Guideline For The Preparation of Environmental Management Plans 2004
Guideline For The Preparation of Environmental Management Plans 2004
Guideline For The Preparation of Environmental Management Plans 2004
Preparation of
Environmental
Management Plans
© Crown copyright 2004
Department of Infrastructure, Planning and Natural Resources
Henry Deane Building
20 Lee Street
Sydney, NSW, Australia 2000
www.dipnr.nsw.gov.au
Disclaimer
While every reasonable effort has been made to
ensure that this document is correct at the time of
publication, the State of New South Wales, its agents
and employees, disclaim any and all liability to any
person in respect of anything or the consequences
of anything done or omitted to be done in reliance
upon the whole or any part of this document
Environmental Management Plan Guideline
Foreword
There is a reliance on the EMP to ensure that a project’s actual environmental impacts
are consistent with those evaluated in the environmental impact assessment (EIA)
process. The EMP is therefore fundamental to the EIA process and should ensure that
commitments given at a project’s planning and assessment stage are carried through
to the construction and/or operation stage.
The Guideline may also be useful to an EMP’s users as well as its preparers. Councils
may wish to use this document as a guide when requiring that an EMP be prepared as
part of a development consent. The general public may use the Guideline when
reviewing EMPs for projects or activities that may affect them.
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Contents
Glossary of Terms ii
1 Introduction 1
1.1 Background 1
1.2 What is an EMP? 1
2 Scope and Purpose 2
2.1 Purpose 2
2.2 Scope 2
2.3 Other Related Documents and Requirements 3
3 EMP Preparation 5
3.1 Why Prepare an EMP? 5
3.2 When Should an EMP be Prepared? 5
3.3 Who Should be Consulted? 5
3.4 Who Should Prepare, Certify and Approve an EMP? 6
3.5 Should an EMP be Reviewed? 6
4 Model EMP 8
4.1 Types of EMPs 8
4.2 EMP Structure 8
4.3 EMP Document Description 10
4.4 Project Size and Complexity 16
5 Role of DIPNR 21
6 Key Success Factors 22
7 Information Sources 23
APPENDICES
A Post-Approval EMP Process
B EMP Content Checklist
C Site Plan Example
D Example EMP Implementation Sections
LIST OF FIGURES
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Glossary of Terms
conditions of approval Obligations imposed on an activity assessed
under Part 5 of the Environmental Planning &
Assessment Act 1979.
conditions of consent Obligations imposed on a development assessed
under Part 4 of the Environmental Planning &
Assessment Act 1979.
construction environmental A site or project specific plan developed to ensure
management plan (CEMP) that appropriate environmental management
practices are followed during the construction
phase of a project.
construction method statement A component of a Framework EMP that
(CMS) addresses environmental management issues
relevant to a specific site and/or activity.
environmental aspect Element of an organisation’s activities, products or
services that can interact with the environment.
environmental impact Any change to the environment, whether adverse
or beneficial, wholly or partially resulting from an
organisation’s activities, products or services.
environmental management plan A site or project specific plan developed to ensure
(EMP) that appropriate environmental management
practices are followed during the construction
and/or operation of a project.
environmental management A person generally appointed for large projects to
representative (EMR) independently review, audit and endorse a
project’s environmental activities.
environmental management The part of an organisation’s overall management
system (EMS) system that includes organisational structure,
planning activities, responsibilities, practices,
procedures, processes and resources for
developing, implementing, achieving, reviewing
and maintaining the environmental policy.
environmental policy Statement by an organisation of its intentions and
principles for environmental performance.
framework EMP An overarching EMP providing environmental
management information relevant to an entire
project.
government agency NSW Government department, authority or state
owned corporation.
minister Minister administering the Environmental Planning
and Assessment Act 1979
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1 Introduction
1.1 Background
The Department of Infrastructure, Planning and Natural Resources (DIPNR) prepared
this Guideline for the Preparation of Environmental Management Plans (EMP
Guideline) to assist government agencies, contractors, developers and other
stakeholders prepare effective environmental management plans (EMPs).
