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Pensar Environmental & Waste Management Plan
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ENVIRONMENTAL/ WASTE MANAGEMENT PLAN
(EMP)
For
Project Number: G20-010
Project Name: 215 David Low Way, Peregian Beach
Pensar Project Infrastructure Pty Ltd. ABN 49 626 424 842
8 Hockings Street, South Brisbane QLD 4101
PRINCIPAL CONTRACTOR:
Position Name Signature Date
Prepared By: Ryan Vass
Project Manager
Reviewed By: Daryl Curran
HSEQ Manager
Approved By: Michael Bissett
Director/GM
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Page 2
Environmental Management Plan
Table of Contents
EMP Review Process 3
1. Introduction 5
1.1 Purpose of this Plan 5
1.2 Pensar Environmental Management System Requirements 5
1.3 Control of Copies 5
1.4 Statutory Requirements 5
1.5 Project Scope 6
1.6 Project Environmental Objectives and Targets 6
1.7 Environmental Aspect Identification & Risk Assessment 7
2. Project Specific Data 7
2.1 Measuring Equipment 7
3. Site Environmental Management Requirements 8
3.1 Environmental Control Measures 8
3.2 Consultation with other Stakeholders 8
3.3 Hazardous Substances 8
3.4 Training 9
3.5 Site Access 9
3.6 Erosion and Sediment Control Plans 9
3.7 Water Management 10
3.8 Waste Management 10
4. Monitoring and Review 12
5. Incident and Emergency Management 12
5.1 Incident Reporting and Investigation 12
6. Document Control (for template) 15
List of Appendices
Table of Environmental Aspects/Environmental Risk Assessment 13
Significant Environmental Aspects and Impacts 13
Environmental Management Procedure 14
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Environmental Management Plan
EMP Review Process
The Environmental Management Plan (EMP) must be reviewed after any of the following:
• Changes to the scope of works or if there are any:
• Changes to the design that create additional safety risks;
• Changes to relevant legislation, Codes of Practice or industry standards;
• Changes to the Client’s Environmental Systems;
• Environmental alerts from external bodies that are relevant to the scope of works;
• After Environmental incidents, not limited to the project, where internal system changes are
implemented.
Any additional risks must be documented on the project risk assessment (WHS-RA-003), which is filed
with the WHSMP.
The Project Manager (PM) is responsible for ensuring that any changes to the EMP are communicated
to the members of the Project Management Team (PMT) and relevant workers and subcontractors.
This communication is to be recorded on the toolbox meeting record (WHS-FRM-014) and kept in: Folder
9: Minutes (Refer to PMP, Section 1.3 Folder Structure: Site Office”)
EMP REVIEW
Changes Reviewed
Project Relevant
Rev Reason for Changes made workers
Date Mgt. Status
No. Review and sub- By
(if applicable) Team
contractor whom
Y/N Y/N
A 25/11/201 Initial Draft – Nil – Initial Draft Y N/A RV Closed
9 Issued for
Review
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Environmental Management Plan
1. Introduction
1.1 Purpose of this Plan
This plan is a component of the Integrated Management System (IMS) for 215 David Low Way, Peregian
Beach and defines the manner in which Pensar will manage its environmental obligations as Principal
Contractor for the project. As a component of the IMS, the plan should be read in conjunction with the
Project Management Plan (PMP), WHS Management Plan (WHSMP), and the Quality Management Plan
(QMP) where applicable.
The plan addresses the statutory and other requirements listed at section 1.4 below.
1.2 Pensar Environmental Management System Requirements
The Environmental Management Procedure (ENV-PRO-001) defines the role of this EMP in the
company’s Environmental Management System, and in particular how this is to be implemented on all
projects.
Environmental objectives for this project and management controls to be implemented are defined in this
EMP.
The Environmental Management Procedure is located in Appendix C
1.3 Control of Copies
This document is the only copy prepared and approved. It is for use on the project site. The Foreman is
responsible for maintaining the PMP folders (including this EMP) in good condition, and for addition of
readily retrievable records as the project proceeds.
Uncontrolled copies of this document will be prepared as warranted (e.g. for reference by clients or their
representatives). Such copies will not include project records.
Revisions of this EMP will be prepared as warranted by project circumstances. As necessary, parties who
have been provided with copies of the original/previous version will be informed of changes to the EMP
Constraints and Risk Analysis
1.4 Statutory Requirements
This plan addresses the requirements of the following references:
Environment Protection & Biodiversity
Environmental Protection Act 1994 (QLD)
Conservation Regulations 2000
Environment Protection & Biodiversity
Waste Reduction and Recycling Act 2011
Conservation Act 1999
Noise Conservation (Administration)
Nature Conservation Act 1992
Regulation 2006
Aboriginal Cultural Heritage Act 2003 Queensland Heritage Act 1992
Vegetation Management Regulation 2012 Queensland Heritage Regulation 2015
Vegetation Management Act 1999 Soil Conservation Act 1986
Nature Conservation (Wildlife Management)
Biosecurity Regulation 2016
Regulations 2006
Natural Assets Local Law 2003 Vegetation Management Act 1999
Public Land and Council Assets Local Law 2014 Vegetation Management Regulation 2012
AS14001: 2004 ‘Environmental Management
Environmental Protection Regulation 2008
Systems’
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Queensland’s Waste Reduction and
Environmental Protection (Air) Policy 2008
Recycling Strategy 2010-2020
Environmental Protection (Noise) Policy 2008 Environmental Protection (Water) Policy 2009
Biosecurity Act 2014 Water Act 2000
Water Regulation 2016
In addition to the above requirements, the following references have also been addressed in development
of this plan:
• Pensar Integrated Management System Manual (IMS Manual).
