Great White North Environmental Services Limited provides environmental auditing services to a wide range of private sector clients and governmental agencies.  An environmental audit is the procedure used to identify and assess environmental risks at a site.  There are numerous types of environmental audits that may be conducted on a given site.  These include Property Transaction, Compliance, and Facility (Management Systems) Audits.  Great White North Environmental Services Limited observes the guidelines, wherever applicable, as published by the following governmental agencies:

• “Generally Accepted Standards for Environmental Investigations;”[1]

•  “Phase I Environmental Site Assessment, Environmental Technology, A CSA Information Product;”[2] and

•  “Environmental Audit Guidelines for the Petroleum Industry.”[3]

Phase I Property Transaction Audit

The Property Transaction Audit is conducted to determine the environmental integrity of the site and adjacent properties.  This type of audit addresses issues relating to past and present land uses and provides information concerning potential and/or existing contaminant sources.  This auditing process answers the question, "Is there any reason to suspect that the environmental integrity of the subject or adjacent properties has been impacted by the presence of contamination?"  The activities that constitute an Environmental Property Transaction Audit include the following:

• Site Reconnaissance (on the subject site, adjacent, and proximate properties);

• Interviews (for the subject site, adjacent, and proximate properties);

• Historical Aerial Photographic Review;

• Historical Land Titles Search; and

• Regulatory Agency Enforcement Action and Municipal Records Research.

Site Reconnaissance

A "walkabout" of the subject property will reveal obvious signs of present or pre-existing contamination.  Denuded or stained surface soil, dead vegetation, debris, drums of unknown material, and surface piping from underground storage tanks are only a few of the indicators of potential contamination.  Wherever underground storage tanks are found, information concerning their structural integrity (such as fill records, pressure leak tests, etc.) is important to determine the presence of soil and/or groundwater contamination.  When the investigator conducts a Phase I Environmental Audit, it is important to determine the source locations of potential contamination.  Such locations include, but are not limited to, underground fuel storage tanks, loading/unloading areas, containment ponds and lagoons, surface tank storage, and chemical storage areas.

The complexity of the site reconnaissance relates directly to past and present land uses.  Where the land is of a heavy industrial nature (e.g., chemical manufacturing, smelting, plating, etc.), Industrial Facility Audits may take several weeks and require specialized personnel.  Conversely, Property Transaction Audits (e.g., office towers, single family dwellings, etc.) may be completed in less than ten (10) days.

During a Phase I Property Transaction Audit the subject site is thoroughly inspected for the presence of polychlorinated biphenyls (PCBs) in fluorescent light ballasts and the presence of asbestos containing materials (ACMs) in floor and ceiling tile and as insulation for walls and pipes.

Historical Aerial Photographic Review

This required task of the Phase I Environmental Audit reveals information concerning past land uses on the subject and adjacent properties.  A stereoscope is utilized to view the aerial photographs under magnification, in a three-dimensional manner.  The photographs are reviewed, with respect to time, thus revealing past land uses.  Former facilities, such as abandoned landfills, service stations, and industrial sites, may indicate that the environmental integrity of the site has been impacted and that contamination may exist.  Such findings are crucial to a thorough investigation.

For example, in downtown Calgary, Alberta there are no less than thirty-six (36) aerial photographs that exist from 1924 to the present.  Great White North Environmental Services Limited, therefore, attempts to retrieve all seventy-two (72) aerial photographs so as to review all of the data for each year stereoscopically.

Historical Land Titles Search

This task, similar to the Historical Photographic Review, may reveal information that concern past land uses.  The names of past businesses, found on the former land titles, often provide information as to the type of activities that occurred on the subject site.  This information is useful to indicate whether contamination is absent or present and, if present, what type of contamination potentially exists on the present day site.

Regulatory Agency Enforcement Action and Municipal Records Research

The subject and adjacent properties are cross-referenced against regulatory agency lists of locations cited for breach of environmental legislation.  Examples of agencies providing such information are Environment Canada, Alberta Environment, the Alberta Energy and Utilities Board and City and Municipal agencies.  Any location that has been cited for breach of environmental legislation is duly noted in the audit report.

