Introduction
Let’s look at monitoring that is required to determine environmental performance. Before we get started, I think we better define what monitoring means, in this context, as there are many definitions. Monitoring is an activity that is undertaken very regularly, in some organisations every day, it is usually the most frequent type of performance evaluation looking at day to day activities, rather than the system that is in place to manage them (as an audit considers and at an even higher level, a management review). This is a little pedantic but it is the definition that is commonly used in environmental management by the likes of the ISO and NEBOSH.
Legal
There are numerous reasons why an organisation may need to monitor environmental performance. Arguably, the most important is that it is a legal requirement. There are many environmental laws that are likely to require some for of monitoring such as:
- Permits/consents to discharge to the sewage system or surface water.
- Abstraction licences/permits that require monitoring of the amount of water taken from the ground.
- Monitoring the amount of greenhouse gas emissions for legal reporting requirements.
- Integrated permits that require all sorts of monitoring of raw materials, energy, emissions and wastes.
Laws and guidance to laws require careful study as they will often state much detail about how the monitoring should be undertaken such as the frequency, standards by which samples must be taken and what needs to be monitored. Indeed, in the UK many types of environmental monitoring must be undertaken using equipment and personnel that are MCERTS qualified (this is a competency and equipment reliability certification scheme). MCERTS is required so that the regulator can be sure that the monitoring data reported to them is accurate.
Organisational requirements
An organisation itself may set requirements to monitor that are voluntary in nature. They may produce a publicly available sustainability report and this will require the collection of data on all sorts of environmental issues such as waste, greenhouse gas emissions and energy consumption that may not necessarily be required by law. Additionally, a site may be part of a group and must report various sources of data to the head office, so that a full picture of the organisation’s impacts may be calculated. Many organisations will also monitor overall environmental performance by tracking a number of environmental performance indicators. These will be a big driver in what is monitored by an organisation.
Management system
The next driver is to meet the requirements of a formal environmental management system (EMS), such as those developed to the ISO 14001:2015 standard. Clause 9.1 of ISO 14001 is fairly vague as to what is required to be monitored and how the organisation decides. However, Clause 9.1.2 of the standard explicitly states that organisations must evaluate their performance against compliance obligations.
What type of monitoring that needs undertaking for ISO 14001 then will really be strongly driven by legal requirements, organisational requirements, and the need to specifically evaluate performance against legal requirements.
Documenting monitoring
I have seen many organisations develop a table that depicts what environmental monitoring they undertake. This is a useful document as it summarises what is being monitored, the frequency and standards that are used to gain data.
Final Note
You should be aware that monitoring is not auditing or management review, it is a day to day activity that does not concentrate on management reasons for conformance and non conformance, rather day to day activities. The drivers for what environmental monitoring is undertaken will vary, but will include legal requirements, organisational requirements and management system requirements.
John Binns BSc (Hons), MSc, MIEMA
John Binns BSc (Hons) MSc MIEMA is an experienced environmental tutor and consultant.