• Industry Codes of Practice
• Advisory Standards / Codes of Practice (e.g. ‘Best Practice Erosion & Sediment Control for
building & construction sites’ Nov 2008 – International Erosion Control Association of
Australasia)
• Local government specific laws
• Client contract and/or site specific requirements.
• Pensar aspects and impacts table
- As Principal Contractor, Pensar is responsible for ensuring that all persons on site maintain at all
times a responsible attitude towards environmental management and always act in a manner that
strives to prevent significant environmental impact, and should environmental harm occur,
minimizes the potential for environmental impact – this includes all Pensar employees, employees
of subcontractors and suppliers, and visitors.
1.5 Project Scope
The project scope is defined in the Project Management Plan (PMP), section 2.1
The scope of works for 215 David Low Way, Peregian Beach, includes all design related aspects from
initial conception to issuing of for construction plans, production of as constructed documentation and
final submission to Council (including plan sealing and cadastral survey set out and registering of
properties). In summary the design aspects includes;
• Full Civil Construction design (bulk earthworks stormwater, sewerage, water reticulation,
roadway, etc.)
• Electrical Design including conduit alignment, pit locations, cabling details, location of pad mount
transformers, property connections any additional electrical fixtures;
• Landscaping Design including all revegetation works in accordance with Sunshine Coast
Regional Council’s Development Approval.
1.6 Project Environmental Objectives and Targets
The following environmental objectives and targets apply to this project:
• There will be no significant environmental impact. All environmental aspects and impacts are
identified, and control measures implemented, to minimise the potential for environmental harm.
This is achieved by using the Table of Environmental Aspects / Environmental Risk Assessment
(Appendix A).
• All personnel on the project site at any time are to be fully inducted and adequately briefed on
company and site specific environmental requirements. This includes employees of sub-
contractors and suppliers.
• There will be NIL environmental infringement notices.
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• Pensar vehicles are to ensure “Idling time” is kept to a minimum. All vehicles visiting the site are
to turn their engines off once parked.
• Waste will be recycled where possible.
• Where an Erosion and Sediment Control Plan (ESCP) has been developed for the project, its
compliance will be maintained.
• Any environmental incidents (including breaches) will be reported and discussed. Causes will be
identified so that preventative measures can be put in place.
• Causes of environmental incidents or breaches are identified and acted upon within 5 working
days of an incident or breach arising (and where appropriate, before the relevant work activity is
recommenced).
1.7 Environmental Aspect Identification & Risk Assessment
All relevant environmental aspects are identified, their potential for causing environmental harm is
assessed, and control measures that minimise the potential for environmental harm are defined and
effectively implemented. This information is captured in:
Appendix A: Table of Environmental Aspects / Environmental Risk Assessment
The Risk Management Procedure (WHS-PRO-003) defines the process to be used for identifying the
environmental aspects involved with all work activities in a project and for assessing the level of risk and
potential for environmental harm associated with each environmental aspect, so as to facilitate definition
and implementation of appropriate control measures for every component of each work activity.
The Risk Management Procedure also defines the processes used for involvement of all relevant
personnel (including sub-contractors) in definition and implementation of control measures, and for
monitoring and review to ensure effective implementation of them.
The following tools have been used in accordance with this procedure to identify high risk construction
activities and significant environmental aspects and to define all necessary control measures for this
project:
•Hazard Identification & Risk Assessment – Projects Form (WHS-FRM-015)
•Risk Assessment (WHS-RA-004) Risk Assessment - Projects and the Risk Assessment
Calculator in it.
The completed forms are filed as per “Folder Structure: Site Office” (Section 1.3) of the Project
Management Plan.
All significant environmental aspects with potential for causing environmental harm are listed in:
Appendix B:Significant Environmental Aspects and Impacts
The aspects are hyperlinked to relevant legislation listed in
https://www.enviroessentials.com.au
Pensar does not communicate externally its significant environmental aspects unless directed by the
Client or an Authority.
2. Project Specific Data
2.1 Measuring Equipment
The equipment listed below is to be used on this project for measuring environmental parameters in
accordance with the relevant control measures:
- Environmental Measuring and Testing Equipment will be utilised as required and will be assessed
on a case by case basis.
Measuring equipment is to be used and calibrated in accordance with the principles defined in the
Management of Plant and Equipment Procedure (PLT-PRO-001) and in accordance with the
manufacturer’s instructions. Specialist equipment calibration agents are engaged as required for
calibration of this measuring equipment.
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3. Site Environmental Management Requirements
3.1 Environmental Control Measures
Work procedures are defined for all high risk construction activities on this project (including those
activities with potential for causing environmental harm)
These work procedures are documented SWMS of the processes to be used, and/or project specific work
procedures. They may include control measures and responsibilities for specific work activities, including
involvement of subcontractors, equipment, machinery and materials; and are intended to ensure orderly,
efficient, environmentally responsible and safe execution of the relevant work activities.
The following environmental documents apply to this project:
• Project-Specific SWMS.
