Evaluating environmental performance is important. It allows you to measure and assess the effectiveness of your controls. The results of your evaluation can present a wide range of opportunities, including:
- demonstrating your controls are in accordance with the GED
- demonstrating compliance with other regulatory controls and permission conditions
- assessing the effectiveness of your selected risk controls
- identifying opportunities for resource efficiency
- identifying opportunities for waste reduction
- confirming the suitability of your environmental performance indicators
- establishing performance benchmarks to compare future performance against
- identifying opportunities for improvements in training
- assessing the long-term impacts of environmental incidents and the corrective actions taken.
A combination of monitoring, auditing and reviewing your environmental performance is necessary to ensure the ongoing effectiveness of your environmental controls and to drive continuous improvement, in accordance with the GED.
Internal auditing
Audits of your environmental performance are systematic assessments of your organisation’s operations, activities and processes. The frequency of these audits should be set by an audit schedule. They may be performed internally or by an independent consultant who specialises in these types of audits. This is part of meeting your C05/G05 permission condition.
Internal audits identify:
- the effectiveness of your organisation’s environmental management practices and processes
- the degree of compliance with environmental laws and regulations, and industry standards
- how your environmental performance aligns with your environmental commitments (for example, organisation policies, environmental objectives)
- any new and potential environmental risks
- areas where additional training is required
- areas for improvement, and recommendations for minimising your organisation’s environmental risks.
EPA expects your RMMP to include an environmental performance audit plan. This plan should describe how you will measure the effectiveness of your monitoring activities, controls and procedures.
Review and continuous improvement
In addition to monitoring and conducting audits, it is best practice to formally review your overall environmental performance. This review can assess whether your environmental procedures and objectives remain adequate.
The review should aim to identify any potential gaps in your environmental performance, and opportunities for improvement. The purpose of the review is to ensure your existing critical controls are up to date with current information and available technology. What constitutes a reasonably practicable risk control changes over time as new knowledge emerges and new techniques and technologies are developed. Your review may also be influenced by any factors that have triggered a review of your risk assessment, as described in Management of change.
Environmental performance reviews can be conducted in various ways. A typical review team includes management, environmental advisors, site personnel and technical specialists where needed. Each time you complete a review, it is suggested that you include different site personnel. Their perspective might generate ideas for improvement that have not been identified before. Involvement of senior management demonstrates a commitment to environmental performance internally and to EPA.
Monitoring, auditing, and reviewing is necessary as they form the basis for driving continual improvement. The ultimate objective of continual improvement is to eliminate the risks of harm to human health and the environment so far as reasonably practicable.
EPA expects your RMMP to include a description of your environmental performance review approach. Your approach should outline how information from your risk assessment, environmental performance objectives, monitoring and audits is used to evaluate and improve your environmental performance.
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