The primary purpose of the EMP Guideline is to ensure a minimum standard and
consistent approach to EMP preparation. Use of this guideline will improve the
contribution that an EMP can make to the effectiveness of the EIA process and assist
in ensuring that commitments made in a project’s EIA are implemented.
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2.1 Purpose
A criticism of the EIA process is that once approval or consent for a project is obtained,
the implementation of identified environmental controls is not subject to the same
scrutiny. As a result, a project’s construction and operation impacts may not be
consistent with earlier predictions or commitments. One method of improving the
effectiveness of the EIA process is to strengthen a project’s EMP.
2.2 Scope
The EMP Guideline was prepared primarily for proponents of projects requiring consent
or approval from the Minister. It is intended to cover both construction and operation.
The Guideline may also be useful to an EMP’s users as well as its preparers. Councils
may wish to use this document as a guide when requiring that an EMP be prepared as
part of a development consent. The general public may use the Guideline when
reviewing EMPs for projects or activities that may affect them.
The scope of an EMP will vary depending on the scale and nature of a project. The
EMP Guideline is applicable to a range of projects and activities. For example it may
be used for large linear projects, such as the construction and operation of freeways, or
it may be used for smaller site-based projects or activities such as the construction and
operation of a mine or factory.
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The Minister has a consent or approval role for some projects assessed under Part 4,
and for all projects assessed under Division 4 Part 5 of the EP&A Act. Details of the
differences between these types of project can be found on DIPNR’s website
(www.dipnr.nsw.gov.au). When approving a project the Minister may impose
conditions on the approval (Division 4 Part 5 projects) or conditions of consent (Part 4
projects).
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The EIA documentation that will need to be considered when preparing an EMP may
include:
Conditions from approvals, licences and permits required from other government
agencies will also need to be considered in the EMP. These agencies may include:
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3 EMP Preparation
• define details of who, what, where and when environmental management and
mitigation measures are to be implemented
• provide government agencies and their contractors, developers and other
stakeholders better on-site environmental management control over the life of a
project
• allow proponents to ensure their contractors fulfil environmental obligations on
their behalf, and
• demonstrate due diligence.
In addition, EMPs are often required as part of tendering for projects and are essential
for some types of government projects.
The broad steps for the preparation of an EMP in relation to the post-approval process
are illustrated in the flowchart contained in Appendix A. The flowchart summarises the
implementation of environmental requirements for a project from approval or consent
through to construction, operation and decommissioning.
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During the preparation of an EMP, all relevant parties should be consulted as early as
possible to facilitate a reasoned response.
In all cases, the specific requirements arising from environmental assessment and
consultation should be established and defined as early as possible for inclusion in the
EMP.
The certification and approval requirements for an EMP should be recognised before
the document is prepared to ensure that sufficient time is allowed.
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Review timings depend on the nature and scale of the project but would typically be
undertaken:
The review process should include looking at the environmental controls and
procedures in use to make sure they remain effective. Reasons for making changes to
the EMP should be documented. A copy of the original EMP document and
subsequent versions should be kept for the project records.
The EMP should state under what circumstances an updated EMP should be re-
submitted to an approval or consent body, for review and approval. A requirement to
submit updated EMPs to the relevant authority may also be stipulated in conditions of
approval or consent.
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4 Model EMP
All EMPs should include information covering the four elements shown in Figure 4-1.
A description of information and issues that may need to be addressed under each
element is provided in Section 4.3. Figure 4-1 is also provided in the format of a
checklist in Appendix B which can be used to ensure that the EMP addresses these
common elements.
Each of the four elements may have different end users and their preparation should be
tailored to suit. Table 4-1 identifies potential end users.
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Background
Introduction
Project Description
EMP Context
EMP Objectives
Environmental Policy
Environmental Management
Environmental Management Structure and Responsibility
Approval and Licensing Requirements
Reporting
Environmental Training
Emergency Contacts and Response
Implementation
Risk Assessment
Environmental Management Activities and Controls
Environmental Management Plans or Maps
Environmental Schedules
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4.3.1 Background
4.3.1.1 Introduction
An introduction may be appropriate for large or publicly available EMPs. It can be used
to provide a brief description of the project’s background including its objectives and the
steps that led to the selected project. It could also identify the key players involved.
