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DEPARTMENT: WATER AFFAIRS
INTEGRATED ENVIRONMENTAL MANAGEMENT (IEM) SERIES
IEM SERIES: SUB SERIES No 1.7
ENVIRONMENTAL MONITORING AND AUDITING GUIDELINES (EM&AG)
Prepared by
The Directorate: Water Abstraction and Instream Use Sub-Directorate: Environment and Recreation
For further information please contact: Ms. Valerie du Plessis
Tel: 012 336 8679 E-mail: [email protected]
or
Miss Samukelisiwe Mkatshwa Tel: 012 336 8083 E-mail: [email protected]
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - ii - May 2005
Published by
Department of Water Affairs
Private Bag X313
PRETORIA, 0001
Republic of South Africa
Tel: (012) 336 7500/ +27 12 336 7500
Fax: (012) 323 0321/ +27 12 323 0321
Copyright reserved
No part of this publication may be reproduced in any manner
without full acknowledgement of the source
This report should be cited as:
Department of Water Affairs and Forestry, 2005 Environmental Monitoring and
Auditing Protocol. Integrated Environmental Management Sub-Series No.1.7 .
Second Edition. Pretoria.
Co-ordinated by:
Sub-Directorate: Environment and Recreation
Private Bag X313
PRETORIA
0001
In Collaboration with:
Nemai Consulting
PO Box 1673
SUNNINGHILL
2157
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - iii - May 2005
DOCUMENT INDEX
Reports as part of the Integrated Environmental Management Series (IEMS)
Report number Report title
Sub-Series 1.1 Administration of the IEM Series
Sub-series 1.2 Environmental Policy
Sub-series 1.3 Consolidated Environmental Implementation and Management Plan (CEIMP)
Sub-series 1.4 Integrated Environmental Management Framework (IEMF)
Sub-series 1.5 Environmental Decision Support System (E-DSS)
Sub-series 1.6 Environmental Best Practices Guidelines and Specifications (EBPG&S)
Sub-series 1.7 Environmental Monitoring and Auditing Guidelines
Sub-series 1.8 Environmental Reporting Framework
Sub-series 1.9 Sustainable Development Management System (SDMS)
Sub-series 1.10 Environmental Legal Guide Booklet and Database
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - iv - May 2005
APPROVAL
TITLE: Integrated Environmental Management Series –
Environmental Monitoring and Auditing Guidelines
DATE: May 2005
AUTHORS: S. Holt and D. Naidoo
SUB-SERIES NO.: 1.7
FORMAT: MSWord and PDF
WEB ADDRESS: www.dwaf.gov.za
Approved for the Department of Water Affairs by:
_________________________________
Ms Valerie du Plessis
Deputy Director: Environment and Recreation
_________________________________
Mr Charles M‟Marete
Director: Water Abstraction and Instream Use
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - v - May 2005
ACKNOWLEDGEMENTS
The following individuals are thanked for their contributions to the document:
Project Management Committee
Valerie du Plessis Department of Water Affairs
Anet Muir Department of Water Affairs
Geraldine Munro Department of Water Affairs
Jerry Methula Department of Water Affairs
Shane Naidoo Department of Water Affairs
Pieter Ackerman Department of Water Affairs
Samukelisiwe Mkatshwa Department of Water Affairs
Chantal Matthys Department of Water Affairs (promoted to DEA)
Nicky Naidoo Nemai Consulting
Shelley Holt Nemai Consulting
TABLE OF CONTENTS
TABLE OF CONTENTS ............................................................................................ vi
APPENDICES .......................................................................................................... vii
LIST OF TABLES ..................................................................................................... vii
LIST OF FIGURES ................................................................................................... vii
DEFINITION OF ACRONYMS ................................................................................ viii
1. INTRODUCTION ............................................................................................... 1
2. USER‟s GUIDE ................................................................................................. 3
2.1 How Should this Document be Used? ........................................................ 3
2.2 Who Should Use the EM&AP? ................................................................... 4
2.3 When Should the EM&AP be Used? .......................................................... 4
2.4 EM&AP Structure and Content .................................................................. 5
3. THE MONITORING PROTOCOL ...................................................................... 6
3.1 Definition of Monitoring .............................................................................. 6
3.2 Types of Monitoring ................................................................................... 6
3.3 Generic Monitoring Process ..................................................................... 14
3.4 Guideline for Writing a Monitoring Report ................................................ 24
3.5 Instituting Corrective Action, Continual Improvement and Preventative
Measures ............................................................................................................ 27
4 THE AUDITING PROTOCOL .......................................................................... 28
4.1 Definitions of Auditing .............................................................................. 28
4.2 Types of Auditing ..................................................................................... 29
4.3 Generic Auditing Process ........................................................................ 37
4.4 Guideline for Writing an Auditing Report .................................................. 48
4.5 Instituting Corrective Action, Continual Improvement and Preventative
Measures ............................................................................................................ 51
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - vii - May 2005
APPENDICES
APPENDIX A Worked Example: Monitoring
APPENDIX B Worked Example: Auditing
APPENDIX C Tools Checklists for DWAF functions
APPENDIX D EIA Audit Effectiveness
APPENDIX E EMP Audit Effectiveness
APPENDIX F EMS Audit Checklist
APPENDIX G Audit Checklist for the Institutional Environmental
APPENDIX H Checklist for Monitoring Forestry Performance
APPENDIX I EMP Compliance Checklist
APPENDIX J Checklist for Monitoring Pest Control Operations
APPENDIX K Checklist for Auditing Pest Control Operations
LIST OF TABLES
TABLE 1: Types of Monitoring Applicable to DWAF Functions
TABLE 2: Recommended Monitoring Frequencies
TABLE 3: Typical Format of an Environmental Monitoring Report
TABLE 4: Types of Auditing Applicable to DWAF Functions
TABLE 5: Recommended Auditing Frequencies
TABLE 6: Typical Format of an Environmental Auditing Report
TABLE 7: Typical Format of a Non-compliance and Correction Report
LIST OF FIGURES
FIGURE 1: Aim of the EM&AP
FIGURE 2: Monitoring Nodes and Types for a Typical WRM Development
Project
FIGURE 3: Monitoring Nodes and Types for a Typical WS Development
Project
FIGURE 4: Overview of Monitoring Process
FIGURE 5: Audit Nodes for a Typical WRM Development
FIGURE 6: Audit Nodes for a Typical WS Development
FIGURE 7: Overview of Auditing Process
FIGURE 8: Typical Audit Process Showing Corrective Action
FIGURE 9: Deming Model/PDCA Cycle
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - viii - May 2005
DEFINITION OF ACRONYMS
CEIMP Consolidated Environmental Implementation and Management
Plan
DEAT Department of Environmental Affairs and Tourism
DWAF Department of Water Affairs and Forestry
EIA Environmental Impact Assessment
EIMS Environmental Impact Management System for water services
EM&AP Environmental Monitoring and Auditing Protocol
EMP Environmental Management Plan
EMPR Environmental Management Programme Report
EMS Environmental Management System
EPA (United States) Environmental Protection Agency
EPE Environmental Performance Evaluation
ESM&RS Environmental Site Management And Rehabilitation
Specifications
HO Head Office
IEM Integrated Environmental Management
IEMF Integrated Environmental Management Framework
ISO International Standards Organisation
NEMA National Environmental Management Act, No. 107 of 1998
NFAP National Forestry Action Plan
O&M Operations and Maintenance
PDCA Plan Do Check Act
RD Regional Director
RO Regional Office
RoD Record of Decision
SEA Strategic Environmental Assessment
WRM Water Resource Management
WS Water Services
Second Edition - 1 - May 2005
1. INTRODUCTION
The Environmental Monitoring and Auditing Protocol (EM&AP) is part of the
Integrated Environmental Management Series (IEMS), a DWAF initiative to ensure
that the organisation has factored in all aspects of environmental management in its
business functions either as a Developer and/ or Operator of schemes (Operations
and Maintenance) with an impacting function on the environment or as a Regulator,
with a management function, to control activities that may have an impact on the
environment. The EM&AP forms Sub Series 1.7 of the IEMS.
Purpose of the EM&AP: The purpose of environmental monitoring and auditing
is to verify that all relevant laws and policies are adhered to, that environmental
management tools are used effectively, and to identify and correct environmental
issues. The EM&AP is in line with DWAFs overall aim of ensuring the protection of
our water resource and to promote sustainable development. The EM&AP will enable
DWAF to produce an annual report on the implementation of the departments
Environmental Consolidated Implementation and Management Plan (CEIMP).
Aim of the EM&AP: The aim of the EM&AP is threefold, as captured below.
Figure 1 Aim of the EM&AP
The EM&AP will be
used by DWAF
officials to monitor
and to perform
internal audits on the
organisation at a
strategic level (ie at a
policy and regulation
level) to ensure
compliance with
internal systems such
as an EMS and with
relevant legislation.
The EM&AP will be
used by DWAF
officials to monitor
and to perform
internal audits on the
organisation at a
strategic level (ie at a
policy and regulation
level) to ensure
compliance with
internal systems such
as an EMS and with
relevant legislation.
11Strategic LevelStrategic Level 22DWAF as a DWAF as a
Developer Developer
and/or Operatorand/or Operator 33DWAF as a DWAF as a
RegulatorRegulator
The EM&AP will be
used by DWAF
officials to monitor
and audit external
parties (such as
water use licencees)
were DWAF assumes
the role of a
Regulator in which
case DWAF will have
a management
function.
The EM&AP will be
used by DWAF
officials to monitor
and audit external
parties (such as
water use licencees)
were DWAF assumes
the role of a
Regulator in which
case DWAF will have
a management
function.
The EM&AP will be
used to monitor and
audit DWAF projects
were DWAF assumes
the role of a
Developer and/or
Operator of schemes.
DWAF as a
developer or operator
(also referred to as
an Impactor) will
have an impacting
function on the
environment.
The EM&AP will be
used to monitor and
audit DWAF projects
were DWAF assumes
the role of a
Developer and/or
Operator of schemes.
DWAF as a
developer or operator
(also referred to as
an Impactor) will
have an impacting
function on the
environment.
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 2 - May 2005
The EM&AP is an instrument to verify the following:
DWAF as an organisation complies with relevant policies, legislation
and regulations;
DWAF projects/activities/programmes comply with the relevant
policies, legislation and regulations; and
External parties, including water use licence applicants, comply with
conditions prescribed by DWAF.
The EM&AP will be used by officials responsible for environmental functions in the
Water Resource Management (WRM), Water Services (WS) and Forestry
Directorates. WRM, WS and Forestry have impacting and management functions,
the EM&AP must be read in light of these functions.
The EM&AP will enable corrective action to be initiated to promote continual
improvement. Preventative measures can thereafter be implemented. The selection
of corrective actions is largely dependent on whether DWAF has an impacting or
management function.
The EM&AP is intended to promote environmental best practice, legal compliance,
protection of the resource, and promote sustainable development and sustainable
use of water resources.
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 3 - May 2005
2. USER’S GUIDE
2.1 How Should this Document be Used?
The EM&AP is a protocol which describes the process/procedure to be followed
when monitoring or conducting an audit. The document proposes a generic
monitoring and auditing process which can be adapted for all types of monitoring and
auditing. Also, the EM&AP is designed as a generic protocol that can be adapted for
DWAF‟s roles at a strategic level, as an Impactor or a Regulator.
Project life cycle diagrams indicating monitoring and auditing nodes for WRM and
WS development projects are included in the document. Each node is defined in
terms of the applicable monitoring type.
A worked example for a monitoring type is included in Appendix A while an example
of a third party audit of DWAF is included in Appendix B to further assist the user in
understanding the EM&AP. Appendix C to K contains various checklists to assist the
user in monitoring or to conduct an audit. The checklists are included to provide
guidance to the user.
The user must firstly establish whether he/she will be monitoring or auditing in the
following roles:
Monitoring or auditing DWAF for compliance from a strategic
perspective i.e. at a Policy and Strategy level.
Monitoring or auditing internal development projects where DWAF is
the developer (or Impactor) that is DWAF has an impact on the
environment.
Monitoring or auditing internal DWAF activities which are not
development projects but have an impact on the environment from a
operations and maintenance perspective such as pest control on dam
walls, the operation and maintenance of schemes, clearing activities,
etc. were DWAF has an impact on the environment.
Monitoring and auditing external parties where DWAF is the Regulator
such as water use licences, protection of the resource, etc. were
DWAF has a management function.
Once the User has established the context in which the monitoring and/or auditing
will be undertaken, the necessary checklists and the relevant steps of the protocols
must be consulted.
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 4 - May 2005
2.2 Who Should Use the EM&AP?
The monitoring protocol should be used by suitably qualified DWAF officials. Various
types of monitoring can occur at a strategic, programme and project level. The
monitoring protocol is designed such that it can be used to monitor internal DWAF
projects and to monitor external parties for compliance with conditions prescribed by
DWAF.
The auditing protocol should be used by DWAF staff responsible for ensuring the
following either at Head Office or at the Regional Office:
DWAF is compliant with environmental legislation, policy and
regulations.
DWAF‟s internal environmental objectives, goals and targets are being
met.
DWAF has met all performance compliance requirements.
Compliance by external parties to DWAF requirements.
Likewise, the auditing protocol is designed such that it can be used by DWAF officials
responsible for auditing external parties in terms of DWAF‟s management functions
namely compliance to water use licence conditions.
The frequency for conducting an internal audit must be reasonable and practicable to
allow for continuous improvement, a minimum of once a year is an accepted norm
provided that ongoing monitoring is instituted.
An external party should audit DWAF at least once every three years. The external
auditor may choose to use the EM&AP.
The EM&AP can be used by Head Office and Regional Office Officials. It is
imperative that the protocols and checklists are used by appropriately qualified
officials as the documents presented in this Sub Series is designed to assist the
officials but not to make a decision for the official, the interpretation of all monitoring
data and auditing findings remains the responsibility of the official.
2.3 When Should the EM&AP be Used?
The period for monitoring and auditing is dependent on DWAF‟s roles and
responsibilities. Table 2 and 5 of the document contains possible monitoring and
auditing frequencies. Please note that the frequencies provided in the report are only
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 5 - May 2005
considered a guideline. The auditing and monitoring frequency of each of DWAF
functions/activities/projects/programmes is dependent on the impact on the
environment.
2.4 EM&AP Structure and Content
Section 1: provides an introduction to the EM&AP including the aim and purpose of monitoring and auditing.
Section 2: contains document user information on who
should use the EM&AP, how should it be used
and when should it be used.
Section 3:
provides details on the recommended
monitoring protocol for DWAF. The protocol
consists of a definition of monitoring, the types
of monitoring, a generic monitoring process, a
guideline for writing a monitoring report and
guidance on instituting corrective action for
continual improvement.
Section 4:
provides details on the recommended auditing
protocol for DWAF. The protocol consists of a
definition of auditing, the types of auditing, a
generic auditing process, a guideline for writing
an auditing report and guidance on instituting
corrective action for continual improvement.