• Land Titles Offices (e.g., Alberta Land Titles Office);

• Municipal Building and Planning Departments (e.g., City of Calgary - Planning and Building Departments);

• Municipal By-law Enforcement, Engineering and Environmental Services Departments (e.g., City of Calgary - By-law Enforcement, Engineering and Environmental Services Department);

• Municipal Environmental Offices (e.g., City of Calgary Office for the Environment);

• Municipal Fire Departments (e.g., City of Calgary Fire Prevention Bureau);

• Municipal Archives (e.g., City of Calgary Archives);

• Petroleum Tank Management Association of Alberta;

• Alberta Public Safety Services, Dangerous Goods Control Division Co-ordination and Information Centre;

• Environmental Law Centre (replaces Alberta Environmental Protection since privatization);

• Henderson’s Business Directory;

• Municipal Numerical and Street Address Directories (e.g., Calgary Numerical and Street Address Directory); and

• Insurers’ Advisory Organization (1989) Inc. Database:  Historical Environmental Information Report System (HEIRS).

The Phase I Compliance Audit

The key purposes of an Environmental Compliance Audit are to firstly provide a management tool to assess risk and to ensure compliance with permits and with environmental laws of general application.  Secondly, it is used to determine whether there is in existence a due diligence pollution prevention system.  The Compliance Audit is concerned with issues such as:

• Hazardous Materials Management;

• Hazardous Waste Management;

• Indoor Air Quality;

• Outdoor Environment;

• Employee Health and Safety; and

• Emergency Preparedness.

The Phase I Facilities (Management Systems) Audit

The Management Systems or Facilities Audit is conducted to determine the environmental integrity of the site and adjacent properties due to past and current hazardous materials handling disposal practices and plant process facility operations.  This type of audit addresses issues relating to past and present land uses and provides information concerning potential or existing contaminant sources.  The activities that constitute a combined Compliance and Facilities (Management Systems) Audit include the following:

• Legislation and Regulations Applicable to the Operation;

  • Summary of requirements;

  • Certificate of Approval and Permits;

  • Compliance schedules to be met;

  • Monitoring; and

  • Reporting.

• Management Systems Organization;

• Policies;

• Organization, Responsibilities, and Accountability;

• Procedures, Planning, and Goal Setting;

• Commitment of Resources for Staffing, Training, Equipment, and Maintenance; and

• Procedures for Handling Spills, Incidents, Violations, and Enforcement.

• Site Characterization;

• Operations; and

• Management Systems.

• Organization and Responsibilities;

• Routine Monitoring and Record Keeping;

• Reporting:  External, Formal, Routine, and Special Incidents (e.g. spills);

• Government Liaison:  Responsibilities and Routine;

• Training; and

• Maintenance and Repair Procedures:  Environmental Component.

Phase I Environmental Auditing for the Petroleum Industry

Environmental Site Assessments

Environmental Site Assessments (ESAs) for the petroleum industry are conducted as per the Canadian Petroleum Association’s document entitled, “Environmental Audit Guidelines for the Petroleum Industry” and the Consulting Engineers of Ontario document entitled, “Generally Accepted Standards for Environmental Investigations.”

The ESA consists of the following tasks:

• Detailed Site Reconnaissance;

• Historical Records Review;

• Historical Aerial Photographic Review;

• Historical Land and Subsurface Titles Search; and

• Regulatory Agency Enforcement Action and Municipal Records Research.

Site Reconnaissance

Special emphasis is placed on the site reconnaissance, where the physical condition of the site facilities are observed and recorded.  Denuded or stained surface soil, dead vegetation, debris, drums of unknown materials, and surface piping from underground storage tanks are only a few of the indicators of potential contamination.  Wherever underground storage tanks are found, information concerning their structural integrity (such as fill records, pressure leak tests, etc.) is important to determine the presence of soil and/or groundwater contamination.  Source locations of potential contamination are noted.  Such locations include, but are not limited to, loading/unloading areas, containment ponds and lagoons, surface tank storage, and chemical storage areas.

Historical Records Review

A Historical Records Review includes, but is not limited to, the collection of data from the following sources:

• facility processes;

• produced products;

• produced wastes;

• underground storage tank sites;

• underground disposal sites;

• other waste disposal data;

• spills of oil or hazardous chemicals;

• media reports;

• interviews with long service employees;

• Alberta Energy and Utilities Board (AEUB);

• Alberta Environmental Protection, Pollution Control Division;

• Alberta Environmental Protection, Regulatory Approval Centre;

• Alberta Energy, Government Information Centre; and

• Alberta Environmental Protection, Land Reclamation Division.

