Environmental Audit on the Waste Management Scheme of the Birmingham City Council - Term Paper Example

Environmental Audit Report on the Waste Management Scheme of the Birmingham Council Table of Contents Executive Summary 3 0 Introduction 5 1.1 Background 5 1.2 Scope 6 1.3 Purpose 6 1.4 Site Description 7 2.0 Audit Methodology 8 2.1 Methodology for Assessment of the Sites and the Distribution Of Questionnaire 8 2.2 Basis for the Audit 9 2.3 Applicable of Legislations 10 2.4 Visits to the Various Sited 10 2.5 Survey by Distribution of Questionnaire 11 3.0 Results 11 3.1 Summary 11 3.2 Commentary on Compliance 13 3.3 Results from the Questionnaire to the Employees 14 4.0 Findings 15 4.1 Limitations to Audit 16 5.0 Recommendations 16 6.0 References 19 Acknowledgements Environmental Audit Report on the Waste Management Scheme of the Birmingham City Council Submitted to Council Situated at: Birmingham City Council Council House Victoria Square Birmingham England B1 1BB Executive Summary The Environmental Baseline Audit in accordance with the regulations laid out by EMAS outlined the purposes of the Audit as: 1. A survey and assessment of how well the local council is doing in its legal compliance under UK environmental laws with special reference to the waste management under the provisions of UK Pollution Prevention and Control Act and other applicable regulations and 2. An assessment of the current environmental scenario, the creation of awareness among the staff and adopted practices for a sustained maintenance of the practices for the purpose of the environmental protection The Council had created a Department of Environmental Protection in the year 2005 and has announced its Environmental Policy in March 2006. An excerpt from the Environmental Policy of the Council adopted by a meeting of the council on March 21 2006 states among other things: The Environmental protection by way of efficient waste management will be given a top priority by the Council as to maintain a cleaner city and to ensure maximum protection to the environment of the City as set out in this Environmental Policy of the Council. The Council will strive to comply with regulations laid down by the County’s legal systems as well as by all the international conventions dealing with the environmental protection in the EU countries. The aim of the Council is to attain the maximum standards prescribed for the protection of environment in respect of Waste Management. As proclaimed in the Environmental policy in order to ensure that the compliance with the various environmental regulations are kept up to date and also to educate the staff of the Council on the importance of the Environmental protection, the Council has strengthened the ‘Department of Environmental Protection’ by increasing the scope of the department with more number of staff appointed there for. This department is entrusted with the specific task of taking care of the issues relating to the environmental protection and also the compliance with various environmental regulations has been made the responsibility of the department. A senior level manager has been appointed to oversee the functions of this department. The Council has appointed field inspectors to visit the various waste management sites of the Council located throughout the Council area, inspect the progress made by the sites on the environmental management and make a report thereon. The audit conducted a survey among 324 departmental employees who are entrusted with the various responsibilities for the waste management at 12 different sites of the Council. These employees were selected randomly out of the total employees of the Council. The audit also included the visits to the various sites during the period between April 2006 to March 2007 and a study of the reports maintained by the Council for a period of 3 years. The Department initiated the baseline assessments for the 12 major sites and received the reports submitted by the departmental staff. A review of these reports indicates that the Department had prescribed minimum requirements for compliance and the systems followed by the site staff were inadequate for compliance with the regulations in this respect. Moreover this audit finds that there was no proper allocation of fund to this department to ensure proper compliance and also the staff was inadequate to carry out the requirements. Hence this audit reports that “the compliance of the Council with the prescribed UK environmental protection laws and other applicable international regulations is inadequate and needs to be strengthened with immediate effect” 1.0 Introduction: 1.1 Background: As laid down by the Institute of Environmental Management and Assessment (IEMA), “Organisations have a legal and moral duty to comply with environmental laws and regulations; regulatory compliance is society’s licence to operate”. As such environmental protection and compliance with the legislations in this respect has been considered as an enhanced obligation of various organizations especially of the government departments with the creation of DEFRA the Department for Environment, Food and Rural affairs and the UK Environmental Agency. The Council initiated the action for the protection of the environment by creating a separate department and announcing the Environmental Policy in March 2006. The Environmental Policy makes a serious commitment of the staff of the Council including managers, supervisory staff and other clerical and operational staff to the objective of environmental protection by employing such practices as may be necessary to achieve this objective. The Council had also committed to ensure strict compliance with the UK environmental protection laws and the EU regulations as laid down in Eco-Management and Audit Scheme (EMAS). Audit work was conducted under the directive of UK Environment Agency. The audit includes a survey by questionnaire circulated to more than 300 staff of the council entrusted with the responsibility of waste management and site audits in 12 chosen locations across the various locations of the Council. 