Environmental aspects and legal compliance checklist

Aspects and obligations

• An environmental aspects and impacts register covers normal, abnormal and emergency conditions for every activity, product and service on the site, including suppliers and contractors where the site can influence them, and the significant aspects are identified with a documented method.
• A legal register lists every environmental obligation that applies (the National Environmental Management Act and its Waste, Air Quality and Biodiversity Acts, the National Water Act, municipal by-laws on effluent, waste, noise and nuisance, and customer and scheme requirements), with the clause, what it requires and who owns it.
• The legal register is updated when the law changes (a subscription or a quarterly check is in place) and the change is communicated.
• An evaluation of compliance is done at a set interval for every obligation, with evidence and actions where a gap is found.
• An environmental policy is signed by top management, and objectives and targets with owners and dates address the significant aspects.

Permits, waste, water and air

• Every permit, licence, registration and authorisation the site needs is current and on file: water use licence or general authorisation, trade effluent permit from the municipality, waste management licence or registration where thresholds are met, atmospheric emission licence where listed activities apply, and environmental authorisation for any listed development.
• Waste is classified and recorded as the Waste Act and its regulations require, with manifests and safe disposal certificates from licensed contractors.
• Hazardous waste (oils, chemicals, fluorescent tubes, laboratory waste) is stored and disposed of separately.
• Trade effluent is monitored against the permit limits (pH, chemical oxygen demand, fats, oils and grease, suspended solids, temperature) at the frequency the permit sets, and results and exceedances are recorded and reported.
• Water use is metered, monitored and reported, and losses are investigated.
• Air emission sources (boilers, generators, fryers, refrigeration plant, dust, odour) are identified, the equipment is maintained, and emissions are monitored where the licence or by-law requires, with refrigerant gas records kept.
• Energy use is monitored and the significant users are known, with targets where energy is a significant aspect.

Emergencies, people and records

• Environmental emergencies (chemical spill, ammonia leak, fire water run-off, effluent overflow, fuel spill) are covered by procedures, spill kits and bunding, with a drill in the last twelve months.
• Any emergency incident that may harm the environment is reported as NEMA section 30 requires (as soon as reasonably practicable to the Director-General, the SAPS, the relevant fire service, the provincial head of department or municipality and anyone whose health may be affected, with a written report within 14 days), and the procedure names who does it.
• Chemical, fuel and oil storage is bunded, labelled and inspected, and tank integrity is on the maintenance schedule.
• Staff and contractors are trained on the aspects of their work and the emergency response, and competence records are kept.
• Monitoring instruments and laboratories used for compliance measurements are calibrated or accredited.
• Internal audits and the management review cover environmental performance, compliance status and incidents, with minuted decisions.