Historical Aerial Photographic Review

This required task of the Phase I Environmental Audit reveals information concerning past land uses on the subject and adjacent properties.  A stereoscope is utilized to view the aerial photographs under magnification, in a three-dimensional manner.  The photographs are reviewed, with respect to time, thus revealing past land uses.  Former facilities, such as abandoned landfills, service stations, and industrial sites, may indicate that the environmental integrity of the site has been impacted and that contamination may exist.  Such findings are crucial to a thorough investigation.

For example, in downtown Calgary, Alberta there are no less than thirty-six (36) aerial photographs that exist from 1924 to the present.  Great White North Environmental Services Limited, therefore, attempts to retrieve all seventy-two (72) aerial photographs so as to review all of the data for each year stereoscopically.

Historical Land and Subsurface Mineral Titles Search

The Historical Land Titles Search is conducted in the same fashion as all other Phase I Environmental Audits with the exception that a Historical Subsurface Mineral Titles Search is also conducted.  This information is provided by Petroleum Information Canada and the Alberta Energy and Utilities Board (AEUB).  Additional information provided by the above referenced agencies include the following:

• Interim Directives;

• Information Letters;

• List of All Wells;

• Well Records Summary;

• Battery Records Summary; and

• Environment Information System (Spill Reports).

Information obtained from the Alberta Energy and Utilities Board includes the following:

• List of All Wells in Alberta that provides the status of all wells pertinent to each subject site.  This information includes the well identification, well name, license number, field/oil sands area, pool/oil sands deposit, operator and licensee, well status, drilling depth and finish drilling date;

• Environmental Information System (Spill Reports) contains information concerning details on the location, date, source, cause, product released, extent of the release, remediation and reclamation dates; and

• Well Records.

Regulatory Agency Enforcement Action and Municipal Records Research

The subject and adjacent properties are cross-referenced against regulatory agency lists of locations cited for breach of environmental legislation.  Examples of agencies providing such information are Environment Canada, Alberta Environment, the Alberta Energy and Utilities Board and City and Municipal agencies.  Any location that was cited for breach of environmental legislation is duly noted in the audit report.

• Alberta Land Titles Office;

• Municipal Environmental Offices;

• Municipal Fire Departments;

• Environment Canada;

• Petroleum Tank Management Association of Alberta;

• Alberta Public Safety Services, Dangerous Goods Control Division Co-ordination and Information Centre;

• Environmental Law Centre;

• Alberta Environmental Protection, Regulatory Approval Centre;

• Alberta Energy, Government Information Centre;

• Alberta Environmental Protection, Land Reclamation Centre; and

• Alberta Energy and Utilities Board (AEUB).

Information obtained from Alberta Environmental Protection, Pollution Control Division, Compliance Branch, includes the following:

• The issuance of Control Orders, Stop Orders, Prosecutions, and/or Tickets issued to any company/person(s) owning the subject properties as they may pertain to the Hazardous Chemicals Act, Clean Water Act, Clean Air Act, Agricultural Chemicals Act, or the Environmental Protection and Enhancement Act.

Phase I Environmental Site Assessment Facilities or Management Systems Audits

The Facilities or Management Systems Audit is conducted, as per the Canadian Petroleum Association’s document, “Environmental Audit Guidelines for the Petroleum Industry,” to determine the environmental integrity of the site and adjacent properties due to past and current hazardous materials handling disposal practices and plant process facility operations.  This type of audit addresses issues relating to past and present land uses and provides information concerning potential or existing contaminant sources.  This organization of the Audit System, as provided by the CPA Audit Directory is subdivided into three (3) categories:

Loss Control or Safety Audits

General

The Loss Control or Safety Audit is conducted in accordance with the following documents:

•  “Basic Safety Program Audit;”[4]

•  “Impact 2000 - A System for Evaluating the Management of Health and Safety Programs;”[5] and

•  “Voluntary Environmental Management System.”[6]

In order to ensure that the proactive safety and environment management programs, procedures and practices comply with all relevant regulatory requirements, Great White North Environmental Services Limited follows the revised 1996 industry standard, "Basic Safety Program Audit" (BSP) produced by the Upstream Petroleum Industry Task Force on Safety (U.P.I.T.F.O.S.), the "Impact 2000" system for evaluating the management of health and safety programs, and the “Voluntary Environmental Management System,” CSA Z750-94.

Greater emphasis is placed on utilization of the, “Basic Safety Program Audit” provided by the Upstream Petroleum Industry Task Force on Safety (U.P.I.T.F.O.S.).  This document is specific to conducting Loss Control and Safety Audits for the petroleum industry and is also the most current having been revised recently in January, 1996.  “Impact 2000,” authored by the Workers Compensation Board in 1992, is utilized as a reference document as it is less specific to the petroleum industry and is not as current as the “Basic Safety Program Audit.”