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 6 - May 2005
3. THE MONITORING PROTOCOL
3.1 Definition of Monitoring
The term environmental monitoring is not used consistently in the environmental field
and is often referred to by various terms. The British Standard EN ISO 14031:1999
defines Environmental Performance Evaluation (EPE) as an internal management
process and tool designed to provide environmental management with reliable and
verifiable information on an ongoing basis to determine whether an organization‟s
environmental performance is meeting the criteria set by the management of the
organisation. EPE can be interpreted as a certain type of environmental monitoring.
For the purposes of this document environmental monitoring is defined according to
DWAF‟s Integrated Environmental Management Framework (IEMF) as “the repetitive
and continued observation, measurement and evaluation of environmental data to
follow changes over a period of time to assess the efficiency of control measures”.
Monitoring has a smaller scope, usually at a project or programme level. Monitoring
is undertaken on an ongoing basis for the duration of the project, programme or
activity – usually before, during, and after implementation of each project or
programme.
3.2 Types of Monitoring
The aim, purpose and need for monitoring determines the type of monitoring that is
required. A series of monitoring types is discussed below.
Administrative
Monitoring
Administrative monitoring aims to ensure that deed restrictions, land use
restrictions, etc., are enforced and not violated. This type of monitoring is
similar to compliance monitoring, which is described later in the document.
The monitoring of state land and other land related matters by DWAF are
typical examples of administrative monitoring.
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 7 - May 2005
Inspection
Monitoring
Inspection monitoring is the most common and simplest form of monitoring and
involves the periodic inspection of an activity for any stated purpose. Inspection
monitoring may include: (1) Physical Monitoring – to ensure the integrity of
physical structures (e.g., landfill covers, berms, operating remedial systems,
gates, and fences); and (2) Contaminant Monitoring – to confirm the status of
protected areas, and may be used to detect and locate any release and
migration of pollution. Inspection monitoring could also take the form of toxicity
monitoring or biological monitoring.
Compliance
Monitoring
(Regulatory
Permit
Monitoring)
Environmental protection and management can be ensured through the
monitoring of compliance by a regulating organisation such as DWAF, of the
regulated body such as a water use licence applicant. Compliance with
environmental laws, regulations, permits, licences etc., is controlled through
effective monitoring and compliance assessment. Such compliance must be
monitored to ensure that control mechanisms have the desired effect.
Inspection and regulatory permit monitoring are directed to human activities
such as discharges, rather than to the biophysical environment per se (for
example, the stream itself), though DWAF does require monitoring such as
SASS, the habitat integrity index, riparian index, WQ monitoring etc.
Compliance monitoring aims to:
Determine compliance with applicable laws, regulations, permit
conditions, orders and settlement agreements;
Review and evaluate the activities of the regulated body; and
Determine whether or not conditions presenting imminent and
substantial endangerment may exist.
Compliance monitoring consists of a wide range of activities in six basic
categories which may overlap:
1) Surveillance - a pre-inspection activity to obtain general site information
prior to entering the site;
DWAF can perform inspection monitoring on internal development projects or
on a third party project such as a water use licence holder.
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 8 - May 2005
Compliance
Monitoring
(Regulatory
Permit
Monitoring)
(continued)
2) On-site inspections may include record reviews, observations,
sampling, interviews, etc., and may have different foci.
3) Investigations are more detailed inspections and may be needed if an
inspection or record review suggests the potential for serious,
widespread, and/or continuing violations.
4) Record reviews may be conducted at the regulator‟s offices, or at the
site, and may or may not be combined with fieldwork.
5) Records may be derived from routine self-monitoring requirements,
inspection reports or remote sensing.
6) Targeted information gathering may be used to provide or acquire more
accurate information on the status of compliance and/or environmental
conditions.
Remediation compliance monitoring of work required by regulation, permit,
order or settlement includes ensuring timely submissions, review of submittals
for adequacy and oversight of remedial activities. This may include sampling,
sample analysis, observations, and issuance of information, letters, directives or
subpoenas.
DWAF‟s role in compliance monitoring as a Regulator may include:
The collection and analysis of compliance and enforcement data;
Conducting inspections/ investigations;
Developing policy and legal guidance when questions arise as to
the interpretation of environmental laws, regulations and policies;
Technical assistance to provinces and local governments; and
Management and oversight of compliance monitoring
enforcement.
However, DWAF‟s role in compliance monitoring as an Impactor (developer
and/or operator of schemes) may include:
The submission of monitoring data to the relevant authority for
review such as DEAT;
Conducting ongoing internal inspections/investigations on DWAF
development projects in terms of compliance to the EMP and
ESM&RS; and
Taking monthly samples such as the monitoring of fish stocks to
determine the impacts on natural fish species, etc. and the
interpretation of the data to institute proactive mitigation
measures.
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 9 - May 2005
Baseline
Monitoring
(Monitoring of
Ambient
Environmental
Quality)
Baseline monitoring is the regular measurement of specific indicators to
detect environmental change due to the direct or indirect effects of a
development or activity, and to distinguish those changes from natural
variability. Baseline monitoring is applicable to DWAF‟s projects which
involve an environmental impact, particularly construction projects which
could affect water quality. The results of such monitoring (e.g. of water
quality) are often used for testing the validity and reliability of impact
assessment and testing mitigate measures.
Programme
Evaluation
Monitoring
(productivity
measurement
or
performance
auditing)
Programme evaluation monitoring is often used to measure the efficiency or
effectiveness of policies or programmes implemented by an organisation. This
type of monitoring is used to measure progress in achieving goals, identifying
problem areas, help set improved productivity targets and develop worker
incentive schemes.
Baseline monitoring could also be part of compliance monitoring, for instance
an RoD issued by DEAT to DWAF for a development project may require
that there is ongoing baseline monitoring of noise levels if the development is
within a built up area. Further, baseline monitoring may be required during
the reconnaissance phase of a project to identify long-term environmental
impacts of the proposed development.
Should DWAF monitor the conditions of RoDs issued for water use licences,
to ensure that the conditions take into account environmental principles and
are in line with DWAF policies such as the IEMF, then this would a typical
example of programme evaluation monitoring.
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 10 - May 2005
Monitoring of
Project Impact
Management
(Environmental
Health
Monitoring,
Reconnaissance
Monitoring)
Monitoring of project impact management is used to assess a wide range
of environmental, social, and economic impacts arising from a particular
project or activity. The aim of the monitoring is twofold: firstly to evaluate
measures which have been put in place to reduce or mitigate negative
impacts, and to check the accuracy of impact predictions against the
actual impacts and secondly to monitor the environmental impact of a
project which is not a listed activity according to the EIA Regulations hence
no environmental approval is required.
Cumulative
Impact
Monitoring
Cumulative impact monitoring is usually required in geographic regions where
rapid industrial or agricultural development and/or dramatic social-economic
change are taking place. The focus is on monitoring all critical issues in a
region, or changing socio-economic patterns, whether they are related to a
project or government program or occur independently. The sum of interrelated
effects over time is likely to be greater than those generated separately by
particular projects or programs. Cumulative Impact Monitoring is most likely to
be used as part of a Strategic Impact Assessment to monitor trends on the
social or biophysical environment.
Many WS projects such as the installation of internal water reticulation
pipelines do not qualify for environmental approval however, the
development does have an impact on the environment. Monitoring of project
impact management would be the most appropriate type of monitoring for
these projects.
When a dam is built and people are displaced or re-located, the cumulative
impact of the re-location on their well being and way of life may need to be
monitored, as well as the impact that the dam on regional biophysical
aspects. Cumulative impact monitoring is often performed in a catchment to
determine the impact of development on sensitive environments such as
wetlands. Understanding the cumulative impacts in a catchment will result in
more informed decisions in the catchment.
Second Edition - 11 - May 2005
Table 1: Types of Monitoring Applicable to DWAF Functions
Application Administrative
Monitoring
Inspection
Monitoring
Compliance Monitoring
(Regulatory Permit
Monitoring
Baseline
Monitoring
Programme
Evaluation
Monitoring
Monitoring Of
Project Impact
Management
Cumulative Impact
Monitoring
Developer
Policy and Strategy
Regulating water use
Table 2: Recommended Monitoring Frequencies
Construction Commissioning O&M
Expansion /
Modification
Closure/
Decommissioning
Strategic/Organisational
Level
Developer Listed
Activity RoD RoD
RoD/every three months
(impact dependant) RoD RoD
Developer Non-
Listed Activity Monthly Monthly
Every three months (impact
dependant) Annually Annually if applicable
O&
M
Transfer
Schemes/ Pump
Stations/Dams
Operating Plan or every six
months
Weirs/ Canals/
Pipelines Annually
Policy and Strategy Annually
Regulating Water
Use
RoD/bi-
monthly RoD/monthly RoD/once very 6 months RoD
Second Edition - 12 - May 2005
Second Edition - 13 - May 2005
Second Edition - 14 - May 2005
3.3 Generic Monitoring Process
The purpose of monitoring is to follow changes over a period of time and to assess
the efficiency of control measures, through a process of repetitive and continued
observation, measurement and evaluation of environmental data. Checklists are the
most widely used monitoring tools however other monitoring tools include electronic
decision support instruments, online digital monitoring instruments and before and
after pictures.
The monitoring process is designed such that the process is applicable at a strategic,
programme or project level. Specific indicators need to be monitored regularly to
ensure that projects/programmes, irrespective of whether DWAF is the Regulator or
the Impactor, are socially, environmentally and ecologically sustainable. Further, the
monitoring process is applicable to all types of monitoring. Refer to Figure 6 for an
overview of the monitoring protocol.
Second Edition - 15 - May 2005
Figure4: Overview of Monitoring Process
Monitoring Objective
Scope of Monitoring
Information Required
Gather Information
Conduct Monitoring
Evaluate Results
Present Results
Decision-making
Corrective actions
Post- Monitoring
Conducting Monitoring
Pre- Monitoring Planning
Second Edition - 16 - May 2005
Step 1. What is the objective of monitoring?
Monitoring objectives need to be determined, bearing in mind the environmental
goals and objectives of DWAF. Legislation, regulations and best practices should
also be borne in mind when determining objectives. Examples of monitoring
objectives could include:
ensuring legal compliance for instance monitoring to ensure that permit
conditions are met or compliance to the EMP, EIA, etc.(compliance
monitoring);
monitoring of pre-determined indicators e.g. ensuring that the water in a river
downstream of a dam is of the correct quality and quality; (baseline
monitoring)
ensuring that environmental programmes are effective and used correctly for
their intended purpose (programme evaluation monitoring);
reduce environmental liability on an environmentally sensitive project (e.g.
monitoring of suitable indicators may allay the public‟s concerns, cumulative
impact monitoring);
Gathering of Information
E.g. ensuring legal compliance
Best practices
Legislation
DWAF‟s environmental goals
Scope of Monitoring
Information required
MMoonniittoorriinngg OObbjjeeccttiivvee
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 17 - May 2005
Periodic inspection of a project to ensure compliance with the EMP,
rehabilitation specifications and best practices (inspection monitoring)
or a combination of the above.
Once the objective has been determined, appropriate checklists and other tools can
be used.
Step 2. What is the scope of the monitoring?
Before monitoring can begin, the scope must be clearly defined, based on the
objectives. Usually only one project or programme is monitored at a time.
Gathering of Information
Information required
Monitoring Objective
Usually one project at a time
Based on objectives SSccooppee ooff MMoonniittoorriinngg
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 18 - May 2005
Step 3. What information is required to conduct the monitoring
The general information that will be required includes the details of the actual project,
if is an internal DWAF project, or the details of the Water Use Licence if DWAF is the
Regulator. The following information may be needed:
what is the purpose of the project?
what type of project is it?
copy of the RoD, EMP, EIA report, etc.
what activities are involved, etc.
If indicators are being monitored, background information is also required regarding
the indicators to be monitored and tools that will be used during the project.
Information on the targets and timeframes associated with each indicator is required.
Gathering of Information
Monitoring Objective
Scope of Monitoring
Activities involved
Copy of RoD, EMP, etc.
Type of project
Project‟s purpose
IInnffoorrmmaattiioonn rreeqquuiirreedd
IEM Series Sub Series No. 1.7 EM&AG
Second Edition - 19 - May 2005
Step 4. How will the project monitoring information be gathered?
Depending on the objective of the monitoring, a variety of tools can be used to assist
in monitoring, more often than not checklists are used to gather information during
monitoring. A few checklists were designed for certain DWAF functions and included
in the Appendix of the document. The checklists could be used for monitoring
however one would need to adapt the checklists for specific types of monitoring.
Additional checklists may need to be designed for the different types of monitoring.
Suitable monitoring points for each indicator should be identified at the project site or
in nearby areas as required. Suitable intervals for monitoring each indicator should
be determined. The project team should be made aware of what types of monitoring
will be carried out during the project, and when and where the monitoring would
occur in order to monitor the correct information. Monitoring must be conducted by a
suitably qualified person.
GGaatthheerriinngg ooff IInnffoorrmmaattiioonn
Monitoring Objective
Scope of Monitoring
Information required Qualified person
Monitoring frequency
Monitoring points
Checklists are often used
Monitoring tools
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Step 5. Conducting the monitoring
If DWAF is monitoring in the capacity of a Regulator, a predetermined checklist must
be used. The checklist will be based on the requirements of the EMP approved
during the licence application process and the relevant licence conditions. Checklists
may also be based on relevant laws and regulations.
If DWAF is monitoring its own internal projects, as an Impactor, in line with other
Government Departmental requirements such as DEAT, then monitoring must be
done in accordance with the RoD of the relevant authority. However, if DWAF is
monitoring its internal projects, that are not regulated by any other authority, then a
reasonable monitoring programme must be developed.
Monitoring of indicators can be carried out through making observations and taking
samples at the monitoring points, at the predetermined intervals. The information will
be gathered using the checklist mentioned above as well as any other suitable tools
(e.g. bio-monitoring lists, on-line digital data, etc).
Evaluate results
Present results
Monitoring tools (e.g. checklists)
DWAF Impactor – RoD compliance
DWAF Regulator – EMP and licence compliance
Conduct monitoring
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Step 6. Evaluating the monitoring results
The results of the monitoring are evaluated by comparing the information gathered
with the targets that were originally identified.
Evaluating monitoring results would involve a similar process to that for auditing, with
the exception that certain specific monitoring tools will have their own methods of
evaluation. An example of specific methods of evaluation may be the guidelines
which describe how to evaluate the results of water quality monitoring. The
evaluation/interpretation of the monitoring data is considered the most crucial step of
the monitoring process. Decisions on instituting corrective actions are based on the
interpretation of the monitoring data.
Conduct monitoring
Present results
Crucial step
Specific evaluation guidelines
Comparison of results with targets
Evaluate results
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Step 7. Presenting the monitoring results
Monitoring results can be presented as a completed checklist, however it is advisable
that trends analyses are compiled. Trend reports are an interpretation of the results
of the monitoring reports, and are presented in the form of easily understood
graphics.
Unlike audit results, it is not likely that monitoring results will be included in annual
reports, though they will probably form part of project reports. The monitoring results
must be stored in a suitable information system as they will be required for auditing
purposes.
Conduct monitoring
Evaluate results
Storage for auditing purposes
Trend reports
Completed checklist
Present results
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Step 8. Decision-making based on monitoring results
The decision-making process will be less strategic and more focussed on correcting
environmental performance problems. In monitoring, the decision making process is
driven by the need to resolve the non-compliance immediately.