• Project Specific Work Instructions
• SWMS supplied by sub-contractors and which complement Pensar documentation
These work procedures contain all of the control measures defined following environmental aspect
identification and risk assessment processes addressed in section 1.8 above.
Where sub-contractors are involved in a work activity, relevant Pensar /project SWMS and/or work
procedures incorporate or complement the sub-contractors’ own SWMS. (Sub-contractor Safe Work
Method Statements are maintained in section 3.7 ‘Project Documents’ of the PMP with the relevant
Pensar/project work procedures.)
3.2 Consultation with other Stakeholders
The Project / Construction Manager is responsible for ensuring that adjoining landholders and/or other
parties are consulted and/or informed as necessary in definition of work processes and control measures
(e.g. in relation to any significant environmental aspects associated with the project site or the proposed
work activities).
Appendix G of the WHSMP contains details of all contacts for this project including:
• Emergency contacts
• Project personnel
• Client and client representatives
• Other community and stakeholder parties.
A copy of the “Project Contact Details” must be prominently displayed on the wall or notice board of the
project site office.
Consultation has included the following aspects:
- Definition of work processes that minimise potential for environmental impact – avoid potential for
environmental harm in relation to each stakeholder’s interests.
- Agreement on means to publicise environmental management controls and signage.
- Identification of requirements where policing and/or close monitoring is warranted.
3.3 Hazardous Substances
The project management team are responsible for managing the SDS system on their projects. This
process is administered using the ChemWatch system and is detailed in the Hazardous Substances
Procedure (WHS-PRO-012). This is located in Appendix F of the WHSMP.
Note:
• Guidance on safe and environmentally responsible disposal of hazardous substances is
provided in the SDS for each substance
• A Risk Assessment for each substance must be completed on form: Project SDS Risk
Assessment (WHS-RA-002)
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• As necessary, additional procedures and/or control measures must be defined for site
specific circumstances.
3.4 Training
Environmental training requirements may be identified in a number of ways e.g.:
• During site induction
• In Activity and/or Pre-start Briefings
• In Tool Box meetings
• While observing work practices
• Through investigation of incidents
• Project/activity reviews and audits.
Any employee who identifies any such training requirement (either for himself or another employee) is
required to advise the Foreman or HSEQ Manager who then collaborate in determining the content,
format and priority for the necessary training in the light of particular employee/project circumstances.
3.5 Site Access
Signs are to be erected at the project entry points to inform all visitors of the defined site access
requirements. Temporary fencing and/or barricades will be constructed to ensure that access is
controlled.
Only one main access route to and from the site is to be used if possible to restrict unauthorised access
and to cause as little disruption as possible. Only one access route to a stockpile site is to be used (if
applicable).
Shake down pits or other approved facilities are to be used at site entry points to minimise the transfer of
waste and dust from the site to other roads.
Boundary signage is to be erected at regular intervals for the perimeter of the project site – ‘Danger
Construction Site do not enter’ as a minimum. Barrier fences or bunting is to be placed around the
boundary of the site when portable fencing is not practical.
Walkways are to be closed and appropriately signed when any activity on or near them imposes an
unacceptable risk to the public.
The Foreman will arrange for either a personal visit to all neighbouring houses or arrange for a letter to be
placed in each neighbour’s letter box informing them of the nature of the project, expected duration and
provide contact numbers for use in an emergency, enquiry or complaint.
All workers on site are to direct any visitors to the site office or the Foreman. All site visitors are to be
addressed in a polite and professional manner.
Complaints are to be addressed in a timely manner by the Foreman and/or the Project Engineer. Any
worker or subcontractor confronted by a complaint is to be courteous and let the complainant know that
they will pass the concern onto the Foreman / Project Engineer.
Where continual unauthorised access is occurring, the Local Police are to be informed of the occurrence
and details of the dangers are to be conveyed. This is to be done by telephone in the first instance then
followed up by a letter.
Vandalism and graffiti is to be reported to the Police.
3.6 Erosion and Sediment Control Plans
Generally, the following guidelines will be implemented:
• silt fencing will be installed downhill of all excavations and stockpiles,
• if field inlet pits are within the excavation area, they will be covered with silt fence,
• if gully pits are within the excavation area, they will be protected with a silt sock upstream,
• if spoil is being lifted over gully pits, they will be covered with silt fence, and
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• where overland flow paths cross an excavation area or where significant volumes of water
is release, hay bales will be placed and staked.
3.7 Water Management
The sources of water that have been considered in this plan and will be managed are:
• Rainwater
• Groundwater
• Potable water (from main)
Should rainwater and groundwater inundate excavations, the excavations will be dewatered using a
submersible or flex-drive pump. The pump discharge will be directed through at least 10m of grass. If
screening through grass is not an option, the water shall be first transferred to a holding tank. The holding
tank should then be decanted and discharged to stormwater.
Potable water shall be either discharged across grass or into kerb and channel.
3.8 Waste Management
The EMP will adhere to all regulations around waste management on site including:
• No unauthorised burning of waste or litter,
• No burial of waste on site and
• Provision of bins with lids in all common areas that are to be serviced regularly.
Waste streams will be separated on site. As required, green waste will be mulched and reused on-site.
Materials such as paper, plastic, glass and steel are to be separated for recycling. Construction waste will
be reused on site, where appropriate.