1.2 Scope: The scope of the audit included the assessment and review of the existing environmental protection status as to their compliance outlined by the UK Environment Agency in respect of Waste Management. The environmental aspects studied include: Sites having contamination prospects Management of hazardous wastages Substances having the possibility of depleting ozone Management of waste water Management of bio-degradable wastes Management of non bio-degradable wastes 1.3 Purpose: The purpose of this audit is to assess and report on the current level of the environmental compliance level of the Council. The audit has also to assess the progress made by the council in getting towards the compliance standards since the announcement of its environmental policy in the year 2006. The audit relied on the reports of the Council’s Department of Environmental Protection and also on the on-site assessment of the 12 chosen sites of the council. The purpose of this audit report is to present to the Council the current compliance status of the chosen sites with recommendations for possible improvements. 1.4 Site Description: The City council’s Waste Management Sites are situated in 36 locations spread over the council area convenient to reach by the residents. The sites accept a wide range of both hazardous and non-hazardous household items. Out of the 36 locations 28 are recycling centers in operation. In addition there are 8 community bring-centers which are similar to Recycling Centers but these centers serve a smaller community and accept fewer waste items. Public can deposit every waste items from glass, cans, paper, plastics, garden waste, clean rubbles suitable for recycling, household furniture and electrical goods and clothing in these centers. In addition wastes emanating from used refrigerators, mobile phones, and batteries can also be deposited. The sites do not accept used tyres of cars or other vehicles or materials having asbestos. The Council is not charging any fees or charges for most of the materials. Although most of the sites are outlets for the disposal of waste items maximum possible efforts are taken to recover or recycle the waste items. The sites accept household wastes and some items of trade or commercial wastes. 2.0 Audit Methodology: 2.1 Methodology for Assessment of the Sites and the Distribution of Questionnaire: The assessment of the 12chosen sites was carried out in the following stages: Stage I – Review of Documents For easy comparison of the information pertaining to the sites, a summary of the information from each site is complied and tabulated The information thus compiled was analysed to isolate the findings that appeared in all the review reports A list of all findings that had relevance to the environmental compliance was compiled Stage II – On Site Assessment: Site visits were conducted during the period from April 2006 to March 2007 at the rate of one site per month chosen at random The on site assessment included the observation of the facilities physically, interviews with the site staff and a study of the additional information provided by the site technical staff Stage III – Preparation of Report: Based on the review of the documents and the onsite assessments a detailed report indicating the progress made in respect of the environmental compliance was made. The collection of information on the basis of questionnaire method involved the following stages: Stage I – Preparation of Questionnaire: Based on the requirements as per the UK legislations governing the Environmental Protection in general and the waste management in particular a questionnaire with well laid out thematic questions was prepared The questionnaire was circulated to 324 employees of the Council who are connected with the environmental protection and have a primary responsibility thereof. Stage II – Collection of Information: The feedback reports received from the staff in the form of the questionnaire duly completed were studied, tabulated and compiled to make them meaningful The information so collected was analysed to study the overall progress as well as site wise progress was assessed. Stage III – Preparation of Report: The summary of the information collected from the questionnaire was incorporated in to the main report for presentation to the Council. 2.2 Basis for the Audit: As outlined the primary objective of the audit was to assess how well the council was performing in relation to its legal compliance requirements under the applicable UK environmental laws. The following laws are determined to be applicable in the matter of the environmental issues of the Council. UK Pollution Prevention and Control Act and Eco-Management and Audit Scheme (EMAS) Regulations (EC 1993) The criteria for audit were drawn out of the specific regulatory requirements as laid down by the specified legislation and also from other applicable additional regulations with specific reference to the waste management. The different environmental aspects that the audit report concentrated include: Sites having contamination prospects Management of hazardous wastages Substances having the possibility of depleting ozone Management of waste water Management of bio-degradable wastes Management of non bio-degradable wastes 2.3 Applicable Legislations: The following regulations of the Country United Kingdom are applicable to the Waste Management of the City Council: The Environmental Protection Act 1990 The Control of Pollution (Amendment) Act 1989 The Waste Management Licensing Regulations 1994 (as amended) 2.4 Visits to the Various Sites: The selection of sites was based on the size of them as well as the geographical location of the sites concerned. The audit team selected 12 sites across the council’s boundaries for evaluation. On the visits to each of these sites the auditor followed the system of completing the audit format containing the procedures for conducting the audit including physical observation of the facilities at the sites, review of the documents being maintained at the site, a review of the routine of the staff at the sites and personal interviews with the staff at the sites relating to the environmental protection facilities and their understanding and observation of such practices to ensure compliance. 