A format for compiling an environmental non-compliance report is included in this
document. The non-compliance report can be used to aid the decision-making
process.
Step 9: Instituting corrective action
Instituting corrective action in the monitoring process is more immediate than the
auditing process. All non-compliance issues will need to be corrected immediately in
Corrective actions
Resolution of non-compliance
Focus on corrective actions Decision-making
Corrective actions
Decision-making Follow-up on corrective actions
DWAF Regulator – notification of non-
compliance (timeframe)
Specific actions may need input
Correct non-compliance immediately
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other words it may not be possible from a timing perspective to implement policy
changes in order to improve monitoring results.
The corrective action will be specific to each project and may need the input from all
parties working on the project such as the planners, engineers, contractors, IAPs,
etc.
If DWAF is monitoring an external party, such as a waste disposal site permit holder
or a water use licence holder, the external party must be notified in writing of all non-
compliance and given a timeframe in which to institute corrective action.
The information in the non-compliance report (both those completed by DWAF and
those completed by external parties) will need to be followed up to ensure that the
corrective actions have been completed.
3.4 Guideline for Writing a Monitoring Report
The checklists and monitoring reports for environmental monitoring should be kept by
the environmental manager and should be stored in a suitable information system.
The checklists and reports must be available for use when conducting an audit of
projects, programmes, policies etc. It is the responsibility of the person conducting
the monitoring to ensure that the environmental monitoring report or checklist is
accurately completed, the observations made during the monitoring are correct and
true reflection of the actual situation and that the interpretation of the data is logical
and factual. The party responsible for performing the environmental must sign the
monitoring report.
A monitoring report will not be is not a detailed report, as much of the monitoring
information will be contained in the completed checklists.
The monitoring report must begin with basic administrative information related to the
monitoring. This includes the date/s that the monitoring was conducted, the type and
objective of the monitoring, how the information on the checklist was obtained, who
performed the monitoring, which checklists were used, which office or directorate
within DWAF was responsible for conducting the monitoring, and any problems
encountered during the monitoring process.
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The monitoring report should then have a summary that identifies the key findings
and recommendations of the monitoring, including a summary of compliance and
non-compliance.
A more detailed description of the important monitoring results should then be
compiled. The report should also include a physical description of the site, the
indicators (if relevant) and monitoring sites. The type of information that will be
included in the report is depend on the type of monitoring that was required for the
specific purpose.
The report must clearly suggest recommendations or corrective actions that will
assist DWAF staff or an external party in attaining compliance. Corrective actions will
vary widely and should be decided upon by the person with the delegated powers to
institute change.
It is crucial that the monitoring report includes all relevant supporting information, the
checklists in particular must be completed in full. Diagrams, photographs, and other
data may also form part of the report.
Recommendations to address areas of non-compliance or opportunities to reduce
the risk of harm or detriment to the environment resulting from the activity, may also
be included. The recommendations should be prioritized and dates for instituting
corrective actions should be included where necessary.
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Table 3: Typical Format of an Environmental Monitoring Report
Dept./Company where monitoring will be carried out:
FORM NO.:
Monitoring date:
Monitoring leader and team:
Project/Programme/Activity monitored:
Responsible manager:
Monitoring type:
Indicators measured:
Purpose of monitoring:
Objectives/targets of the monitoring:
Scope of the monitoring:
Main checklists to be used during the monitoring:
Description of the project/programme/activity to be monitored:
Monitoring technique and evaluation of monitoring results:
Description of non-compliance noted during the monitoring: (Was a non-compliance report completed?)
List of supporting documents:
Recommendations and Conclusions
Signed/date: Monitoring leader:
Responsible manager/licence holder
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3.5 Instituting Corrective Action, Continual Improvement and Preventative
Measures
Corrective action for monitoring usually involves simple measures designed to stop
the immediate problem for the short-term. Unlike corrective action for auditing which
is strategic and often involves change in policy, management, etc.
Identifying the simple cause of a monitoring finding is fairly straightforward. The
checklists should allow the monitor to highlight the areas where environmental
problems have arisen. An examination of the facts should then enable the monitor to
understand the problem and identify the cause.
Corrective actions need to be devised which are specific to each problem. The
assistance of a higher-level decision-maker may be useful in establishing appropriate
corrective actions. A suitable deadline for the implementation of a corrective action
should be determined. Further monitoring of this corrective action must be included in
all future monitoring programmes. Refer to Table 7 of the report for a typical non-
compliance and corrective action report.
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4 THE AUDITING PROTOCOL
4.1 Definitions of Auditing
The United States Environmental Protection Agency (EPA, 1997) defines
environmental auditing as a „documented, periodic and objective review of facility
operations and practices related to meeting environmental requirements‟. An auditing
protocol will also ensure consistency in the level of compliance. The aims of an
environmental audit should be to: verify compliance with environmental requirements,
evaluate the effectiveness of Environmental Management Systems, and to assess
the risks from regulated and unregulated practices (EPA, 1997).
Definitions for environmental auditing are also available from the International
Chamber of Commerce and the International Standards Organisation (ISO). The
International Chamber of Commerce defines an environmental audit as „a
management tool comprising a systematic, documented, periodic and objective
evaluation of how well environmental organisation, management and equipment are
performing with the aim of helping to safeguard the environment by:
(1) facilitating management control of environmental practices; and
(2) assessing compliance with company policies, which includes meeting regulatory
requirements. „
The International Standards Organisation (ISO) defines environmental audit as a
„systematic, documented verification process of objectively obtaining and evaluating
audit evidence (verifiable information, records or statements of fact) to determine
whether specified environmental activities, events, conditions, management systems,
or information about these matters conform with audit criteria (policies, practices,
procedures or requirements against which the auditor compares collected audit
evidence about the subject matter), and communicating the results of this process to
the client (organisation commissioning the audit).‟
Environmental audits help in assuring the accuracy and relevance of environmental
monitoring, and the identification of issues via the audit process may also lead to
environmental standards that exceed regulatory requirements.
Audits can apply at a project level as well as at a strategic level. Further, audits tend
to involve a broader scope of projects, though depending on the nature of the
organisation, usually only a sample is taken. Audits are conducted less frequently
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than monitoring, often annually or biannually. Possible methods for conducting an
environmental audit vary from simple checklists to more complex programmes.
These procedures use a systematic and structured approach to record whether an
organisation is meeting its environmental objectives. It is important that all relevant
aspects of the organisation are identified and included in the audit at an agreed level
of detail.
A requirement of an environmental audit is that evidence must be verified by
supporting documents, if this is not the case, then the process is a review, survey or
assessment, but not an audit.
4.2 Types of Auditing
Numerous types of environmental audits can be carried out for various types of
projects or sites. The choice of a suitable audit type depends primarily on the
purpose of the audit. The various types of audit are discussed below.
Environmental
Management
Programme
Audit
An environmental management programme audit may be conducted for
organisations that do not have an environmental management system in
place. This type of audit will cover DWAF‟s entire environmental
management programme, for functions which have an impact on the
environment and for functions which control/regulate impacts on the
environment.
An audit of DWAF‟s CEIMP against objectives and targets set by DWAF and
agreed to by DEAT is an example of an environmental management
programme audit.
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Environmental
Management
Systems
(EMS) Audit
EMS‟s are formally and independently recognised systems. EMS audits are
normally required to maintain accrediation and to ensure that the EMS is
functional, relevant, commitments made in the EMS are upheld, and that the
EMS is properly implemented. There are three levels of Environmental
Management System audits namely:
First Party Audit: A first party audit is an audit by an organisation on itself,
i.e. an internal audit of the EMS.
Second Party Audit: A second party audit is an audit by one organisation,
working on its own behalf, on another. This is usually an audit on a supplier
by a customer.
Third Party Audit: A third party audit is an audit of the EMS against an
appropriate standard and is conducted by an independent organisation.
These standards also require that internal environmental audits are
undertaken according to a timetable developed by management of the
organisation certified to the standard.
Compliance
Audits
Environmental compliance audits examine the compliance of an organisation, a
site or operation with environmental legislation, regulations, licences, and other
documentation, including internal environmental policies. Compliance audits are
applicable at a project and organisational level.
A compliance audit, as part of an EMS audit or programme management audit,
will often involve the services of an environmental lawyer to provide advice on
environmental legislation, while other members of the audit team may include
environmental or technical experts to determine whether the technical aspects
of compliance are being achieved.
The outcome of a compliance audit is usually a 'report by exception', which is a
report that documents only the instances of non-compliance.
DWAF will lneed to conduct a first party audit of an internal DWAF EMS,
once the EMS is in place.
Compliance audits are relevant to DWAF at a strategic level and as a
Regulator. At a DWAF strategic level this type of audit is rarely carried out in
isolation, and will normally form part of a general environmental review or
EMS audit, should an EMS be in place. However, as a Regulator, a
compliance audit of external parties such as water use licence holders may
form part of a technical or process audit.
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Technical
or
Process
Audits
Technical or process audits are specialised types of audits undertaken by industry
or government departments for the purpose of determining whether a particular
operation or process has a detrimental effect on the environment, or to assess the
environmental impact of a specific part of an operation or process.
Due Diligence
Environmental
Audit
Due diligence audits may be required before the lending of funds or by the
organisation considering a merger, acquisition or divestment. This is due to
the fact that financial institutions and purchasers of property are more aware
of the possibility of acquiring environmental liabilities. Another reason that
environmental audits are carried out is to determine the level of
environmental liability or risk of a property or asset. Such audits may be
required by a prospective purchaser, or by a lessor or lessee to determine
the environmental liability arising from pollution of a property. Further, due
diligence environmental audits may be applicable to all state land issues.
As a Regulator, the audit of a water use license is considered a
technical/process audit. However, as an Impactor, the internal audit of
technical developments such as transfer schemes and dams is also
considered a technical/process audit.
This may be applicable when DWAF has undertaken to rehabilitate defunct
mines on behalf of the mine owner with the understanding that DWAF will
recover all costs from the mine owner. Also, due diligence environmental
audits may be required if DWAF is to purchase major assets or property for
development projects such as a dam.
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Environmental
Marketing
Audits
There is an increasing number of legislation and public pressure related to
the environmental cost of consumer products. These include
'environmentally friendly' products and other types of labelling which form
part of the marketing of products. An environmental marketing audit
assesses the environmental standing of a product or a range of products, by
conducting a life-cycle assessment of a product, as well as ensuring that the
company's operations meet legislative requirements and public expectations.
Environmental
Management
Tools Audit
Currently DWAF has a number of environmental management tools including
an EIA evaluation checklist, Standardised EMP guideline, an EMP evaluation
checklist, an EMPR evaluation checklist, Aspect and Impact Register,
Request for Information checklist and Environmental Site Management and
Rehabilitation Specifications to name a few inhouse environmental
management tools.
The environmental management tools need to be audited to ensure the
effectiveness of the tools, the efficient and appropriate use of the tools for its
intended purpose and to ensure that the tools reflect changes in legislation.
The environmental management tool audit aims to assess the extent to
which the tool assist in correctly predicting potential impacts, was the tool
relevant, etc.
This type of audit is of specific importance to DWAF for the purchase and
handling of hazardous material such as pesticides. DWAF is required in
terms of its vision, mission and goal to use environmentally friendly products
and to insist that its Contractors and Professional Service Providers also use
environmentally friendly products in the execution of DWAF projects. Also,
should DWAF decide to implement an EMS, environmental marketing audits
of consumer goods would be required.
For a DWAF development project, an EIA is considered a planning tool to
understand the environmental impact of a proposed development to inform
the feasibility of the project. An environmental management tool audit can
be carried out on a project or programme that has been the subject of the
EIA tool. The EIA itself may be audited as well as the Environmental
Management Plan (EMP) as part of compliance auditing.
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Life-cycle
Audit (more
commonly
known as
Environmental
Performance
Audit)
An environmental performance audit is an on-going environmental
management activity which examines and assesses practices and
procedures which, in the event of failure, would cause an environmental
impact or result in an environmetnal risk. The audit takes into account the
various requirements during the life cycle of a project and/or programme to
ensure that environmental impacts are identified and mitigated against.
Post Project
Audits (also
known as
Project
Evaluation
Monitoring
and/or
Environmental
Review Audit)
This type of audit (monitoring) focuses on evaluating effectiveness and
efficiency, but is applied to projects in order to determine the relative success
or failure of projects after completion. Success is measured in economic,
social and environmental terms. This type of audit provides valuable
management information regarding the environmental success of projects,
the findings of the audit can be used to signpost areas of concern or where
further investigative work is required. Post project audits are considered a
high-level programme audit.
A development project is likely to have various phases namely, Project
Identification/Feasibility Phase, Design Phase, Construction Phase,
Operation Phase and De-commissioning Phase. During each of these
phases various issues need to be monitored, a life cycle audit will ensure
that the monitoring was correctly undertaken and that compliance was
achieved.
DWAF could take a sample of all projects completed annually and evaluate
the environmental success and failure of the projects. The successes will
represent areas to be strengthened while failures will represent areas for
improvement. Post project audits are in itself a type of corrective action, as
the findings of the audit will lead to continuous improvement within DWAF.
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Table 4: Types of Auditing Applicable to DWAF Functions
Table 5: Recommended Auditing Frequencies
Construction Commissioning O&M
Expansion /
Modification
Closure/
Decommissioning
Strategic/Organisational
Level
Developer Listed
Activity RoD RoD RoD RoD RoD
Developer Non-Listed
Activity Annually N/A Annually) Annually Annually
O&
M
Transfer Schemes/
Pump
Stations/Dams
Operating Plan or Annually
Weirs/ Canals/
Pipelines Annually
Policy and Strategy Annually & every three
years by external party
Regulating Water Use RoD/Annually N/A RoD/Annually RoD
Application
Environmental
Management
Programme
Audit
Environmental
Management
Systems (EMS)
Audit
Compliance
Audits
Technical or
Process
Audits
Due Diligence
Environmental
Audit
Environmental
Marketing Audits
Environmental
Management
Tools Audit
Life-cycle
Audit
Post Project
Audits
Developer
Policy and
Strategy
Regulating
water use
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4.3 Generic Auditing Process
In this document auditing is taken to mean a regular, systematic, documented,
verification of whether DWAF and external parties regulated by DWAF are in
compliance with the relevant legislation and policies, and whether environmental
performance objectives and targets and being met.
The auditing protocol can be applied to any level and type of auditing. Thus the
protocol can be used at a strategic, project or programme level and it can be used for
a compliance audit, environmental management programme audit, EMS audit, due
diligence environmental audit, etc. Each step of the protocol must be adapted for
DWAF‟s responsibilities at a strategic level, as an Impactor and/or as a Regulator.
The protocol is not limited or restricted by DWAFs roles as WRM, WS or Forestry.
Refer to Figure 7 for an overview of the auditing process.
Second Edition - 38 - May 2005
Figure 7: Overview of Auditing Process
Audit Objective
Scope of Audit
Information
required
Gathering of
Information
Conduct the audit
Evaluate results
Present results
Decision-making
Corrective actions
Post Audit
Conducting the Audit
Pre-Audit Planning
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The following steps form the basis of an audit.
