a resource guide for local councils - nsw environment, … · 2019-03-28 · iv a resource guide...

A RESOURCE GUIDE FOR LOCAL COUNCILS

Environmental Management of Council Operations

A RESOURCE GUIDE FOR LOCAL COUNCILS

E n v i r o n m e n t a l M a n a g e m e n t o f C o u n c i l O p e r a t i o n s

Council Operations_07.indd Sec1:i 24/9/07 9:32:14 AM

Disclaimer: The State of NSW, the Department of Environmental and Climate Change NSW

(DECC) and the Environment Protection Authority (EPA) have made all reasonable efforts to ensure

that the contents of this document are factual and free of error. However DECC and the EPA shall

not be liable for any damage or loss which may occur in relation to any person taking action or not

on the basis of this document.

This material may be reproduced in whole or in part for non-commercial educational use, provided

the meaning is unchanged and the source is acknowledged.

Published by:

Department of Environment and Climate Change NSW

59–61 Goulburn Street

PO Box A290

Sydney South 1232

Phone: (02) 9995 5000 (switchboard)

Phone: 131 555 (environment information and publications requests)

Phone: 1300 361 967 (national parks information and publications requests)

Fax: (02) 9995 5999

TTY: (02) 9211 4723

Email: [email protected]

Website: www.environment.nsw.gov.au

ISBN 978 1 74122 576 1

DECC 2007/441

September 2007

Front cover photo: Waste collection truck, Camden Council © DECC

Printed on recycled paper

Council Operations_07.indd Sec1:ii 24/9/07 9:32:17 AM

iii

Contents

Acknowledgments iv

Overview v

1 Before you start 1

2 Getting the processes right 13

3 Getting the programs right 19

4 Improving environmental performance 29

5 Case studies 63

Appendices 85

Appendix A: Ten tips for success 86

Appendix B: Example framework project plan 87

Appendix C: Sample standard operating procedures 90

Appendix D: Example environmental audit tool for council work sites 149

Appendix E: General contract conditions 155

Council Operations_07.indd Sec1:iii 24/9/07 9:32:17 AM

A resource guide for local councils: environmental management of council operationsiv

AcknowledgmentsThis publication is based on material prepared for the Department of Environment and Climate

Change (DECC) by GEMS Pty Ltd. Funding for this document was provided by the NSW

Government through its Stormwater Trust.

A large number of people have assisted in the production of this guide, in particular members of the

project management group from Rockdale City Council, Marrickville Council and DECC. In addition

more than 100 council offi cers provided input by responding to surveys or participating in discussions

– their input played a major role in the development of this guide.

Staff from the following councils provided material used in the case studies:

North Sydney Council

Tamworth Regional Council

Blue Mountains City Council

Rockdale City Council

Port Stephens Council

Hurstville City Council

Marrickville City Council

Bankstown City Council.

iv

Photography credits:

Contents opener Litter trap installation, Brown Park, Deniliquin Deniliquin Council

Overview Stormwater management at Bexley golf course Kellie Walters/ DECC

Section 1 opener Barricades around construction work T Maroney/Rockdale City Council

Section 2 opener Typical landfi ll site Kate Calabretta/ DECC

Section 3 opener Blacktown council depot with sediment fencing Blacktown Council

Section 4 opener Recycling at Camden Truda King/ DECC

Section 5 opener Spill response trailer Marrickville Council

Appendices opener Collecting unwanted household chemicals Kate Calabretta/ DECC

Council Operations_07.indd Sec1:iv 24/9/07 9:32:20 AM

vOverview v

On any day in New South Wales, councils across the state are involved in road

construction and maintenance, sewer construction and maintenance, water supply,

parks and garden maintenance, painting, street sweeping, spill response, bridge repairs

and much more. The days of councils being about just ‘roads, rates and rubbish’ are

long gone.

Councils are responsible for providing and maintaining a huge range of public services.

They also manage and maintain billions of dollars worth of public infrastructure.

Councils also have the potential to cause environmental harm if they do not manage the

activities of their operational teams effectively. In order to support councils developing the

environmental management capacity of their operational teams, the NSW Department of

Environment and Climate Change (DECC) has developed this resource guide.

Aims of this guideThis resource guide aims to support councils in developing the environmental

management capacity of their operational teams. It is intended as a practically focused

guide that brings together the experiences and resources developed by many councils

in New South Wales to offer something for those councils just developing environmental

management programs right through to those aiming for ISO 14001 certifi cation, an

international standard of environmental management.

Scope of this guide The guide provides advice and guidance to those councils who are just beginning

to develop their programs on matters like the rationale for having an environmental

management system, including the legal, social and environmental reasons.

The guide also covers the importance of developing a positive environmental culture

and developing corporate and operational ownership of any programs. It reinforces

the critical role played by regular and effective communication in the development of

operational programs.

O ver v iew

Council Operations_07.indd Sec1:v 24/9/07 9:32:20 AM

A resource guide for local councils: environmental management of council operationsvi

It provides guidance on completing a gap analysis for council, developing project plans,

developing specialised knowledge and skills, and other program management issues that

need to be considered before developing any activities.

It then outlines in more detail the key program elements that are important for

encouraging more effective environmental management. These include for example:

• development and delivery of basic environmental awareness training• development of environmentally focused standard operating procedures• development and implementation of an internal environmental audit process• development and implementation of a risk assessment process.

The guide provides a brief overview of the rationale, methodology and evaluation

criteria for each of these program elements, and includes sample texts (e.g. for standard

operating procedures), checklists and other resources. It contains references for further

reading and summarises case studies that feature the experiences of some NSW

councils in developing most of these program elements.

However, this guide is not a recipe book. Councils across the state have developed many

different approaches in order to achieve their ultimate goal of having environmentally

aware and responsible operational teams. These differences in approach refl ect the

diversity of councils across New South Wales.

Council personnel are encouraged to work through this guide and then adopt the

recommendations to suit their own particular situations.

Council personnel are also encouraged to talk to their peers at other councils. They

are all willing to share their experiences in order to achieve the ultimate goal of better-

protected local environments.

Council Operations_07.indd Sec1:vi 24/9/07 9:32:25 AM

1. Before you star t

1.1 How to use this guide 2

1.2 Six reasons to put a program in place 5

1.3 Ten tips for success 9

1.4 To EMS or not to EMS? 11

Before you start 1

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A resource guide for local councils: environmental management of council operations2

1.1 How to use this guideThe best way to use this guide is simply to select the sections you need. The guide is

divided into the following fi ve broad sections, described below, as well as appendices

containing additional information:

• Before you start

• Getting the processes right

• Getting the programs right

• Improving environmental performance

• Case studies.

Before you start This section covers:

• the legal, community and environmental reasons for developing a program designed to

enhance the environmental management capacity of council operational teams

• the ‘ten tips for success’ that anyone implementing this type of program should

remember

• the importance of a systematic approach to guide even the most basic of programs.

Getting the processes right This section looks at the processes seen as being important for the long-term success of

any operations development program. These processes include:

• development of a positive environmental culture

• gathering of high-level support and an ongoing budget commitment

• identifying champions within the operational personnel

• developing ownership

• promoting your program.

Getting the programs right This section details some programs that should be considered before developing specifi c

program elements including for example:

• gap analysis – identifying where your council is at

• training needs analysis – identifying the specialist skills and support that will be required

• project planning.

Improving environmental performance This section covers important program elements for the effective development of council

operational teams. It considers the development of councils through four broad groups.

They are:

• group 1 councils who have no program elements in place but want to get

something done

• group 2 councils who have:

• environmental awareness training

• environmental components in staff inductions

but want to do more


Before you start

3

3

• Group 3 councils who have a number of program elements in place but want to add

more depth to their program, including:

• environmentally focused standard operating procedures

• an internal environmental audit process

• an emergency response process

• a system to effectively manage subcontractors

• Group 4 councils who have:

• environmental performance indicators in operational personnel job descriptions

• environmental performance indicators in senior management contracts.

Group 4 councils may also be considering international certifi cation for their operations

development programs (ISO 14001).

Group 3 and group 4 councils are well on the way to developing the environmental

management capacity of their operational teams.

These groups are not strictly hierarchical – you don’t need to have all the nominated

group 3 program elements in place before implementing any group 4 programs. They

do however give an idea of the types of programs needed at different stages to build

effective long-term systems.

Case studies This section offers case studies from NSW councils linked to the various program

elements outlined in section 4. Case studies are an effective way of providing information

to council offi cers.

Getting the most from the guideIt is strongly recommended that you begin by reading sections 1, 2 and 3. Even if all

you want to do is develop and implement a basic environmental awareness course, it

is important to understand the processes that need attention if that course is to have a

long-term impact. All councils with an accredited environmental management system, for

example, began by offering staff a basic course in environmental awareness.

Sections 1 and 2 can be used in developing the processes and environmental culture

necessary for a successful program. Section 2.1 asks you to rate your council’s processes

for environmental management. The remainder of section 2 shows how you can improve

these processes to develop a culture in council that includes environmental concerns.