The audit process, is comprised of three (3) stages:

• Information gathering and employee notification;

• The audit itself; and

• Audit analysis and report with recommendations to address deficiencies identified in the audit.

The audit itself comprises seven (7) areas of evaluation:

1. Management involvement;

2. Hazard identification and control;

3. Rules and work procedures;

4. Training;

5. Communication;

6. Incident-accident reporting and investigation; and

7. Environmental planning with special attention to risk assessment, waste management, biophysical impacts, and reclamation.

Great White North Environmental Services Limited’s proactive approach to loss control audits is a comprehensive and objective evaluation of the design and effectiveness of a safety program and environmental plan.  The investigator should obtain valuable input from individuals at the work sites on the practicality of the safety program and assesses each component of the operation to determine the success of the current safety program and environmental plan.

Purpose

A Safety Program or Loss Control Audit is a comprehensive and objective evaluation of the design and effectiveness of a safety program.  The objective of a Loss Control Audit of a facility is conducted in order to:

• contribute to improving human health and safety and environmental protection by recognizing operational risks;

• anticipate and respond to potential risks in a timely manner;

• foster an environment in which employees and others at the work sites are encouraged to offer input regarding the usability and practicality of the safety program and environmental management system;

• obtain valuable input from employees and others at the work sites on the usability and practicality of the safety program and environmental management system; and

• evaluate each individual component of the operation to determine how well the program is being implemented.

Meeting these objectives will provide a formula for achieving the desired objectives of:

• Acquiring up-to-date information regarding facilities and operations;

• Evaluating information management systems, regulations, performance, operating practices and facility conditions; and

• Ensuring that current programs, practices and procedures comply with regulatory agency requirements.

The Loss Control Audit Process

The Loss Control Audit process comprises three (3) stages consisting of the following tasks:

Stage I focuses on information gathering and employee notification.  The investigator should gather information on all written materials and/or documents, such as:

1.      job descriptions and/or lists of safety responsibilities;

2.      inspection checklists;

3.      hazard and accident report forms;

4.      standard work procedures;

5.      training materials;

6.      policies; and

7.      emergency procedures.

All employees should be informed that a Loss Control Audit will take place and that they will be requested to participate in the interview process.  The investigator must ensure all employees of interview confidentiality.

Stage II is conducting the Loss Control Audit itself, utilizing the Basic Safety Program Audit Form, and is undertaken via observations, interviews, and an examination of company documentation.  The Loss Control Audit comprises seven (7) phases:

Phase 1     evaluates Management Involvement in the areas of:  Company Safety Policy, Guiding Principles, Safety Responsibilities, and Management Communication;

Phase 2     focuses on issues of Hazard Identification and Control, specifically: Inspections, and Hazard Reporting;

Phase 3     investigates Rules and Work Procedures in terms of:  Safety Rules, Legislative Compliance, Standard Work Procedures, Personal Protective Equipment (PPE), Enforcement, and Emergency Procedures;

Phase 4     assesses the Training component, including: Safety Orientations, and On-the-Job Training;

Phase 5     evaluates Communication, including:  the Communication System, and Safety Meetings;

Phase 6     assesses Incident and Accident Reporting, Investigation and Follow-up Procedures; and

Phase 7     focuses on Environmental Planning and Management with special attention to Risk Assessment, Waste Management, Biophysical Impacts, and Reclamation.

Stage III includes a quantified analysis of the audit, an evaluation of the environmental plan, and submission of a copy of the completed audit and jobsite evaluation.  The evaluation is twofold.  Phases 1-6 are scored according to the BSP.  Audits that score 80% and over reflect high standards and an acceptable safety program; scores under 80% reflect a substandard program.  Phase 7 is evaluated against the CSA Z750-94 model.  The purpose of this phase is to:

The focus of the Loss Control Audit is centered on thoroughness and accuracy.  A review of all collected documentation is included, but not be limited to, the following:

• The company’s safety policies and standard work procedures;

• All other written materials, such as safety responsibility documents, inspection procedures, incident and accident investigation procedures;

• Training and maintenance records regarding personal protective and safety equipment;

• Written emergency response plans;

• Records of safety orientations, on-the-job training, investigations, inspections, audits, safety performance assessments;

• Safety meeting agendas and minutes; and

• Relevant safety legislation.