Step 1. What is the objective of the audit?
The audit objectives should be measurable and will vary depending on DWAF‟s
functions i.e. either as a Regulator, Impactor or at a strategic function. If DWAF is
auditing the organisation at a strategic level, then DWAF‟s auditing goals and
objectives in terms of policy and legal requirements and its vision, mission and
mandate must be considered.
In other instances the objectives of the audit could include:
ensuring legal compliance (first party EMS audit or environmental
management program audit);
checking that the tools are used correctly and efficiently and to check whether
the tools are effectively fulfilling their intended purpose (environmental
management tools audit);
ensuring environmental performance on a continuous basis (life-cycle audit);
reducing environmental liability on environmentally sensitive projects/issues
(technical or process audit);
Gathering of Information
E.g. ensuring legal compliance
Dependant on DWAF‟s functions
Scope of Audit
Information required
AAuuddiitt OObbjjeeccttiivvee
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determining whether the environmental targets for the particular programme
or project are being reached (Post project audits);
or a combination of the above.
Step 2. What is the scope of the audit?
Before the audit begins, the scope must be clearly determined, based on the
objectives. If DWAF is doing a strategic compliance audit then it must be decided if
all departments will be audited or whether a sample will be taken. Similarly if DWAF
is auditing water use licence holders for compliance it must be decided if a sample
will be taken or whether a single licence, project node, or programme will be audited?
In determining the scope of the audit, one can also decide how much time, money
and personnel should be allocated. Appropriate personnel should be appointed. The
appointed team members must be suitably qualified to undertake the audit and are
able to interpret and analyse the data. Once again resource allocation is dependent
on the type of the audit. For instance, when undertaking an environmental
management program audit, EMS audit or a technical audit, the audit team is likely to
comprise of various skilled people such as a legal advisor, technical person
(engineer), financial advisor, project manager, etc. However, for compliance auditing
Gathering of Information
Information required
Audit Objective
Allocation of resources
Based on objectives SSccooppee ooff AAuuddiitt
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or environmental management tools audit of a single project or a programme, one
person with a good understanding of environmental principles is required.
Step 3. Information required to conduct the audit
Two types of information is required, the first type is the details of the actual
programme or project. The following details may be required:
the purpose of the project/activity/programme/tool.
type of project/activity/programme/tool.
Timeframes of the project/activity/programme/tool.
activities of the project/activity/programme/tool.
The second type of information that is required is background information on the
project/activity/programme/tool. The extent of the information will depend on the
objectives of the audit:
If auditing for legal compliance, knowledge of the legislation which pertains to
the project/activity/programme/policy, must be obtained.
Gathering of Information
Audit Objective
Scope of Audit
Information depends on objectives
Background information
Project details
IInnffoorrmmaattiioonn rreeqquuiirreedd
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If auditing tools, the uses of the tools must be known, the current
effectiveness of the tools must be established, as well as the intended
outcome of using the tools.
For compliance audits, a clear understanding of permit/licence/RoD
conditions and the EMP/regulations must be known.
If auditing targets, the targets and mechanisms to achieve the targets must
be known. Targets could be environmental, social or economic and there may
be indicators in place for monitoring the achievement of the targets, in which
case all previous monitoring and auditing data must be known.
Step 4. How will the audit information be gathered?
Audit information regarding legal compliance, performance monitoring data and the
use of tools is best gathered by conducting interviews with the licence holder, the
project manager, the engineer, etc. Information from project reports, trend analysis,
evaluations and raw monitoring data may also be used. The people to be interviewed
during the audit must be identified and informed of the process.
GGaatthheerriinngg ooff IInnffoorrmmaattiioonn
Monitoring Objective
Scope of Monitoring
Information required Monitoring information
Questionnaire/checklist
Observations
Existing information (e.g. reports)
Conducting interviews
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Some sections of the audit may also be carried out through observations made at the
actual project site or other audit areas. Again, the project team should be made
aware of what types of auditing will be carried out during the project, and when and
where the audit will take place.
A questionnaire or checklist should be compiled based on the audit objectives and
scope. Checklists should be carefully prepared for each area to be audited.
Suitable data for each indicator should be gathered based on the information
obtained during the monitoring protocol of each project.
Step 5. Conducting the audit
Once the objective of the audit, the scope of the audit as well as the pre-audit
information is gather, one is ready to conduct the audit. The relevant parties that
need to be present at the audit such as the licence/permit holder, the project
manager, operator, etc must be informed well in advance. The audit must be
conducted in a professional and non-confrontation environment. It is important to
note that the aim of an audit is not to apportion blame but to determine whether the
environment is being protected and if not, then the best way to rectified the situation
Evaluate results
Present results
Auditing tools (e.g. checklists)
Notify attendees CCoonndduucctt tthhee aauuddiitt
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must be determined. This is particularly important in the instances where DWAF is
the Regulator and is auditing an external party.
The results of an audit are obtained by comparing the information gathered during
interviews and from reports with the objectives that were originally identified as well
as the actual on the ground situation.
A commonly used auditing tool is a checklist. Checklists should be designed for each
objective.
Step 6. Evaluating the audit results
Depending on the objective and scope of the audit, there are a number of ways in
which the results of an audit can be evaluated.
It should be noted when evaluating the results, some factors may be insignificant,
while others which seem insignificant may in fact have a cumulative effect.
The simplest way to evaluate the results is to determine which aspects of the
checklist were not evaluated. A trained person must then evaluate the significance of
the omission or problem. Alternatively, the checklists could be divided into sections
based on the importance of each aspect. For example, all legislative requirements
Conduct the audit
Present results
Statistical analysis
Weighting system
Consider aspects not evaluated
EEvvaalluuaattee rreessuullttss
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could be placed separately from DWAF‟s policy requirements. Thus any non-
compliance with legislation can then be viewed as more significant than non-
compliance with a DWAF environmental policy.
A weighting system could also be applied to the checklists. Based on the example
above, legislation could be weighted with ten points and policies with five points. With
this system, a total of ten points or more may indicate that remedial action is
necessary.
Various types of statistical analyses may also be applied to evaluate the results,
particularly the results obtained from auditing indicators and environmental
performance data obtained from the monitoring process.
Step 7. Presenting the audit results
The findings of the audit should be presented to all members that were present
during the audit. In the event of auditing a water use licence, the results of the audit
must be made available to the licence holder. Audits results of internal DWAF
projects must be presented to the relevant senior management. Audit results at a
strategic business level may be included in other reporting mechanisms such as
annual reports.
Conduct the audit
Evaluate results
Verification via supporting documents
Achievement of objective
Include attendees on distribution list
PPrreesseenntt rreessuullttss
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The audit results can be represented in the form of simple graphs which show areas
and levels of compliance/non-compliance. The proportions of objectives/targets
reached could also be represented graphically.
When an audit is done on a third party were DWAF is the Regulator, the results must
be presented in the form of a report. The format of the report is not relevant however
it must be professional and must only present the facts with no use of emotive or
subjective language.
A requirement of an environmental audit is that evidence must be verified by
supporting documents, if this is not the case, then the process is a review, survey or
assessment, but not an audit, hence the audit report must be supported by the
relevant documents indicating non compliance.
Step 8. Decision-making based on audit results
Irrespective of DWAF‟s roles and responsibilities during the audit i.e. at strategic
level, as a Regulator or Impactor, decision making based on the audit results should
have only one objective and that is to improve the present situation and to institute
fair and reasonable corrective action.
A decision should be made based on the significance of the problem and the
resources (financial, human, etc) required to improve the situation. Other factors that
may influence a decision could include:
Public opinion regarding the activity/project;
The length of time it could take to rectify the problem;
Any inherent dangers to the environment, workers or the public; or
Corrective actions
Based on inter alia significance of
issues and available resources
Focus on corrective actions DDeecciissiioonn--mmaakkiinngg
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Adherence to internal best practice policies.
A decision support system for these types of decisions may also need to be
developed.
Step 9: Instituting corrective action
Instituting corrective action is dependent on DWAF roles and responsibilities during
the audit i.e. at a strategic level, as an Impactor or Regulator. If DWAF is the
Impactor, then the recommendations of the environmental audit requires an
environmental action plan to be set up complete with:
goals;
strategies;
performance indicators;
responsibilities;
a timetable for achievement; and
cost estimates.
An environmental audit is an effective management tool only if the auditor's
recommendations are considered as soon as possible. The audit provides a basis for
recommending actions to correct any deficiencies and to address any areas of
environmental risk recorded as part of the audit findings. Matters arising in an audit
which are not addressed in an appropriate time frame should be highlighted in
subsequent audits. An assessment should be made of the reasons for the lack of (or
delay in) remedial action.
Corrective actions could include the development of new policy and strategy for
DWAF.
CCoorrrreeccttiivvee aaccttiioonnss
Decision-making
DWAF Regulator – notification of non-
compliance (timeframe)/Directive
Execute recommendations
Dependant on DWAF‟s duties
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However, if DWAF is acting in the capacity of a Regulator, the nature of the
corrective action remains the prerogative of the external party namely the
licence/permit holder. DWAF is obliged to inform the licence/permit holder of the
findings of the audit highlighting all areas of non-compliance. The applicant must be
given an opportunity to respond either to present his/her case or to recommend
corrective actions. DWAF can make suggestions in terms of the most appropriate
corrective action. Thereafter, a timeframe to institute the corrective action must be
agreed upon.
In the case of gross non-compliance which could result in loss and/or damage to
property, life and/or the environment DWAF can issue a Directive to demand that
corrective action is instituted immediately.
4.4 Guideline for Writing an Auditing Report
In the case of an EMS audit, all forms and reports relating to the audit must be kept
by the environmental manager for use by management when conducting a review of
the EMS and by the external verification body responsible for validating EMS. The
environmental auditor must ensure that any environmental audit report is an accurate
record of soundly based observations and of logical deductions. The environmental
auditor must sign the report, indicating ownership of the findings of the audit.
The EPA audit report guidelines
Of all the reporting procedures that are currently used, the EPA guidelines of 1997 is
considered the most appropriate for DWAF needs. An audit should ideally contain
five sections as a minimum, the content of each section is discussed below.
Section I: Description of administrative aspects of the audit.
This includes the date the audit was conducted, the objective of the audit ie was it a
compliance audit, environmental management tools audit, etc, who was interviewed,
who performed the audit, the office or directorate within DWAF responsible for
conducting the audit, and any limitations or exclusions regarding the audit scope or
methodology, e.g., if the auditors were refused access to certain areas on site.
Section II: Executive Summary
The executive summary must be written that highlights the key findings and
recommendations of the audit report including a summary of compliance and non-
compliance status.
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Section III: Description of the Audit Findings
This section should include the physical description of the project/programme
together with a detailed description of related issues. Each finding of the audit must
be clearly described in terms of compliance, priority and effectiveness.
Section IV: Recommendations
The report must clearly suggest recommendations or corrective actions that will
assist DWAF staff or an external party in attaining compliance. These may range
from simple administrative suggestions to recommendations for capital improvement.
The recommendations may also focus on the need for additional investigation or
further analysis before a final solution is proposed.
Section V: Supporting Data and Information
The audit report must include relevant supporting information such as analytical data,
copies of Notices of Violations, plans or maps, schematic diagrams, photographs,
etc.
It is important to remember that a requirement of an environmental audit is that
evidence must be verified by supporting documents, if this is not the case,
then the process is a review, survey or assessment, but not an audit.
The results of an environmental audit report are the findings and conclusions. The
process for arriving at the findings and conclusions set out in the environmental audit
report (including the objectives, scope and methodology), and any opinion stated,
should be accurately documented and referenced. It should clearly state the
environmental auditor‟s opinion as to the risks posed by the activity, benefits of the
audit, and provide justification for the opinion.
In addition to the above, the environmental audit report may contain
recommendations to address areas of non-compliance or any identified opportunities
to reduce the risk of harm or detriment to the environment resulting from the
project/programme audited. Priorities should be assigned to recommendations, the
priority should be consistent with the outcomes of any risk assessment undertaken
for the purpose of the audit. Environmental audit reports should be concise and
informative, with information being displayed in a format that is easy to interpret.
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Table 6: Typical Format of an Environmental Audit Report
COMPANY/DEPT AUDITED:
FORM NO.:
Audit date:
Audit leader and team:
Project/Programme/Activity audited:
Responsible manager:
Audit type:
List of interviewees (including responsibilities and information reviewed:
Objectives of the audit:
Scope of the audit:
Tools used during the audit:
Description of the project/programme/activity audited:
Audit Techniques:
Evaluation of Audit Results:
Description of non-compliance noted during the audit:
List of supporting documents:
Recommendations and Conclusions:
Signed/date: Lead Auditor:
Responsible Manager/Licence Holder
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4.5 Instituting Corrective Action, Continual Improvement and
Preventative Measures
Effectively implemented, audit recommendations reduce environmental risk
and will assist DWAF and external parties to demonstrate 'due diligence' in a
court of law. Conversely, it could be argued that if companies follow the best
practice in environmental management they are unlikely to be in a court of
law. Auditing usually involves three basic steps: conducting the audit,
identifying problems (audit findings), and correcting identified deficiencies.
When the audit process is expanded, to identify and correct root causes to
non-compliance, the ability to limit negative impacts becomes more effective.
In the model below, audit findings (exceptions) undergo a root cause analysis
to identify the underlying causes of non-compliance events. Management
actions are then taken to correct the underlying causes behind the audit
findings and improvements are made to improve environmental performance
before the next audit. Expanding the audit process allows the organisation
(either DWAF or the external) to successfully correct problems, sustain
compliance, and prevent discovery of the same findings again during
subsequent audits. Identifying the root cause of an audit finding can also
mean identifying not only the failures that require correction, but also
successful practices that promote compliance. In this way, an organisation
can make continual progress toward environmental best practice.
Figure 8: Typical Audit Process Showing Corrective Action
Analyse
exceptions for
cause / effect
Develop actions to
correct underlying
causes
Audit
Fix
Problems
Group findings
for common
causes
Examine each group for
underlying causes
Improve the
effectiveness of
environmental
management
Identify
Problems
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There are a number of ways in which environmental performance can be improved
using the results of an auditing system. However, instituting corrective actions in
terms of external parties is largely dependent on the external party itself. DWAF
must give the external party an opportunity to institute corrective actions however the
corrective action must be approved by DWAF.
Figure 9: Deming/PDCA Cycle
The PDCA Cycle as it could be used for a DWAF project/programme when DWAF is
the Impactor is outlined below. This is a quality control method thus its purpose is to
improve the (environmental) quality of a project/programme. If the results of
monitoring or an audit indicate that the objectives or targets have not been met, then
this cycle could be implemented to help reach the objectives. It may be used for the
remainder of a current project or it may be used for future similar projects until the
problem has been corrected.
Plan
1) Set goals and targets (using legislation and policy as a baseline). What are
the expected results?
Determine
goals and
targets
Determine
methods of
reaching
goals
Engage in
education
and training
Implement
work
Check the effects
of implementation
Take appropriate
action
ACT
CHECK
PLAN
DO
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2) Determine how to reach the goals i.e. which tools should be used.
3) Develop an (environmental) implementation/project plan.
4) Note potential problems in implementing the plan.