You can then complete the gap analysis in section 3.2 to provide a snapshot of your

council’s programs and how effective they are. This exercise will highlight which program

elements need to be implemented in order to improve the environmental management

performance of their operational teams.

In section 4, each program element offers a rationale, a proposed methodology and

examples of program elements that have been introduced by councils across the state.

The relevant case studies in section 5 should be read in line with the relevant program

element from section 4.

A basic fl owchart of how this program could be developed is outlined in fi gure 1.1.

This guide is not meant to be the fi nal word on the development of those operational

teams. It contains references to excellent publications, websites and training programs.

If required these should be located and used to provide further information towards

developing an effective environmental management system to suit any council.



Group 2 councils – develop and implement program elements including:• environmental awareness training• environmental inductions (section 4.1)

Group 3 councils – develop and implement program elements including:• standard operating procedures• environmental risk assessment• internal audit systems• emergency response• managing subcontractors• forming links to occupational health and safety

Group 4 councils – develop and implement program elements including: • progression to certification (section 4.3)• environmental components in job descriptions

Read sections 1, 2 and 3 of guide to gain an overview of processes and programs

Develop necessary project plans (section 3.3)

Review program

Assess your council’s processes for environmental management

(section 2.1)

Establish corporate and operational working parties

Assess your council’s programs for environmental management

(section 3.2)

Figure 1.1 Flowchart showing the development of programs for environmental management of council operations


Before you start

5

5

1.2 Six reasons to put a program in placeIt may be hard to convince management and councillors that resources should be

allocated to developing the environmental management capacity of operational teams.

There are at least six reasons to put a program in place, and these are explained in more

detail below:

• meeting statutory responsibilities

• council’s responsibility as a leader

• council’s policy commitments

• it’s in the management plan

• the community expects it

• . . . (and most importantly) the local environment deserves it.

Meeting statutory responsibilitiesIt is worth pointing out that councils have statutory responsibilities to undertake their

activities in an environmentally responsible manner.

Local Government Act 1993The fi rst stated purpose of the NSW Local Government Act (section 7a) is ‘to provide the

legal framework for an effective, effi cient, environmentally responsible open system of

local government in New South Wales’. Another stated purpose of the Act (section 7e) is

to ‘require councils, councillors and council employees to have regard to the principal of

ecologically sustainable development in carrying out their responsibilities’.

The Act (section 8) sets out the charter of local councils and includes the requirements

for a council to ‘properly manage, develop, protect, restore, enhance and conserve the

environment of the area for which it is responsible’.

Section 403 of the Act sets out the contents of a council’s draft management plan and

also requires that the statement of principal activities should include particulars with

respect to ‘activities to properly manage, develop, protect, restore and conserve the

environment’.

So the Local Government Act sets the broad legal requirement for councils to ensure

their operational activities are carried out in an environmentally responsible manner. It

also specifi es that a council’s management plan should include programs that ensure a

council’s operational activities are carried out in a way that ‘properly . . . protects . . . and

conserves the environment’.

Protection of the Environment Operations Act 1997 (POEO Act)The POEO Act is the main environmental protection law in New South Wales. The POEO

Act’s offences include:

• polluting waters without an environment protection licence; and

• specifi c offences relating to activities causing air, noise or land pollution.

There is clear authority under the law for DECC to act on behalf of the Environment

Protection Authority (EPA) against a councillor or individual employee of council, as well

as the council as an organisation, if it is clear that they have breached provisions of the

POEO Act.



The Act has three tiers of offences. For the most serious offences (Tier 1), the defendant

may use ‘due diligence’ or ‘all reasonable care’ as a defence. This defence cannot

be used for less serious offences (Tier 2 or 3), which are ‘strict liability’ offences (i.e.

the prosecution does not need to prove intent). Offences related to council operations

are most likely to be Tier 2 or 3 offences.The EPA’s Prosecution Guidelines provide

information on the factors the EPA will consider in determining whether a prosecution

for an alleged offence is appropriate. These considerations include any mitigating

circumstances.

The penalties for breaches of the POEO Act can be signifi cant.

Minor breaches can result in a penalty infringement notice (PIN) with a penalty of up

to $1500 for an organisation, while the maximum fi nes that can be imposed on an

organisation are up to $1 million plus clean-up costs and damages, and for individuals up

to $250,000 and seven years jail, as well as clean-up costs and damages.

A number of councils have been prosecuted under this Act. DECC maintains a public

register of successful prosecutions in the POEO public register that can be accessed on

the DECC website, www.environment.nsw.gov.au/prpoeo or by calling Environment Line

on 131 555.

Councils are the appropriate regulatory authority (ARA) under the POEO Act for most of

the development activities that take place within their area. As the ARA, council can issue

notices and fi nes for breaches of environmental laws.

Other legislationWhile the two Acts outlined above are the main ones relating to council operations that

councils need to be aware of, there are many other pieces of environmental legislation

that councils need to comply with, including for example:

• Coastal Protection Act 1979

• Environmental Planning and Assessment Act 1979

• Fisheries Management Act 1994

• Heritage Act 1977

• National Parks and Wildlife Act 1974

• Native Vegetation Act 2003

• Threatened Species Conservation Act 1995

• Pesticides Act 1999.

For further informationFor information on environmental law:

Department of Environment and Climate Change Environment Line

Phone: 131 555

www.environment.nsw.gov.au

Environmental Defenders Offi ce

Phone: 02 9262 6989

www.edo.org.au


Before you start

7

7

Council’s responsibility as a leader As well as being the major manager of infrastructure, councils are also the ARA for

premises that are not scheduled under the POEO Act, including small and medium-sized

businesses.

It could signifi cantly affect council’s credibility if their enforcement offi cers are issuing

penalty notices against small business and local community members for breaches of

pollution laws when their own operational activities are not up to standard.

Council’s policy commitmentsNearly all councils will have an environmental policy or statement even if this is only quite

basic. Select the policy commitments that support the case for your operational project

and put these in the rationale of its project plan. Council may also have a sustainability

plan which you may fi nd useful.

Whether or not it has an environmental statement or policy, a council should be prepared

to demonstrate that the environment has been considered in the development of its

management plans.

It is important that your programs have policy support. Enthusiastic staff have often

developed excellent programs, but these programs are diffi cult to maintain when

the enthusiast moves on. Formal policy support gives programs a longer-term future.

As a fi rst step in policy development have a look at what other councils in your area

have done.

It’s in the management plan All NSW councils are required to develop a management plan. Section 403 of the

Local Government Act sets out the required contents of this plan and requires that the

statement of principal activities should include particulars with respect to ‘activities

to properly manage, develop, protect, restore and conserve the environment’. There

should be a positive commitment in your council management plan about minimising the

environmental impact of council’s operational activities.

Most NSW councils have developed stormwater management plans. Have a look at your

council’s stormwater management plan. You may fi nd a statement or commitment to

ensuring council activities are managed in a way that improves the quality of stormwater

fl owing into local waterways.

Some councils also have plans for managing:

• waste

• the environment/sustainability

• bushland

• waterways

• environmental purchasing.

Have a look through the available plans and identify the statements committing councils

to ensuring that operational activities are carried out in an environmentally responsible

manner. Incorporate these commitments in the rationale for your project plan.



The community expects itDEC’s ‘Who cares about the environment’ (2006) has identifi ed the high level of

community demand for local environments to be properly protected.

The 2006 survey* found, for example, that:

• 53% of people ranked the environment ‘a very important part of their lives’. Only family

(92%) and friends (67%) ranked more highly

• 87% of people say they are concerned a ‘great deal’ or a ‘fair amount’ about

environmental problems

• 71% of people think local councils could do more to help protect the local environment.

Other groups identifi ed as needing to do more included retailers (66%), state

government (81%), Commonwealth government (80%), manufacturing industry (77%)

and individuals (81%).

Clearly there is a high level of community expectation that local councils accept and act

on their responsibilities to protect local environments. The public tends to react negatively

when a council’s failure to meet these responsibilites results in environmental harm or

fi nes.

. . . (and most importantly) the local environment deserves itIncreasing population in many council areas and the associated impacts are placing

greater pressure on our waterways, air, soil, fl ora and fauna. Poorly managed council

operational activities will only add to that pressure, whereas well-managed activities can

actually improve local environments, even as populations increase.

In the end, it’s the local environment, that directly affects the quality of life in a local

council area.

You can use any or all of the above information to help you convince your council they

need to develop an effective operational management program.

* For more information on the 2006 study see www.environment.nsw.gov.au/whocares


Before you start

9

9

1.3 Ten tips for successDuring consultations carried out during the preparation of this guide, council offi cers were

asked to nominate the barriers they had to overcome in order to develop and implement

successful programs.

Their advice has been used to develop the following ten ‘tips for success’. Read through

the list, remember the tips, and even pin them up on the wall in your workplace. Appendix

A provides a one-page list of these tips – you can copy it, put it in a central place, and

refer to it regularly.

Plan, plan, planThere are lots of different actions that need regular attention in a program like this. Put

them down in a plan. A written plan will also make it easier for you to explain to people

what you are doing, why you are doing it and why they should become involved.