2.5 Survey by Distribution of Questionnaire: The process of the survey by the distribution of questionnaire to the randomly selected employees included framing questions that were developed to ensure that the answers to the questions provide a meaningful and objective indication of the level of compliance. This stage was followed by the collection of data, compiling them in order of relevance and finally preparing the summary results of the survey. The scope of the questions contained in the questionnaire included the indication of adherence to the specific standards of compliance and the degree to which the progress was achieved in the opinion of the respondents. The survey includes a sample population of 324 employees of the Council and of these 86.5 percent employees responded by returning the questionnaire duly filled. The overall survey results can be considered accurate at 95 percent confidence level with a minor variation of +/- 1.2 percent. 3.0 Results: 3.1 Summary: The results on an overall consideration reveal that the compliance level of the Council with respect to the environmental issues concerning the waste management is inadequate and needs improvement in various respects. Though some of the sites visited showed improvements over the period the overall performance of the council was not satisfactory in most of the locations. However it was observed that the Department of Environmental Protection of the Council has issued stricter guidelines to the respective site in-charge for a speedier implementation of the compliance formalities. This initiative from the Council may result in an improvement on the compliance position. The following table provides the average trend of the compliance levels in the sites visited during the audit period. Table Showing the Average Level of Compliance in the Different Sites Location Contamination In the sites Hazardous wastage Ozone Depletion Waste Water Biodegradable Wastes Non-Bio Degradable Wastes Location 1 _ _ _ Location 2 _ Location 3 _ _ _ _ _ _ Location 4 _ _ _ Location 5 _ Location 6 _ _ _ _ _ _ Location 7 _ Location 8 _ _ _ _ Location 9 _ _ _ _ Location 10 _ _ Location 11 _ _ _ _ Location 12 _ _ Indicates Improvement - Indicates Deterioration - Indicates Same Status - ‘_’ 3.2 Commentary on compliance: A detailed commentary on the trends that were observed in the various criteria for audit is presented below: Contamination in Sites: On an overall assessment it is observed that the despite the efforts being put to avoid the contamination in the sites there appear to be only lukewarm development in this respect in the various sites visited. On analysis and on the basis of the personal interviews with the site staff it was found that due to insufficient allocation of funds the sites were unable to implement the proposals for the environmental compliance. Though a clear identification of the problems was established it was not possible to implement the remedial measures for lack of funds. Hazardous Wastages: It has been observed except in two sites the treatment of hazardous wastage was not given adequate consideration for safe treatment. The improvements noted in two sites were identified as the personal initiative of the site in-charge. The lacuna in most of the sites is the absence of trained staff to handle the hazardous wastage materials. However the storage capacity posed no problem. Ozone Depleting Materials: The same observation as in the case of hazardous waste also holds good for the ozone depleting materials in that except two sites staff in other sites either do not have knowledge of the concept of depletion of ozone and the effect on the earth or there are no facilities to curtail this environmental concern. Waste Water Management: Waste water management shows a little improvement by the discharges from the sites are well connected to the municipal drainage systems in some of the sites. But some more sites were having the waste water flowing on the surface causing environmental concerns which needs immediate rectification in the systems. Biodegradable Waste: By collecting the household wastages in different bins the treatment and management of the biodegradable waste management shows a noticeable improvement over the period. Once the public I educated to separately dump the waste materials there can be substantial improvement in the management of these waste materials. Sufficient provisions have been made to make these waste materials to decompose naturally in most of the sites. Non-Biodegradable Waste: The non availability of insinuators in most of the sites makes it difficult for the site in-charge to deal with the non-biodegradable waste materials. The non-allotment of sufficient funds was attributed as the reason for the absence of insinuators at the various sites. 3.3 Results from the Questionnaire to the Employees: The questionnaire distributed to the 324 employees of the Council. The samples were selected at random from the list of 2456 employees provided by the council who are closely associated with the waste management and were responsible for the operations of the waste management. The selected employees were notified by means of a covering letter with the questionnaire the purpose and scope of the questionnaire and the contribution it makes for the improvement in the overall waste management. By specifying the significant purpose of the proposed contribution to the improvements the employees were made to answer the questions with more sincerity. The employees selected were at supervisory and above levels. The profile of the respondents was: 24 percent represent site in-charges at Managerial level 43 Percent represent middle level managers 33 percent represent supervisory cadre employee The main findings from the questionnaire survey indicate the following results: The degree of awareness about the legislations governing the environmental protection among the staff can be considered to be at a medium level. This has resulted in the violation of the environmental legislations to some extent. 