Do
1) Follow the implementation/project plan.
2) Use the necessary tools.
3) Undertake any training etc. that may be required.
Check
1) Use auditing tools e.g. checklists, to monitor the progress of the corrective
action.
2) Have the goals/targets been achieved and have the problems that were
initially identified been resolved?
3) If the goals have not been achieved, determine why.
Act
1) Determine whether the monitoring and auditing process can be improved.
2) If problems were encountered, develop measures to prevent these from re-
occurring.
3) If the goals have not been achieved, start the process again.
If the goals have been achieved, move on to the next project.
An important part of implementing corrective action involves communication between
the various levels in DWAF regarding the monitoring and auditing results. Effective
communication of such information is essential for employees to know and fulfil their
responsibilities, and for other interested parties understand the issues (ISO, 2000).
Corrective action may require the development and implementation of new policy
with DWAF.
In order to ensure the continuous improvement and relevance of the EM&AP the
following questions must be periodically asked:
1) Does the monitoring and auditing programme consider all the environmental
issues that are considered to have potential impacts?
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2) Are the issues, methods and frequencies included in the monitoring and
auditing programme judged to be appropriate?
3) Does the EM&AP establish an adequate monitoring framework (organization,
personnel, equipment, and adequate budget to sustain the monitoring and
auditing protocol)?
4) Are any regulatory requirements pertaining to the monitoring system
identified, such as the format and frequency of reports from DWAF to other
government departments?
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Table 7: Typical Format of a Non-compliance and Correction Report.
NON-COMPLIANCE AND CORRECTIVE ACTION REPORT
COMPANY/DEPT.:
REPORT NO.:
Site/Project/procedure/programme audited:
Lead Auditor:
Date:
1. Non-compliance ascertained in during audit:
Confirmation of observations made by responsible party in charge:
Date:
Signature, responsible party:
2. Proposed Corrective Actions, including timeframe for the implementation of corrective actions: The instructions should be examined together with the responsible environmental person in charge of the site/project/programme and the necessary additions should be made to the instructions
Changes will be implemented by: (Date)
Person responsible for carrying out changes
Name:
Position:
Date:
Signature, responsible person:
3. Follow-up on Corrective Actions:
Corrective Action has yield desired results
Corrective Action has not yield desired results
- see audit report no.:
Date:
Signature, environmental manager:
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Second Edition May 2005
APPENDIX A: WORKED EXAMPLE - MONITORING
WORKED EXAMPLE ON THE USE OF THE MONITORING PROCESS
The following is a worked example of Programme Evaluation Monitoring. The
example is based on the monitoring of RoD conditions. The conditions are often
inconsistent and incomplete with regard to the protection of the environment and
therefore monitoring is performed to ensure consistency and environmental
soundness of the conditions. The examples takes the users through the rationale
behind the nine steps of the generic monitoring process.
The first step is to identify the
objective of the monitoring.
This will be based on the
purpose of the monitoring as
well as any targets that have
been identified.
The purpose of the monitoring
in this example is to assess
whether the conditions in the
RoD of the water use licences
take environmental considerations into account. The aim of the monitoring is that the
water use licence conditions should include some environmental considerations.
The second step is to determine the scope of the monitoring that will be carried
out. In this example, the
scope of the monitoring will
be broad because DWAF‟s
policies that guide the
issuing of licences and their
conditions, will be reviewed.
In other words, the scope
will cover all activities for
water uses in S21 (c) and (i)
for which licences have were
granted in the past year.
Gathering of Information
Assess whether conditions of water use licence include environmental considerations
Assess whether conditions of water use licence include environmental considerations
Scope of Monitoring
Information required
Monitoring Objective Monitoring Objective
Gathering of Information
Information required
Monitoring Objective
Cover all activities for S21 (c) and (i) water uses for which licences were granted in the past year
Review DWAF‟s policies that guide issuing of licenses and conditions Cover all activities for S21 (c) and (i) water uses for which licences were granted in the past year
Review DWAF‟s policies that guide issuing of licenses and conditions
Scope of Monitoring Scope of Monitoring
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The third step is to decide on the information needed for conducting the
monitoring. For this example, the details of a suitable sample of issued water use
licences should be obtained.
This information includes:
The licence number;
The licence holder;
H/O file number;
Water use;
Planned activity; and
Conditions of the
licence.
Information regarding how licences are issued i.e. the criteria, and how conditions
are devised has also been ascertained.
The fourth step is the stage where it will be decided how the information
identified in step three would be gathered. This will include details regarding the
frequency of information
gathering, when it will be
gathered, from where it will
be obtained and who will
gather it.
The monitoring type should
be identified at this stage
using Table 1. The table will
also indicate which tools or
checklists are appropriate.
In this case, the monitoring type is Programme Evaluation Monitoring in which the
effectiveness and efficiency of programmes or policies can be assessed. The section
on monitoring type should be read to gain an understanding of what the monitoring
entails.
Table 2 should be consulted regarding an appropriate frequency for the monitoring.
The information in this table does not have to be precisely followed and it is likely that
Gathering of Information
Monitoring Objective
Scope of Monitoring
Licensing procedure (criteria and conditions)
Sample of issued water use licences Licensing procedure (criteria and conditions)
Sample of issued water use licences
Information required Information required
Monitoring Objective
Scope of Monitoring
Information required Monitoring team: experience in water use licensing
Monitoring interval: every 3 months
Monitoring type: Programme Evaluation Monitoring
Monitoring team: experience in water use licensing
Monitoring interval: every 3 months
Monitoring type: Programme Evaluation Monitoring
Gathering of Information Gathering of Information
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one will need to use discretion in determining monitoring frequencies. The monitoring
team leader should make such decisions in consultation with higher-level
management. In this case, an appropriate monitoring interval is every six months,
where a sample of the water use licences issued in that period will be selected for
monitoring. As this is the first time monitoring is taking place for this purpose, a
sample from the past year has been taken.
A monitoring team should be selected. The team may comprise one person or
several people led by a team leader. Suitably qualified people should be selected. In
this example one person will be required to conduct the monitoring and this may take
several days of each month. A suitably qualified person would be someone who
works in the water use licence-issuing department and is familiar with the information
and policies mentioned in step 3. Monitoring will be conducted by the head office.
In this example, no previously compiled checklist is available, thus one has been
compiled.
The fifth step is where the actual monitoring is carried out using the appropriate
tools. As mentioned
above, a checklist may
need to be compiled to
conduct the monitoring.
This is essential to
ensure that each water
use licence and its
conditions are evaluated
on an equal basis. If any
other suitable tools exist,
then these should also be used.
The sixth step is completed by evaluating the monitoring data in the checklists.
The monitoring person should analyse the checklists by looking for gaps, areas of
non-compliance and sub-standard levels of environmental management. The targets
that were identified should be borne in mind. In this example, the licences which did
not comply with certain licence conditions have been evaluated by determining what
Conduct monitoring
Evaluate results
Present results
Complete standard monitoring report
Project - specific checklist Complete standard monitoring report
Project - specific checklist
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percentage of non-
compliance was
associated with each
licence condition. This
information has been
contained within the
checklist for ease of use.
Methods of assessing the
monitoring results will vary
widely depending on the type of results.
This step will also involve completing section1 of the non-compliance report, an
example of which is contained in step 8.
Refer to the completed checklist (overleaf).
Conduct monitoring
Present results
Complete section1 of non - compliance report
% non - compliance associated with each licence condition Complete section1 of non - compliance report
% non - compliance associated with each licence condition
Evaluate results
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No. Checklist question where applicable (i.e. depending on the type of activity) Licence numbers of non-
compliant licences
Percentage of
non-compliance
1 Does the RoD mention that the allocated quantity and quality of water is not guaranteed? None 0
2 Does the RoD state that the conditions of the licence may have over-allocated water, and that the quantity
may be reduced when compulsory licensing is required?
None 0
3 Does the RoD state that the licence does not exempt the licensee from compliance with the provisions of the
Environment Conservation Act?
None 0
4 Does the RoD stipulate that the water user will be subject to rules and regulations of a Water Management
Area?
None 0
5 Does the RoD state that any incident of water pollution must be reported immediately to the regional
director?
None 0
6 Does the RoD state how much water may be used and from what source? None 0
7 If the water use licence is for the abstraction of subterranean water, does the RoD state that the water levels
in production boreholes must be measured monthly and that the details of the measurements must be
recorded?
None 0
8 Does the RoD state that storm water leaving the licensee‟s premises must not be contaminated? None 0
9 Does the RoD mention that water use must be confined to the property in question? None 0
10 Does the RoD state that the licensee must immediately stop all activities to prevent or reduce further
pollution should it occur?
None 0
11 Does the RoD state that the regional director must be informed of any pollution within seven days? None 0
12 Is there a condition that indicates that the proposed development may not restrict the river flow by obstructing
the flow or reducing the overall flow?
None 0
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No. Checklist question where applicable (i.e. depending on the type of activity) Licence numbers of non-
compliant licences
Percentage of
non-compliance
13 Does the RoD state that the operation and storage of equipment in the riparian zone must be limited as far
as possible?
None 0
14 Does the RoD specify that any material removed from the riparian habitat may not be stored in the riparian
zone where it may dam a weir or wash away?
None 0
15 Do the conditions stipulate that indigenous plants are to be used for rehabilitation? None 0
16 Does the RoD require the licensee to control new alien vegetation and not allow alien vegetation to colonise
the area?
None 0
17 Does the RoD state that the development must not impede the upstream movement of fish? None 0
18 Does the RoD convey that the soils that have been compacted by the development be loosened to a depth
which will allow seed germination?
None 0
19 Does the RoD mention that increased runoff resulting from the development must be controlled to decrease
silt flowing into streams and possible bank instability?
None 0
20 Does the RoD indicate that no riparian vegetation (including dead vegetation) may be removed? None 0
21 Does the RoD mention that development activities should start upstream and move downstream? None 0
22 Does the RoD specify that activities that increase turbidity should be minimised? None 0
23 Does the RoD stipulate that the developments must not increase bank instability or the erosive potential of a
stream?
None 0
24 Does the RoD state that mitigation and rehabilitation must occur concurrently with stream diversion
activities?
None 0
25 Does the RoD indicate that proposed mitigation measures must reflect the potential environmental impacts
and the environmental sensitivity of the area?
None 0
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No. Checklist question where applicable (i.e. depending on the type of activity) Licence numbers of non-
compliant licences
Percentage of
non-compliance
26 Does the RoD state that less environmentally harmful alternatives must be provided and that these are
preferred?
None 0
27 Does the RoD mention that measures must be provided to avoid disposal and spillage of any harmful
material instream?
None 0
28 Does the RoD identify the need for compensation if impact minimisation is not possible or inadequate? None 0
29 Does the RoD state that contaminated storm water should be diverted from the water source? None 0
30 Does the RoD specify that the haul road must avoid significant wetlands? None 0
31 Does the RoD mention that the material used to construct the haul road should be devoid of fine, toxic or
carbonaceous material?
None 0
32 Does the RoD indicate that potential storm water should be diverted into grassland buffer zones before
entering a river?
None 0
33 Do the conditions state that temporary stockpiles and overburden should be stored above the 1:50 year
floodline and away from drainage lines?
None 0
34 Does the RoD stipulate that all excavated material must be disposed of at an approved disposal area outside
the riparian zone?
None 0
35 Does the RoD state that the licensee must ensure that the sediment load does not exceed that in the reports
and that the water quality is still fit for downstream users?
None 0
36 Does the RoD state that monitoring must be done in accordance with reports submitted? None 0
37 Does the RoD state that the licensee must report a deviation of turbidity and suspended solids of more than
25%, and that it must be reported when baseline levels return to normal?
None 0
38 Does the RoD stipulate that the date, time and position of each monitoring point must be reported on with the None 0
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No. Checklist question where applicable (i.e. depending on the type of activity) Licence numbers of non-
compliant licences
Percentage of
non-compliance
results of the analysis (on a monthly basis)?
39 Does the RoD indicate that monitoring points may not be changed without notifying and obtaining approval
from the RD?
None 0
40 Does the RoD mention that if the monitoring indicates surface water contamination, that the contamination is
stopped and that the water complies with water quality guidelines?
None 0
41 Does the RoD specify that the methods of analysis may not be changed without notifying and obtaining
approval from the Minister?
None 0
42 Does the RoD state that roads must be rehabilitated upon completion? None 0
43 Does the RoD mention that vehicle access road must not encroach on a wetland or riparian zone except at
the site of the crossing?
None 0
44 Does the RoD include mention of the fact that rehabilitation should create the same mix of habitats that were
present prior to the river crossing?
None 0
45 Does the RoD state that rehabilitation of the stream bed, banks of the river crossing, and wetlands should be
rehabilitated during the dry season after the last dragline has been crossed?
None 0
46 Do the conditions state that the projects should have the approval of the provincial departments of
environment and roads?
None 0
47 Does the RoD state that the EMPR should be approved where one is in place? None 0
48 Does the RoD mention that all reasonable steps should be taken to minimise noise levels and mechanical
vibration in the vicinity of the river?
24069482 B2/2/10 (880) 2.94
49 Does the RoD mention that any constructed channels should be vegetated with appropriate indigenous
plants found in the area?
24069482 B2/2/10 (880) 2.94
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No. Checklist question where applicable (i.e. depending on the type of activity) Licence numbers of non-
compliant licences
Percentage of
non-compliance
50 Does the RoD specify that checks should be conducted every six months or after high flood events to check
the stability and functioning of a diversion canal, erosion measures and plant growth?
24069482 B2/2/10 (880) 2.94
51 Does the RoD stipulate that compliance/non-compliance records must be kept in good order and be
submitted to the department on request?
24069482 B2/2/10 (880) 2.94
52 Does the RoD state that the natural migration of aquatic biota should not be disturbed? 24069482 B2/2/10 (880), and
26023482.
5.88
53 Does the RoD indicate that sub-soil must be evenly redistributed over exposed area as soon as possible
after the operation has been completed?
24069482 B2/2/10 (880), and
26023482.
5.88
54 Does the RoD mention that cleared areas in which the vegetation fails to establish, must be reseeded
immediately?
24069482 B2/2/10 (880), and
26023482.
5.88
55 Does the RoD state that natural drainage lines must not be impeded? 24069482 B2/2/10 (880), and
26023482.
5.88
56 Does the RoD specify that a plan for the construction, maintenance, removal and rehabilitation of borrow
areas is required?
24069482 B2/2/10 (880), and
26023482.
5.88
57 Does the RoD state that an aquatic scientist must be appointed to submit a monitoring programme? 24069482 B2/2/10 (880), and
26023482.
5.88
58 Does the RoD state that an aquatic monitoring report must be submitted annually and may not differ by more
than one class to the reference conditions?
24069482 B2/2/10 (880), and
26023482.
5.88
59 Does the RoD mention that not carbonaceous or other possible pollutant be used during the construction
activities?
24069482 B2/2/10 (880),
26023482, and B2/1T.
8.82
60 Does the RoD stipulate that measures to avoid erosion such as drainage under roads should be repaired if 24069482 B2/2/10 (880), 8.82
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No. Checklist question where applicable (i.e. depending on the type of activity) Licence numbers of non-
compliant licences
Percentage of
non-compliance
debris accumulates? 26023482, and B2/1T.