Recognise there will be barriers Some of the potential barriers include:

• lack of management support

• when you submit your plan to management don’t necessarily expect an enthusiastic

response

• many council managers can be reluctant to commit the time and resources to a new

environmental program

• environmental management is still seen by some as an ‘added extra’ and not a part of

council’s core business

• lack of operational team support

• some members of the operational teams will struggle to accept ‘yet another thing’

they have to take into account when doing their jobs

• lack of operational management support

• ensuring the environment is properly protected takes time and resources

• operational budgets and the time allocated to complete projects will need to take this

into account (in the early stages of this type of program they often don’t)

• lack of time

• be patient; developing the right system takes time.

‘Train’ the people above youPeople above you in the hierarchy will not necessarily know, understand and support

what you are trying to do.

You should build presentations into your project plan to update line and senior

management on a regular basis. This will also help develop their sense of ownership of

the program.

Don’t go it aloneEven if you are just starting off with developing and delivering a basic environmental

awareness course you shouldn’t try to do this by yourself. From the start, involve council’s

personnel or training offi cers. You should also develop some components of the basic

environmental awareness course in discussion with team leaders or supervisors and their

line managers. As your program develops you will need to involve other people in sharing

the workload. If you try and do it all by yourself you could end up burnt out and frustrated.



Develop ownershipApart from sharing the workload, involving others helps to develop a sense of ownership

of the activity as well. Having other people as well as yourself ‘own’ the program gives it

a much better chance of success, particularly if you move on to another part of council or

another job altogether. Wherever possible involve supervisors, team leaders and gangers

in the development of your programs.

Make sure you get a budgetEverything costs money. Even a basic training program delivered by you will come at a

minimum cost to cover printing, refreshments and other resources. You should ask for a

dedicated budget within your project plan.

Make sure you also include a component in the budget for training yourself (see below).

It is also important that you identify budget commitments that will be required in future

years.

Learn to prioritiseWhere to start? That is always one of the key questions. As you develop your plan,

particularly as you move from one group to the next, it will be important to prioritise.

You cannot do everything at once.

Councils with very effective environmental management systems have taken around four

to fi ve years to develop them.

Train yourself Build into your budget an allowance for developing your own knowledge and skills. You

don’t know all the answers and there are some excellent programs, for example, on

environmental awareness, environmental management systems, internal environmental

auditing and risk assessment.

Recognise good practiceA lot of time and energy is often dedicated to fi nding out what’s going wrong and fi xing

it. Dedicate some part of your program to identifying good practice, and then recognise

that good practice through your presentations to management and other elements of your

communications program. Recognising good practice will generate a lot more interest

within your operational teams as well.

Communicate, communicate, communicateYou spend all your time on your programs and have very little energy left for telling people

what you are doing. Include a communications plan in your project plan at all stages of

this activity. Allocate yourself time to implement it as well. Tell your management, tell your

councillors, tell your operational teams and tell the community what council is up to.

Effective well-managed communications will play a critical role in developing that all-

important ‘positive environmental culture’.


Before you start

11

11

These tips sound simple and they do make sense. It is important however that you

refer to them regularly and make sure you are putting them in place. Using them will

help ensure your program is successful in both the short and the long term and that you

continue to enjoy what you do.

1.4 To EMS or not to EMS?All of those councils with excellent programs in place have adopted a systematic

approach. This took time, rigour and resources, yet they all maintain that the effort was

worthwhile. For most of the councils, this approach was built around an environmental

management system (EMS).

What is an EMS?The International Organization for Standardization (ISO) defi nes an EMS as ‘the part

of the overall management system that includes organisational structure, planning

activities, responsibilities, practices, procedures, processes and resources for developing,

implementing, achieving, reviewing and maintaining the environmental policy’ (ISO

14001, 1996).

In simple terms an EMS is the framework that helps an organisation follow its

environmental objectives effi ciently and effectively in a systematic way. DECC

identifi es the primary benefi t of an EMS as giving an organisation a way of managing its

environmental performance.

A number of councils described an EMS as ‘a management framework that guides the

development and implementation of their environmental management programs’.

Establishing an EMSAccording to the ISO guidelines, there are fi ve broad phases in the establishment and

development of an EMS and these can be paraphrased as follows:

1 Defi ne where you are at now in terms of environmental management. What is your

current environmental performance? What is your environmental policy?

2 Defi ne the purpose of the EMS and establish a plan. Why are we doing this? What do

we hope to achieve? How are we going to do it?

3 Implement the EMS. Put the system into effect and support it.

4 Check and correct. Analyse performance within the system and correct any problems.

5 Review and improve. Modify the system for continual improvement.

If you are considering only the development and delivery of an environmental awareness

course, then the whole idea of an EMS is probably daunting. If however you plan to

develop a more rigorous program you are encouraged to investigate having an EMS.

An excellent place to begin is with the general documents provided by Standards

Australia, (such as Environmental management systems – general guidelines on principles, systems and supporting techniques (AS/NZS 14004:2004)). EMS training

courses are also available.

An EMS can provide the framework and the rigour your program will need to succeed in

the short, medium and long term.



Case studiesSee:

5.1 Developing an environmental management system (EMS): a metropolitan

experience – North Sydney Council

5.2 Developing an integrated management system: a regional experience –

Tamworth City Council

ResourcesEnvironmental management systems – specifi cation with guidance for use

(AS/NZS ISO 14001: 2004)

Environmental management systems – general guidelines on principles, systems and

supporting techniques (AS/NZS ISO 14004: 2004)

Guidelines for quality and/or environmental management systems auditing

(AS/NZS ISO 19011: 2003)


Getting the processes right 13

2 . G e t t i n g t h e p ro ce s s e s r ig ht

2.1 Reviewing your council’s processes 14

2.2 Developing a positive environmental culture 15

2.3 Developing corporate ownership and commitment 15

2.4 Developing operational ownership and commitment 16

2.5 Developing a communication strategy 17



2.1 Reviewing your council’s processesCouncils across the state vary from those who are thinking about getting an operations

development program underway to those that have a certifi ed internationally accredited

environmental management system in place.

Most councils are somewhere in between.

So if you are thinking of doing something about developing the capacity of your

operational teams, the best fi rst step is to identify where your council is at now.

In order to identify gaps in your council’s processes, use the scale below to rate your

council’s performance in each of the areas in table 2.1.

1 Non-existent

2 Poor

3 Average

4 Good

5 Excellent

Table 2.1 Reviewing council processes

Question Council’s performance (1–5)

Cross-references to further information

Is there a culture within council where

‘environmental management’ is

recognised and supported as a core

business?

2.2 Developing a positive

environmental culture

Do you have corporate ownership

and commitment to improving the

environmental management of your

operational teams?

2.3 Developing corporate

ownership and commitment

Do you have operational ownership

and commitment to improving the

environmental management of your

operational areas?

2.4 Developing operational

ownership and commitment

Do you have an effective

communication strategy promoting

your environmental improvement

programs within your council?

2.5 Developing a

communication strategy



2.2 Developing a positive environmental cultureHere is the challenge: how do you develop a culture within council where environmental

management is recognised and supported as a core business and not an ‘added extra?’

Your fi rst step may need to be convincing your council colleagues that environmental

management really is part of council core business and if it is not, it should be. Refer to

section 1.2 ‘Six reasons to put a program in place’ for help in putting your justifi cation

together.

It’s not however just a matter of convincing management and then having everything

else fall into place. Developing and maintaining a positive environmental culture and the

programs that support that culture is not a simple task. It takes time, resources and rigour.

Some councils have suggested that it can take up to fi ve years to develop a positive,

sustainable environmental culture.

You should put systems in place to introduce new programs and review existing ones.

You should ensure that communication across all sectors of council is effective, that

good practices and programs are appropriately recognised and that poor practices and

programs are appropriately dealt with. The following sections outline some of the basic

processes that should be put in place to develop that culture.

Be aware of the culture and its importance. Councils with a positive environmental culture

continue to develop their programs year after year. Those that have programs in place

without the supporting culture often fi nd their most worthwhile programs disappear once

the offi cer responsible for that program moves on.

Cultural change takes time and attention.

It is worth the effort.

2.3 Developing corporate ownership and commitmentAny program designed to develop the environmental management capacity of operational

teams needs support from a broad cross-section of council.

The fi rst person you will need to have support your proposal will be your supervisor

and, from there, all management up to director level. Use section 1.2 from this guide to

develop your case.

Once you have obtained that support you will need to put in place processes that

encourage support from other areas of council. You will also need a budget and other

resources.

In order to encourage this support and identify and confi rm resource requirements, you

should convene a management stakeholder meeting. The purpose of this meeting will be

to consider the rationale for an operations development program and accept responsibility

for moving that program forward.

The council personnel who could be involved in this meeting include:

• section managers or equivalent

• divisional managers or equivalent

• operational managers or equivalent

• selected gangers/leading hands

• environmental offi cer/manager



• natural resource managers

• occupational health and safety offi cer

• training offi cer/manager

• business manager

• human resources manager

• interested councillors

• council planners

• contracts managers

• other interested council personnel.

