Environmental compliance audits – Norms and Standards

Posted on 13 Dec 2021

Compliance audits are used to assess and verify aspects related to or undertaken by an organisation against a specific objective. These compliance commitments can be found in various regulatory approvals such as an Environmental Authorisation (EA) or a specific management licence (related to waste, water, the atmosphere and more). The approval document sets specific legal management measures for the activity to prevent environmental harm. These measures, or conditions, must be adhered to when undertaking the activity. The competent authority requires the holder of these authorisations to ensure that these conditions are adhered to.

 

In some instances, an EA is not issued for a specific activity if the activity or a standard method is already prepared for similar undertakings. For the latter, legislation referred to as Norms and Standards are published which must be used to guide the activities as undertaken and which must be adhered to if applicable to the operations.

 

Generally, three specific Norms and Standards are referred to when mining, manufacturing and processing operations occur of which two are related to mainly waste and another to water as referred to below.

 

  • The National Environmental Management: Waste Act: National norms and standards for the storage of waste (GN 926) was developed for the purpose of providing a uniform approach to management waste storage facilities, ensuring best practice, and providing a set of minimum standards for the design and operation of waste storage facilities.
  • In similar fashion, the National Environmental Management: Waste Act: Norms and standards for shredding, grinding, crushing, screening or bailing of general waste (GN 1093) was developed to provide a uniform approach to management of waste facilities in reference to the activity listed.
  • For activities operating as a mining activity and associated operations which fall within the definition of an activity defined and regulated by GNR 704 of 1999: Regulations on Use of Water for Mining and Related Activities Aimed at the Protection of Water Resource (GNR 704), another set of norms and standards are provided.

 

GN 704 defines an “activity” as follows:

 

  1. a) any mining related process on the mine including the operation of washing plants, mineral processing facilities, mineral refineries and extraction plants, and
  2. b) the operation and the use of mineral loading and off-loading zones, transport facilities and mineral storage yards, whether situated at the mine or not,

 

(i) in which any substance is stockpiled, stored, accumulated or transported for use in such process; or

 

(ii) out of which process any residue is derived, stored, stockpiled, accumulated, dumped, disposed of or transported;

 

From the definition above operations falling within the criteria must adhere to the requirements stipulated in GN 704.

 

Norms and standards set out clear requirements for operations undertaking activities triggered, listed, or identified within these norms and standards. From the onset, organisations have a clear framework in which to operate and ensure compliance with the requirements for the specific activity without waiting for specific approval or conditions based on an Environmental Authorisation.

 

Conducting compliance audits using the norms and standards as audit criteria, can assist organisations in ensuring they comply with the specific requirements set out and / or to find fatal flaws or areas of concern where a future focus can be placed on to sufficiently ensure that avoidance, management and mitigation of environmental impacts associated with the activity is managed.