The Foreman / Site Supervisor will be informed of the proposed licensed waste facility to be used for the
works. Refer to below for further detail relating to waste disposal and recycling methodology during the
demolition works:
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4. Monitoring and Review
Risk Management Procedure (WHS-PRO-003) defines the scope of monitoring and review activities to
be undertaken on all Pensar projects.
• A systematic process is to be used to ensure the implementation and effective operation of
this Site Environmental Management Plan, including all relevant procedures and those of
sub-contractors.
• The following review mechanisms are to be routinely undertaken:
• All workers look out for each other – ensure environmentally responsible work practices at
all times.
• Site Safety & Environmental Inspections by the Foreman recorded on form: Weekly Site
Safety & Environmental Inspection Record (WHS-FRM-013)
• Regular check of SWMS implementation – use SWMS checklists.
• Environment Audits by the HSEQ Manager / General Manager / Director: Monthly Project
Compliance Audit (Q-FRM-011) and /or via iAuditor.
• Periodic inspections by the Project Engineer and/or a client appointed environmental
representative.
• Internal audits.
Where site/project requirements &/or circumstances dictate, project specific monitoring and review
activities are to be inserted here.
Environmental Management Audits will be undertaken as warranted – e.g. to assess:
• Application and effectiveness of SWMS
• Compliance with this EMP and/or IMS procedures
• Compliance with client project environmental management requirements.
Environmental Management Audits shall be filed in “Folder 8 – “Quality” as per section 1.3 of the PMP.
5. Incident and Emergency Management
5.1 Incident Reporting and Investigation
Procedures and responsibilities for reporting and investigating incidents (including environmental
breaches) are defined in the following procedures:
• Environmental Management Procedure (ENV-PRO-001) (Section 12)
• Incident Reporting Procedure (WHS-PRO-001)
Original Incident Reports (on form WHS-FRM-027) are to be forwarded to the HSEQ Manager as defined
in Incident Reporting Procedure Copies of Incident Reports are to be maintained (together with an
appropriate Incident Register) in Folder 8 (as detailed in Section 1.3 of the Project Management Plan)
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Table of Environmental Aspects/Environmental
Risk Assessment
Further information to be provided at Operational Works approval
Significant Environmental Aspects and Impacts
Further information to be provided at Operational Works approval
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Environmental Management Procedure
.
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ENVIRONMENTAL MANAGEMENT PROCEDURE
ENV-PRO-001
REV: 4
Position Name Signature Date
Prepared By: Daryl Curran 18/09/2018
Reviewed By: Samantha Samuels 18/09/2018
Approved By: Daryl Curran 18/09/2018
Page 16
Environmental Management Procedure Table of Contents 1. Introduction 3 2. Environmental Obligations and Policy 3 3. Appreciation of Legal and Other Requirements 3 4. Environmental Management Framework 3 5. Consultation, Communication & Reporting 4 5.1 Consultation 4 5.2 Communication 4 5.3 External Stakeholders 4 5.4 Reporting 4 6. Identify Environmental Aspects of Company Operations 5 7. Assessment of Risk & Potential Environmental Impacts – Projects 5 8. Environmental Control Measures 6 9. Site Environmental Management Plan 6 10. Monitor & Supervise Environmental Control Measures 7 11. Environmental Training for a Specific Project 8 12. Incident Reporting and Environmental Breaches 8 12.1 Project Incidents or Breaches 8 12.2 Non-Project Incidents or Breaches 9 13. Emergency Preparedness 9 14. Evaluation of Effectiveness – Environmental Assessment & Control Measures 9 15. Assessment of Compliance with Environmental Obligations 10 16. Reference Documents 10 Document Control 11 Document Number: ENV-PRO-001 Date: September 2018, REV: 4 Page 2 of 11
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Environmental Management Procedure
1. Introduction
Pensar has engaged this procedure to ensure that our business and our project sites are operated in an
environmentally responsible manner in accordance with the requirements of the Environmental Protection
Act 1994 (QLD). We aim to prevent the occurrence of any significant environmental impact.
The potential for significant environmental impact is identified for each project and for all other operations
of the company – and:
• Impacts of each significant aspect are identified
• Control measures that minimise environmental impacts are defined, including actions to
remediate the effects of any such impacts, and
• Appropriate action is taken to implement and assess the effectiveness of these control measures.
2. Environmental Obligations and Policy
The Environmental Protection Act places an obligation on Pensar to ensure that its operations are
conducted in an ecologically sustainable manner that encompasses:
• Defining environmental objectives
• Developing effective environmental strategies
• Implementing its environmental strategies integral with efficient resource management, and
• Ensuring that no significant environmental impact is caused.
These obligations are addressed as follows:
• Defining an environmental protection policy – refer Environment Policy
• Identifying environmental aspects of company operations and defining controls that minimize the
potential for causing environmental harm
• Determining those aspects that have or can have significant impact on the environment.
• Setting objectives and targets to fulfil the commitments established in the Environment Policy and
in the defined control measures.
• Establish waste management and materials recycling arrangements, including minimization of
waste creation, recycling of used materials as far as possible and responsible disposal of waste.
• Promote responsible environmental practices by all employees (including other project personnel
– suppliers, sub-contractors, etc.)
3. Appreciation of Legal and Other Requirements
The General Managers / Directors and the HSEQ Manager are responsible for ensuring that an adequate
appreciation is maintained of the following reference materials:
• Legislation and regulations (national, state and local governments).