A typical agenda for the meeting would cover:

1 Reasons for developing the environmental management capacity of operational teams

(see section 1.2, Six reasons to put a program in place)

2 What council has done to date in the development of its operational teams

(see section 3.2, Rating council’s performance)

3 What some other councils have done to develop the environmental management

capacity of their operational teams (see section 5, Case studies)

4 What council needs to do to develop its operational teams (see section 4, Improving

environmental performance)

5 How to take the project forward (see section 3.3, Developing project plans).

At the fi rst meeting, broad options should be presented for consideration after which you

will probably be required to develop a more detailed project plan.

It is very important you include detailed budgetary and resourcing requirements within

that project plan and identify that these are likely to extend over a number of years.

As a follow-up to the fi rst meeting you may consider forming a corporate working

party which could meet regularly (e.g. quarterly) to support the development and

implementation of your project plans. Try to identify people within this fi rst meeting

who are supporters of what you are trying to do and encourage them to be involved in

the working party. The higher the level of support that you can gather from within the

management hierarchy, the better chance you will have of securing long-term support for

your programs.

2.4 Developing operational ownership and commitment

Operational personnel have come under more and more pressure in recent years. The

way they do their jobs has changed for lots of reasons. While most operational personnel

accept the need for these changes, many do not like it, particularly when the changes in

practice are not supported by appropriate changes in project timetables or budgets.

It is strongly recommended therefore, if you are developing a program for your

operational teams, that you identify leaders from within the ranks of the operational

teams who could become champions of the environmental program. Speak to the line

managers: they will know who could take on this leadership role.

Invite these gangers/leading hands and their line managers to a meeting very early in

the development of your project plan. Put the environmental challenges to them and ask

them what they think would be the best way to deal with those challenges.



Use this input to develop your project plan. Ask the group to review the project plan and

accept responsibility for discussing the project plan with their team members.

These ‘champions’ should also be involved in the development of the main components

of your project plan. If for example you are developing an environmental awareness

course you should clarify your objectives and then discuss how best to achieve those

objectives with these champions. Involving them at the early stages of development and

throughout all components of the program will encourage a level of ownership within the

operational networks. This could help to overcome the problem of operational members

seeing this as ‘just another thing being forced upon them by management’.

A review of all the program elements in section 4 would indicate that your champions

should be involved in the development of most of them. They should have a say in the

most effective way to:

• develop and deliver the environmental awareness course

• incorporate environmental considerations into new staff inductions

• develop and deliver training about how to incorporate environmental components into

standard operating procedures

• develop and implement an internal audit program

• develop a method for dealing with poor practice and recognising good practice

• develop and implement emergency response systems

• develop and implement a risk assessment process

• develop an effective subcontractor management system

• link environmental and safety programs together

• link with other relevant council programs

• incorporate environmental components into job descriptions.

Development of ownership within the operational ranks will also give your program a

much better chance of long-term success.

2.5 Developing a communication strategyCommunication is often treated as an ‘added extra’ in operational development programs

and not as a part of ‘core business’. Yet consultations during the preparation of this guide

reinforced the importance of effective communication in the development of a positive

environmental culture throughout council. Some possible elements of an effective

communication strategy are listed below.

Program theme brandingSome councils have successfully involved their operational teams in the development of

a theme or slogan for their operations development program, and then incorporated the

theme into all program promotional material.

Email program updatesMonthly program updates can be sent by broadcast email to all key stakeholders involved

in the initial management meeting and other interested personnel. Copies of the emails

can also be posted on the notice boards at council depots and other work sites.



Toolbox talksA number of councils have a ‘toolbox talk’ program. This involves either the ganger or

leading hand working through issues with their crews. Toolbox talks can also incorporate

some level of training.

Some councils have found it extremely worthwhile to incorporate information about the

environmental development program into their toolbox talks. They did identify, however,

that leaders of the talks should receive individual training on the program to allow them to

talk with more confi dence about its implementation.

Formal presentationsIn some councils formal presentations on the operations development program are made

every six months to senior management and, if appropriate, councillors and members of

council’s community environmental liaison group or similar body. This ensured all senior

management and leading local community fi gures were aware of developments in the

program.

Signs and postersA number of councils use basic in-house signs and posters to promote positive

environmental messages. These signs and posters were displayed in strategic places at

depots, lunchrooms, work sheds and council offi ces.

Messages on payslipsPositive environmental messages can be put on payslips to reinforce the importance of

protecting local environments. Payslips may possibly be the most closely read piece of

paper within councils.

Council internal and external newslettersThese can be used to promote the good work of the operational teams both internally and

to the broader community. It is important that the operational teams see any newsletters

containing an article about their work.

In developing a communication strategy talk to your council colleagues. Some may have

specialist communications skills. Ask them to look over your communication strategy and

see if they can refi ne it for you. (Remember tip 4: don’t go it alone.)

The strongest message of all from the consultations in relation to communication,

however, was that it should be a part of the program and not an optional extra.


Getting the programs right 19

3 . G e t t i n g t h e p ro g r a m s r i g h t

3.1 Introduction 20

3.2 Rating council’s performance 20

3.3 Developing project plans 22

3.4 Developing specialised knowledge and skills 24

3.5 Program review 25

3.6 Other project management issues 26



3.1 IntroductionEffective long-term programs can only be built on a sound base. That’s why up until this

section, this guide has focused on putting the processes in place that will provide that

base.

There are a number of program issues that also need to be considered before you get

underway. The program issues and tools outlined here will provide the specifi c detail you

need to develop effective programs.

The best fi rst step is to identify what you need to do. The checklist provided in section

3.2, Rating council’s performance, works like a basic gap analysis. From this gap analysis

you will have a list of the program elements that council could consider introducing (tip

7, Learn to prioritise). A priority order for the introduction of these program elements

needs to be established. This priority order should be developed in consultation with your

corporate and operational working parties (tip 5, Develop ownership), taking into account

the relative environmental impacts of different council operations.

Once the priority order is established, it’s time to start developing project plans (tip 1,

Plan, plan, plan). A recommended format for project plans is included in section 3.3.

In completing the project plans, you will identify the specifi c knowledge and skills you

may need to develop or seek out in order to effectively implement that particular program

element.

Section 3.4, Developing specialised knowledge and skills, offers some ideas on how best

to complete that part of your work.

Finally, section 3.6 outlines a range of other issues identifi ed through consultations as

being important considerations for anyone developing a detailed, long-term program.

3.2 Rating council’s performanceThere is more to a successful program than just having the systems in place. It is

important to identify whether those systems and program elements are being successfully

implemented. In doing so you will also be identifying what needs to be done in order to

take your council program forward.

You are also encouraged to think about the ‘big picture’ issues like having a positive

environmental culture, taking corporate and operational ownership and developing

effective communication strategies. These do not just develop by themselves, but need

attention just as much as the other program elements.

Table 3.1 will assist you in carrying out a quick and simple analysis of the programs you

have in place at your council. Use the worksheet to rate council’s performance (see

section 2.1) as before from 1 (non-existent) to 5 (excellent) for each program element. If

there is no aspect of a program element in place, rate the council’s performance as a 1.

Ask your corporate and operational working parties to work through the worksheet too.

From there you will get an excellent idea of where you stand and what you need to work

on at the program level.

The scores will quickly show you where your council has made a start and where further

work is needed. If you have scored 1 for each of the program elements in the table, you

are a group 1 council.



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Now that you have identifi ed where you stand and what you need to do, it is important to

prioritise the process and program elements that need attention (tip 7, Learn to prioritise).

Once you have done that, you need to develop project plans for each of the elements

and processes you want to implement. The next section outlines in detail how best to put

those project plans together.

Now is probably a good time to discuss with your working parties whether council wants

to achieve an average, good or excellent standard in each of the processes and program

elements.

3.3 Developing project plansRemember tip 1, Plan, plan, plan. Many councils who have successfully developed

positive environmental cultures and, from that, effective long-term environmental

operations development programs, have stressed the importance of formal planning.

Some council comments about project plans have included:

• ‘It’s pretty silly to keep it all in your head, you should write it down’

• ‘Put it down on paper’

• ‘Show it around – it gives your project credibility’

• ‘They convince people of your professionalism and commitment’

• ‘Be prepared to re-write your plans regularly’

• ‘Use them to get appropriate budget allocations’

• ‘They give management confi dence in what you are trying to do’.

Even getting a straightforward project element like the development and delivery of an

environmental awareness course underway requires the organisation of a number of key

components. A fi rst step, for example, with this particular activity would be to get your

operations and corporate working parties together in order to discuss:

• who needs to attend the training

• what the training needs to cover

• who should develop the fi nal training product

• who should deliver the training

• where and when the training should be delivered

• how the training will be evaluated

• what budget will be required

• who will be responsible for organising operational participation in the training

• what special skills and knowledge will be required

• how council’s senior management and the community will be informed about the

project.

All of these issues should be considered in the development of a project plan.