61 Does the RoD state that no stormwater channels should be dug within a wetland? 24069482 B2/2/10 (880),
26023482, and B2/1T.
8.82
62 Does the RoD indicate that road haul crossings should not affect the geometry and topography of an
identified wetland?
24069482 B2/2/10 (880),
26023482, and B2/1T.
8.82
63 Does the RoD state that the construction camp must not be located within the 1:100 year Floodline, or 100m,
whichever is greater?
24069482 B2/2/10 (880),
26023482, and B2/1T.
8.82
64 Does the RoD specify that a contingency plan for the identification, management and rehabilitation of
spillages into the watercourse from trucks using river crossings, must be submitted and implemented?
24069482 B2/2/10 (880),
26023482, and B2/1T.
8.82
65 Does the RoD state that impacts on shallow groundwater should be identified, quantified and mitigated? 24069482 B2/2/10 (880),
26023482, and B2/1T.
8.82
66 Does the RoD state that a minimum buffer width of 10m be established between land to be developed and
the stream canal?
24069482 B2/2/10 (880),
26023482, B2/1T, and B2/1D.
11.76
67 Does the RoD state that complete stream alterations must be designed to handle a 1:1 year flood event? 24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D and
B2/1M.
14.71
68 Does the RoD stipulate that the flow of water agreed to by the licensee will continue to flow through the year? 24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D and
B2/1M.
14.71
69 Does the RoD state that Biomonitoring tests must include biotic integrity, habitat integrity and riparian
habitat?
24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D and
14.71
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No. Checklist question where applicable (i.e. depending on the type of activity) Licence numbers of non-
compliant licences
Percentage of
non-compliance
B2/1M.
70 Does the RoD state that the quantity of water needed for the ecological reserve for the river reach diverted
will be subject to the conditions of the reserve?
24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D and
B2/1M.
14.71
71 Does the RoD state that an external auditor must perform annual auditing of the performance of the
diversion?
24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D and
B2/1M.
14.71
72 Does the RoD state that the compliance with the conditions of the reserve be audited annually? 24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D and
B2/1M.
14.71
73 Does the RoD state that reports generated by auditors be submitted annually? 24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D and
B2/1M.
14.71
74 Does the RoD state that environmentally sound engineering and management practices be employed for all
actions that could affect the habitat?
24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D, B2/1M,
and B190/1/144.
17.65
75 Does the RoD state that all support operations such as gravel washing be done outside the riparian zone? 24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D, B2/1M,
B190/1/144, B191/2/1930/3,
B2/1E, B191/2/210/3, B2/1M***.
29.41
76 Does the RoD state that the „wilderness‟ quality of a river be maintained and that visual impacts seen from a 24069482 B2/2/10 (880), 29.41
IEM Series Sub Series No. 1.7 EM&AG
Second Edition May 2005
No. Checklist question where applicable (i.e. depending on the type of activity) Licence numbers of non-
compliant licences
Percentage of
non-compliance
boat be minimised? 26023482, B2/1T, B2/1D, B2/1M,
B190/1/144, B191/2/1930/3,
B2/1E, B191/2/210/3, B2/1M***.
77 Does the RoD state that a flood retention dam be sealed with Bentofix to prevent pollutants from
contaminating groundwater?
24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D, B2/1M,
B190/1/144, B191/2/1930/3,
B2/1E, B191/2/210/3, B2/1M***.
29.41
78 Does the RoD state that where a permanent water course alteration leads to a loss in aquatic habitat, it must
be compensated for by an improvement in the habitat quality?
24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D, B2/1M,
B190/1/144, B191/2/1930/3,
B2/1E, B191/2/210/3, B2/1M***,
B191/2/120/5, B2/2/110(34),
B2/2/40(246), B2/1R.
41.18
79 Does the RoD state that the cumulative impacts of possible future activities be taken into consideration? 24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D, B2/1M,
B190/1/144, B191/2/1930/3,
B2/1E, B191/2/210/3, B2/1M***,
B191/2/120/5, B2/2/110(34),
B2/2/40(246), B2/1R.
41.18
80 Does the RoD state that no construction vehicles are allowed out of delineated servitudes within the wetland
areas?
24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D, B2/1M,
41.18
IEM Series Sub Series No. 1.7 EM&AG
Second Edition May 2005
No. Checklist question where applicable (i.e. depending on the type of activity) Licence numbers of non-
compliant licences
Percentage of
non-compliance
B190/1/144, B191/2/1930/3,
B2/1E, B191/2/210/3, B2/1M***,
B191/2/120/5, B2/2/110(34),
B2/2/40(246), B2/1R.
81 Does the RoD state that no construction camps or stockpiles may be constructed in a water course system? 24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D, B2/1M,
B190/1/144, B191/2/1930/3,
B2/1E, B191/2/210/3, B2/1M***,
B191/2/120/5, B2/2/110(34),
B2/2/40(246), B2/1R.
41.18
82 Does the RoD state that the RD may ask for a report on the Habitat Integrity annually if there is a large
discrepancy after the development?
24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D, B2/1M,
B190/1/144, B191/2/1930/3,
B2/1E, B191/2/210/3, B2/1M***,
B191/2/120/5, B2/2/110(34),
B2/2/40(246), B2/1R,
B191/2/720/37/38, 24023049.
47.06
83 Does the RoD state that the SASS total scores downstream of the disturbance may not be more than 20%
less than that of the upstream site, and that the average score per taxon may not be more than 10% less
except after floods or droughts?
24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D, B2/1M,
B190/1/144, B191/2/1930/3,
B2/1E, B191/2/210/3, B2/1M***,
47.06
IEM Series Sub Series No. 1.7 EM&AG
Second Edition May 2005
No. Checklist question where applicable (i.e. depending on the type of activity) Licence numbers of non-
compliant licences
Percentage of
non-compliance
B191/2/120/5, B2/2/110(34),
B2/2/40(246), B2/1R,
B191/2/720/37/38, 24023049.
84 Does the RoD state that appropriate experts at botanical or horticultural societies should be contacted to
decide how to deal with wetland plants?
24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D, B2/1M,
B190/1/144, B191/2/1930/3,
B2/1E, B191/2/210/3, B2/1M***,
B191/2/120/5, B2/2/110(34),
B2/2/40(246), B2/1R,
B191/2/720/37/38, 24023049,
L27/2/2/B72K/239, B21R
52.94
85 Does the RoD state that specific impact mitigation measures be put in place for peat mining? N/A
86 Does the RoD state that wetland mitigation measures and new wetland creation, takes into account the
habitat requirements of plant and animal species that inhabit the wetland?
24069482 B2/2/10 (880),
26023482, B2/1T, B2/1D, B2/1M,
B190/1/144, B191/2/1930/3,
B2/1E, B191/2/210/3, B2/1M***,
B191/2/120/5, B2/2/110(34),
B2/2/40(246), B2/1R,
B191/2/720/37/38, 24023049,
L27/2/2/B72K/239, B2/1R, B2/2/16,
26022385,
73.53
IEM Series Sub Series No. 1.7 EM&AG
Second Edition May 2005
No. Checklist question where applicable (i.e. depending on the type of activity) Licence numbers of non-
compliant licences
Percentage of
non-compliance
16/2/7C223/C296B191/2/320/1,
B2/1S, B2/2/60(543), B2/1U,
B191/2/2220/12
IEMS Sub Series No. 1.7 EM&AP
Second Edition May 2005
The seventh step involves presenting the monitoring results, usually to higher-
level management who will need
to make decisions regarding
corrective action etc. The
completed checklists can be
presented together with the
monitoring report and all
supporting documentation Once
further monitoring takes place
and more monitoring data is
available, then trends analyses
should be performed on the data. This would involve the application of statistical
techniques to identify whether DWAF is getting closer to reaching its targets.
During this step the standard Monitoring Report (see overleaf) was completed.
Conduct monitoring
Evaluate results
Trends analyses Completed checklists presented Trends analyses Completed checklists presented
Present results
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Second Edition May 2005
During this step the standard Monitoring Report (as follows) was completed.
Dept./company where monitoring will be carried out:
Water use licence issuing department
FORM NO.:
001
Monitoring date:
30 September 2004
Monitoring leader and team:
Mr Smith
Project/Programme/Activity monitored:
The monitoring of water use licences conditions for environmental soundness
Responsible manager:
Mr John
Monitoring type:
Programme Evaluation Monitoring
Indicators measured:
N/A
Purpose of monitoring:
To determine whether the Rod for water use licences issued by DWAF are in line with DWAF‟s environmental policies such as the IEMF an whether the conditions take into account environmental principles
Objectives/targets of the monitoring:
Environmental considerations
Scope of the monitoring:
All activities for all Section 21(c) and (i) water uses for which licences are granted
Main checklists to be used during the monitoring:
A checklist was compiled.
Description of the project/programme/activity to be monitored:
The water use licence conditions will be evaluated from the selected sample of water use licences that were issued during the past year.
Monitoring Technique and Evaluation of Results:
The monitoring technique included only the use of a checklist ie a desktop analysis. No parties were interviewed during the monitoring session. The checklist that was devised for this monitoring exercise was an effective and efficient tool. (In this section one may describe any changes that will be made to checklists for future monitoring). The percentage of non-compliance was determined by understanding which RoD gave a negative (non-compliance) to the questions of the checklist.
Description of non-compliance noted during the monitoring: (Was a non-compliance report completed?)
The completed checklist shows which licences have not complied with certain requirements.
List of supporting documents:
Completed checklist; Conditions of RoD issued in the last year for all S21(c) and (i) water uses.
Recommendation and Conclusions:
The existing policy for determining appropriate water use licence conditions requires adjustment, as it is not effective enough to allow DWAF to reach its environmental goals and targets for water use. (Descriptions of proposed adjustments should be written into the non-compliance report‟s corrective action section). This forms part of Step 8.
Signed/date: Monitoring leader:
Responsible manager/licence holder
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Second Edition May 2005
The eighth step is decision-making. As previously mentioned, decision-making in
monitoring will involve relatively small corrective measures to solve the problem,
though with Programme
Evaluation Monitoring, more
strategic corrective action
would be required. In this
example it is likely that the
policy for determining conditions for water use licences will need to be adjusted.
NON-COMPLIANCE AND CORRECTIVE ACTION REPORT
COMPANY/DEPT.:
REPORT NO.:
Site/Project/procedure/
programme monitored:
As in monitoring report
Monitoring leader:
As in monitoring report
Date:
1. Non-compliance ascertained in during monitoring:
A number of water use licence conditions were not included in several water use
licences in the sample (see completed checklist for details).
Confirmation of observations made by responsible party in charge:
Confirmed by Mr John
Date:
Signature, responsible party:
2. Proposed changes, including dates for such changes:
The results of the decision-making to institute corrective action should be included
in this section. In this example, the policy adjustments that have been decided on
will be described. It is proposed that the policy regarding the conditions for water
use licences be changed to ensure that all relevant conditions are included. All
2(c) and 2(i) licences should be forwarded to the Sub-Directorate: Environment
and Recreation for review. Standard environmental licence conditions will be
determined and included in all 2(c) and 2(i) licences conditions.
Corrective actions
Strategic corrective actions Strategic corrective actions Decision - making
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Second Edition May 2005
Changes will be carried out by:
An appropriate date will be decided on by the decision-maker. For the purposes of
this example all 2(c) and 2(i) licences should be forwarded to the Sub-Directorate:
Environment and Recreation for review as from 01/01/05.
Person responsible for carrying out changes
Name:
Position:
Date:
Signature, responsible person:
3. Follow-up on change:
The changes will be followed up through continuous monitoring of the conditions of
water use licences. Next monitoring is scheduled for April 2005
Change works as intended
Change does not work as intended
- see monitoring report no.: 001
Date:
Signature, environmental manager:
The last step, step 9 involves instituting the corrective actions which are
detailed in the corrective
action section of the non-
compliance report. As the
report indicates, the dates
for completing the corrective
action will have been determined during the decision-making step, step 8. Thus step
9 will involve continuous monitoring and assessment of the monitoring results.
Section 3 of the non-compliance report should be completed as part of this step.
Corrective actions
Decision - making
Complete section 3 of non - compliance report
Completion date for corrective actions – refer to step 8
Refer to non - compliance report
Complete section 3 of non - compliance report
Completion date for corrective actions – refer to step 8
Refer to non - compliance report
IEMS Sub Series No. 1.7 EM&AP
Second Edition May 2005
APPENDIX B: WORKED EXAMPLE - AUDITING
The following is an example of a Third Party Audit (by the Auditor General) of DWAF
at a strategic level. The audit type is a compliance auditing. Evening though the
Auditor General approach to the audit is in line with the Auditing Protocol.
IEM Series Sub Series No. 1.7 EM&AG
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CHECKLISTS RELEVANT TO DWAF’S REGIONAL OFFICES AND HEAD OFFICE
Checklist name Used by Head Office Used by Regional
Office
Tools Checklists for
DWAF functions X
EIA Audit Effectiveness X
EMP Audit
Effectiveness X
EMS Audit Checklist X
Audit Checklist For
Institutional
Environmental Issues
X
Checklist for Monitoring
Forestry Performance X X
EMP Compliance
Checklist X X
Checklist for Monitoring
Pest Control of a Dam
Wall
X
Checklist for Auditing
Pest Control of a Dam
Wall
X
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Second Edition May 2005
APPENDIX C: TOOLS CHECKLISTS FOR DWAF FUNCTIONS
(For monitoring the use of appropriate tools)
WATER RESOURCE MANAGEMENT
FUNCTION POTENTIAL APPLICABLE TOOLS
WHICH TOOLS ARE RELEVANT/REQUIRED?
WHICH TOOLS HAVE BEEN USED?
NON-COMPLIANCE DETAILS AND RECOMMEN-DATIONS
Water resource infrastructure – Planning, Development and Operation
Construction, upgrading and maintenance of bulk water resource infrastructure
Guidelines for Standardised Environmental Management Plans for Water Resource Management Projects,
Environmental Implementation and Management Plan (EIMP),
Integrated Environmental Management Framework (IEMF),
Strategic Environmental Assessment (SEA),
Environmental Site Management and Rehabilitation Specifications (ESM&RS),
Social Assessment and Development Framework (SAAD),
Auditing and Monitoring Protocol for Construction Sites (Construction EM&AP).
Operations and Maintenance Guidelines for Standardised Environmental Management Plans for Water Resource Management Projects,
IEMF,
check comment at checklist
ESM&RS,
SAAD,
Construction EM&AP.
Storage of waste and water containing waste
Guidelines for Standardised Environmental Management Plans for Water Resource Management Projects,
EIMP,
IEMF,
ESM&RS,
SAAD,
Construction EM&AP.
Stream flow reduction activities
Guidelines for Standardised Environmental Management Plans for Water Resource
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Management Projects, EIMP, IEMF, EIA, ESM&RS, SAAD.
Intentional recharge of an aquifer
Guidelines for Standardised Environmental Management Plans for Water Resource Management Projects,
EIMP,
IEMF,
ESM&RS,
SAAD.
