In terms of environmental management, continuous improvement and enforcement of approved authorisations as completed in an Environmental Impact Assessment (EIA) process have been slow and, in most cases, completely inexistent. To improve on this aspect, the appointment of on-site Environmental Control Officers (ECOs) has been widely applied. In South Africa, the Department of Environmental Affairs (DEA) has provided guidelines for Environmental Management Programmes (2005), in which one of the client’s responsibilities is to appoint an ECO for the entire duration of the project. The ECO has a direct link to the Project Manager in order to provide feedback with regard to all environmental matters present on-site. Contractors working on relevant projects are answerable to the appointed ECO for any non-compliance and have the responsibility to implement any mitigation measures specified in the EA or EMPr. The ECO should be qualified and competent within the field of environmental management, while the most important requirement remains the independency of the representative ECO.
ECO’s are required to monitor and report on compliance with regard to the approved EA and Environmental Management Programme. Other duties of the ECO comprise of, but not limited to:
Conduct site visits and inspections;
Ensure legal compliance;
Ensure environmental training is conducted;
Liaise with the Client and Competent Authority; and
Provide overall environmental support.
The work of the ECO ultimately results in the compilation of audit reports (weekly, monthly, or quarterly) which are subsequently submitted to the Client and Competent Authority. The audit reports focus on the status of compliance, with regard to the conditions set out by the EA and EMPr, as well as providing recommendations to improve overall environmental compliance on-site, assisting the Client in implementing Chapter 5 of the National Environmental Management Act (Act 107 of 1998).