Components of a project planYour council may well have an existing format for project plans. If so, fi nd out what it is

and use it. If not, there are a number of key elements that could be incorporated into a

project plan. They are:

• project name

• project offi cer

• project element/title

• overview – provides an overview of what the project is about and what it hopes to

achieve (i.e. the project objectives)

• rationale – provides the reasons for putting the plan in place (see section 1.2)

• project components – describes the main components of the project. For the

environmental awareness course example, the components would be:

• developing course content

• fi nalising target groups

• identifying and confi rming trainers

• identifying and confi rming venues

• identifying and confi rming evaluation strategies

• identifying and confi rming budgets

• identifying and confi rming people responsible for organising operational participation

• identifying and confi rming communication strategy

• methodology – outlines how each of the project components will be developed and

delivered

• budget – outlines the budget required for the effective completion of the project, and

ensures likely budgetary needs for subsequent years are identifi ed in the initial project

plan

• timetable – identifi es your fi rst program milestone and then very approximate dates

for the completion of other activities. You should track how well you meet the program

milestone and use this as an indicator when considering future milestones

• communication – identifi es how the program will be promoted to the various key

stakeholder groups before, during and after the training

• evaluation/performance indicators – identifi es how the effectiveness or otherwise of the

training will be assessed – a useful way of establishing these performance indicators

would be to ask your project planners and your working parties to complete the

following two sentences in relation to each program element:

• ‘This project element will be a success in the short term when . . .’

• ‘This project element will be a success in the long term when . . .’

• evaluation criteria for an environmental awareness program would include for example:

• short term – increase in participants’ basic environmental knowledge. This could be

assessed by asking all participants to complete a survey both before and after the

training program

• another short-term indicator could be changes in purchasing practice through the

store (e.g. increases in orders for sediment and erosion control fencing, straw bales,

sediment socks, chemical spill and clean up kits etc.)

• long term – improvements in environment management practice which can best be

measured through an internal audit program

• identify the special skills and support resources that may be required to effectively

implement this part of your program.

Appendix B provides a framework project plan to assist council offi cers in developing their

own project plans.



Reviewing project plansOnce you have developed a draft project plan for a particular program element you

should ask members of your working parties to review the plan.

Finalising project plansProject plans are never fi nal. It is important that you are willing to modify project plans

at any time. It is strongly recommended that a document control system be developed

for project plans. It is also important once you amend a plan that you send a copy of the

amended plan to anybody who has received and is working with a prior version of the

document.

Project credibility and longevityWell-written and managed project plans usually give a project a level of credibility with

council managers. Project plans outline what is going to happen by when, how much it

will cost and how council will know whether it has been successful or otherwise. Council

managers can identify for themselves the likely outcomes of a project and also speak with

some confi dence about how it is to be planned and implemented.

The other main advantage of project plans is that other offi cers from council deliver a

project if the initial project offi cer becomes unavailable.

3.4 Developing specialised knowledge and skillsA single council offi cer is unlikely to have detailed specialised knowledge of

environmental law, emergency spill response, internal environmental audits, policy

development, environmental management systems and sediment and erosion control.

The effective implementation of a complete operations development program will require

a broad range of knowledge and skills that may already exist within your working parties.

If so, utilise them. Staff from adjoining councils or regional council coordinators may also

be able to contribute. You could also use external consultants.

There is however a suite of skills that should be developed in-house in order to ensure

the program has a solid knowledge base. To develop that knowledge base, you could

provide specialised training to relevant key participants in the operations development

program.

At a minimum, specialised training should be provided in project management and

basic environmental management systems. In developing project plans you may

also identify the need for specialist in-house knowledge and skills in emergency spill

response, sediment and erosion control, environmental law, environmental audits and

communications management.

It is important therefore that a budget be set aside for developing these specialist skills in

key stakeholders.

If you plan to use external training providers or other consultants it is recommended that

you talk to your neighbouring councils fi rst to fi nd out who they have used effectively.

Once you have identifi ed what you need, it is important that you speak to council’s human

resources and training specialists for advice.



3.5 Program reviewHow will you know if the various program elements in your operations development

program are making an overall contribution to achieving council’s environmental

objectives? The success of any program can only be determined through review. Ideally,

a review methodology or framework should be established prior to implementing the

program. Findings from this review can feed back into each program stage, forming the

basis of a council’s continuous improvement approach.

The review should look at two main areas – program implementation and outcomes.

Review of implementationThe review of the program’s implementation should happen fairly regularly, for example

monthly. These reviews are effectively ‘spot checks’ to see that everyone in the plan is

doing what the plan says they should do. If everything is on track, great. If some of the

actions aren’t being implemented, look at why. This could be because the people involved

are not aware of or fully understand their roles, or they lack commitment, or some of

the actions in the plan are harder to do than expected or are inappropriate in practice.

Some fi ne-tuning of the plan or improved communications may be needed to fi x any

implementation issues.

Review of outcomesThe project plan framework outlined in section 3.3 notes that planners should identify

evaluation criteria for each program element – this will help the review of the plan’s

outcomes. The review could initially compare the evaluations from each element, but they

will really only give you an idea about that particular element. Council should also review

the whole operations development program. This review should concentrate on both the

outcomes achieved and the effectiveness or otherwise of the processes. In particular:

• compare program outcomes with the initial program objectives (did the program do

what we intended?)

• evaluate the effectiveness of those outcomes (could we have done this differently?)

• determine what, if any, changes need to be made to the program (do we need to

change the objectives, the way we evaluate outcomes, or program elements?).

If the outcomes meet the expectations, the review can ask what next stages can be

implemented to further improve the program. The results of reviews can, importantly, also

justify the operation of a system by identifying the associated benefi ts (such as improved

environmental performance, increased morale, etc.).

As a part of this review you could speak to council’s enforcement personnel

(environmental health offi cers, rangers) to identify any improvements in performance or

environmental outcomes they have identifi ed. While the information from the enforcement

personnel will be anecdotal, it will still be useful.

Making the results countOnce the review is completed, it is a good idea to organise a presentation to senior

management and, if appropriate, councillors. Presentations of this nature are important to

encourage the ongoing commitment of senior management and elected offi cials. At the

end of the review, pencil in the date of the next system review. Most councils complete a

system review every 12 or 24 months.



Within the context of this resource guide, program review is the only mechanism available

for determining whether a council is progressing from one category to another (e.g.

from group 2 to group 3; see table 3.1). Such progression is based on whether they

are successfully implementing a more structured and strategic approach for reducing

environmental impacts arising from the council’s operations.

Where councils are moving towards establishing an environmental or integrated

management system, review fi ndings can also feed into a corrective actions framework

that allows for the issues or problems to be addressed as they arise.

3.6 Other project management issuesSome issues have occasionally been identifi ed by council offi cers as important

considerations for councils developing operationally focused programs. A brief overview

of each of those issues is outlined below.

Document controlProject plans should be regularly reviewed and amended in line with outcomes; standard

operating procedures should change as machinery or best practice improves; internal

audit documents develop as they are used in the fi eld.

It is very important to put a system in place that ensures all relevant stakeholders receive

copies of any amended documents.

A number of software programs have document control systems. These work well,

provided a list of relevant stakeholders is maintained.

Underestimating resistance to changeThe culture of councils varies. In some the predominant culture is to embrace change

while other councils have a more conservative approach to ‘getting the job done’.

There can be sub-cultures within the dominant culture of council, so even if your council

appears to be leading the way in some areas of environmental management, you may

occasionally have to deal with someone who does not welcome changing a system that in

their opinion has ‘kept council out of trouble for the past 15 years’.

On the other hand you may work within a council that has a reputation for not changing

much at all. Within this type of council you may still fi nd people who are willing to

investigate changes to the way things are done. That’s why it is important to convene

the working parties very early on in your project development. In the last 20 years, local

government has undergone signifi cant change, and so some resistance to further change

should not be surprising. It is important however to anticipate that resistance, and to have

good plans and committed colleagues in place to deal with that culture.

Falling back into bad habitsChanging behaviours can take time, particularly if they have been in place for many

years.

In the early days of your project, when the messages from training are fresh, people will

change the way they do things. Yet once the training fi nishes and the communication



drops off and some minor hurdles get in the way, there will be a tendency in some council

operational areas to go back to doing things the old and less challenging way.

That’s why a regular review, internal audits, consistent communication and a means of

recognising good practice are all important components of an operations development

program. Providing this type of support on a regular and consistent basis helps overcome

the temptation of reverting to the old way of doing things.


Improving environmental performance 29

4. Improv ing env i ronmental p er for mance

4.1 Becoming a group 2 council 30




30 A resource guide for local councils: environmental management of council operations30

4.1 Becoming a group 2 councilGroup 2 councils are those that know they need to have a basic program in place and

want to get something underway. If you are a group 1 council, the journey to group 4 may

appear to be long and tough.

Effective operational development programs should be considered in smaller achievable

steps. Change can take time, but if rushed can lead to disappointment.

It is also important to make sure the processes outlined in section 2 of this guide are put

in place for even the most basic of programs.

Every group 4 council, including those with internationally accredited environmental

management systems for their operational activities, began by developing and delivering

an environmental awareness course.

