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Sustainability goes Beyond the Annual Sustainability Report.

REPORTING The annual Sustainability Report must be more than a glossy booklet filled with feel-good stories. The report is a statement to external stakeholders on the performance of the company that should: Satisfy the Global Reporting Initiative (GRI) standard criteria at a … Continue reading

Environmental Advisors Working in the Mining Industry [FREE GUIDE TO MANAGING APPROVALS]

To help expand your knowledge of the Environmental Approvals process, I have put together a free guide to managing approvals:

 

https://www.google.com/url?q=http://enperitus.com/managing-approvals/

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So many environmental professionals are frustrated by the number of approvals, number of government department websites, and the time it takes to find the information they need relating to environmental approvals. The legislation is broad and complex.

 

Where do you START? You want to value-add but finding the resources and knowledge to do so is difficult and time consuming.

 

You want guidance from someone who has been through the process; you want resources that don’t take hours to find the answers. We’re going to make it easier for you by providing free reports and resources, and working together to expand your knowledge.

 

https://www.google.com/url?q=http://enperitus.com/managing-approvals/

 

The fact is there are three essential elements you need to know about managing approvals that make it effortless to communicate your value to your organization so that you can value-add without requesting time from your Manager.

 

Discover EXACTLY how you can have that knowledge and value-add the way you want to using:

 

  • Simple strategies.
  • Building your resources.
  • Providing informed advice.

 

In order to get your FREE copy, register here.

 

https://www.google.com/url?q=http://enperitus.com/managing-approvals/

 

Beyond Compliant

We now live in an era where the resources industry is expected to go beyond just complying with the law.

So what does it mean to go beyond compliant?

Eucalyptus ficifolia F. Muell (Red flowering gum) (Myrtaceae) (11 Jan 2002) - CopyHere are some ideas:

  • Meeting the expectations of external community on a local, national and international level.
  • Transparency in meeting objectives that address those expectations.
  • Creating a culture of respect for the environment.
  • Awareness of the potential impacts as a result of mining activities.
  • A genuine show of environmental responsibility among the mining workforce that extends beyond the mine.
  • Being proactive in going beyond those expectations.

This does not need to be an expensive exercise! Internal culture building programs can be developed by information, environment themed activities, employee involvement and decision-making that extends beyond the environment teams. The budget is minimal.

There does, however, need to be endorsement and support by senior management. This support from the leadership team tends to be the one aspect that is missing and the one aspect that is most frustrating when building a culture that extends beyond being just compliant with the law and license conditions. So, the most important step (and possibly the most difficult step) is to gain that endorsement and support.

The transient nature of the mining workforce adds to the difficulty. However if an industry wide approach was taken then the positive outcomes from such programs would be observed much sooner.

It is also worthy to note that this is a long-term initiative and in most cases will likely take at least five years to see results.

Inspired by a Hero

The death of such a prominent and deeply influential person, such as Nelson Mandela, results in reflection of their legacy and how that relates to you. You relate to someone or look up to them because there is often something there that you have in common: A value or a characteristic that you both share. For example, a stubbornness to not let go of your belief or vision is what I relate to when I read of Nelson Mandela’s journey in life. While I don’t expect to be the equivalent of Nelson Mandela, I am inspired by how he has used that trait to his advantage.nelson-mandela

I am sure Nelson Mandela would never have predicted that his journey in life would take the twists and turns that it did. His focus was on his vision and his beliefs, and not on where he was at any one point in time. Even during the direst time in his life, he did not focus on the circumstance, the people around him or what they were saying or how they were treating him or where he was but continued to focus on his vision for the future. And to do that for twenty seven years of imprisonment was nothing short of amazing.

During this time of reflection, what can we learn from Nelson Mandela’s walk to freedom?  For one, despite the culture of mining, despite the attitudes of the people around us which are often so negative or filled with skepticism, and despite our own circumstances, we have the ability to focus on making a difference and on moving towards our vision or ultimate goal. This can be done because our struggles and challenges in the workplace or at home are minute compared to those experienced by this great man during his lifetime.