• Codes of Practice and guidelines (government and services authorities).
• Client requirements.
The scope of and means for obtaining the necessary information are defined in the procedure:
Maintaining Appreciation of Legal and Other Requirements (GRP-PRO-005)
4. Environmental Management Framework
This procedure defines the framework for implementation of the company’s Environment Policy and
objectives. It is based on:
AS/NZS 14001: 2016 Environmental Management Systems – Requirements with Guidance for Use’
and defines processes and responsibilities for:
• Identification of significant environmental aspects associated with any of the company operations
and definition of controls that minimise their potential impacts
• Development of project site environmental management plans and work method statements
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• Induction and training
• Incident reporting and emergency processes
• Management review of environment policy and objectives, including the effectiveness of defined
procedures and control measures.
Overall the company’s environmental goals and objectives are defined in the context of guiding principles
in the Environmental Policy. The GM’s / Directors and the Construction Manager are responsible for
defining specific operational and project environmental objectives, performance targets and dates for their
achievement.
Regular reports on progress towards achievement of environmental objectives and targets are prepared
by the HSEQ Manager for consideration at Board and Management Review meetings.
5. Consultation, Communication & Reporting
The General Managers / Directors are responsible for ensuring that effective processes for consultation,
communication and reporting are maintained throughout the company.
5.1 Consultation
Mechanisms for consultation with employees, including sub-contractors, on environmental matters
include:
• Discussion with employees regarding feedback on environmental aspects, including
consideration of findings from review of the effectiveness of measures defined / implemented for
minimisation of environmental impacts
• Interactive discussions in toolbox sessions on project sites and other employee briefing sessions
• Involvement of employees (as necessary) in the process of customising generic Work Method
Statements (WMS) and Work Procedures (WPs) as part of project and activity planning, and
• Interactive discussions on the effectiveness of defined procedures and control measures (e.g. in
IMS training sessions).
5.2 Communication
The processes used for communication of environmental matters include:
• Face-to-face interaction between all levels of management and employees
• Inductions and activity briefing sessions
• IMS Bulletins
5.3 External Stakeholders
The Project Manager / Project Engineer is responsible for ensuring (as necessary) adequate interaction
with external stakeholders about project environmental aspects and how they are to be managed,
generally by consultation and communication about the following:
• Any potential for significant environmental impact during or as a consequence of the project
• Control measures to be implemented in order to avoid significant environmental impacts and/or to
minimize the frequency and/or severity of those impacts.
Pensar does not communicate externally its significant environmental aspects unless directed by the
Client or an Authority
5.4 Reporting
Records for each of the above communication processes are prepared by the employee(s) responsible
for the respective activities. Various reviews of environmental management are also recorded:
• Daily Supervisor Sheet (GRP-FRM-002)
• Weekly Site Safety & Environmental Inspection Record (WHS-FRM-013)
• Weekly Site Safety & Environment Inspection Record – Building (WHS-FRM-033)
• Incident Report - Part A (WHS-FRM-027A)
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• Monthly Project Compliance Audit (Q-FRM-004)
• Minutes of meetings, correspondence with client, authority and/or community representatives
and/or diary notes as necessary.
6. Identify Environmental Aspects of Company Operations
The General Manager/Director is responsible for review of the operations of the company as well as any
relevant regulatory requirements and for identifying any environmental aspects that have potential to
cause environmental harm.
The Construction Manager or Project Manager is responsible for all project operations and for ensuring
that any environmental aspects that have potential to cause environmental harm in accordance with
clause 7 below are identified. Employees, suppliers and sub-contractors are included in these
assessments as necessary.
The Director / General Manager and HSEQ Manager are responsible for identification of any
environmental aspects pertaining to all non-project operations of the company and for definition and
implementation of control measures for minimising the potential for environmental harm from these
operations.
7. Assessment of Risk & Potential Environmental Impacts –
Projects
The Construction Manager / Project Manager is responsible for ensuring that any employee given the
task of identifying environmental aspects and their potential for causing environmental harm is competent
and experienced in identifying them. The list of environmental aspects while prepared prior to the
commencement of works can be added to at any time during the works following suggestions from staff or
employees (e.g. following toolbox meetings, as a result of a regular site inspection, client/representative
instructions). These assessments also consider any relevant regulatory requirements.
If the project or site circumstances warrant, the Project Manager / Engineer shall engage e xpert
assistance in identifying environmental aspects and assessment of their potential for causing
environmental harm.
Initial identification of environmental aspects and potential for causing environmental harm on projects
sites is the responsibility of the Estimator – determination of environmentally responsible working
methods is a key requirement in the process used to determine the tender price (for individual work items
and for the overall project); this includes approval as warranted by the General Manager/Director or the
Construction Manager.
The Project Manager and/or the Project Engineer are responsible for ensuring that all projects are
reviewed for possible environmental issues prior to commencement. This review forms part of project
planning and is recorded in the Pre-start Checklist (WHS-FRM-004). This task may be delegated to an
outside consultant if necessary.
Risk Management Procedure (WHS-PRO-003) defines the approach taken for risk management in
planning and execution of all projects. In particular, the Project Manager and/or the project engineer is
responsible for identification of environmental aspects and potential for causing environmental harm, and
for determination of control measures for minimising environmental harms well as activities for ensuring
their effective implementation.