The company should inform employees that an audit is to take place and that they will be interviewed by the consultant’s auditors.  To ensure that those interviewed provide accurate and true information, the auditors must inform them that their names will be kept confidential.  It is important to protect the rights of individuals to express their opinions freely without apprehension of consequences.

Stage II:         The Loss Control Audit

Phase 1:          Management Involvement

Company Safety Policy

The company’s written safety policy can effectively convey management's commitment and positive attitude toward safety and health functions.  To be effective, management must promote the policy and philosophy actively throughout the company. The investigator should evaluate the policy to ensure it contains:

• signature of the most senior manager at the facility and/or company president;

• reference to management responsibility;

• requirement to comply with government regulations;

• reference to supervisors' responsibilities; and

• reference to workers' responsibilities.

Documentation is examined, interviews are conducted, and observations are undertaken to ensure that:

• the policy is distributed to employees through handbooks, safety training programs, or in policy/program manuals, and via new employee orientation;

• employees are given a copy of the policy;

• the policy is posted in areas where workers are most likely to see it; and

• the policy is discussed during indoctrination, training sessions, safety meetings or informally with supervisors and managers.

Guiding Principles

The Petroleum Industry's Guiding Principles on Safety were developed by industry associations to promote the importance of the safety function between their member companies.

Documentation is examined, interviews are conducted and observations are undertaken to ensure that:

• the guiding principles are posted in locations where employees and contractors are most likely to see them, as with the policy statement; and

• management is committed to the philosophy stated in the guiding principles.

Safety Responsibilities

Safety responsibilities establish specifically who does what, and when, for activities identified in the safety program.  Responsibilities must be quantifiable in the safety program in order to measure or evaluate performance.  Management cannot control what cannot be measured.  To meet the intent of this element, the task or responsibility must be clearly stated, the position responsible for performing the task must be identified, and the frequency of the task performed must be included.

The consultant should investigate whether responsibilities are identified for every position that may have an impact on safety within the company.  This includes managers, supervisors, employees, contractors, and visitors.

The consultant should investigate whether a process for measuring performance of established safety goals and objectives is in place.

Management Communication

Managers cannot control the success of the safety program in isolation; they require the participation and commitment of employees.  Managers should demonstrate their commitment to the safety function by communicating with employees at all levels, contractors, clients, and suppliers on the importance of safety and related issues including safety responsibilities and safety performance expectations and should include the following:

• Meeting minutes and records should be reviewed to assess content and to verify attendance and frequency;

• Log books, tour sheets, and inspection records should be reviewed; and

• Management, supervisors, and workers should be interviewed to verify the frequency and content of tours.

Phase 2:          Hazard Identification and Control

Inspections

Routine planned inspections are an effective pre-loss method of identifying hazardous conditions and acts.  This involves a systematic review of the company’s facilities, equipment, tools and the employees who use them.  These inspections can help to identify hazards proactively and ensure that company and legislative standards are being followed.

Documentation is examined, interviews are conducted, and observations are undertaken to:

• assess the inspection format and daily inspection requirements;

• evaluate completed inspection results;

• address lingering deficiencies;

• ensure workers are involved in inspections on a regular basis; and

• confirm the system is effective.

Hazard Reporting

Hazard reporting is the ongoing process of identifying and correcting hazardous conditions or acts.  This process fills the gaps between regularly scheduled inspections, and comprises three steps: identifying the hazard and the associated risk, reporting the hazard, and correcting the hazard.

Documentation is examined, interviews are conducted and observations are undertaken to:

• determine if training in hazard recognition has been provided;

• ensure employees have received training;

• ensure hazard reporting is practiced;

• verify consistency with documented hazards; and

• determine if obvious hazards have been addressed, if reported hazards have been corrected, and if hazards are recurring.

Phase 3:          Rules and Work Procedures

Safety Rules

The company’s rules and procedures should identify company and legislative requirements and expectations to all employees and contractors.  They should serve as a reference and the minimum standard by which business is conducted.  Most importantly, rules and procedures should ensure consistency in the performance of tasks by all employees.

To assess whether the company’s rules and procedures are complete and appropriate, the consultant needs to be familiarized with operations through process reviews and tours.

Documentation is examined, interviews are conducted, and observations are undertaken to:

• assess whether the rules address the hazards associated with the critical work tasks performed by the company;

• determine if the rules have been distributed and if they have been effectively communicated to each employee and contractor;

• determine if the rules are referred to during orientation;

• determine if safety rules are referred to during safety meetings and training sessions;

• determine the level of understanding with respect to the intent of the rules; and

• make recommendations regarding a system that will promote full compliance to safety rules.

