Environmental auditing

Q&A on environmental audits


Q&A on environmental audits + Expand all Collapse all

  • What should an environmental audit report contain?

    There are standard requirements for what must be included in a report. These include the following:

    • An evaluation of the environmental quality of the site or the risk posed by the site or activity to the environment.
    • An assessment of whether the condition of the site or activity is detrimental or potentially detrimental to any part of the environment.
    • An assessment of whether any clean up is required. If clean up is required, the report must make recommendations on how to undertake the cleanup.

    Detail on the requirements can be found in Environmental auditor (contaminated land) – Guidelines for issue of certificates and statements of environmental audit (publication 759) and Environmental auditor guidelines for conducting environmental audits (publication 953).

  • Why do sites require an environmental audit as well as a site assessment?

    Sites require an environmental assessment and audit when there is a need to understand the nature and extent of any contamination that may be present and whether that contamination poses a risk to the environment.

    The assessment provides the scientific data and approach for understanding whether there are any risks and how they might be mitigated. Assessments are undertaken by professionals who are paid by private entities to undertake the work. While low, there is a risk that professionals may seek to gain by improperly requiring or not requiring works. Additionally, there is no formal accreditation or training for assessors and so there is considerable variation in ability and knowledge.

    The audit provides an independent, robust and defensible process to assess the extent of the contamination and the risk posed to the environment. In the simplest terms, it validates the assessment. It draws on the data collected as part of a site assessment or monitoring program. An auditor is also paid by a private entity, but has a legal duty first and foremost to the State of Victoria and can face significant penalties (including imprisonment) for false or misleading information.

    There are two types of audits.

    Section 53X audits, which result in a certificate or statement of environmental audit, are conducted on potentially contaminated land proposed to be redeveloped (such as housing on former industrial land), to satisfy planning permit requirements. Local government can enforce the need for an environmental audit through the application of an environmental audit overlay within a planning scheme. Audits can also be undertaken voluntarily to satisfy commercial due diligence requirements.

    Section 53V audits are used to understand the risk to the environment posed by an industrial activity or to validate a cleanup of contaminated land or groundwater. This includes audits associated with the construction and operation of landfills; owners demonstrating they are complying with a licence or notice; or when there is a planning permit application for a site located in a landfill buffer zone. EPA approves the scope of a 53V audit.

  • How long does an environmental audit take from start to finish?

    The timeframe for an audit is highly dependent on the nature and extent of contamination and the level of assessment and monitoring required. The audit period can be further extended if cleanup works are required prior to completion of the audit. The entire process can take anything from a few months to more than a year.

    Auditors can normally provide an indicative timeframe based on their knowledge and experience.

  • When does the process of a site audit officially begin?

    An environmental audit begins when an auditor receives (and accepts) a request to issue a certificate or statement (for 53X audits) or a 53V audit report. Within seven days of receiving a request, the auditor must send EPA a statement in writing specifying the following:

    • name of the person making the request
    • location of the site to be audited and reason for the audit
    • proposed completion date of the environmental audit.

    An auditor should be appointed at the outset of the site assessment process, or otherwise as early as possible in the process. This allows auditors to provide advice on the scope of assessment works and may avoid the need for extra data collection later in the process.

  • What if the audit report is incorrect?

    Auditors may provide a copy of the audit report to the person that requested the audit prior to issuing it. This allows any inconsistencies to be identified and raised with the auditor at this point.

    While an environmental audit is designed to provide a high-level of assurance about the usage of a site, there is a small chance that something could be missed. If something is found at the site that is not consistent with the certificate or statement issued, the auditor and EPA should be contacted. The auditor can withdraw and reissue the audit to address the issues identified.

  • What if the audit is terminated?

    If the auditor is requested to stop the audit process or decides not to proceed with an audit, the audit will be terminated and the auditor must notify EPA. EPA may seek further information from the auditor (or any other person) about the condition of the site. If warranted, EPA may require a cleanup of the site through the use of a remedial notice.

  • Does a statement of environmental audit mean the land is badly contaminated?

    The statement of environmental audit indicates the nature of  the remaining contamination and the steps required to manage it for specified uses.

    A site that receives a statement does not necessarily mean the site is horribly contaminated; it indicates that there may still be contamination present but it can be managed. To protect humans and the environment the statement specifies conditions that must be followed; for example, there may be heavy metals in the soil, so additional clean soil may be used to cover exposed areas on the site to prevent people and animals from accessing the soil and ingesting the heavy metals.

  • What if the Statement conditions are difficult and costly to implement?

    If statement of environmental audit conditions seem unusual or difficult to implement, the owner/occupier should discuss their concerns with the planning authority and the auditor to ensure they comply with the purpose of the condition or if any other options are available. These discussions can occur before the statement is issued.

  • How do I access completed audits or those under way?

    Since the environmental audit system began in Victoria in 1990, EPA has maintained a list of properties issued with a certificate or statement of environmental audit (under part IXD of the Environment Protection Act 1970).

    A list of audits currently under way is not publicly available but auditors are provided with a list on a regular basis to ensure they are aware of potential audits in an area of interest.

  • How are environmental audit conditions enforced?

    The enforcement of environmental audit conditions is the responsibility of local government and not EPA. If a landowner or occupier fails to comply with requirements set out in a statement of environmental audit, then the local council or EPA should be notified.

    If the requirements of the statement are set out in the planning scheme or planning permit, this provides for enforcement action by local government under the Planning and Environment Act 1987.

  • What are the statutes and policies supporting the environmental audit system in Victoria?

    The Environment Protection Act 1970 underpins the audit system in Victoria. Further direction is provided by Ministers Direction No.1 – Potentially Contaminated Land (1989).

    The Environment Protection Act was amended in 1989 to include the function of environmental auditors. The Act was amended again in 2001 to strengthen auditing provisions, and in 2006 to allow audit guidelines to be applied to any other Act. 

    The National Environment Projection (Assessment of Contaminated Sites) Measure (the ‘ASC NEPM’) was created in 1999. It provides an efficient and effective, nationally consistent approach to the assessment of site contamination. A new version of the ASC NEPM was introduced in 2013. Following a 12-month transition period the new ASC NEPM will be adopted for all audit reports from May 2014, unless alternative arrangements have been agreed with EPA.

    EPA expects auditors to conduct environmental audits in accordance with published EPA guidelines and any interim guidelines.

Page last updated on 3 Dec 2013