The Hazard Identification Form (WHS-FRM-015) & Risk Assessment – Projects Form (WHS-RA-004) are
used to assist with identification of all work activities that warrant implementation of control measures
including the list of WMS and WPs to be applied. This form facilitates a planned approach to
determination of the applicable WMS and WPs for all relevant work activities in a project, and is utilised in
a manner that progressively shows the status of “sign-off” for each, including –
• Applicable Pensar and/or subcontractor WMS/WPs
• Any project specific WMS/WPs to be prepared
• Additional controls that are to be applied (usually forms/checklists in the Pensar IMS) – e.g. Sub-
Contractor SWMS Compliance Review (WHS-FRM-040), Sub-contractor SWMS checklist (WHS-
FRM-012), Permit to Excavate (WHS-FRM-010)
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• The Risk Assessment – Projects form (WHS-RA-004) and the Risk Assessment Calculator in it
for each work activity added to the above list for specific projects, and for work activities where it
is necessary to assess whether or not standard control measures (e.g. Work Method Statements,
Work Procedures) are adequate for the project circumstances.
The Project Manager and/or the project engineer consult as necessary with the estimator and/or the
construction manager in the above assessment and in preparation of the Site Environmental
Management Plan (EMP),or Minor Works Combined Management Plan (MWCMP), to ensure that all
provisions for management of environmental aspects included in the derivation of the tender price are
correctly interpreted and accommodated in the EMP / MWCMP.
Project/activity specific work method statements are defined by the project manager and/or the project
engineer and incorporated in the Site Environmental Management Plan / MWCMP. The company
standard Safe Work Method Statements are adapted as necessary. This is undertaken in consultation (as
warranted) with:
• Supervisors, foremen, Leading Hands, plant operators and workmen, sub-contractors and
suppliers.
• Other relevant parties (e.g. Energex, QR, Main Roads, Local Authority).
In the event that the client provides specific requirements for control of environmental aspects (e.g. in the
form of erosion & sedimentation control plans), the project engineer and foreman shall incorporate these
in the above considerations.
8. Environmental Control Measures
Control measures are defined as the output from the environmental risk assessment processes defined in
clause 7 above to ensure that the potential for project/operational activities to cause environmental harm
are minimized – these shall generally be in the form of:
• Work Method Statements (WMS)
• Work Procedures (WPs); or
• Specific instructions.
Control measures include as necessary:
• documented procedures, instructions or work activity methods;
• identification of acceptable operating criteria;
• processes for regular monitoring of environmental aspects and implementation of control
measures;
• employee briefing (e.g. induction or training sessions);
• Client instructions (e.g. erosion & sedimentation control plans).
If warranted, requirements for monitoring the implementation of environmental control measures will be
defined in a Monitoring Plan. In particular, Safe Work Method Statements (SWMS) include definition of
requirements for continuously monitoring implementation of the various control measures defined in them.
Each SWMS incorporates a checklist for use in recording periodic assessment by the construction
management team of compliance with those control measures.
9. Site Environmental Management Plan
Note: A Minor Works Combined Management Plan (MWCMP) may be used for projects with a duration of
less than 6 months and/or a contract value of < $1M; and as approved by the business division General
Manager/Director. A MWCMP is issued in place of a Site Safety Plan, Environmental Management Plan,
Quality Management Plan and Project Management Plan. A MWCMP will contain, as necessary, all items
listed below.
The Project Manager and/or the Project Engineer consult as necessary with the HSEQ Manager and the
Construction Manager in preparation of the Environmental Management Plan (EMP) or MWCMP.
The EMP / MWCMP shall generally be prepared in the format of the EMP template and includes as
necessary:
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• Project details and/or cross references to the Project Management Plan, Traffic Management
Plans, and the Site Safety Plan, including relevant dates and / or work programs.
• Responsibilities for environmental management & the project organization chart, including
relevant company details.
• Hazard Identification Form (WHS-FRM-015) & Risk Assessment – Projects Form (WHS-RA-004)
• Work Method Statements, Work Procedures and Project Specific Work Procedures.
• Site specific emergency procedures and contacts.
• Site rules and induction requirements.
• Incident reporting requirements.
• Monitoring/inspection procedure and timetable.
• Training requirements.
• Daily Pre-Starts and work activity briefings.
• Toolbox meeting and work activity briefing arrangements.
Day-to-day works activities are planned, and control of their implementation executed by the project
manager/engineer and the foreman in accordance with the Project Management Plan (PMP), the Site
Safety Plan (SSP) and the EMP with specific reference to the control measures defined in Work Method
Statements and Work Procedures. Where a MWCMP has been developed this will operate in place of the
SSP, EMP and the PMP.
All employees and all workers on a workplace are obliged to ensure that any departure from defined
control measures, or additional environmental aspects they observe, are reported to the foreman and/or
the safety manager.
The construction management team and the HSEQ Manager are responsible for ensuring that the EMP /
MWCMP requirements are implemented. The Project Engineer is responsible for ensuring that sufficient
resources and staff are available to carry out the plan.
The Project Manager and/or the Project Engineer define arrangements for briefing supervisors, foremen,
operators, workers, sub-contractors and suppliers on site environmental aspects and their potential for
causing environmental harm, and on the implementation of the EMP / MWCMP. Records of all such
briefings are documented on the relevant forms as Job Inductions, pre-start and works activity briefings
and/or as Toolbox meeting records.