Clearing activities:
Terrestrial (chemical, biological and mechanical
Aquatic (chemical, biological and mechanical)
Vegetation and weeds
Guidelines for Standardised Environmental Management Plans for Water Resource Management Projects,
EIMP,
IEMF,
ESM&RS,
SAAD.
Policy and strategy development
Legislation and regulations EIMP, IEMF, SAAD.
National water resource strategy
EIMP, IEMF, SEA, SAAD.
Catchment management strategy
EIMP, IEMF, SEA, SAAD.
Pricing strategy EIMP, IEMF, SAAD.
Water resource protection
Resource Directed Measures: national classification system, resource quality objectives
EIMP, IEMF, SAAD.
Reserve determinations EIMP, IEMF, SAAD.
Source based controls EIMP, IEMF, SAAD.
Water conservation and demand management: Conservation plan for water resources
EIMP, IEMF, SEA, SAAD.
Controlling and regulating water use
Authorising and regulating water use
EIMP, IEMF, EIA, SEA, ESM&RS, SAAD.
Waste management (permitting waste disposal sites)
IEMF, EIA, ESM&RS, SAAD.
Setting water use charges EIMP, IEMF, SAAD.
Development of a waste discharge charge system
EIMP, IEMF, SAAD.
Authorising controlled activities
Atmospheric precipitation (Cloud seeding)
Guidelines for Standardised Environmental Management Plans for Water Resource Management Projects, IEMF, EIA, SAAD.
Irrigation with waste water Guidelines for Standardised Environmental Management Plans for Water Resource Management Projects, IEMF,
IEM Series Sub Series No. 1.7 EM&AG
Second Edition May 2005
EIA, ESM&RS, SAAD.
Power generation activity altering the flow regime of water resources (Eskom)
Guidelines for Standardised Environmental Management Plans for Water Resource Management Projects, EIMP, IEMF, EIA, SEA, ESM&RS, SAAD.
Intentional recharge of an aquifer
Guidelines for Standardised Environmental Management Plans for Water Resource Management Projects, IEMF, EIA, ESM&RS, SAAD.
Monitoring, evaluation and auditing
Guidelines for Standardised Environmental Management Plans for Water Resource Management Projects, EIMP, IEMF, EIA, SEA, ESM&RS, SAAD, Construction EM&AP, EM&AP, checklists.
WATER SERVICES
FUNCTION POTENTIAL APPLICABLE TOOLS
WHICH TOOLS ARE RELEVANT/REQUIRED?
WHICH TOOLS HAVE BEEN USED?
NON-COMPLIANCE DETAILS AND RECOMMEN-DATIONS
Water and sanitation programme via the development and implementation of water services business schemes
Environmental Impact Management System for Water Service projects (EIMS), EIMP, IEMF, SAAD.
EIA for sanitation projects (responsibility of District councils‟ management)
EIMP,I EMF, EIA, ESM&RS, SAAD, Construction EM&AP.
Water services planning and development
Construction, upgrading and maintenance of water supply infrastructure
Reservoirs
Oxidation ponds
Sewerage works
Stormwater
Outfall sewer
Pipelines
Purification works
Pumpstations
Reticulation works
Impeding and diverting the flow of water
Altering the bed, banks and characteristics of a watercourse
EIMP, IEMF, EIA, ESM&RS, SAAD, Construction EM&AP.
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Construction of on-site sanitation
Ventilated improved pit latrine (VIPs)
Urine Diversion Facilities
Septic tanks
French drains
IEMF, EIA, ESM&RS, SAAD, Construction EM&AP.
Operation and maintenance of water related activities
Disposal of waste and water containing waste
IEMF, EIA, ESM&RS, SAAD.
Controlled activities: irrigation with waste water
IEMF, EIA, ESM&RS, SAAD.
Discharging of waste or water containing waste into a water resource
Domestic
Industrial
Including treatment chemicals e.g. to clean canals
IEMF, EIA, ESM&RS, SAAD.
Water and sanitation schemes IEMF, EIA, ESM&RS, SAAD, Construction EM&AP.
Maintaining policy and strategies
EIMP, IEMF, SAAD.
Support (capacity building) EIMP, IEMF, SAAD.
Regulation and intervention EIMP, IEMF, SAAD.
Information management EIMP, IEMF, SAAD.
Monitoring and auditing
Monitoring and evaluation
Monitoring system for WSDPs
EIMP, IEMF, EIA, SEA, ESM&RS, SAAD, Construction EM&AP, EM&AP, checklists.
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FORESTRY
FUNCTION POTENTIAL APPLICABLE TOOLS
WHICH TOOLS ARE RELEVANT/ REQUIRED?
WHICH TOOLS HAVE BEEN USED?
NON-COMPLIANCE DETAILS AND RECOMMEN-DATIONS
Facilitating and supporting community forestry
EIMP, IEMF, SAAD
Development of industrial / commercial forestry sector
Small scale growers in forestry sector
EIMP, SEA,I EMF, SAAD
Managing DWAF owned woodlots
IEMF, EIA, ESM&RS, SAAD.
Support development of new afforestation both commercial and community needs
EIMP, IEMF, EIA, SEA, ESM&RS, SAAD
Policy development:
Policy and guidelines on state forest access
EIMP, IEMF, SAAD
Regulations – licences, servitudes on state forest areas
EIMP, IEMF, SAAD
Sustainable management of natural forests
EIMP, IEMF, EIA, ESM&RS, SAAD, EM&AP, checklists
Development of a Forest Resource Information System to support decision making in respect of forestry, to produce a national document on the “State of the Forests” and to monitor change on the sustainable management of forests.
EIMP, IEMF, SAAD, EM&AP, checklists
National forest type classification contributing to management planning
EIMP, IEMF, SAAD
National Forestry Inventory EIMP, IEMF, SAAD
Forest protected areas system planning – conservation targets, analysis of forest patches for conservation value.
EIMP, IEMF, EIA, SEA, SAAD, EM&AP, checklists
Fire management EIMP, IEMF, SAAD, EM&AP, checklists
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APPENDIX D: EIA AUDIT EFFECTIVENESS
NUMBER AUDIT QUESTION RELEVANT? HAS THE
TARGET /
OBJECTIVE
BEEN MET?
PREVIOUS
AUDIT
RESULTS
NON-COMPLIANCE
DETAILS AND
RECOMMENDATIONS
1 Was screening and scoping carried out as part of the EIA process? Was this completed to a suitable standard?
2 Was the EIA carried out at the correct phase in the project life-cycle (i.e. before the planning or decommissioning phases)?
3 Are the reasons for the
development clearly outlined
in the EIA?
4 Does the EIA provide enough
detail and is it adequate in
scope, to ensure that sound
decisions can be made
based on its content?
5 Is there enough information
of sufficient quality to
effectively communicate the
environmental constraints
and requirements of the
project? Has such
communication taken place?
6 Have all potential
environmental impacts been
appropriately dealt with?
7 Are all the environmental
standards, both legislated
and best practise, current
and accurate?
8 Are all the measures for
mitigating impacts, clear,
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NUMBER AUDIT QUESTION RELEVANT? HAS THE
TARGET /
OBJECTIVE
BEEN MET?
PREVIOUS
AUDIT
RESULTS
NON-COMPLIANCE
DETAILS AND
RECOMMENDATIONS
feasible, necessary and cost-
effective?
9 Have all possible alternatives
been considered in terms of
the types and severity of
potential impacts?
10 Is the baseline information in
the EIA reliable, and are the
assumptions accurate?
11 Are the environmental
monitoring and auditing
programmes appropriate and
comprehensive enough to
ensure that environmental
objectives will be met?
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APPENDIX E: EMP AUDIT EFFECTIVENESS
NUMBER AUDIT QUESTION RELEVANT? HAS THE
TARGET /
OBJECTIVE
BEEN MET?
PREVIOUS
AUDIT
RESULTS
NON-COMPLIANCE
DETAILS AND
RECOMMENDATIONS
1 Is the EMP practical and implementable?
2 Does the EMP cover all
phases of the project?
3 Does the EMP provide
enough detail for each project
phase, to ensure that the
environmental objectives are
met (e.g. legislative
compliance)?
4 Does the EMP address all
components of the
environment – biophysical
and social?
5 Does the EMP indicate who
is responsible for each
section of the plan, and what
communication channels
should be followed?
6 Are all the environmental
standards, both legislated
and best practise, current
and accurate?
7 Are all the measures for
mitigating impacts,
remedying pollution and
rehabilitation, feasible,
necessary and cost-
effective?
8 Would the implementation of
the EMP ensure legislative
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NUMBER AUDIT QUESTION RELEVANT? HAS THE
TARGET /
OBJECTIVE
BEEN MET?
PREVIOUS
AUDIT
RESULTS
NON-COMPLIANCE
DETAILS AND
RECOMMENDATIONS
compliance and adherence to
organisational environmental
policies?
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APPENDIX F: EMS AUDIT CHECKLIST
E M S a u d i t s a r e u s e d t o
c h e c k t h e p e r f o r m a n c e
o f a n E M S a g a i n s t i t ' s
o w n f o r m a t , p o l i c y ,
o b j e c t i v e s a n d t a r g e t s .
T h e f o l l o w i n g c h e c k l i s t
c a n b e u s e d t o g u i d e a n
i n t e r n a l , f i r s t p a r t y ,
E M S a u d i t .
No.
CHECKLIST QUESTION/ ISSUE RELEVANT? HAS THE TARGET /
OBJECTIVE BEEN MET?
PREVIOUS AUDIT
RESULTS
NON-COMPLIANCE DETAILS AND
RECOMMENDATIONS
1 How does DWAF identify legal requirements that are applicable to the environmental aspects of its activities?
2 Does DWAFsubscribe to any requirements, such as industry codes, business principles, or other voluntary standards, that are related to the environmental aspects of its activities?
3 Does management provide resources essential to the implementation and control of the environmental management system? E.g. specialised skills, technology and financial resources.
4 Has DWAF considered whether it will proactively communicate with interested external parties on its significant environmental aspects? What has been the outcome of this consideration? Where is that outcome recorded?
5 How does DWAF identify significant environmental aspects of the goods and services it uses? Has DWAF established procedures related to identified significant environmental aspects of goods and services it uses?
6 Does DWAF have an EMS policy?
7 Is the EMS suitably structured and are responsibilities clearly defined?
8 Does DWAF undertake training awareness and assess competence?
9 Are the channels of communication
IEM Series Sub Series No. 1.7 EM&AG
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related to the EMS effective?
10 Is documentation related to the EMS complete and appropriately controlled?
12 Are the operational aspects of the EMS suitably controlled?
13 Are emergency preparedness procedures related to the EMS in place?
14 Have the recommendations of previous EMS audits been followed?
16 Does DWAF have established and maintained procedures to identify the environmental aspects of its activities that it can control and over which it can be expected to have an influence, in order to determine those which have or can have significant impacts on the environment?
17 Does DWAFensure that the aspects related to these significant impacts are considered in setting environmental objectives and keep this information up to date?
19 Has DWAF established and do they maintain a procedure to identify and have access to legal and other requirements to which they adhere, that are applicable to the environmental aspects of their activities?
20 Has DWAF established and do they maintain documented environmental objectives and targets, at each relevant function and level within DWAF?
21 When establishing and reviewing its objectives, does DWAF consider the legal and other requirements, its significant aspects, its technological options, and its financial, operational, and business requirements, and the views of interested parties?
22 Are the objectives and targets consistent with the environmental policy?
23 Has DWAF established and does it maintain programmes for achieving its objectives and targets, including designation of responsibility for achieving objectives and targets at each relevant function and level?
24 Has DWAF established, and do they maintain a program for achieving their objectives and targets including the means and time-frames by which they are to be achieved?
25 Have programs been amended where relevant to ensure that environmental management applies to projects that relate to new development and new or modified activities?
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APPENDIX G: AUDIT CHECKLIST FOR INSTITUTIONAL ENVIRONMENTAL ISSUES
Number
Checklist Question/ Issue Frequency Relevant? Has the target
/ objective
been met?
Previous
Audit
results
Non-Compliance
Details And
Recommendations
Integrated Environmental Management (IEM) Indicators
1 Multi-lateral environmental
agreements
2 Budgetary allocation to biodiversity
conservation
3 Budgetary allocation to environmental
education
4 Budgetary allocation to environmental
research
5 Inclusion of IEM principles into
strategic planning initiatives
6 Conciliation cases
7 Voluntary adoption of environmental
management systems
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8 Voluntary use of environmental
accounting and reporting
9 Capacity for environmental
management
10 Environmental reporting by
government departments
Environmental Governance
11
Has DWAF audited its plans, policies
and programmes for adherence to the
NEMA principles?
12
For each of the following, is there a
current, adopted plan that is
integrated and aligned to the IDP?:
Air Quality, Integrated Waste
Management; Oil Spill Contingency;
Water Services Development ; plan to
provide access to basic water
services; and an Invasive Species
monitoring, control and eradication
plan.
13 Are DWAF‟s environmental
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management policies, plans and tools
aligned to the National Biodiversity
Strategy and the Bioregional Plan?
14 Has DWAF officially adopted the
Agenda 21 process?
15 Is there an approved implementation
plan for Agenda 21?
Forestry Policy
16 Regular reports to the Minister by the
NFAC
17 Regular reports by the Minister to
parliament on facts and trends in
forest management
18 Renewal and updating of NFAP by
the Minister
19 Compliance with sections 39(1) and
40(1) of the National Water Act
(afforestation permits)
20 Compliance with sections 21 and 22
of the Environment Conservation Act
(EIAs)
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21 Compliance with section 7 of the
National Forest Act (prohibition of
destruction of trees in natural forests)
22 Number of forest graduates from
forest training institutions, according
to race & gender
23 Number of refereed forest
management articles in accredited
journals from SA research institutions
24 DWAF Forestry Chief Directorate
Budget
25 Overall capital investment in forest
industry
26 Compliance by DWAF with NEMA‟s
EI&MP requirements
27 Effective participation by DWAF in
CEC
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APPENDIX H: CHECKLIST FOR MONITORING FORESTRY PERFORMANCE
This checklist can be adapted for use in various forestry related monitoring programmes.
NUMBER CHECKLIST QUESTION/ ISSUE FREQUENCY RELEVANT? HAS THE
TARGET /
OBJECTIVE
BEEN MET?
PREVIOUS
AUDIT
RESULTS
NON-COMPLIANCE DETAILS
AND RECOMMENDATIONS
Social
1 Are systems in place to control access to and use of forests, and forest managers have the capacity to monitor and ensure compliance with management systems?
2 Is an effective process implemented to enable stakeholders to have input into decisions regarding forest management, and sharing of costs and benefits of forests?
3 Is information and documentation collected and maintained on the identity, location and socio-economic characteristics of all stakeholders living in the vicinity of the forest or claiming rights to the forest?
4 What is the number of visitors per annum to forests and the proportion of forestry sites available for recreation and tourism, which are impacted unacceptably by visitors?
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5 Are appropriate mechanisms in place to identify, mitigate, resolve grievances and provide fair compensation for the impacts of forestry activities on stakeholders?
6 Does decision making around sustainable forest management reflect output from stakeholder meetings, and is there evidence of both agreements involving local communities in co-management responsibilities and actions and responses taken in forest management?
