysis
Recommendations:
Methodology:
1.Identification of Environmental Activities & Risk
Assessment
(a) Hazard Identification
Segregation of processes/activities within each
Area
Inspection and observation of work areas
Interviews with staff
Identification of the current and potential
environmental issues and risk (liability) and its
effect/impact on the environment under a range
of operating conditions
Identification of existing control measures
Determination of proposed risk reduction/control
measures
Methodology:
(b) Risk Assessment
Workshops and participant risk ranking sessions
Determination of inherent and residual risk
Determination of consequence, likelihood and risk rating
Any risks classed as High, Very High or Extreme were
recognised as being significant

(c) Risk Control

Identification of proposed or additional control measures
Methodology:
2. Assessment of Legal Compliance
Review of ERAs, notifiable activities, documents, records
and pertinent legislation and other requirements
Inspection and observation of work areas
Findings were coded as follows:
Non-compliance (NC) A direct non-compliance with a
Statutory requirement. Typically of a higher risk or
consequence
Observation (O) - Provided as guidance or comment to
facilitate improvement in performance. Should be actioned
where practicable
Methodology:
3. ISO 14001 Gap Analysis
Identifies the actions needed to qualify for ISO 14001
certification
Assessment against each element of ISO 14001 Standard:
Policy
Emergency preparedness and response
Responsibilities and accountabilities
Environmental monitoring
Records and data management
Incident reporting
Planning and implementation of initiatives &
programs
Compliance Score (%) determined
Results Impact by Category:
Results compliance risks:
Overall, an understanding of statutory obligations relative to
environmental management and performance is demonstrated
The assessment identified 25 instances of non-compliance
with environmental legislation. These related to:

Conduct of a notifiable activity without approval (1)

Management & storage of hazardous substances &
dangerous goods (18)
The establishment & maintenance of documentation (6)

All 25 non-compliances will be addressed by end of Nov 2010

Results Gap Analysis:
70% compliance with Communication, Emergency
Preparedness & Response, Control of Records and
Roles, Responsibilities and Authority
50% compliance with Environmental Aspects, Legal &
Other Requirements, Objectives & Targets, EMS
Documentation, Monitoring & Measurement, Evaluation
of Compliance and Preventative and Corrective Action
<40% compliance with Competency, Training &
Awareness, Document Control, Operational Control and
Internal Audit
0% compliance with Environmental Policy and
Management Review
Recommendations:
Develop an Environmental Management Plan
(EMP)
Conduct of environmental audits of contractors
used for the collection & transport of general &
regulated waste
Provision of formal hydrocarbon and chemical
spill response training
Development of wide chemical spill response
procedure and incident reporting procedure
Installation of general and chemical spill kits
Regular inspections of flammable storage
cabinets
Development of standard templates
Laboratories: SOPs for fieldwork
Recommendations (Cont.):
Increase level of education and
awareness:
Waste management
Separation of hazardous substances
Environmental incident reporting
Environmental risk assessment
Significant environmental impacts
(risks)
Emergency response procedures
Legal obligations and statutory
guidelines
Address non-compliances raised in the
legal compliance assessment
Encourage eco-friendly packaging and
increase recycling efforts
 THANK YOU

FOR YOUR ATTENTION