10. Monitor & Supervise Environmental Control Measures
Day-to-day works activities are planned and control of their implementation executed by the Project
Manager Engineer and Supervisor / Foreman in accordance with the Project Management Plan, the Site
Safety Plan, the Site Environmental Management Plan, Work Method Statements and Work Procedures.
Alternatively, these can be defined by the Minor Works Combined Management Plan (MWCMP).
Work Method Statements (WMS) include definition of requirements for continuously monitoring
implementation of the various control measures defined in them. Each WMS incorporates a checklist for
use in recording periodic assessment by project management staff of compliance with those control
measures.
All employees and all workers on a workplace are obliged to ensure that any departure from defined
control measures, or additional hazards they observe, are reported to the Foreman, Supervisor, and /or
the HSEQ Manager.
As necessary, the Project Engineer shall define a Monitoring Plan (as part of the EMP / MWCMP) that
includes measures by which all of the environmental aspects (and their potential for causing
environmental harm) that have been identified are to be monitored with a view to their effective
implementation.
The Project Manager / Engineer, Supervisor and Foreman are responsible for oversight of
implementation of all work method statements and for implementation of the Monitoring Plan, including
monitoring of environmental aspects and control measures in accordance with the Monitoring Plan.
Monitoring inspections shall include verification of work practices, plant maintenance & operation, and as
warranted:
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Environmental Management Procedure
• Visual inspection of silt traps, fences, water courses, drains, etc.
• Measurement of noise levels, water quality, air quality, etc.
• Auditing of the Monitoring Plan (especially if environmental aspects, potential for environmental
harm, and project duration necessitate this).
Records of monitoring must be maintained in accordance with the monitoring section of the EMP /
MWCMP:
• By Supervisors and Foremen – on the Weekly Site Safety & Environment Inspection Record -
form (WHS-FRM-013) (Civil projects) or form (WHS-FRM-033) (Building projects)
In addition to routine inspections for environmental issues or hazards on work-sites, including issues
relating to operation of plant and equipment, the Project Engineer, Supervisor and Foreman are
responsible for carrying out additional inspections whenever significant changes in site circumstances
arise (e.g. new phase of project, heavy rain) or in the event of an incident.
All monitoring reports and associated test results must be filed in accordance with procedures for control
of project records defined in procedure ‘Controlling Documents Plans & Data’ (Q-PRO-001) and any
project specific requirements defined in the PMP.
Non-conformances detected in relation to implementation of work instructions (WMS and WPs) or activity
specific work method statements are recorded on an Incident Report (WHS-FRM-027A) and processed in
accordance with procedure “Incident Reporting Procedure” (WHS-PRO-001)
When all necessary investigations and improvement decisions are made, inspection and other relevant
forms are filed as defined in procedure Controlling Documents, Plans and Data (Q-PRO-001)
11. Environmental Training for a Specific Project
Responsibilities and processors are defined in the procedures listed below:
• Site specific inductions
• Managing Construction Procedure (GRP-PRO-001)
• Project Site Induction Procedure (WHS-PRO-005).
The Environmental Management Plan, the Site Safety Plan and/or the Project Management Plan define
any project specific training in addition to the above (e.g. in relation to management of nominated
environmental aspects), including any training specified or to be provided by the client and any additional
or specialist training requirements.
Any environmental training of a particular employee, supplier or sub-contractor that is warranted by site
circumstances or client requirements shall be identified in the Project Management Plan or Environmental
Management Plan as the case may be.
The Project Manager/Engineer, Supervisor/Foreman and HSEQ Manager are responsible for ensuring all
the prescribed project-based training is carried out and for maintaining evidence of those trained,
including sub-contractors.
The Project Engineer may call on specialists if necessary to provide any project specific environmental
training.
The HSEQ Manager is responsible for ensuring that any environmental training necessary in relation to
non-project operations is conducted at the appropriate time, and for maintaining relevant records.
12. Incident Reporting and Environmental Breaches
Procedures for reporting of incidents are defined in the Incident Reporting Procedure (WHS-PRO-001).
Employees are required to report to a member of the Construction Management Team or company
management any potential environmental breach and / or Incident or environmental breach.
12.1 Project Incidents or Breaches
The Foreman is responsible for notifying the Project Engineer if incidents or breaches arise that involve
failure to comply with defined control measures or inadequacy of control measures is suspected.
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The Project Engineer determines action(s) to be carried out immediately to mitigate the impact of each
incident or breach.
All incidents/breaches are recorded on the Incident Report Form-Part A (WHS-FRM-027A)
Depending on the severity or nature of an incident or breach, the Project Engineer will notify the client’s
representative of the breach. All other parties involved with the project will be advised and informed as
necessary.
The Project Engineer and the Foreman are responsible for notifying the HSEQ Manager of all
incidents/breaches and actions in hand to process the Incident Report.
The HSEQ Manager is responsible for ensuring that all notifiable incidents are reported in the prescribed
format to the Environment & Resource Management Department, Queensland. The HSEQ Manager
maintains the Incident Register to facilitate monitoring of follow-up and eventual close-out of all incidents.
The Construction Manager / Project Engineer is responsible for ensuring that all reported incidents are
adequately investigated and that any necessary training and/or improvements to systems or work
procedures are implemented promptly.