Legislative Compliance

Legislative compliance should be considered the minimum basic standard by which the company operates.  Rules and work procedures must follow or exceed the intent of the legislation.

Standard Work Procedures

The intent of a procedure is to ensure consistency in the performance of hazardous work and it must form the minimum standard by which a specific task is performed.  All procedures should be written in an easily referenced format and readily available to the worker performing the tasks.  Workers must have a clear understanding of the procedures they are required to follow.  A system for periodic review of procedures and employee input for continuous improvement should exist.  All company workers should be observed to determine if they are following procedures.

Personal Protective Equipment (PPE)

Procedures and rules for the use of PPE should be written, and understood by all company employees.

Documentation is examined, interviews are conducted, and observations are undertaken to confirm that:

• employees know where to obtain PPE;

• there is an appropriate and adequate supply of PPE;

• employees are wearing PPE, when required;

• workers have trained in the use of PPE; and

• PPE is maintained according to manufacturer specification.

Enforcement

An enforcement policy should be based on positive reinforcement that recognizes safety behaviours and corrects violations immediately.  Company employees must have a clear understanding of the intent of the rules and training must be provided regarding what behaviours are expected.  Corrective actions to prevent recurrence with non-compliance to rules should be consistent with guidelines that have been established by the company.

Documentation is examined, interviews are conducted, and observations are undertaken to confirm communication of the company’s disciplinary policy through an evaluation of written policy, training and orientation records, postings and behaviour.

Emergency Procedures

The company’s emergency procedures should identify who does what, and when, in the event of an emergency.  Responsibility for coordination of emergency actions must be identified.  All emergency scenarios should be identified.  All company employees must be aware of the content and location of procedures.  Contact lists associated with procedures must be current.  Procedures must be updated and tested on a regular basis.

Phase 4:          Training

Safety Orientations

Initial safety training is one of the most important aspects of any safety program.  All company employees and contractors should receive some level of basic safety training specific to the facility/company/process, before commencing work.

Documentation is examined and interviews conducted to confirm that appropriate orientations are given to:

• employees;

• contractors;

• subcontractors; and

• visitors.

The orientation is assessed according to its inclusion of:

• company policies and procedures;

• specific job hazards;

• safety precautions;

• job responsibilities;

• regulatory requirements;

• company enforcement policy; and

• worker right to know and refuse unsafe work.

The investigator should confirm whether critical issues are addressed on the first day of the job, or the first day on a new job site.

On-the-Job-Training

The consultant should examine the training program to determine if responsibilities, training requirements and required competency levels are addressed.  Interviews are conducted to determine the level of employee involvement in the training program.

Phase 5:          Communication

Communication System

Communication between the company and its’ employees is very important.  Formal communication systems take such form as safety meetings, health and safety committees, suggestion boxes, and newsletters.

The consultant should examine the company’s policies and procedures, and interviews employees to verify the existence of an open communication system, and to ensure the system allows for two-way communication and includes a feedback loop.

Safety Meetings

Safety meetings are intended as group communication sessions to provide information on new company programs, initiatives and procedures.

Documentation is examined and interviews conducted in order to:

• determine if safety meeting guidelines include schedules, responsibilities, key topics, and standards for attendance;

• verify that employees are given an opportunity to attend safety meetings;

• verify that meetings are regularly scheduled, occurring and attended; and

• test effectiveness of safety meetings and follow-up.

Phase 6:          Incident Accident Reporting and Investigation

Incident and Accident Reporting

All types of accidental loss or near loss should be reported, either verbally or in writing, including injury, property damage, equipment failure, environmental loss, security-related loss, vehicular loss, and near-miss.
The investigator should examine documentation to verify that employees are required to report all types of loss and potential loss, and to determine if the incident/accident reporting procedure is complete and applicable.  Employee interviews and examination of equipment is conducted to verify that all incidents and accidents are being reported.

Investigation and Follow-up

All accidents and near-miss incidents should be investigated to determine what caused the problem and what action is required to prevent a recurrence.  Company employees required to perform investigations should be trained in accident investigation techniques.  Investigation reports should concentrate on determining what the underlying causes were, what management systems failed, and what the company can do to prevent other similar losses.  This should be a "fact finding" exercise rather than a "fault finding" one.

Stage III:           Evaluating the Audit

The consultant should conduct a quantified analysis of the audit and an evaluation of the environmental plan, and submit to the company a copy of the completed audit and jobsite evaluation.