So in order to get from group 1 to group 2 you should:

• read through the program elements for group 2 councils carefully (table 3.1)

• develop a project plan (section 3.3)

• organise your corporate and operational working parties to develop and review your

project plans

• try to fi nd peers at other councils who can provide support

• get to work.

Successful operational programs are about energy, focus and commitment. Through

putting the processes in place, developing your project plans and seeking support from

both inside and outside your council, you will be giving yourself an excellent chance to

achieve your objectives.

The program elements for a group 2 council are:

• council commitment (section 2)

• environmental awareness training

• environmental inductions.

Environmental awareness training

OverviewEnhanced environmental awareness is an important fi rst step in encouraging improved

environmental management performance. If people don’t know or understand the

importance of more effective environmental management on job sites, they will not

change their practices.

That is why the cornerstone of any effective long-term environmental improvement

program should be a basic environmental awareness course for all appropriate

personnel.

The objectives of this course should be:

• the personal benefi ts of a better-protected local environment, including quality of life

(health and lifestyle) and a better future for children

• the legal responsibility of every individual at all levels in an organisation to ensure the

environment is protected

• the increasing community expectation for better-protected local environments

• their council’s response to that increase in community expectations



• how their work has the potential to impact on the quality of life of the community, plant

and animal communities, air quality, water quality and soil

• the basic steps they need to take in order to minimise those impacts.

Methodology

1 Course contentThere are a number of courses on basic environmental awareness and protection.

Councils may decide however to develop their own environmental awareness course.

In that case, the fi rst step in developing course content is to decide on some clear and

concise objectives for the training. The objectives outlined in the example course in this

section are recommended as a good place to start.

The following sections provide a sample framework of a general environmental

awareness course.

2 Course developmentEven if council decides to present one of the existing environmental awareness courses,

it is strongly recommended that appropriate council personnel be involved in ‘localising’

course content.

Appropriate personnel should include:

• council’s corporate and operations working parties

• council’s human resources or training manager to advise on course evaluation and

delivery. In the longer term, they could also be asked to advise on incorporating

appropriate environmental performance indicators in both operational, line management

and senior management job descriptions.

Involving these people at this early stage of the program should also encourage some

long-term ownership across council. It could also help to identify possible ‘champions’

who could be involved in other aspects of program development and delivery.

3 Course participantsIt is important that all operational personnel and their direct line managers participate

in this course. There are signifi cant advantages in having direct line managers sit in on

at least one session so the operational personnel can see environmental awareness is

being promoted across the organisation.

Some councils insist on all people with either direct or indirect responsibility for

environmental management participating in at least one session of the environmental

awareness course.

Other councils have also encouraged their enforcement personnel to sit in on at least

one session. The value of having enforcement personnel participate is that operational

personnel can discuss any local issues of concern.

4 EvaluationIt is important that an evaluation strategy be developed before the course is delivered.

That way, the success or otherwise can be measured and, if appropriate, amendments

made. Councils have used various evaluation strategies in different timeframes, including

the following:

• immediate

• participants invited to complete a survey both before and after the training course to

identify any changes in knowledge or awareness achieved through the training course



• operational personnel who may have diffi culty in reading or writing would have

diffi culty completing these types of surveys and may need support

• short term

• indicators may include changes in purchasing practice through the store (e.g.

increases in orders for sediment and erosion control fencing, straw bales, sediment

sock, chemical spill clean-up kits)

• increases in requests for specialised training from operational personnel or

suggestions on changes in practice

• long term

• an internal environmental audit is the most effective way of tracking improvements in

environmental management practice on council job sites.

5 Likely outcomesThe operational personnel who complete this basic environmental awareness training

course are likely to identify the need for:

• standard operating procedures

• internal environmental audits

• ongoing communication programs.

Recommendations on establishing each of these components are included in the

following sections of this guide.

Outline of an environmental awareness course for local councils

The panel on page 33 outlines details of an environmental awareness training course

that has been successfully delivered to operational personnel and other council offi cers at

more than 30 different councils across the state.

Case studySee 5.3 Environmental awareness and induction programs – Blue Mountains City Council

For further informationDECC and your neighbouring councils may be able to provide advice on environmental

awareness training programs they have implemented.



Environmental awareness course (example)

TitleLocal council operations and environmental protection

ParticipantsThis training program is suitable for all council operational staff and their direct

line management. Authorised offi cers (rangers, EHOs, and health and building

surveyors) have also joined the course in a number of council areas and all have

found it to be ‘most worthwhile’.

ObjectivesBy participating in this course, operational staff, their managers and other relevant

council personnel will:

• understand and acknowledge the potential environmental impact of their work

• know what they need to do in order to minimise that impact

• understand and acknowledge their community, organisational and legal

environmental responsibilities

• understand what they need to do in order to ensure they meet their environmental

responsibilities

• know how to identify environmental risks at their job sites and what to do to

minimise those risks

• know who the appropriate regulatory authority (ARA) is for their job sites and how

to respond to a site visit from a representative of the ARA

• understand and acknowledge the need for an ongoing internal environmental

review program.

ContentThis course has fi ve main components:

• Introduction

• Identifying and managing the environmental impact of council operational

activities

• What the laws require

• Identifying environmental risk

• Conclusion.

1 IntroductionThis course opens with a discussion on the personal benefi ts of a better-protected

environment. All participants are required to complete the following statement:

‘I think it is important to protect the environment because . . .’

Gaining some type of personal commitment from all participants at the beginning of

the session provides an excellent platform for the rest of the training program. The

issue of ‘what difference can one person really make’ is also dealt with.



2 Identifying and managing the environmental impact of council operational activities

Participants select one or two typical jobs that they do and identify the potential

environmental impact of those jobs. Participants usually work in small functional

groups for this exercise.

Parks and gardens staff could select refuelling, spraying or lawn mowing. Road

construction staff could select concrete cutting, footpath construction or hot mix

spreading, while water and sewer staff could select pipe laying or dealing with

sewer overfl ows.

Each group then explains to the rest of the class the potential impacts of their jobs.

The trainer asks each group the type of questions an offi cer from the Department

of Environment and Climate Change (DECC) might ask if they were to visit their job

sites. This helps to identify basic issues that could require attention (e.g. protection

of downstream drains, cleaning of tools after a concreting job or the availability of

material safety data sheets).

3 What the laws requireParticipants are taken through a brief history of environmental law.

Participants are then provided with a scenario where they apply their own logic

to prepare a basic environmental law. Their logical environmental law is then

compared to the main elements of the POEO Act. This is an effective way of

teaching people about what laws require.

The key concept of due diligence and strict liability for pollution is also covered in

detail. Appropriate regulatory authorities are also explained, as are the powers of

DECC, the notices associated with the POEO Act, and the way council offi cers

should respond if they have an incident on their site or a visit from a DECC offi cer.

4 Identifying environmental riskThrough this component, participants complete a basic desktop review or audit of

one of their typical projects. They are asked to identify what would be the worst

possible thing that could go wrong on their job sites and how well placed they are to

deal with something going wrong.

Within this component a series of council case studies are reviewed and course

participants are asked to identify what should have been done differently. (If local

case studies are available they can form the main part of this component of the

course.) During this component a series of actual council prosecutions are also

examined.

5 ConclusionThe course concludes with each participant being asked to nominate what they will

do differently, if anything, as a result of completing the work and what they need to

do in order to ensure that they act at all times with due diligence and all reasonable

care. These responses are collated and provided to management.

TimingEach course takes approximately 3–3.5 hours to complete.



Environmental inductions

OverviewEnsuring all new staff are aware of their council’s commitment to protecting local

environments is important. This is best done through the council induction program.

Staff inductions are a legal requirement under occupational health and safety regulations

and so the process of formal inductions should already be in place at your council.

It’s a matter of convincing the people who put the induction program together that an

environmental component needs to be included (see section 1.2, Six reasons to put a

program in place).

Even though the prime focus of this project is developing the environmental management

capacity of operational teams, it is strongly recommended that an environmental

component be incorporated into the induction programs for all staff. Ensuring all people

who work for council know the organisation is serious about environmental management

will have a signifi cant infl uence on the development of an all-important ‘positive

environmental culture’.

MethodologyIn order to ensure an appropriate environmental component is included in council’s

induction program it is recommended that:

• the people responsible for the induction process (usually human resources staff) are

convinced of the importance of incorporating environmental components into staff

inductions

• the corporate and operations working parties, with the support of council environmental

specialists, develop the content of the induction component. A typical environmental

component of an induction program covers:

• council’s commitment to environmental management

• important local environmental issues

• overview of council’s environmental management program and policies

• environmental laws

• individual environmental responsibilities

• who to talk to for specialist environmental advice

• further environmental training/development opportunities

• if appropriate organise for one or two members of the working parties to be trained

in the delivery of the induction course. These staff should be supported by council’s

environmental specialists at each of the courses

• develop course materials in consultation with council’s training manager and/or human

resources manager

• organise for a senior member of staff to introduce the environmental induction

component. This will also confi rm council’s commitment to environmental protection

• develop and implement an evaluation strategy for the induction course

• review course content and delivery every two years or as directed by council’s training

specialists.



