Environmental compliance as a business improvement strategy

By Craig Beyers

Environmental laws are constantly evolving and we have seen a regulatory shift in recent years across a number of states where companies and organisations must take steps to demonstrate they’re not causing any problems.

These laws are moving away from fixed limits and compliance being a process of staying within those limits. Increasingly businesses have to demonstrate they're not doing any harm, which requires a more systematic and ongoing approach of monitoring, record-keeping and innovation, and most importantly, someone helping the businesses with experienced and professional advice.

As a result, there will be greater pressure on businesses to understand and ensure compliance in an increasingly technical area, and established habits of compliance as an annual audit and reporting obligation won’t be sufficient in many cases.

This may on first consideration seem to be a time-consuming or costly inconvenience however, there is a way to make environmental compliance an invaluable business improvement strategy rather than a regulatory obligation or headache.

Treating compliance as an ongoing and integral part of your business, working with experts to address challenges and incorporate systems early, can save your business time and money, improve efficiencies and boost the organisation’s reputation.

When we work with out clients on an ongoing basis, we speak with them regularly to track what is happening and remain informed, and through that, our clients are able to use ongoing information and reporting as an opportunity to change or improve the business and operations.

Ultimately, the cost of dealing with notices and enforcement actions means you as the person running the business or organisation aren’t focusing on core business - you're putting out grass fires rather than growing.

 

Benefits of ongoing compliance

  • early detection and rectification of any potential breaches
  • operating and complying with environmental regulations becomes easier
  • potential to identify financial and environmental savings in re-using waste emissions as a resource instead. For example one AMG client is now capturing heat from their used gas emissions so they can use that in other processes rather than losing that energy as emissions to air.
  • improved reputation with regulators and a smoother pathway through compliance processes. When a regulator sees a business is working with a trusted and professional consultant such as AMG, they feel confident compliance matters are well in hand.
  • less likely to receive notices of noncompliance and therefore can avoid the time, money and effort required to deal with regulators, auditors and rectification works.

 

Common compliance mistakes

Leaving it too late.

Ideally, compliance should be an ongoing, year-round process, staying on top of what's happening in the business so that when the annual compliance check comes around, it's already under control.  

However for many businesses without a dedicated environmental officer or consultant, the reporting period is often ignored until the last minute, resulting in a panicked phone call to our office when there are only days left to deadline.

This leads to the business having to provide an explanation and request an extension of regulators, and ultimately, you would expect to end up with a regulator coming out do to a site inspection and audit to see how many other things have been ignored.

Not reading or understanding the EA.

Often we'll find that the Environmental Authority or Permit has been filed, more or less permanently, without being read and certainly not fully understood.

While this is understandable - management teams are busy operating their business and most are not conversant in environmental issues or language - it doesn't help the business, and can in fact be detrimental leading to uninformed and costly decisions.

Playing dumb

For long-standing businesses, doing what they've always done for two or more decades seems easy and correct, but is no defence when a non-compliance notice is issued.

A number of times confused business owners have said to us: “But we've always done it this way” or they'll claim it's not their fault because they didn't know any differently.

Neither of those excuses will fly with regulators - the onus is on the business to stay up to date and compliant.  

 

How to do compliance well

* Go over a copy of your Environmental Authority or Permit - have a good read of it, line by line. Do you understand it? Are there any areas you're not compliant? If there are any areas of doubt, pick up the phone and call a specialist consultant.

* Talk it through. Highlight the things in the EA that you're currently not doing or not sure of, and make a note if there are areas that no longer match your business at all. Businesses change and you may be operating outside of your authority, or you may no longer need to meet some conditions.

* Start now. Compliance should be continual, and the longer lead time you have until your deadline, the easier it will be to have a smooth time of the process. With most areas, anything that requires a change will take longer than a week or month - most environmental monitoring takes a minimum of four weeks - or in the case of a licence change, even six months. So the longer you have to bring things into order, the easier it will be.

* Stay with it. Once everything is reviewed and updated, and compliance has been met, don't leave it until next year. With regular catch-ups and updates, your consultant can help you stay on track and next year's compliance deadline won't even cause a ripple in your schedule.

 

 

 

Case Study: Odour Monitoring and Modelling

AGRICULTURAL SECTOR (ABATTOIR)

This project involved looking at two sources of wastewater generated by a tannery plant and abattoir.

The wastewater from each section of the business was very different in terms of chemical composition and was previously, handled and disposed of separately on site.

Given the differences in chemical composition, this separate treatment and disposal of the wastewater products resulted in a number of issues for the plant including the need for duplicate infrastructure and corrosion caused by the chemical composition of the waters.

The client was interested in investigating the potential benefits and/or adverse impacts as a result of the treatment and combined storage and irrigation of wastewater from both the abattoir and tannery operations.

