An effective environmental management system is built around effective environmental management strategies; i.e. ones that are capable of dealing with the technical and emotional nature of environmental issues, the often conflicting interests and that offer constructive ways of managing these issues.

The method for identifying environmental management strategies described here consists of the following five successive steps:

HSE meeting

Keeping track of ever changing environmental expectations from legislation, corporate standards and specific stakeholders is quite a challenge, as is the tracking of management decisions and actions following from these expectations.

I recommend compiling a set of documents designed to provide single point access to all information relating to the management of environmental issues, while providing accessible overviews of the management strategies of each environmental issue, their drivers and the associated targets, programs and tasks. A good way to achieve this is by a set of intranet pages.

Risk sources and hazards

ISO14001 does not make a distinction between risk sources and hazards, but I suggest you do. ISO causes confusion by referring to these as aspects. Environmental risk sources are the activities, processes and equipment that have the potential to cause, or contribute to, pollution; such as industrial processes and trucks. Environmental hazards are the pollution or hindrance caused by these. You can’t assess the significance of risk sources, but you can of the hazards they exhibit.

Environmental Issues

The identification of environmental aspects follows the identification of environmental risk sources and their emissions and discharges (hazards) and should result in a comprehensive list (or register) of all potential environmental impacts from which to select aspects that need to be managed.

The international environmental management standard ISO14001 provides a definition of environmental aspects, but is not very clear: i.e.: “Element of an organization’s activities, products or services that can interact with the environment”. An element of an organization’s activities could be anything from a specific activity, the use of a chemical, a piece of equipment, an environmental objective, an operational practice, a plant component, an environmental impact, a specific process, an emission or discharge, a non-routine event, etc. I have seen quite a few aspect registers. Some of these only list emissions and discharges, while others list interactions between risk sources and environmental sensitivities, but most have a mixture of the possible interpretations of ‘element’.

It proves a challenge to limit the number of environmental aspects. When listing interactions between environmental sensitivities and emissions and discharges, the number of environmental aspects can easily become unmanageable. Many environmental aspect registers are neither transparent nor practical as a result. The number of aspects can be made more manageable by grouping related interactions into issues.

Significance assessment

The significance of environmental issues is traditionally established by plotting the probability and severity of an adverse effect/event onto a risk classification chart. Mild consequence / low probability risks are generally acceptable, whereas severe consequence / high probability risks are not. Medium risks need to be reduced as far as reasonably possible. Not the presence of a hazard is assessed, but the likelihood that such a hazard translates into undesirable effects.

There are a number of problems with this way of environmental risk assessment. The first is the lack of agreement about what environmental risks are significant. What is significant to one person may well be insignificant to another. Although guidance exists for risks impacting individuals or groups of human beings, it does not for risks impacting the environment as a whole or any of its non-human components. The second problem is that the likelihood scale makes little sense when determining the significance of stakeholder concerns or of non-compliances. The third problem is that the significance of cumulative impacts cannot be determined with the traditional method.

To compensate for these flaws, I split the significance assessment process into three criteria. I systematically review each issue against three criteria to determine whether it is significant. This provides assurance that any hazard with the potential, or perceived potential, to cause significant harm to humans and/or the environment is identified and addressed. The three significance assessment criteria are described in the following sections.

MILE: M = I + L + E

Management = Impact + Legislation + Emotion

Science informed opinion (I)

Broadly, scientific criteria for significance assessment can be summarized as:

  • Demonstrable effects in the field;
  • Evidence from laboratory studies suggesting toxic effects which dispersion modelling indicates could produce effects in the field.

Findings from scientific studies are generally expressed as concentrations of pollutants at which a certain environmental effect is expected to occur. Much occurring environmental impact indicators include: NEC (no effect concentration) and LC50 (the concentration that is lethal to 50% of a certain population of organisms. In assessing the risk of a hazard, consideration must be given to its extent, magnitude, duration and reversibility, as well as the sensitivity and species rarity of the receiving environment. A lot of work has been done by other organizations in this area, especially relating to the toxicity of individual chemicals. In such work, a comparison is made between the sensitivity of the receiving environment and the expected concentration of the chemical (PEC/NEC ratio). Safety factors are applied to increase confidence. It would be devastating if areas of outstanding natural beauty would disappear or if rare animal or plant species would become extinct, and it would be even more devastating if impacts would extend to a regional or even global scale.

I rank the significance of issues from science informed opinion as follows:

Low Negligible or no discernible effects. Minor contribution to cumulative impacts.
Medium Discernible impact on local environmental quality.

Moderate contribution to cumulative impacts.

High Discernible impact on regionally important environmental sensitivities.