ExampleA typical environmental induction program would include:

1 Local environment issues – presented by council’s environmental specialists

2 Why protecting the local environment is important – presented by the community

relations manager or environmental specialists

3 Environmental policy – all participants should be given a copy of the environmental

policy that outlines clearly the commitment their new employer has made in terms of

protecting local environments

4 Environmental management program – presented by the appropriate manager within

council. This should outline all the environmental management activities council has in

place.

5 Environmental law – this section should provide a brief overview of relevant

environmental laws

6 Seeking specialist environmental advice – participants should be given contact details

for council’s environmental specialists

7 Raising issues of concern – here the process for council personnel to raise

environmental issues for concern should be identifi ed

8 Questions.

ResourcesIn developing course content it is strongly recommend that basic environment information

be sourced from a range of appropriate government and other agencies including the

Department of Environment and Climate Change (NSW).

Phone: 131 555


Information is available on environment protection, environmental issues and

environmental law.



4.2 Becoming a group 3 councilYour environmental awareness program has been successfully developed and delivered

and all of council’s new personnel are aware of your organisation’s commitment

to protecting the environment and the programs they have in place to meet that

commitment. You are now well and truly a group 2 council.

In order to become a group 3 council you need to put a new range of additional program

elements in place (table 3.1). These elements are listed below and are described further

in the following sections:

• standard operating procedures

• environmental risk assessment

• internal environmental audits

• emergency spill response

• managing council subcontractors

• forming links with occupational health and safety (OH&S) management.

Many of the program elements can be developed simultaneously if time and resources

allow, or you could develop and implement one program element at a time. If you are to

do one at a time, decide the order of development with your corporate and operational

working parties. Once the order has been decided, develop your project plans. Plans

should be prepared at two levels. The fi rst plan will identify the program element as

a whole and the order in which you will be implementing them. If you are planning to

implement all group 3 program elements, allow around two to four years within your

project timeline to achieve this goal. Separate project plans should then be developed for

each program element.

In order to work towards becoming a group 3 council:

• decide which program elements you will be implementing and their priorities in

consultation with your corporate and operational working parties

• develop an overall project plan to implement these program elements (identify the need

for ongoing budget and resource commitment over the life of the project)

• develop project plans for each program element

• make a copy of the ten tips for success (appendix A) and place it prominently in your

work area and refer to it regularly

• establish contact with your peers in other councils who are developing and

implementing other programs. Write into your project plan an allowance for spending

some time with those peers

• start work.

The journey from group 2 to group 3 is probably the most challenging in developing

a long-term program to improve environmental aspects of council operations. By

developing and implementing project plans and maintaining your own energy, focus and

commitment, you are now building the framework for what will be an effective long-term

program.



Standard operating procedures

OverviewStandard operating procedures (SOPs) are an excellent way of developing consistency

and staff understanding as to the requirements, training and responsibility of all staff

members associated with an activity. The purpose of SOPs is to ensure that works are

carried out:

• in an effective manner to achieve maximum productivity and quality

• to a standard that ensures the safety of the staff and residents within the work area

• to minimise pollution and to meet the requirements of the POEO Act.

Sample operating proceduresA series of sample standard operating procedures for key areas of activity for councils are

presented in appendix C. They are:

• road construction and maintenance

• parks and gardens

• depots

• golf courses

• swimming pools

• waste collection and management.

MethodologyDeveloping SOPs tailored to your council is a cross-council function. The process

requires the support and input from the general manager, directors, OH&S offi cers,

training offi cer, line managers, team leaders and all operational staff.

It’s not however just a matter of developing the SOPs and handing them over to the

operational personnel. The process of development needs to encourage ownership. A

training component to introduce the SOPs to all council personnel could also be written

into project plans.

Before getting your SOP development program underway, some key issues that need

attention include:

• resources

• who is going to lead this project?

• who is going to be ultimately responsible for the ongoing maintenance and review of

the SOPs?

• who is going to sit on a committee to review and amend the SOPs to maintain

consistency?

• document control

• how are all the SOPs going to be controlled in relation to version, and electronic

storage and access?

• how do you ensure that everyone has the latest version of the SOPs?

• maintenance

• what maintenance is going to be carried out and by whom?

• what review process will be in place?

• who will have authority to remove or develop new SOPs?



These matters should be discussed with the operational and corporate working parties.

Once they have been resolved it will be time to develop SOPs across the council. A

staged approach to developing SOPs may be needed, focusing initially on activities with

the highest likelihood of causing pollution.

The suggested fi rst step is to break down operational activities into service units. Sample

service units include:

• roads

• parks

• properties

• drainage

• cleansing services

• mechanics

• stores

• tree services

• project management

• sewer construction

• sewer maintenance.

Once the service units have been identifi ed, convene a meeting with key stakeholders

from each unit. Outline to these stakeholders what the project is about and discuss the

best way of developing, and then training personnel in the application of, the SOPs for

their units.

One approach for developing SOPs that a number of councils have used successfuly is to:

• ask the manager or team leader and other key operational players within each of the

service units to list all of the tasks that they carry out. Each service unit carries out

many tasks, for example the parks service units can be broken down to the following

tasks:

• maintaining parks

• preparing fl oral displays

• controlling noxious plants

• regenerating bushland

• ask your managers/team leaders and other key operational players to break down each

of these tasks into activities. For example, maintaining parks could involve:

• removing rubbish

• raking softfall

• watering garden beds

• cleaning toilets

• inspecting for public risks

• mowing

• edging

• whipper-snipping paths and fencelines

• weeding gardens

• spraying herbicides

• fertilising gardens

• mulching.

These activities will provide you with the list of safe operating procedures that need to be

produced.



• Each of the activities should then be broken down into the components of an SOP.

These components include:

• how do you carry out this task (step by step)?

• what are the identifi ed risks involved?

• what safety controls do you have to put in place?

• what personal protective equipment (PPE) is required?

• what qualifi cations are required to carry out this work?

• what additional training is required?

• what plant or equipment is required to carry out this work?

• what maintenance checks have to be carried out?

• what are the environmental issues?

• the task (e.g. waste disposal)

• the associated impact (e.g. ground contamination)

• the controls used (e.g. broom waste and dispose at designated landfi ll site).

• After all this information has been collected, it is time to place it into a format that you

feel would be suitable to the organisation (see sample provided in appendix C).

• Once the SOPs have been compiled they should be sent back to the managers/team

leaders and leading operational personnel for review and comment.

• The SOPs should then be sent to the operational personnel for review. This process

works well in a team meeting environment:

• on presenting the SOP, ensure that the team understands that these are draft copies

only and are open for comments

• ensure that the manager or team leader is available at the meeting for any

questioning – run through a few prior to the meeting so they are familiar with the

format

• then leave the draft SOP in circulation for a few weeks so that relevant staff have time

to review it – this period may vary in relation to the number of SOPs developed

• the manager or team leader should approve any changes before they are made.

• Once all staff have agreed on the information within the SOPs, they can then be issued

as fi nal documents. It is important however to stress that SOPs can be changed. There

are always new ways of doing things, new equipment coming out and better technology.

SOPs have to change to refl ect the way operational jobs are changing.

Once the SOPs have been issued as fi nal the review process outlined earlier in this

document should be implemented.

Case study See 5.4 The development of safe operational procedures – Rockdale City Council

Resources See appendix C, Sample standard operating procedures

Department of Environment and Climate Change NSW

Phone: 131 555


DECC has a range of industry guidelines that could be used to assist in the development

of standard operating procedures.

California Stormwater Quality Association, 2003. California stormwater BMP handbooks, www.cabmphandbooks.com



Environmental risk assessments

Overview Environmental risk assessment (ERA) is a tool that enables managers and their teams

to deal with uncertainty. It provides a step-by-step process to examine the current or

potential environmental impacts of your council’s operational activities and deal with them

before they become a problem.

Using ERA, managers and their teams can identify those aspects of their activities that

represent the highest risk and address these issues in the development of environmental

management programs.

In many ways, council operations staff have been doing ERAs since the concept was

fi rst developed. The difference now is that both community and legal standards have

been raised to the point where formal and structured approaches are often needed.

Making sure that the environmental considerations of any operational project have been

identifi ed in project planning and are being managed during the course of doing work is

good practice. The possible environmental impacts of your project or activity should be

assessed before damage is done and measures put in place to protect or minimise any

environmental damage that might occur.

MethodologyERA follows the same basic principles as assessing a workplace for occupational health

and safety risk. The main stages (shown in fi gure 4.1) are:

• identify the environmental hazards associated with council operational activities

• assess the likelihood and potential environmental consequences of the hazards

• identify the environmental risk

• prioritise the risks to get an idea of which measures need the most attention,

remembering not to forget about the seemingly ‘small’ things

• determine what control measures are needed to prevent environmental harm, or to

minimise impacts if something does occur – if no measures are available to bring risk

within acceptable levels, then the project may need to be redesigned, or sometimes

even halted

• review, apply and monitor environmental protection measures for effectiveness and

ongoing maintenance.