What trait or value do you relate to when you read about and are inspired by Nelson Mandela’s achievements?

You can be motivated to achieve your vision with the same dignity and without fear, knowing that this man, this humble human being has showed you how.

Golden Gecko Awards 2012

The Golden Gecko Award is the most prestigious award for environmental practitioners working in industry in Western Australia. It is an initiative of the Department of Mines and Petroleum (DMP), and one that recognises “leading practice and innovation in environmental management”.

The last time I attended the Award ceremony was back in 2010, when I was representing Crosslands Resources. We won the award that year, along with  Phoenix Environmental, for innovative research into the effects of vibration on the shield back trapdoor spider, Idiosoma nigrum. I remember being so proud of the entire team for just getting shortlisted. I crossed my fingers, arms and legs and hoped for the best as the awards were being announced. As Crosslands was named the Golden Gecko Award winner, our team let out a cry of excitement, and were hugging and congratulating each other. It was an incredibly exciting time.

This year I attended the ceremony with the Aurecon environmental team for what was an amazing evening. I sat in the audience with the same sense of anticipation as I did two years ago, remembering and understanding what the participants must be feeling. It was very surreal. The companies that were shortlisted for the award were: Karara Mining Ltd; Murphy Pipe and Civil; Pendoley Environmental Pty Ltd; Barminco Ltd; Argyle Diamonds Ltd; Citic Pacific Mining Management Pty Ltd; and ESS Support Services Worldwide.

The charming emcee described each project as visuals were cast onto the screen. The Hon Norman Moore spoke for the last time at the Awards as he finishes his final year before enjoying his retirement, and was joined by the Director General, Richard Sellers, Deputy Director General, Approvals Group, Tim Griffin and Executive Director, Environment, Phil Gorey of the Department of Mines and Petroleum. We were also honoured with the presence of the Chief Scientist of Western Australia, Professor Lyn Beazley. And then the winners were announced:

  • The Certificate of Merit went to Argyle Diamonds Ltd; and
  • The Golden Gecko Award went to Pendoley Environmental Pty Ltd

    Golden Gecko Awards 2012

    The Hon. Norman Moore presenting at the 2012 Golden Gecko Awards

When the group from Pendoley were called out, cheers and woo-hoo’s came from the audience.  Kellie Pendoley accepted the Award from the Hon. Norman Moore with a hug and kiss on the cheek. As Phil Gorey described the science and innovative approach to tracking and understanding the movements and ecology of the turtles visiting Australia’s coastlines, Kellie stood on stage glowing with pride and excitement. This Award represented years of hard work and dedication. Kellie described the beginnings of the company after being let go from a previous organisation due to cost-cutting, how as a company they often provided information to the community, consultants and industry free of charge, and how their work was never compromised by answering to industry, government or other various stakeholders. Kellie made us laugh and infected us with her excitement. The atmosphere in the room was electric. The innovation, collaboration, hard work and leadership was an inspiration to us all.

Hon. Norman Moore, Kellie Pendoley and Phil Gorey

Hon. Norman Moore, Kellie Pendoley and Phil Gorey

The evening was brilliant, thanks to a small team from the DMP. The jovial nature of those handing out our name tags, the choice of venue, the drinks and nibbles, the stage backdrop, length of speeches and program in general was all coordinated by, what is to most of us, a virtual group of people. My only suggestion for improvement is that they should have been brought on stage and applauded for doing such a great job.

The Golden Gecko Award and everything they represent both directly and indirectly inspired our environmental team to further embrace the Aurecon values:

  1. Fostering human achievement through excellence, innovation and collaboration;
  2. Celebrate diversity and respect others by acting with integrity and honesty;
  3. Work to build a vibrant and brighter future for all.

The Awards this year represented the values that Aurecon as an organisation stands for – an amazing event inspired this year by an amazing woman leading a company that has demonstrated leading practice and innovation in environmental management.

