Tag Archives: mining

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.


Using Non-Local Provenance Seed for Restoration/Rehabilitation

Did I hear correctly? I am sitting in the local shire council offices participating in a coastcare coordinators meeting and we get onto the topic of future seminars. I think I almost chocked when it was explained to me that Professor Richard Hobbs (2011 WA Scientist of the Year) was presenting the idea that perhaps we should be planting species in our restoration projects that are more likely to cope with the rapid climate changes in the future (i.e. not local provenance species). This took me by surprise. It goes against all that I have been taught, which is basically that local provenance species should be used in restoration projects.

In mining, our Mine Closure Plans often refer to collecting, storing and using the seed of local provenance species for rehabilitating disturbed areas. If this new way of thinking is correct then we should be planning on rehabilitating post-mining areas with species that are better adapted to a warming climate? These post-mining landscapes may serve as islands of contingency (supporting species that are more likely to survive in the local area as the climate changes, and in areas where the local species are not expected to survive or be able to adapt quickly enough).

However, what are the risks? If we use the same species (but from locations considered not local), then cross-pollination of introduced plants with naturally occurring local provenance plants may result in any number of problems – weedy species, weaker populations, not to mention dramatic changes in community composition and structure.

Debate around the issue above is very healthy amongst the scientific community. It challenges the way scientists think about current best pratice in restoration given the rapid changes in climate. However, as a group consisting of practitioners, government and regulators, we are challenged as to which advice and direction to take. The question that comes to my mind is how much time do we have to debate such issues?

Environmental Culture-Building Program

The coexistence of those with environmental interests and those with mining interests is often perceived to be like “chalk and cheese.” While that may have been the case 10 years ago, it is no longer the case now. Australians naturally have very strong connections with their environment – our beaches, our small country towns surrounded by natural areas, our climate and our unique flora and fauna. Protecting our way of life and the values associated with being Australian and a lover of the great outdoors coincides with looking after our countryside, our beaches, our outback.  So, there is no reason why this connection wouldn’t extend into the workplace and thus there is no reason why there should be a conflict.

Factors that may influence that conclusion may include:

  • the remote locations of the workplace in comparison to the home location and therefore a disconnect with the outdoor values associated with being at home; and
  • the male-dominated nature of the workforce (an average of 19% female within the mining industry in Western Australia, 2012).

Building an environmental culture within a mining company isn’t easy. The transient nature of the Australian mining workforce and the short-term nature of project construction adds to the difficulty. It is also worthy to note that this is a long-term initiative and will likely take at least five years to see results.

If an industry-wide approach to building an environmental culture was taken then the positive outcomes from such programs would be observed much sooner.

There is such a positive arguement for implementing a culture-building program:

  • the budget requirements for such a program can be minimal;
  • reduces risk of impacts to the environment;
  • involving the broader workforce encourages diversity of ideas; and
  • an environmental culture extends beyond the mine site and into homes and our way of life.

Support and endorsement by the senior management team is critical to its success. While an environmental culture-building program can be implemented without the directive of senior management, the success of any program within a mining company is very much dependent on a top-down approach.

Internal culture-building programs can be developed by:

  • provision of information;
  • environment-themed activities; and
  • employee involvement to facilitate decision-making that extends beyond the formal environment teams.

Examples of such initiatives are provided below.

Provision of information:

  • weekly newsletters (email and posted in tea rooms);
  • prompts for recylcing waste, energy (e.g. turning off computer screens) and water usage;
  • signage;
  • environmental-themed calenders.

Environment-themed activities:

  • celebrating and reflecting on significant dates (earth day, world environment day);
  • tree planting.

Employee involvement

  • green committee’s at all facilities and implementation of their intiatives to reduce and recycle waste, increase energy efficiencies, and reduce water efficiency.
  • competitions (going beyond compliance, nature photo competition for annual calender).
  • developing “environmental representative” programs and involvement for those that dont have a formal environmental education.

Please send me any ideas or initiatives that you have implemented. I’d be keen to hear what you are doing and how you measure success of the program.

Biomimicry: It’s Potential Application to Mining

This application of science is one that I am very, very excited about……

Biomimicry is the examination of nature, its models, systems, processes, and elements to emulate or take inspiration from in order to solve human problems (referenced from Wikipedia).

Janine Benyus presents a nice summary of biomimicry on Ted.com, and the book Biomimicry: Innovation Inspired by Nature, as well as, the Biomimicry Institute’s AskNature website provides some great examples.