7 Do forest management plans reflect a sensitivity to the impacts of forestry on sense of place and landscape integrity and aim to reduce these impacts?
8 Is there evidence of a reasonable level of public satisfaction with forest management and information regarding forest management and outcomes of monitoring and research is accessible to all stakeholders?
9 Is there evidence of mechanisms developed to include marginalised groups, especially women, in decision making?
10 Do employment and business strategies benefit local people and
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contribute to local economic development?
11 Do people invest in their surroundings (i.e. time, effort and money) and link their and their children's future with the management of forest resources?
12 Do forests act as a contributor or detractor to local or regional identity and to the aesthetics and amenity value of a local place or region?
13 Are the impacts of globalisation and its relationship to the forestry industry monitored, with particular reference to its impact on Local Economic Development?
14 Is there evidence that forestry and the forestry industry is playing a developmental role in local and regional areas?
15 Are tenure and forest rights are clearly defined and respected?
16 Do stakeholders perceive rights of access to and use of forests to be fair?
17 Are sites of cultural, ecological, economic and religious significance clearly identified and managed in cooperation with stakeholders?
18 Do opportunities (strategies) exists for local and forest dependent
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people to receive reasonable benefits from forestry through employment, training, and other services related to forest enterprises?
19 Do effective mechanisms exists for communication, negotiation, and decision making related to forest management among all stakeholders?
20 Are strategies implemented that meets or exceeds all applicable laws and/or regulations covering health and safety of employees, their families and the broader public?
21 Are education and awareness raising activities (programmes) in place to create an increased awareness of the necessity of sustainable forest management among the general public?
22 What is the number of people dependent on the forest for subsistence uses, livelihoods and traditional and customary lifestyles?
23 What forest industry interest groups are involved?
24 What are the details regarding forest ownership and / control - Distributions in time, space and social representation?
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Environmental
25 Is there a map of natural evergreen forest (indicating forest type, ownership & conservation status)?
26 Is there a database of natural evergreen forest (indicating province, forest type, ownership, conservation status, and FMU of each forest >2 ha in size)?
27 Have the Forest Act regulations for protection of forests been consulted?
28 Is there an inventory of forest resource needs?
29 Does forest land use form part of regional and sub-regional plans?
30 Have forest types been identified and described?
31 What is the conserved proportion of each forest type?
32 Is fire controlled in the forest environment?
33 What is the ratio of recruitment of harvested species?
34 Is the viability of gene flow patterns and processes within the system maintained?
35 Do nutrient cycling processes continue uninterrupted?
36 What proportion of forest edges are in good condition (gradual or soft, & functional)?
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37 Is there a list of species in need of special protection (is maintained)?
38 What are the control measures of inappropriate resource use (harvesting, hunting, fishing, trapping, collecting, etc.)?
39 What is the status of gene pool & flow of key species?
40 What is the status of development of alternative resources (to satisfy demands for natural forest products in limited supply, i.e. through coppice systems, cultivation outside the forest)?
41 What is the level of promotion of indigenous tree species (for their economic, social and environmental value)?
42 What is the status of SEA, EIA & IEM in developments affecting natural forests?
43 What is the status of control of invasive alien species (practices, their potential facilitation of restoration of natural evergreen forest)?
44 What are the harvesting rates & levels of resource use (in relation to production rates of the forest and target species [recruitment, growth & mortality])?
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45 Is planning and monitoring of harvesting levels according to species specific biology and socio-economic cost-benefit analysis taking place?
46 What is the harvesting cycle of resource use (consider production rates, ecological requirements of target species, harvesting costs, and potential social impacts?
47 What is the level of diversified, multiple resource use?
48 What is the level of product output versus waste from harvested resources (maximizes product output and minimizes waste, such as utilising timber, branchwood & bark from harvested trees, or utilising both pulp and seeds of forest fruits, where appropriate)?
49 What are the levels of forest protection (from illegal harvesting, settlement and other unauthorized activities)?
50 Is there a documented resource use plan?
51 Is there a policy framework to guide diverse resource use (in line with national and provincial laws and regulations)?
52 Is there a statistically acceptable
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resource assessment?
53 Is there a monitoring plan for resource use impacts?
54 Is there a plan and budget for relevant ecological and socio-economic research?
55 Is there a plan and budget for appropriate training and capacity building (for acceptable resource management practices)?
56 What is the area under Forest - Indigenous Forest and Plantations (Forest type, Age class distribution, Area Temporary Unplanted, New Afforestation / Deforestation)?
57 What is the situation regarding the forest Management Systems and Audits?
58 What is the situation regarding Forest Protection - Fire, Biological organisms, pollution?
59 What is the situation regarding Biological Diversity - Type/Species distribution, Protected areas, Patch size /Edge to Area?
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APPENDIX I: EMP COMPLIANCE CHECKLIST
This checklist is to be used as a guideline, from which a checklist should be drawn up for the specific EMP.
NUMBER
EMP MITIGATION MEASURE FREQUENCY RELEVANT? HAS THE TARGET /
OBJECTIVE BEEN MET?
PREVIOUS AUDIT
RESULTS
NON-COMPLIANCE DETAILS AND
RECOMMENDATIONS
Soil
1. Topsoil to be stored
2. Manner of stockpiling soil, e.g. no compaction
3. Soil not stockpiled on drainage lines
4. No soil imports
5. Limit vehicle access over rocky outcrops
6. Don‟t use equipment displaying oil and fuel leaks
7. Removal of contaminated soils
Water
8. No development within 1: 50 year floodline
9. Don‟t impede natural water flow
10. Sedimentation control measures at watercourse crossings
11. Use of in-stream diversions when working in watercourses
12. Control of pollution entering watercourse
13. Avoid swimming and personal ablutions in watercourses
14. Use of groundwater strictly prohibited
15. Stormwater management system provided and maintained
Air
16. Speed limits on all roads on site
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NUMBER
EMP MITIGATION MEASURE FREQUENCY RELEVANT? HAS THE TARGET /
OBJECTIVE BEEN MET?
PREVIOUS AUDIT
RESULTS
NON-COMPLIANCE DETAILS AND
RECOMMENDATIONS
17. Regular dust suppression on site (roads and stockpiled soil)
18. Notification of IAPs in the close vicinity of construction
19. Inform nearby IAPs of noisy after hours work
20. No site fires allowed
Social and Cultural
21. Prevent casual access to construction site
22. Compensation for damage to property
23. Inform landowner of any planned damage to properties
24. Maintenance of photographic record of damage
25. Housing of labour force
26. All conditions binding upon sub-contractors
27. Limit construction workers access to private property
28. Inform SAPS of any crimes on site
29. Inform employees about site specific environmental risks
30. Contractor‟s employees to be clearly identifiable
Aesthetics
31. Limitation of damage to visual impressions of the area
32. Above ground structures to blend with the environment as far as possible
33. No access roads wider than four meters
34. Recording of complaints regarding site
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NUMBER
EMP MITIGATION MEASURE FREQUENCY RELEVANT? HAS THE TARGET /
OBJECTIVE BEEN MET?
PREVIOUS AUDIT
RESULTS
NON-COMPLIANCE DETAILS AND
RECOMMENDATIONS
appearance
Archaeology and Cultural Sites
35. Finds of human remains reported to the SAPS/SAHRA
36. Avoid graveyards
37. Work ceased when buried artefacts discovered
38. Fenced erected to protect archaeological sites
39. No employee access to identified archaeological and cultural sites
Flora
40. Rare flora seeds to be stored at a nursery
41. Protected plants tagged prior to construction
42. Limit felling of trees
43. Alien or invader plants to be removed
44. Documentation of damage to priority and riparian plants
45. Use of approved flora in rehabilitation
46. No damage to flora outside of works footprint
47. Grass seeding following proper procedures
Fauna
48. No poaching of animal species
49. No fishing permitted
50. Anthills not to be disturbed
51. Recording of incidents regarding disturbance of animals
52. Bird nesting sites not disturbed
Infrastructure
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NUMBER
EMP MITIGATION MEASURE FREQUENCY RELEVANT? HAS THE TARGET /
OBJECTIVE BEEN MET?
PREVIOUS AUDIT
RESULTS
NON-COMPLIANCE DETAILS AND
RECOMMENDATIONS
53. Notification of interruptions of service due to construction
54. No fences or gates interfered with
55. Protection to exposed pipelines
56. Telephone poles not interfered with
57. Complaints of damage to infrastructure recorded
58. Proper storage facilities for site requirements
59. Adequate precautions regarding traffic control
60. Appropriate signs displayed
61. Traffic to use actual development main road
Safety & Security
62. Care regarding flashover of overhead power lines
63. Protection of workers during thunder storms
64. Fire prevention measures
65. Periodic checking of open excavations
66. Perimeter fencing erected and maintained
Waste
67. Sanitation facilities to be installed on site (adequate quantity)
68. Suitable litter receptacles provided
69. Prohibition of littering
70. Waste disposal at registered landfill site
71. Chemical spills contained and cleared up
72. Vehicles serviced within designated areas on site
73. Cement mixed in allocated areas
74. Mitigation of spillage from elevated fuel tanks
Rehabilitation and Site Clearance
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NUMBER
EMP MITIGATION MEASURE FREQUENCY RELEVANT? HAS THE TARGET /
OBJECTIVE BEEN MET?
PREVIOUS AUDIT
RESULTS
NON-COMPLIANCE DETAILS AND
RECOMMENDATIONS
75. Site specific rehabilitation plan complied
76. Rehabilitation of 2 drainage lines on site
77. Access roads rehabilitated on completion
78. All construction residue removed after construction
79. Indigenous trees replanted
80. Borrow pits reshaped to even surfaces and closed off
81. Indigenous vegetation mix used in rehabilitation
82. Scarify areas compacted by vehicle movements
83. Site specific instruction regarding closure followed
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APPENDIX J: CHECKLIST FOR MONITORING PEST CONTROL OPERATIONS
The purpose of this checklist is for the highly specialised monitoring of DWAF‟s pest control operations.
NUMBER
CHECKLIST QUESTION/ ISSUE RELEVANT? HAS THE TARGET /
OBJECTIVE BEEN MET?
PREVIOUS AUDIT RESULTS
NON-COMPLIANCE DETAILS AND RECOMMENDATIONS
1 What is the objective / target of the pesticide application? When will these be reviewed?
2 What is the objective / target of the monitoring? When will these be reviewed?
3 How will the abovementioned objectives and targets be achieved?
4 What are the legal requirements regarding the proposed pesticide use?
5 Have the views of interested and affected parties planning parties been obtained? What aspects of these views must be borne in mind when carrying out the pesticide application?
6 What are DWAF‟s environmental goals regarding pesticide use? Are the targets and objectives in line with these goals?
7 Have responsibilities been allocated for each level and function relating to the pesticide application? Are all personnel suitably qualified?
8 What communication procedures are in place?
9 Is there an EMS or EMP in place?
10 Are there sufficient resources for the pesticide application?
11 What type of pesticide was used?
12 How often will the pesticide be applied?
13 What quantity of pesticide will be applied?
14 For what purpose was the pesticide developed?
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Will it be used for its intended purpose?
15 What potentially harmful substances are present? If relevant, include details about the effects of dilution and the time taken for the harmful substances to break down.
16 What are the potential effects of this pesticide? List all possible effects, including cumulative effects and effects due to potential interactions with other substances. Also list which species could be affected, how they may be affected, and what their tolerance level is for the harmful substances.
17 Were fact sheets and instructions obtained from the supplier of the pesticide?
18 Was the person appointed to carry out the pesticide application appropriately trained for the particular pesticide?
19 What safety equipment is required while applying the pesticide? Has this equipment been obtained / maintained? Has the person applying the pesticide been trained in how to use the safety equipment?
20 What are the water quality targets for the water in the dam to be treated?
21 What substances in the water (from the pesticide or its interactions) will be monitored?
22 Where are the monitoring points? Provide a map and details about why these points were chosen.
23 How often will water quality samples be taken?
24 What sampling methods will be used?
25 How will the water samples be analysed?
26 Who will analyse the water samples and what qualifications do they have?
27 How will the results of the sample analysis be presented? Will they be analysed statistically?
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28 Who will the results be presented to?
29 How will the documentation and records be maintained?
30 Are all relevant personnel aware of the potential impacts of the pesticide application, their roles, the contents of the EMP/EMS?
31 What type of reporting system is in place?
32 Have the water quality targets been met? Attach a list of the results for each monitoring point.
33 What negative impacts from the pesticide use have been identified from the water analysis? Are these impacts acceptable?
34 How will incidences of non-conformance be handled?
35 What are the procedures for implementing corrective actions? Provide documentation of any corrective actions taken.
36 What mitigation measures should be put in place to reduce the impacts of pesticide use in future?
37 What, if any, alternatives to pesticide use have been explored?
38 What were the results of alternative methods tested?
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APPENDIX K: CHECKLIST FOR AUDITING PEST CONTROL OPERATIONS
As with the checklist for monitoring pest control, this is a highly specialised checklist for auditing various pest control operations.
NUMBER
CHECKLIST QUESTION/ ISSUE RELEVANT? HAS THE
TARGET /
OBJECTIVE
BEEN MET?
PREVIOUS
AUDIT RESULTS
NON-COMPLIANCE
DETAILS AND
RECOMMENDATIONS
1 Were pesticide monitoring checklists
completed in full?
2 Were the targets set for pesticide application
and monitoring suitable? Were the targets
reviewed?
3 Were the targets / objectives achieved?
4 Was public participation carried out and were
the public‟s views taken into account?
5 Were the pesticide application projects in line
with legislation and DWAF‟s environmental
goals?
6 Were appropriate communication procedures
used?
7 Were EMSs or EMPs in place and were
these complied with?
8 Were there sufficient resources for the
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pesticide applications?
9 Was the type, quantity and interval of
pesticide application suitable? List these.
10 Was the pesticide used as intended?
11 Were details obtained regarding the harmful
substances and potential effects of the
pesticides?
12 Was information obtained from the supplier
about the pesticide?
13 Was appropriate equipment used and was it
properly maintained?
14 Were the water quality monitoring points in
suitable places?
15 Were there sufficient monitoring points?
16 Were the monitoring time intervals
acceptable?
17 Was the person appointed to carry out the
monitoring appropriately qualified? Was
suitable training undertaken? Were other
personnel appropriately qualified and
trained?
18 Were the water quality targets identified, for
different types of water use, for the
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substances to be tested?
19 Were the substances to be tested for correct
based on the pesticides used?
20 Was the person / agency who analysed the
samples suitably qualified?
21 Were water quality targets met after pesticide
use?
22 Were the water quality results appropriately
analysed and were the results presented to
the correct people?
23 Analyse the water quality results to determine
any trends.
24 Was a suitable type of reporting system in
place?
25 Were the documentation and records
properly maintained?
26 Were all personnel aware of their roles as
well as the contents of the EMS/EMP?
27 Were the water quality targets met? If they
were not met, was suitable corrective action
carried out?
28 Were mitigation measures designed to
reduce the impacts of pesticide use?
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29 Were alternatives to pesticide use explored?
30 Were the results of alternative methods
tested and appropriately analysed?
31 Were the expected cumulative impacts of
pesticide use identified? Were these
acceptable?
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