12.2 Non-Project Incidents or Breaches
The Project Manager and the HSEQ Manager are responsible for ensuring that any non-project incidents
or environmental breaches are reported, adequately investigated and recorded.
13. Emergency Preparedness
Emergency procedures are defined in:
• Emergency Procedure: Project Sites (WHS-PRO-008)
• Emergency Procedure: Office (WHS-PRO-009)
Where the probability and level of risk to the environment are considered high or where legislation
requires, the project and/or other operation environmental assessment and control measures shall define
in addition to the above procedures the steps to be taken in the event of an Environmental Incident
occurring.
Project Managers / Engineers, Foremen and HSEQ Manager are responsible for ensuring that all
personnel are adequately briefed on these procedures, including conduct of rehearsals of the above
procedures at regular intervals. Appropriate records of rehearsals, de-briefings and any subsequent
training shall be maintained by the responsible officer.
14. Evaluation of Effectiveness – Environmental Assessment &
Control Measures
The Construction Management Team (for projects) and company management (for other operations) are
responsible for reviewing the application of defined procedures and control measures following each
emergency, incident or environmental breach in order to identify any requirements or opportunities for
improvement. The Project Engineer / HSEQ Manager is responsible for ensuring that post-incident
reviews are adequately and promptly undertaken.
The effectiveness of the processes for environmental aspect identification, risk assessment and definition
of control methods is evaluated through the following activities:
• Daily / Weekly checks – Foreman.
• HSEQ Board Report - HSEQ Manager
• Toolbox Meetings – Employees, Foremen, Project Engineers.
• Review of Incident Reports.
• Internal audits.
• Management Review.
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15. Assessment of Compliance with Environmental Obligations
On completion of projects and at other times during projects, compliance with environmental obligations is
assessed by the HSEQ Manager, generally as part of site safety and environmental audit assessments
and recorded on the Monthly Project Compliance Audit (Q-FRM-004)or on the Weekly Site Safety &
Environment Inspection Record - form (WHS-FRM-013) (Civil projects) or form (WHS-FRM-033) (Building
projects)
The HSEQ Manager is responsible for ensuring that adequate evidence of compliance with environmental
obligations is recorded as part of project on-maintenance actions and in accordance with requirements for
compilation of the Project Completion Review (GRP-FRM-007) as defined in the Managing Construction
Procedure (GRP-PRO-001)
16. Reference Documents
Document No. Document Name
ISO 14001:2004 Environmental Management Systems
Environment Policy
GRP-PRO-005 Maintaining Appreciation of Legal and Other Requirements
GRP-FRM-002 Daily Supervisor Sheet
WHS-FRM-013 Weekly Site Safety & Environment Record
WHS-FRM-033 Weekly Site Safety & Environment Inspection Record - Building
Q-FRM-004 Monthly Compliance Audit
WHS-FRM-027A Incident Report – Part A
WHS-FRM-004 Project Pre-Start Checklist
WHS-PRO-003 Risk Management Procedure
WHS-FRM-012 Subcontractor SWMS Checklist
WHS-RA-004 Risk Assessment - Projects
WHS-FRM-010 Permit to Excavate
WHS-PRO-005 Project Site Induction Procedure
WHS-PRO-008 Emergency Procedure – Project Sites
WHS-PRO-009 Emergency Procedure -Office
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Document Control
Reviewed By:
Name Position Date Reviewed
Sam Samuels Systems and Compliance Coordinator 18/09/2018
Document Approval
Name: Daryl Curran Position: HSEQ Manager
Signature: Date: 18th September 2018
Revision Record
Amended
Version Date Description Approved by
by
0 October ‘17 Initial Upload S Samuels D Curran
1 December ‘17 Re-Brand S Samuels D Curran
Updated to include references to
2 August ‘18 S Samuels D Curran
MWCMP
3 August ‘18 Added Cover Page S Samuels D Curran
4 September ‘18 Additional References to MWCMP S Samuels D Curran
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Environmental Management Plan
6. Document Control (for template)
Reviewed By:
Name Position Date Reviewed
Daryl Curran HSEQ Manager 8/12/2017
Sam Samuels Systems and Compliance Coordinator 12/02/2019
Document Approval
Name: Daryl Curran Position: HSEQ Manager
Signature: Date: 26th July 2018
Revision Record
Rev Date Description Amended by Approved by
0 August 2017 Initial Upload S Samuels D Curran
1 December ‘17 Re-brand S Samuels D Curran
2 December ‘17 Updated Policy S Samuels D Curran
3 January 2018 Updated Appendices S Samuels D Curran
4 February 2018 Updated reference to PMP (s6) S Samuels D Curran
Internal Audit – hyperlinks and references
5 March 2018 S Samuels D Curran
updated.
6 July 2018 Updated to link with PMP and WHSMP S Samuels D Curran
7 August 2018 Added Section 3.7 and 3.8 S Samuels D Curran
November
8 Updated Appendices S Samuels D Curran
2019
9 January 2019 Updated Certification Logo S Samuels D Curran
10 April 2019 Updated Policy, Objectives and Targets S Samuels D Curran
Environmental Management Plan (ENV-PLN-001-G20-010) April 2019, Rev: 10
215 David Low Way, Peregian Beach/ G20-010 Page 15 of 15