Significant contribution to cumulative impacts.

Science informed opinion is particularly useful in cases where an impact is (mainly) caused by a single source; e.g., the location of a windmill.

If other risk sources contribute to the problem under assessment, such as is the case in rivers and seas where the environment is impacted by a large number of different sources, it is of limited relevance, as environmental science does not discriminate between risk sources. Environmental science can answer whether a desired environmental quality standard is exceeded, but it cannot answer whether a discharge from, for instance, an offshore oil production facility is more or less acceptable than the same discharge from a merchant vessel carrying medical supplies.

The latter is a political decision, which usually translates into industry specific performance standards. In significance assessments, you should draw on science informed opinion wherever possible, and on performance standards in all other cases.

To accommodate the assessment of cumulative impacts, a ranking is included specifically for such impacts, rather than dismissing those as being of low significance.

Performance standards (L)

Relevant performance standards make up the second set of risk assessment criteria.

Performance standards may be associated with pertinent legislation, operating licences, operational consents, guidelines issued by statutory authorities, industry-wide practices and company internal standards. Impacts are deemed significant when these standards are not being met.

Performance standards are particularly useful for assessing the significance of individual contributions to local, regional and global problems that are being caused by the sum of different risk sources (cumulative impacts).

The significance of performance standards will largely be determined by the specificity of such standards. Achieving a specified discharge standard, for example, requires a higher level of priority than aligning company activities with non-specific guidance, such as an aspiration for a better environmental quality. This philosophy does not suggest that less specific guidance should not be considered; it simply means that it is of lesser significance.

Low Non-specific.
Medium Hazard and project specific.
High Performance specific or regulatory obligation.

I label any regulatory or legislative obligation as being of high significance. I place the level of significance regarding performance standards into one of three categories:

Risk perception (E)

In addition to scientific evidence and applicable performance standards, I base any assessment of environmental issues on the opinions of stakeholders.

An awareness of risk perception issues is very important in environmental management. In general terms, while the formal risk assessment is the process adopted by the scientists and the experts when facing a public health or an environmental issue, risk perception is the process dominating the judgment about such risks for the laymen and the general population (Peter Sandman, 1993).

I place the level of stakeholder concern regarding a hazard into one of three categories:

Low No issues raised.
Medium Issues raised by broad interest groups, by individuals or by businesses.
High Widely held concern in society.

Issue Characterization

In traditional risk assessments these three issue significance criteria are also used, but here they are used in a fundamentally different way. Where in traditional approaches they are used to determine IF an issue should be managed; this approach uses the significance assessments to determine HOW the issues should be managed.

Issue character refers to the nature of the significance and not to the level of significance. An issue with a high regulatory significance |Low|High|Medium| is different to one with a measurable environmental impact |High|Low|Medium| or one with significant stakeholder resistance |Low|Medium|High|.

Issue Characterisation™ provides focus to the management of environmental issues and makes it much more effective. Issue Characterisation™ is an EnvAid trademark. Copyright Jos Tissen 2003 – All rights reserved.

Abraham Lincoln

Character is like a tree and reputation like a shadow. The shadow is what we think of it; the tree is the real thing.

Issue Management

The EnvAid trademark method for drafting appropriate issue management / environmental communication strategies distinguishes between two main response options:

Impact reduction Reducing the physical environmental impact by reducing the use of resources, by reducing emissions or discharges, or by reducing noise emissions.
Risk communication Increase the acceptance of the issue by better explaining the acceptability of the issue, by challenging the motives of stakeholders or by sharing control with stakeholders.

Determining an appropriate response

An appropriate response to an issue with a |Low|High|Medium| ranking would be to physically reduce the emission or discharge that created the issue, while perhaps argue for less stringent performance standards at the same time. This is because the performance standards seem to have been driven by risk perception rather than by scientific arguments.

Impact Reduction is an appropriate response strategy if such is required to meet environmental quality standards, specific legislative requirements, or if stakeholders are particularly motivated towards impact reduction. Risk communication is an appropriate response strategy in all other cases.

Finding a balance

Environmental improvements beyond scientific necessity or legislative compliance need to be balanced against other business objectives and the societal mandate of the business or facility in question.

The key to effective environmental management lies in the correct interpretation of societal expectations and positioning the organization where it can take advantage of these.

This requires the organization to know where it stands in relation to the expectations of its operating environment. That requires an understanding of its environmental performance and its opportunities for improvement. It also requires an understanding of the expectations of its stakeholders and the reasons for these.

Issue Management™ is an EnvAid trademark. Copyright Jos Tissen 2003 – All rights reserved.