Great White North Environmental Services Limited provides a complete report to the company that includes conclusions and recommendations as to how the company can improve its loss control management and operating practices.  All completed Basic Safety Program Audit Forms are included as an appendix.  The report addresses specifically an assessment of the current practices and procedures presently in force at the company’s facilities and provides recommendations so as to reinforce a proactive safety and environmental management program.  In addition, the report addresses current procedures and practices with respect to compliance with regulatory agency requirements, and if any procedures and/or practices are found to be lacking with respect to said compliance, the report makes recommendations to ensure that such compliance will be satisfied.

Scoring

Phases 1-6 are scored according to the Basic Safety Audit scoring protocol.

Total audit scores from each phase are ranked against adjusted scores from each phase (i.e., total possible score less the maximum weight of questions deemed inapplicable), and a percentage is calculated.

Audits that score 80% and over reflect high standards and an acceptable safety program; scores under 80% reflect a substandard program.

This scoring system will help the company identify areas within the safety program that are not meeting company objectives.

Recommendations

Great White North Environmental Services Limited makes recommendations to the company, in compliance with provincial regulations, to address and correct deficiencies identified during the course of the audit.  As well, we refer to the, "ISO 14000 Environmental Management Standards"[7] in its’ recommendations to improve the company’s environmental planning system.  The ISO 14000 will enable the company to integrate quality management systems within their business operations without relying solely on external laws.  The ISO 14000 addresses:

• Environmental Management Systems;

• Environmental Performance Evaluations;

• Environmental Auditing;

• Life Cycle Assessment; and

• Environmental Labeling.

Environmental Planning and Management Systems

The company’s management system and environmental plan should incorporate environmental elements to provide the framework to balance and integrate its economic interests, and those of society, with environmental interests.  A well functioning environmental plan will provide the company with confidence that[8]:

• policies, objectives and expectations are achieved;

• emphasis is placed proactively on environmental impact prevention rather than reactively on detection and treatment;

• it can provide further evidence of reasonable care; and

• the system supports continuous improvement.

     The potential benefits of such a system include:

• enhanced image and market share;

• reduced costs and legal liabilities;

• increased profitability;

• conservation of input materials;

• enhanced access to human resources, financial resources, and locations in which to operate;

• improved state of the environment and human health; and

• increased stakeholder satisfaction and confidence.

Great White North Environmental Services Limited evaluates the company’s Environmental Management System (EMS) according to the structure and content of the following model, as described in the CSA Z750-94.
 

Elements of an EMS:            Purpose, Commitment, Capability, and Learning

Purpose:         The company should know what needs to be done; it should have purpose.

The management system elements relating to this principle are environmental policy, risk assessment, and environmental objectives and targets.

Environmental Policy should establish an overall sense of direction and set the parameters of action. This should be built on the company’s:

• mission: the reason the company exists, the societal need it fulfills, and its fundamental business focus; and

• vision: the state to which the company aspires.

The mission and vision are intended to provide long-term guidance for the company, and they should be explicitly stated.

• core values and beliefs: part of the culture and ethical position of the organization;

• stakeholder requirements: the expectations placed on the company by all stakeholders; and

• guiding principles: these serve to focus the company’s actions and can provide an ethical position in areas of importance to the company and its stakeholders.

Risk Assessment of the company’s activities, processes, products and services should help to prioritize its objectives and targets.  The risk assessment is a process that will identify the impact of the company’s activities on the natural environment.  This assessment would also include the impact to the health and safety of people and the potential legal and business exposure affecting the company.

A list of key issues should include:

• Air Quality;

• Regulated emissions; and

• Fugitive emissions.

• Water Quality;

• Surface water;

• Ground water;

• Sanitary sewer discharges; and

• Storm sewer discharges.

• Land/Soil Quality; and

• Leaks and spills of stored materials;

• Transportation leaks and spills;

• Disposal and containment; and

• Use of potentially harmful materials.

• Waste.

• Packaging;

• Paper;

• Toxic materials;

• Regulated materials; and

• Opportunities to reduce, reuse, recycle.

Environmental Objectives are the overall aims in terms of environmental performance that should arise from the company’s environmental policy.  Targets are the detailed performance requirements that the company should set out to achieve.  All targets should be measurable.

Objectives and targets should include:

• regulatory compliance;

• environmental protection;

• pollution prevention;

• environmental impact reduction;

• emergency preparedness;

• stakeholder expectations;

• continuous improvement;

• work practices improvement; and

• synergy with the company’s overall objectives and business targets.