A project description should be provided in enough detail to define the nature and
scope of the project. It should include the following:
Location
The site location should be described and a plan indicating the location of the activities
provided. A general description of the environment of the site and surrounds would
also be useful.
Construction/Operation Activities
This section should describe how the EMP fits into the overall planning process for the
project. This will involve providing a list of the project’s environmental studies (e.g.
EIS/REF/SEE) and any approval or consent documentation.
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Any government agency or other stakeholder consultation that has been undertaken
during the preparation of the EMP should be summarised. A summary of how the
outcomes of the consultation outcomes were incorporated into the EMP should also be
provided.
This may be a point form list of what the EMP is trying to achieve. It can include
objectives that relate to general site management, special site features and best
practice environmental management. The objectives should be project specific and not
broad policy statements.
An EMP should provide a clear organisation structure for the project including the
names and positions of personnel responsible for environmental management. A
description of the roles and responsibilities of each identified person should also be
documented. The roles and responsibilities of subcontractors should also be identified.
A person should be nominated with the specific task of ensuring that the EMP is
implemented and maintained. This is generally a project’s manager or an
organisation’s environmental manager.
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4.3.2.3 Reporting
A description of the reporting requirements for the project should be provided and
include:
All employees should undergo general environmental awareness training and training
about their responsibilities under the EMP. The training should ensure that all
employees understand their obligation to exercise due diligence for environmental
matters. Employees in this instance means all people working on-site including
contractors and subcontractors.
• a site induction
• familiarisation with the requirements of the EMP
• environmental emergency response training
• familiarisation with site environmental controls, and
• targeted environmental training for specific personnel. For example, plant
operators may require specific training in dust minimisation.
The need for additional or revised training should be identified and implemented from
the outputs of monitoring and reviewing the EMP.
The EMP should nominate a contact person(s) for emergencies that will be available 24
hours a day, seven days a week, and who has the authority to stop or direct works. It
should also document the procedures to be followed in the event of an environmental
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emergency. An environmental emergency is any event that causes or has the potential
to cause material harm to the environment. These procedures need to include:
• the names and contact details (including all-hours telephone numbers) for
emergency response personnel
• response personnel responsibilities
• contact details for emergency services (ambulance, fire brigade, spill clean-up
services)
• the location of on-site information on hazardous materials, including Material
Safety Data Sheets and spill containment materials
• steps to follow to minimise damage and control an environmental emergency, and
• instructions and contact details for notifying relevant government agencies, local
councils and, if necessary, nearby residents.
4.3.3 Implementation
4.3.3.1 Risk Assessment
The type and level of risk assessment will vary depending upon the stage of a project
(i.e. whether design, construction or operation). Documents or investigations that
contain risk assessment information include:
• EIA document (i.e. EIS/SEE/REF)
• representations report
• assessment or decision report
• conditions of approval or consent
• detailed design, and
• construction methodology.
Their relevance to the EMP risk assessment would vary according to the project’s
stage. There are also several Australian standards that discuss risk assessment.
This section of the EMP should generally follow the following steps:
1) provide a list of the activities to be carried out. This should describe all project
activities including those undertaken by subcontractors or suppliers together
with ancillary works such as materials transport to and from the site and site
establishment
2) identify the actual and potential environmental impacts associated with each
activity
3) identify which environmental impacts are significant. Methods for risk
assessment should be selected that are appropriate to the project and the
existing EIA
4) use this information to design the environmental management activities, controls
and monitoring to prevent or minimise those environmental impacts
appropriately, and
5) state how often, and when, this risk assessment will be carried out.
The function of the risk assessment is not to repeat or supersede a project’s EIA or its
conditions of approval or consent. Rather it is to ensure that these are effectively
translated into actual construction or operation techniques.
