Practical Help - Initial Environmental Review

Methods that can be used to examine existing environmental management practices and procedures include

• interviews with persons previously or currently working for or on behalf of the organization to determine the scope of the organization's past and current activities, products and services,
• evaluation of internal and external communications that have taken place with the organization's interested parties, including complaints, matters related to applicable legal requirements or other requirements to which the organizations subscribes, past environmental or related incidents and accidents,
• gathering information related to current management practices such as :

1. process controls on purchasing hazardous chemicals,
2. the storage and handling of chemicals (e.g. secondary containment; housekeeping, storage of incompatible chemicals),
3. controls on fugitive emissions,
4. waste disposal methods,
5. emergency preparedness and response equipment,
6. use of resources (e.g. use of office lights after working hours),
7. vegetation and habitat protection during construction,
8. temporal changes in processes (e.g. changes to crop rotation patterns affecting fertilizer discharges to water),
9. environmental training programmes,
10. review and approval process for operational control procedures, and
11. completeness of monitoring records and/or ease in retrieving historical records.

The review can be conducted using checklists, process flowcharts, interviews, direct inspection and past and current measurements, result of previous audits or other reviews depending on the nature of the organization's activities, product and services. The results of the review should be documented so that it can be used to contribute to setting the scope and establishing or enhancing the organization's environmental management system, including its environmental policy.

It is imperative that an organisation has a clear ideas of its current position in relation to environmental management. This is essential for determining priorities for further action and for defining baseline conditions.

Therefore, it is important to assess the current environmental status of the organisation. This Initial Environmental Review (IER) is "the means by which an organisation establishes its current position with regard to the environment". This reviews is not a mandatory requirement of ISO 14001, but is suggested in ISO 14004, General Guidelines on Principles, Systems and Supporting Techniques.

The IER is not an environmental audit but a data gathering exercises. The context within which the environmental management system will be developed is both internal and external organisation. Therefore, the IER should consider both internal and external factors including both normal and abnormal operating conditions, as well as possible emergency conditions.The emphasis will be on identifying the risks associated with the environmental aspects of the organisation.

At minimum the initial environmental review should cover :

• Identification and evaluating of all the potential environmental issues and concerns arising from the operations.
• Existing management and operational practices and procedures (eg. who is responsible for waste management and disposal of hazardous waste, how are wastes stored).
• Previous environmental complaints, near misses, accidents/incidents, fines/penalties and mitigation/abatement measures.
• Legal and regulatory requirements and the status of the operation with respect to these requirements (eg. does the organisation have the required licenses and understand the obligations cotained in them).