52 percent of the staff affirmed that they were aware of the violations of the provisions of the environmental regulations and 33 percent of the respondents were not aware of the regulatory provisions According to 38 percent of the respondents there was no priority to the legal compliance in the sites. 73 percent of the sample agreed that lack of training was the main cause for the abysmal progress in environmental protection and 65 percent of the staff complained about lack of facilities for ensuring compliance 4.0 Findings: On the basis of the Audit conducted on the 12 sites of the Council it can be reported that the compliance levels at most of the sites of the Council are below the standards and are not in conformity with the environmental policies announced by the Council. Though the Department of Environmental Protection of the Council is entrusted with the responsibility of ensuring the compliance to the maximum levels of the prescribed standards, the periodical reports to the department remained unattended and hence there was no serious review of the environmental protection activities at the various sites. For an efficient environmental management system and compliance a number of systems have to be evolved and put into practice. Another major concern is lack of awareness among the staff which demands the imparting of the training at various levels. Similarly the provision of adequate funds to get the sites equipped for better waste management is also considered essential. 4.1 Limitations to Audit: The major limitation of the audit was that the vastness of the records coupled with different format used for reporting in the various sites made the study of the past records difficult. In addition out of the responses received for the questionnaire compilation of the information pose a problem because of the subjective nature of the issues involved. 5.0 Recommendations: The establishment of an efficient Environment Management System coupled with training of the employees is the primary recommendations this audit report makes to the Council: 1. Establishment of an Effective Environment Management System: It is for the Council to establish an effective Environment Management System (EMS) with the following clear objectives: Objective (i) Establishment of Compliance levels and fixing up of the accountability of the for the compliance at all levels including reporting requirements for every programme and sites Action Recommended: The Department of Environmental protection of the council will formulate a detailed framework for the establishment of the compliance levels for thevarious waste items and sites with appropriate indications of people responsible for the maintenance of the standards. This statement would be prepared and submitted by Mr. Stanley Louise the Manager – Environmental Compliance to the General Manager of the Department Mr. D. Logan on or before 30th June 2007. Objective (ii) A Comprehensive and well laid out programme of compliance monitoring and Reporting that gives a clear picture of periodical progress made in the matters relating to Environmental Compliance Action Recommended: It is suggested to make a critical assessment of all the baseline reports so far made and form the findings and on the basis of meetings to be conducted at the departmental level, the Manager – Compliance Monitoring Mr. James Watson will prepare and submit to the General Manager Mr. D. Logan with a copy to the Manager – Environmental compliance for approval, the program for the monitoring and reporting on the compliance in the various sites in respect of the different materials. This program will be prepared and submitted by Mr. Watson on or before 30th June 2007. The program apart from mentioning the tasks to be accomplished, should also fix the accountability on the individual staff to be named in the program Objective (iii) A Review of the roles and responsibilities of all the staff and managers connected with the Department of Environmental Compliance should be done Action Recommended: The General Manager Mr. Logan needs to undertake an organisational and functional review of the Department for the possible identification of strengths and weaknesses and improvement. It is also recommended that a periodic review of the reports submitted by the Field Inspectors be undertaken by the General Manager to review the progress being made. 2. Training programmes: Well coordinated training progrmmes encompassing the requirements of the legislative requirements in respect of environmental protection and the role and responsibility of all the staff should be organized to impart training to the staff at the various levels. 3. Provision of Adequate Funds: Adequate funds for the provision of various facilities for the effective implementation of the environmental protection programmes should be given top priority if the Council wants to see considerable improvement in the matter of environmental protection. References: 1. IEMA Managing Compliance with Environmental Law: A Good Practice Guide http://72.14.235.104/search?q=cache:kGKCHIj0DGgJ:www.iema.net/download/legal/Practitioner%2520Vol%25206%2520Legal%2520Compliance.pdf+model+environmental+baseline+audit+report+under+EMAS+guidelines+%2B+UK&hl=en&ct=clnk&cd=27&gl=in&client=firefox-a 2. Audit and Evaluation Directorate Audit of Environmental Compliance http://www.dfo-mpo.gc.ca/communic/cread/audits/03-04/envcomp_e.htm#Executive%20Summary (Source for the format of the Audit Report) Read More