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An EMP should specify all the environmental management activities, mitigation and
control measures that will be used to prevent or minimise environmental impacts. It
should include the detailed mitigation measures identified from the risk assessment.
This is usually the largest section of an EMP.
This section must assign responsibility for control measures to specific personnel and
provide timeframes for their implementation. It may also specify the monitoring
measures associated with the control measure. Where monitoring measures are
identified the EMP should state the minimum performance level or criterion to be
achieved. Quantitative criteria are preferred but this may not always be possible in
which case qualitative criteria may be used.
Environmental control plans or maps are a particularly useful on-site reference tool and
should be included in every EMP. An example is a plan (or plans) indicating the
location of the following:
Plans may also form the basic implementation section of an EMP for a specific site. An
example of an environmentally sensitive area plan produced as part of a CEMP is
provided in Appendix C.
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This section of the EMP should explain how environmental management activities and
controls will be monitored.
Details of how monitoring records will be collated, distributed and stored should also be
provided.
The EMP should describe the program and procedures for periodic auditing of the
EMP’s implementation and effectiveness. The audits should determine whether or not
the EMP was properly implemented and maintained and provide information for the
EMP review.
The audit program and procedures should cover both internal and external auditing
requirements, including scope, frequency and methods, as well as the responsibilities
and requirements for conducting audits and reporting results.
The frequency of audits should reflect the level of significance of environmental impacts
and the results of previous audits.
The EMP should define procedures for dealing with non-compliance with environmental
management controls, environmental incidents and emergencies. The procedures
should also define who is responsible and has the authority for handling and
investigating non-compliance, taking action and completing corrective and preventative
action.
This section should describe how the EMP will be reviewed; including looking at the
environmental controls and procedures to make sure they are still applicable to the
activities being carried out. It should include:
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For small projects (for example projects small in area with no complex environmental
issues) the structure of the EMP may be organised using checklists or a site or issues
based format. For large projects (for example involving multiple sites and/or complex
environmental issues) there are a range of EMP formats. These could be based on
each stage and/or each site.
Whichever EMP format is used the documentation should be as short and simple as
possible, to facilitate easy use in the field, and provide practical and accessible
information. Wherever possible, plans and/or checklists should be used in preference
to written descriptions.
Example of Environmental
Size of Project Format of EMP Management Activities and
Controls section of EMP
A template EMP may include much of the generic information required to be included in
‘Background’ and ‘Environmental Management’ elements of the EMP that is similar for
each site. Space may be provided for tailored ‘Implementation’ and ‘Monitoring and
Review’ sections (i.e. site specific information such as environmental activities and
controls, plans, monitoring and review details).
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Checklists are often developed for use during site inspections. They should include a
list of control measures to be implemented, space for indicating if the controls were
implemented and space for comments. Checklists should also be signed and dated by
the person completing the inspection.
Tables should be created for each identified environmental issue and the relevant
control measures included. The table should also include who is responsible, the
timing/frequency of implementation of controls, space for sign-off and dating to verify
implementation and sources/references. Plans should be used where practical.
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The following discussion relates to construction activity but the logic could be equally
applied in an operation EMP.
This document structure is illustrated in Figure 4-2. The following sections provide a
general overview of the structure and content of each document.
The contents of the construction framework EMP and the sub-plans and construction
method statements can vary depending on how the documents are structured. The
following outlines provide a general guide. Similarly the need for issue specific sub-
plans will depend on the project and level of information provided in the construction
framework EMP.
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Framework EMP
Document Structure
‘Background’ Element
‘Environmental Management’ Element
Risk Assessment
Matrix of issue specific sub-plans and CMSs
Program for provision of sub-plans and CMSs
Consultation requirements
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The sub-plans should contain the information in the ‘Implementation’ section of the
EMP (Section 4.3.3) and should contain information as described in Section 4.4.4.
They should include detailed information relating to environmental monitoring of the
specific issue and contingency planning for exceedances.