Congratulations to Kellie and the team at Pendoley Environmental Pty Ltd!

http://www.dmp.wa.gov.au/goldengecko/index.html

Meeting the requirements of the National Greenhouse Emissions Reporting Act 2008

Companies that exceed specified facility or corporate emissions thresholds are required under the National Greenhouse Emissions Reporting Act 2008 (NGER Act) to measure and report greenhouse gas emissions and energy consumption/production. There are considerable penalties for the company as well as individuals (i.e. CEO, CFO) if found by the regulator to be non-compliant with the NGER Act.

In order to comply with the NGER Act, the following approach should be considered for implementation:

  1. Governance: Ensure NGER compliance is addressed within the company governance structure.
  2. Resources: Ensure adequate resources are available.
  3. Commitment: Develop a vision and policy with regard to greenhouse gas emissions.
  4. Systems: Ensure procedures, work instructions and forms are reviewed or developed to describe how the company will meet NGER Act requirements.

1. Governance

The CEO is be responsible for communicating NGER Act compliance to the Board. The risk and audit subcommittee of the Board should be responsible for monitoring risk associated with changes to or introduction of legislation with respect to greenhouse gas emissions, and monitoring compliance with the NGER Act, as well as reviewing audit outcomes specific to the NGER Act. This should be incorporated into the Audit and Risk Subcommittee Charter. A Carbon Working Group, consisting of managers from finance, corporate environment, facility resident managers, and facility environmental representatives, should be formed to be proactive with regard to requests from and report to the Audit and Risk Subcommittee on matters relating to greenhouse gas emissions. A champion for NGER Act compliance (most likely the Environmental Manager) should oversee all actions relating to the implementation of the above listed approach.

2. Resources

Resources to be considered for the implementation of NGER Act requirements includes:

  • Personnel: Additional personnel may be required or review of the capability of existing personnel to implement the data collection requirements of the NGER Act.
  • Budget: A budget will need to be developed and approved to address the resource requirements listed here, and the implementation of the approach described in this document.
  • Consultants: Training, development of documentation for systems described below, compilation of data and NGER reports, guidance on determination of operational control and boundaries, external audit to measure and provide certainty on compliance, legal advice on interpretation of the NGER Act and contractual development for existing and new contractors.
  • Equipment: Additional equipment may be required at facilities to ensure accurate data collection. An equipment list is required when data collection points are identified.
  • IT systems: A review of IT systems in place or the requirements for a new one with capability for data storage, collation and reporting is required.
  • Time: The time required to collect and collate data and report along with personnel capability should also be assessed.

3. Commitment

The Board should develop a vision with regard to greenhouse gas emissions (e.g. is the vision to be carbon positive or just to comply with reporting requirements). The CEO, and senior management will develop, endorse and communicate a policy, with the aid of the Environmental Manager.

4. Systems, Procedures, Work Instructions and Forms

The carbon policy (which may be integrated within the environmental policy) should be implemented through the review of the corporate management system, and development and roll out of additional procedures, work instructions and forms. Consideration of NGER Act requirements within the standard operating procedures of the corporate management system should include:

  • Legal: NGER Act requirements will be added to the legal obligations register, and changes to legislation will be monitored.
  • Document control: all documentation relating to NGER Act implementation will be maintained as per the company’s document control and record keeping procedures.
  • Management Plans: A carbon management plan will describe how the company will implement its carbon policy and legal obligations, as well as any proactive measures to reduce or offset carbon emissions (depending on the ambitions of the carbon policy and any associated vision).
  • Risk Assessment: Consideration of the NGER Act requirements will be given during annual corporate and technical risk assessment workshops, and action plans will be implemented to mitigate high risk severity.
  • Audits and Inspections:  Internal and external audits will be undertaken to ensure compliance. An internal audit checklist shall be developed.
  • Incident and Corrective Actions: Non-conformances with NGER related data collection processes shall be recorded in the company’s electronic incident register (along with H&S, and environmental incidents) and an investigation of the cause will be carried out.
  • Change Management: Implications of changes to equipment, procedures, activities or legislation with regard to greenhouse gas emissions shall be considered through the change management process.
  • Objectives and Targets: Objectives and targets for the reduction of greenhouse gas emissions, accuracy of data collection, training of personnel and culture change initiatives shall be determined, and monitored against progress.
  • Training: Training requirements for personnel and contractors with regard to NGER Act compliance will need to be identified in the Training Needs Matrix.
  • Communication: Internal and external communication will be undertaken using a variety of mechanisms including newsletters, prestart meetings, weekly management meetings, monthly Green committee meetings, annual NGER reporting, CEO presentations to the Board.
  • Contract Management: Consideration of NGER requirements shall be included in contracts. Some of this “approach” may in fact be the responsibility of the contractor (especially in an EPCM situation) but that would depend on the requirements of the contract. I would suggest an Environmental Specification for Contractors document should be referenced within the contract, and the details of the contractor role be included and clearly laid out in this document.
  • Management Review: Management will review performance, audit outcomes and incident records to determine effectiveness of complianc e with NGER Act and implementation of the policy to determine progress towards achieving the vision.

Work Instructions: A Carbon Emissions Work Instruction(s) shall describe task specific data collection procedures.

Forms: A Monthly Carbon Emissions Form shall be developed to record emissions for the month by functional area managers at each facility.

The above approach should be considered essential going forward. In addition,  it is recommended that a similar approach should be implemented regardless of whether or not carbon emissions thresholds are exceeded.

The Role of the Board in Environmental Compliance

The Board has a responsibility to ensure that a compliance program is in place and operating effectively (Australian Institute of Company Directors Course, 2011).

A compliance program is an essential component of the company. The program includes:

  1. Policies and procedures, which ensure it meets the requirements of regulatory frameworks in which the company operates.
  2. A positive environmental culture, an important component of any compliance program, which is often overlooked.

7 questions for directors to explore in relation to environmental compliance include:

  1. Does the company have a register of all applicable legal obligations?
  2. Is there training and awareness, including refresher courses of all applicable legislation? Explore this further by requesting topic, audience (who attended, representation from all levels, departments, voluntary or not), competency testing, qualifications of the educator?
  3. How often are changes to legislation being reviewed? communicated? assessed for implications to the company?
  4. Is there a change control procedure in place to assess compliance requirements for changes to equipment (e.g, diesel storage), activities, processes, disturbance footprint? (if change occurs and has not been assessed for legal implications by appropriate personnel then this is the most likely time that a company will become non-compliant)
  5. Historically, when were the change control procedures implemented? If some time has passed following company establishment, has an assessment/external audit been conducted to determine if non-compliances have occurred as a result of changes prior to the implementation of the change control procedure?
  6. How often are internal and external audits conducted to determine: if there are non-compliances? if the change control procedure is being implemented effectively? if the above questions have been answered correctly?
  7. Is there an ISO 14001 certified Environmental Management System in place? (there are simply no excuses for not having this system in place, it can be implemented cheaply, it can be implemented fit-for-purpose, it can be implemented when other systems in the business are lacking!).

One question that I havent included is: Is there a positive culture of environmental responsibility? It is often difficult for directors to assess this and would need to gauge culture through informal discussions and observations of leadership teams at all levels, including management’s reactions to environmental topics in various meetings. Most mining companies don’t have a positive culture at all levels of the organisation. Therefore, regardless of how well the questions above are answered, there will likely be a risk of occurrence of environmental non-compliances unless a culture-building program (see Blogs in the category Environmental Culture) is implemented.

The comprehensive assessment and monitoring of the implementation of compliance programs may be the responsibility of the Audit and Risk Sub-committee of the Board.

In addition, the questions above should also be applied to land tenure, OHS, corporate governance, intellectual property, industrial relations and human resources, information systems, taxation and finance.

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Geologists Going Beyond Geology

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You all know that a geologist is “a scientist who studies the solid and liquid matter that constitutes the Earth, as well as the processes and history that has shaped it” (Wikipedia, 23 June 2012). I believe, however, that those … Continue reading