Commitment:              The EMS inherently requires a commitment to take the appropriate actions

Commitment addresses the motivation of company employees to make decisions and take actions, including follow-up, that contribute to the achievement of the company’s environmental objectives.  It is this commitment that transforms an EMS from paperwork into an effective process.

Environmental Values should be common throughout the company, and should be translated into actions.  These actions should be consistent with the vision.  The company is judged by its actions.  It is imperative to encourage full acceptance among all company employees.

Alignment and Integration, the degree to which individual elements of the company’s EMS and organizational structure support each other, are key to the effectiveness and success of environmental planning initiatives.

Integrated management system elements should include:

• information and support systems;

• reward and appraisal systems;

• training;

• development;

• processes and guidelines;

• resources;

• accountability structure; and

• consequences of success or failure.

Accountability and Responsibility, and commensurate authority for the overall effectiveness of the EMS, should be assigned to company senior personnel.  This person should ensure that:

• accountability for component parts of the environment plan is assigned to specific organizational units and individuals, as appropriate;

• the effectiveness of the overall EMS is monitored; and

• regular reports are made to senior management and the Board of Directors regarding environmental performance and/or recommendations.

Employees at all levels should be accountable for environmental performance in support of the overall EMS. Accountability must be matched with commensurate authority.

Capability:      The company should have the capability of acting in support of its objectives.

The resources that the company requires should evolve in response to changing stakeholder requirements, a dynamic business environment, and the process of continuous improvement.

Resources:     Human, Physical, Financial should be appropriate to the company’s environmental policies and the achievement of its objectives, and should be defined and made available.

Knowledge, Skills and Training essential to the company’s environmental policies and objectives should be identified.  These should be considered in personnel selection, recruitment, training, skill development and ongoing education.  The level and detail of training will vary according to the task, continual education, and training.  This should ensure that company employees are current with industry standards and the organization's policies and objectives.  Procedures should be established for identifying training needs and for providing the appropriate training for all personnel.  Training records should be maintained.

Information Management and Procedures are essential to the EMS.  The key features of an Information Management System are:

• means of identification;

• collection;

• indexing;

• filing;

• storage;

• maintenance;

• retrieval; and

• disposition of pertinent EMS documentation and records.

All documentation should be dated (with dates of revision), readily identifiable, organized, and retained for a specified period.  The company should ensure that:

• documents can be identified with the appropriate organization, division, function, activity, and/or contact person;

• documents are periodically reviewed, revised as necessary, and approved by authorized personnel prior to use;

• the current versions of relevant documents are available at all locations where operations essential to the effective functioning of the system are performed; and

• obsolete documents are promptly removed from all points of issue and points of use.

Learning:    Those aspects of the company’s management system that ensure the company is dynamic, capable of reacting to changes in the environment, and capable of learning how its own processes can be improved.

Measuring and Monitoring should be systematized to assess performance against the company’s environmental objectives and changes in the operational environment.  These metrics should track actual performance against established targets.  The results should be analyzed and used to determine areas of success and to identify areas requiring correction and improvement.

Communication and Reporting to stakeholders of the company’s environmental policy, objectives, targets, and performance should be undertaken.  The company should consider the extent of disclosure to stakeholders.  Results from monitoring, system audits, and management review and evaluation should be communicated to company personnel responsible for environmental performance improvement.

System Audits should be established to provide assurance of environmental system implementation and its adequacy as a system in achieving environmental objectives.

Management Reviews of the EMS should be undertaken by the company’s senior personnel, at appropriate intervals, to ensure its continuing suitability and effectiveness.  These reviews should include:

• recommendations and findings from EMS audits and action plans;

• the continuing suitability of EMS policy and the need for changes in light of:

1. changing legislation;

2. changing expectations and requirements of stakeholders;

3. changes in the products or activities of the organization;

4. advances in science and technology; and

5. lessons learned from environmental incidents.

Documentation of the findings, conclusions, and recommendations reached as a result of EMS audits and reviews, should be undertaken.

Implementation of recommendations should be undertaken by the company’s senior management.  Where required, the EMS should be improved upon, and the relevance and completeness of the system should be revisited.

Continuous Improvement should be achieved by improving the company’s operational processes, and is sustained by training and learning.  The company should have a system for identifying potential weaknesses in environmental management and operational systems, and for taking action to eliminate these weaknesses.  The responsibility and authority for instituting corrective action should be defined.