E12 - Air quality protection
The level of effort required to meet subsequent clauses in this standard is determined by materiality thresholds, described in guidance to this standard.
Additional information on the intent/interpretation of the clause
The purpose of this clause is to define a level of risk for air impacts that the business has determined to be as low as reasonably practical (ALARP).
Refer to the Materiality Thresholds for Air Quality Impacts to determine whether or not a business is classified as “above threshold” or “below threshold” and evaluate accordingly.
Evaluation steps
[I] Ask the designated representative from the business whether or not the business has compiled an air emission inventory.
[I] Ask the designated representative from the business to walk through the operation’s air emissions inventory to determine whether or not the business is “above threshold” or “below threshold”
[D] Review the operations air emission inventory.
[I] Ask the designated business representative if prevention of a breach of applicable criteria under normal and reasonable worst case operating and meteorological conditions has been considered. Refer to clause 1.3 in the standard.
[I] Ask the designated representative from the business about current practice for identifying, characterizing and evaluating air quality protection impacts. Ask what the qualifications of the individual participating in the risk assessment must be.
[D] Review the operations environmental risk register, for air quality protection risks. Risks classified as Level III or greater require additional follow up such as a review of risk mitigation plans with assigned accountable parties and evidence of risk reduction progress tracking.
Repeat Finding
Identify, characterise and document all significant air emission sources from the operation.contaminants of concern must also be included.
Additional information on the intent/interpretation of the clause:
Each operation should prepare a basic emissions inventory. For those businesses that are “above threshold” an air emissions inventory should detail the physical characteristic of all significant emissions sources and the overall annual amount of pollutants released.
Evaluation steps
[D] Complete a desktop review the business’s most recent air emissions inventory.
[I] Ask the designated representative from the business what sources were considered and how significance is determined.
[O] Auditor should refer to notes from the orientation tour of the business and surrounding area to determine whether sources identified during the tour are included in the inventory. For those sources that the auditor believes should be on the inventory but are not, further follow up is required.
[D] For businesses that are “above threshold”, verify the air emissions inventory includes relevant characteristics for significant sources.
Repeat Finding
Characterise and document background ambient air quality and meteorological characteristics in the vicinity of the operation.
Additional information on the intent/interpretation of the clause:
Each operation should be able to discuss background air quality and meteorological characteristics. Typically, data collected by government agencies will be sufficient if representative of the region in which the business operates.
Evaluation steps
[I] Ask the designated representative from the business to articulate background air quality and meteorological characteristics for the area in which the business operates.
[D] Obtain and review documentation that demonstrates consideration of relative regional or national air quality regulations, criteria and /or license conditions.
[I] Ask the designated business representative whether or not the background air quality characteristics rely on established monitoring sites, such as a regulatory ambient air monitoring network, or other characterization techniques.
[D] If the business maintains its own ambient air quality monitoring program review the protocol by which the program was established.
[D] Ask to review a current sample of the monitoring data.
Repeat Finding
Consider and document air risks and impacts during management of change, including opportunities to avoid or reduce impact, prior to implementing a change.
Additional information on the intent/interpretation of the clause:
Changes in air emissions and air impacts should be considered in the business’ management of change protocols. For those business that are “above threshold” specific consideration should be given as to how changes in air quality impacts can be mitigated and alternatives should be considered.
Evaluation steps
[D] Complete a desktop review of the business’ management of change protocols paying particular attention to how changes in air emissions and/or impacts are evaluated.
[I] Ask the designated business representative how changes in air emissions and/or impacts are evaluated.
[D] Review a random sample of outputs from the management of change process to evaluate how changes in air emissions or air impacts are evaluated and followed up on.
[I] For those business that are “above threshold” ask the designated business representative to review a historical management of change process output that included changes in air emissions and impacts, and review documentation of how those impacts were mitigated and how alternatives were considered. If alternatives were not considered and if the impacts were not mitigated follow up is required.
Repeat Finding
Consider and document air risks and impacts as part of the technical and financial evaluation of capital projects.
Additional information on the intent/interpretation of the clause:
Evaluation reports for capital projects should address air risks and impacts.
Evaluation steps
[D] Review the business’ capital plan. Select a capital project that has gone through the evaluation process to determine if air quality impacts were assessed and documented.
[I] Ask the designated business representative how air quality impacts associated with capital projects are evaluated.
[I] If the evaluation assessment requires follow up, ask the designated business representative to demonstrate what follow up actions were taken if any.
[D] If the capital project has been implemented determine if a post investment review has been completed. If so, review the post investment report paying attention to how air quality impacts and any associated mitigation techniques were implemented and documented.
Repeat Finding
Implement an ambient air monitoring programme. Air dispersion modelling can be used to demonstrate protection of human health, environment, biodiversity and ecosystem services, when the impacts and risks are conservatively demonstrated to be negligible.
Additional information on the intent/interpretation of the clause:
All businesses must implement an ambient air monitoring program.
Evaluation steps
[D] Complete a review of the business’ ambient air monitoring program. If the business is “above threshold” the business’ program should demonstrate consideration of key receptors.
[I] Ask the designated business representative how the ambient air monitoring was established, such as the frequency, type, number and location of the monitoring.
[D] Review a random sample of monitoring results and monitor calibration records. If results seem inconsistent or if the calibration records are out of date additional follow up is required
Repeat Finding
Are actions required to be raised?
Summary