Nature has produced prototypes over millions of years. Their success or failure has been determined by natural selection. In economic terms, the evolution of these prototypes equates to trillions of dollars. No company could afford to undergo the same rigorous process undertaken by nature thus making it understandable that human engineered structures are no match in comparison and not sustainable. These successful biological prototypes have no patent, and are freely available. Let’s look at some examples from AskNature (http://www.asknature.org/browse):

Water Collection

  • The desert-dwelling Namibian beetle (Stenocara gracilipes) obtains the water it needs to survive from ocean fog due to the surface of its forewings, which are covered in microscopic bumps with hydrophilic (water attracting) tips and hydrophobic (water repelling) sides. The beetle’s forewings are aimed at oncoming fog and as a result water droplets condense on its back and slide down channels into its mouth. Synthetic surfaces mimicking the beetle’s back have been created that are several times more effective than existing fog-catching nets, and could be used to generate clean freshwater supplies in arid regions, refugee camps, and at the tops of skyscrapers. These require no pumping.

Waste Management/ Bioremediation

  • The fern Pteris vittata can tolerate 100 to 1,000 times more arsenic than other plants. An arsenic pump of sorts takes the arsenic from the soil and stores it in the fronds in the fern. A protein, which acts as the pump, encoded by [an isolated] gene ends up in the membrane of the plant cell’s vacuole. The protein moves arsenic into the cell’s equivalent of a rubbish bin and stores it away from the cytoplasm so that it can’t have an effect on the plant.  The application of this species ability to move and store arsenic could lead to ways to clean up arsenic-contaminated land. (ScienceDaily 2010)

Energy Capture

  • Conventional silicon-based solar panels capture, separate, and transport light energy in one highly-purified material whose manufacture requires large amounts of energy, toxic solvents, and bulky infrastructure to support rigid panels. Plant-inspired solar cells mimic photosynthetic dyes and processes to generate solar energy many times more cheaply than silicon-based photovoltaics. In addition, they have the flexibility to be integrated with a building outer-layer. These dye-sensitive solar cells use a variety of photo-sensitive dyes and common, flexible materials that can be incorporated into architectural elements such as window panes, building paints, or textiles. Although traditional silicon-based photovoltaic solar cells currently have higher solar energy conversion ratios, dye-sensitive solar cells have higher overall power collection potential due to low-cost operability under a wider range of light and temperature conditions, and flexible application. The organism that inspired this technology, Kokia cookei O. Deg., is a hibiscus, which is native to Hawaii and has an IUCN red list status of “extinct in the wild”.

It is becoming increasingly more evident that the mining industry needs to become more:

  • energy efficient,
  • water efficient, and
  • reduce and recycle waste.

As described above, the use of biomimicry may help us to achieve these outcomes. Given the enormous library of organisms on this planet, I believe nature’s potential is yet to be unleashed. Countries, industries and individual companies that invest in research and development programs have proven to have a competitive advantage. We’ve only to look at India and China’s R&D programs as examples. This exciting area of science is shown to provide some answers and would definately be a worthwhile investment.

Building an environmental culture in mining: Application of CBSM

Building an Environmental Culture

When building an environmental culture, mining companies often place most of their resources into educating their employee’s using a variety of media (e.g. booklets, inductions, posters, newsletters, training, tool box meeting topics). Mining personnel are often inundated with information, which is important but not sufficient alone to drive a change in culture.  Results from broader community based programs have demonstrated that education alone and millions of dollars invested in such programs does not guarantee that they will work.

The CBSM Approach

I recently attended a 3-day workshop held by Dr Doug Mckenzie-Mohr on Community Based Social Marketing (CBSM). Doug is an internationally recognised environmental psychologist, a leader in his field, having published books on CBSM and developed an informative website (http://www.cbsm.com/public/world.lasso) sharing success stories and information.

As the only representative from the mining industry at that particular workshop, I recognised the potential application of Doug’s CBSM methodology to the mining community. The methodology that Doug outlines is as follows:

  1. Select behaviours based on environmental aspects that are material to the business e.g. turning off computer screens have the potential to have a 20% energy saving in a corporate office.
  2. Identify barriers and benefits e.g. based on face to face surveys with a subset of the office community it may be determined that the barrier is not attitude. It may be identified that employees are not in the habit of turning off the screen.
  3. Develop a strategy e.g. using the computer screen example – the strategy may be to send reminders to those that commit to turn off their screen (and are happy to receive reminders) for a period of two weeks to get them into the habitat.
  4. Pilot program – test the strategy on a subset of the population. This wont work if the mining community is small (< 150 employees) and thus for a small mining company this will fall under Step 5, but may serve as a pilot program for the industry more broadly if the outcomes were shared. For a larger company, implementing a pilot program initially (Step 4) will ensure the broader program is cost-effective.
  5. Implement broadly and evaluate.

It is worthwhile reading Doug’s books, Fostering Sustainable Behavior: An Introduction to Community-Based Social Marketing
and Social Marketing to Protect the Environment: What Works,
or attending a course if this blog sparks your interest. There is so much more to the methodology than that outlined above.

Stay tuned to future blogs as I explore the use of Doug Mckenzie-Mohr’s CBSM approach to fostering sustainable behaviour within the mining industry.