While the blending of these waters provided a number of clear benefits for the operation of the facility, the potential odour generation as a result of the storage and irrigation of the blended wastewater was unknown.

odour monitoring abattoir

As part of the project, AMG worked with the client to

  • Review all available information to inform the development of a trial test program;
  • Collection and analysis of odour samples collected from the blended wastewater;
  • Comparison of the measured odour emissions for the blended wastewater with those for the separate sources; and
  • Undertake odour dispersion modelling to assess the potential for adverse off-site amenity impacts.

 

PROJECT CHALLENGES 

The project involved blending two streams of wastewater with very different compositions and trying to determine what the odour generation would be over the full treatment life at the facility (from generation to irrigation).

Through a detailed literature review the expected variability of odour generation potential across the treatment process was determined and a sampling plan developed to allow the odour emissions to be determined. This included development of a holding tank solution (to simulate the storage of the blended wastewater in a pond) with the tank dimensions and water holding times selected to allow similar air/water interaction to occur.

 

RESULTS

The work undertaken was able to support the blending of these wastewater streams for on-site disposal.

Overall, the project delivered a number of positive outcomes including:

  • Cost-savings for the client through reduced infrastructure costs;

  • Increased nutrient and water reuse through the ability to apply the blended water to the existing agricultural property (rather than disposal to sewer);

  • Reduced potential for odour impacts through recommended modification of the irrigation zones used on the farm to prevent off-site amenity impacts.

 

Innovation within industry provides significant potential benefits in terms of operational efficiency, cost saving and improvement of work conditions. Understanding the full range of potential impacts associated with this innovation requires input from a team that is able to move beyond standard impact assessment methodologies.

AMG’s ability to use our wide and varied experience to develop methodologies to determine the potential impacts of these innovative solutions is essential when considering the risks associated with a change in operations.

 

Paving the way for the asphalt industry

by Craig Beyers

As residential planning initiatives continue to try to curtail urban sprawl in Australian cities, sustainable infill development closer to city centres presents a significant challenge to the asphalt industry.

With residential housing now increasingly being approved for areas that once acted as buffer zones from industrial areas, the potential for complaint and conflict over emissions is increasing.

Timely investigation and strategic planning though can offer some protection for asphalt plants looking to avoid this conflict and the potential associated costly remedial or relocation works.

ASPHALT - RAP Drum - VSMALL - shutterstock_33641857.jpg

What we’re seeing at the state government level is that most planning now places emphasis on development and intensification of specific zones, including former industrial areas, fringe industrial areas and surplus government land.

New housing development is occurring within these defined zones, particularly around transport hubs and areas with urban-renewal potential.

These developments typically trigger a town planning approval process which attempts to seek a balance between the competing interests of existing industrial operators and housing developers.

This process though gives rise to potential complaints and damaging public relations coverage for existing asphalt facilities, and post-approval, the potential conflict can continue and we’re already seeing cases of this, whether it’s in regards to potential health effects of emissions, or when facilities seek an amendment to their operations.

Either way, the sustainability, growth and economic viability of these facilities can be compromised or hampered.

A proactive approach to protect the plant and neighbours

Taking the lead on the issue before a problem arises, and seeking out professional assessment to provide the means for strategic planning can maintain harmony with community as well as protect the commercial viability of the plant.

It enables the company to foresee potential future complaints and issues, and make production and equipment decisions to avoid them.

Over the life of an asphalt plant, decisions are made about what products to make, when to produce them, what equipment to purchase and where to place it.

Understanding how the odour emitted from the various products can influence the surrounding area provides valuable information that can inform a number of these choices and therefore minimise the potential for complaint or conflict.

As changes are made to the operation of an asphalt plant, understanding how these changes could influence the ability of the plant to operate can assist in minimising the potential for regulatory compliance issues.

There are a number of examples around Australia where a lack of understanding (often by regulators and planning authorities) of the influence of odour emissions from a plant have resulted in community complaints and regulatory involvement.

Ultimately, these external factors can lead to difficult decisions about capital upgrades and in some cases, the viability of a particular site or operation which had they been considered in advance, may have been avoided.

The key information to minimise conflict risk

A professional assessment of the plant will give management three essential pieces of information they can use to minimise emissions and therefore also minimise the risk of complaint.

These are:

  • Understanding what odour is being generated now and where the influence of the site extends;

  • How changes to production can influence odour generation;

  • Ability to consider odour emission as a key part of any design or capital purchase process so that plant designs, whether new or upgraded, are able to continue to operate into the future.

Seeking advice prior to changes in production and plant operations can also protect the facility from costly mistakes.

Read more about our emissions monitoring, modelling and reporting services.