Separate CMSs can be prepared for specific construction sites and/or activities (such
as tunnelling, rock breaking, etc). They should include relevant information from the
‘Environmental Management’ (Section 4.3.2) and ‘Monitoring and Review’ (Section
4.3.4) EMP sections and all of the information from the ‘Implementation’ (Section 4.3.3)
EMP sections. CMSs can be as simple as a plan.
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5 Role of DIPNR
Conditions of approval or consent issued by the Minister often require that construction
or operation EMPs be prepared for a project. A further requirement may be that these
documents be approved by the Director General of DIPNR (or delegate) before the
activity occurs. In its examination of an EMP DIPNR would consider factors such as:
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Key success factors for preparing and implementing an effective EMP were identified
from stakeholder consultation during the EMP Guideline’s preparation. Table 6-1
provides a summary of the factors stakeholders thought were important components of
an EMP. These factors could be used as a further checklist of an EMP’s adequacy and
usability.
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7 Information Sources
A wide variety of information is available discussing an EMP’s content and preparation.
Details of some relevant websites are contained in Table 7-1 while relevant Australian
Standards include:
• Australian Standard/New Zealand Standard (AS/NZS) International Organisation
for Standardisation (ISO) 14000 Series (including AS/NZS ISO 14001
Environmental management systems – Specification with guidance for use)
• AS/NZS ISO 19011:2003: Guidelines for quality and/or environmental
management systems auditing
• AS/NZS 4360:1999 Risk management, and
• HB 203-2000: Environmental risk management - Principles and process.
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Appendix A
Approval or Consent
Proponent’s Decision to
Proceed
Continual Improvement
Continual Improvement
Construction and CEMP Operation and OEMP
Implementation Implementation
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Appendix B
Introduction
Project Description
EMP Context
EMP Objectives
Environmental Policy
Reporting
Environmental Training
Risk Assessment
Environmental Schedules
Environmental Monitoring
Environmental Auditing
Corrective Action
EMP Review
Note: This checklist highlights the main components of an EMP. It is not an EMP
template.
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Appendix C
DIPNR thanks Sydney Water for its permission to reproduce this “Environmentally
Sensitive Area Plan”, sourced from Sydney Water’s Priority Sewerage Program -
Jamberoo Sewerage Scheme. The plan presented in the Appendix is reduced in size
from that used by construction personnel.
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Appendix D
Note: These examples are intended to indicate broad formats and typical levels of
detail for the ‘Implementation’ section of an EMP. Detailed information relevant to
specific issues shown in the examples should not necessarily be regarded as correct.
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Signature:
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Noise
Environmental Management Control Person Timing / Frequency Completed Reference / Notes
Responsible (Initials/Date)
Ensure construction or demolition activities are restricted to the Site Supervisor During demolition SEE Section 4.11,
following hours: Consent Condition 10
- 7:00 am to 6:00 pm Monday to Friday
- 8:00 am to 1:00 pm Saturday
- No work on Sundays or public holidays
If the hours of demolition and construction activities need to be Site Supervisor During demolition Consent Condition 11
varied, ensure prior written approval is obtained from the local
council. Any request to alter construction hours should include:
- a clear justification of the need for the work
- details of the type of activity and the extended hours, and
- an analysis of the resultant noise levels at residences in the
vicinity of the site.
Before commencing work, send a letter to all residents and Environmental Before demolition Consent Condition 12
industrial/commercial users whose premises may be affected by Manager
demolition noise. Ensure the letter includes:
- hours of operation and duration of the demolition work, and
- contact details for more information and/or to register
complaints.
Ensure that all noise complaints are recorded in a logbook. Environmental During demolition Consent Condition 13
Ensure all complaints are investigated and concerns addressed. Manager
Ensure high efficiency mufflers are used on all construction Site Supervisor Before and during SEE Section 4.11
equipment and manufacturer’s noise control equipment is intact. demolition
All equipment used on site shall have evidence of compliance with
recommended noise levels outlined in AS2436, 1981.
Ensure all construction equipment is well maintained. Site Supervisor During demolition SEE Section 4.11
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