The advice of councils who are already implementing ERA is that the process works

best when tied in with the assessments being used by most councils to comply with the

OH&S Act.

Who’s responsible?The simple answer to this question is ‘everyone’. Ultimately, everyone involved in a

project, from the planning phase to the clean-up at the end of the project, has a role to

play in assessing the risk of environmental damage and doing what they can to prevent

environmental damage.

Under the POEO Act, both individuals and organisations can be penalised for damaging

the environment. Recent heavy penalties handed down by the courts show that these

laws are being taken seriously. So if you want to avoid being on the wrong side of the law,

a thorough environmental risk assessment will help.



Making it happenThere is no single way of approaching ERA. The most important thing is to ensure that

it is carried out at all relevant stages of project development and implementation, from

planning a project, to organising the equipment, through to making sure that the roadway

is swept after the day’s work, for example.

Phases of ERA typically include those listed below. Each has a slightly different focus:

• project planning phase

• identify and assess all the potential environmental risks of a project and plan ways to

address them

• systems planning phase

• incorporate environmental risk assessment into existing systems, like safe work

method statements

• implementation/operational phase

• ensure that the measures identifi ed as necessary in the planning stages are

implemented and are being maintained appropriately

• evaluation

• assess whether the measures proposed in the planning phase worked

• if not, how can they be improved for future application?

Project planningWhether planning for a one-off road construction project or a weekly operation such

as maintenance of parks and gardens, it is important that potential environmental risks

are identifi ed. For each risk you should identify ways of protecting against all of the

possible scenarios where you could cause damage to the environment. For example,

trucks carrying hazardous chemicals must have all of the required signage prominently

displayed, and drivers should be aware of the label requirements for cleaning up a

chemical. An important part of the project planning phase is ensuring that all of the staff

who are going to be delivering a project have suitable skills, training and equipment to

carry out the proposed environmental protection measures.

Systems planningA number of councils have incorporated an environmental risk component into their

standard operating procedures or safe work method statements (see case study 5.5,

Risk assessment, an integrated management system and council operations, Port

Stephens Council)

They assessed each particular activity completed by the operational personnel as being

of potential high, medium or low environmental risk and then identifi ed the measures

required to minimise that risk.

For example, concrete cutting can be a high environmental risk activity and the standard

operating procedure or safe work method statement for concrete cutting identifi es the

need for appropriate environmental protection equipment that should be used whenever

concrete cutting is undertaken.

On the other hand, grass mowing is usually identifi ed as being of low environmental

risk so therefore appropriate environmental controls are usually only required when the

activity is being completed near a waterway or drain.



Implementation/operational stageThe most thorough of plans is only useful if it is carried out as intended. However,

sometimes even the best plans need to be revised after a project starts because of

changed circumstances, so monitoring the effectiveness of the planned measures is

important. Having a process in place for making sure that all the protective measures are

maintained is also critical.

An internal environmental audit (section 4.2.3) is a very useful way of identifying the

effectiveness or otherwise of council’s ERA process.

EvaluationMany of the benefi ts of risk assessment depend on being able to predict how your

environmental protection measures will work in a given situation. Evaluating how things

have worked will help to prevent the same mistake being made more than once and

improve the future environmental performance of your council.

Figure 4.1 The environmental risk assessment process

Identify the environmental hazards of a proposed activity

Are the risks acceptable?

Yes No

No

Terminate project

Yes Modify project

Identify and implement environmental risk

management systems & procedures

Ensure systems & procedures are

maintained as necessary during the project

Evaluate measures for ongoing effectiveness and

future reference

Adapt measures if necessary

Can the project be modified

Assess how likely it is that environmental damage will occur in carrying out the project

What scale will the damage be in each potential scenario?



Identifying the risksThe following list shows some ways that environmental risks can be worked out:

• brainstorming – talking through the possible environmental risks of a project with as

many as possible of the project staff involved

• evaluation using multi-disciplinary groups – seeking input from a variety of specialist

areas (e.g. bushland, water quality, fi sheries, engineers, planners etc.)

• specialist and expert judgement – seeking the input of a specialist or professional

expert to provide formal advice (e.g. issues like acid sulphate soils)

• structured interview/questionnaires – surveying relevant people internally and/or

externally with specifi c structured questions to help guide environmental protection

measures

• operational modelling – a step-by-step analysis of the process analysing each of the

possible risk scenarios throughout the process

• historical analysis – how successful a particular activity has been in the past

• risk-weighting formulas – using objective formulas to help gauge the level of risk (see

example, page 45).

Whichever method you choose, it is important that you:

• consult the relevant people

• identify all of the potential environmental risks, the scale of each risk, and its probability

of occurrence

• identify appropriate measures to manage each of these risks within acceptable levels

• inform the relevant staff of their responsibilities

• provide the training, skills, and equipment needed to carry out the environmental

protection.

Case study

See 5.5 Risk assessment, an integrated management system and council operations

– Port Stephens Council

ResourcesRoads and Traffi c Authority, 2001. Contractor’s environmental management plan – pro formas and guidance notes Standards Australia, 2006. Environmental risk management – principles and processes

HB203:2006



Risk assessment in Tweed Shire Council

Many councils are adopting risk assessment techniques as part of their operations.

Tweed Shire Council is implementing an environmental risk assessment process as part

of its integrated operational management system and has developed a risk assessment

matrix to help to identify the level of risk for each of its operational activities (fi gure 4.2,

table 4.1).

Each of Tweed Council’s standard work procedures state that: ‘When carrying out

an activity you are required to act in such a way as to minimise any potential for

environmental damage’.

Council procedures also identify the six main types of environmental damage to avoid

when carrying out the job:

• water pollution (e.g. fuel/chemical spillage, erosion and sedimentation)

• air pollution (e.g. sewage odours, dust, excessive vehicle emissions)

• noise pollution (e.g. machinery/vehicle use in close proximity to neighbours)

• excessive waste generation (e.g. little re-use or recycling, poor storage)

• soil contamination (e.g. fuel/chemical spills, disturbing acid sulfate soils)

• harm to plants and animals (e.g. disturbing nesting sites, habitat destruction).

It is a requirement of operational staff that ‘ . . . environmental damage shall be managed

in such a way as to prevent its occurrence. If damage to the environment occurs, you

should take all appropriate measures to fi x any damage and take action to prevent it

re-occurring’.

How severe is the hazard you found? For each hazard think about:

1. How severely could it hurt someone, how

ill could it make someone, or how severely

would it impact the environment?

2. How likely is it to be that bad?

OH&S severity

Environmentalseverity

Very likely Likely Unlikely

Very unlikely

Kill or cause

permanent disability or

ill health

Catastrophic

environmental

event

1 1 2 3

Long-term illness or

serious injury

Major environmental

event 1 2 3 4

Medical attention and

several days off work

Moderate

environmental event 2 3 4 5

First aid needed Minor environmental

event 3 4 5 6

The numbers show you how important it is to do something

1 top priority: do something immediately6 low priority: do something when possible

To help in assessing the risk of environmental damage, the council’s risk matrix (fi gure

4.2) is a guide to assessing environmental risk levels and table 4.1 contains council’s

defi nition of environmental harm. The assessment process has been integrated into the

existing OH&S assessment process, meaning that it is not a burden for busy staff.

Figure 4.2 Risk assessment matrix – Tweed Shire Council



Internal audit systems

OverviewThere are two ways for council to fi nd out if their operational teams are meeting their

environmental management responsibilities. They are:

• developing and implementing an internal environmental audit process, informal or formal

• waiting for the community or DECC to tell them.

The internal environmental audit process is clearly the preferred option. The main

reasons for establishing an internal environmental audit process are to:

• minimise environmental damage that can be avoided

• get a good idea of current practices

• identify current standard practices that may require amendment

• ensure a high standard of routine maintenance activities

• identify whether environmental training has been effective

• identify and promote good practice

• identify and rectify poor practice

• demonstrate council is acting with due diligence.

An internal environmental audit process is an excellent way of encouraging a systematic

approach to environmental management across all council activities.

Table 4.1 Defi nitions of environmental harm – Tweed Shire Council

Catastrophic environmental event• long-term closure of the council operation, or

• loss of more than 70% of critical assets, or

• irreversible environmental damage, or

• death, or

• large public outrage.

Major environmental event• environmental harm that is irreversible or not long term, or

• suspension of licences, or

• termination of agreements, or

• prosecution, or

• serious injury/employee lawsuits, or

• signifi cant negative media coverage, or

• fi nancial losses of over $100,000.

Moderate environmental event• regulatory breaches, or

• negative community/customer feedback, or

• fi nancial losses up to $100,000.

Minor environmental event• no need for additional resources, or

• can be managed by implementing simple on-site controls.



Methodology

1 Developing an audit protocol and toolIt is recommended that council involve leading members of their operational teams in the

development of the internal environmental audit process. Council may consider inviting

one or two leaders from each of their main areas (i.e. road construction, water and sewer,

parks and gardens, and depots). These people then become part of the internal audit

working party. A typical agenda for the fi rst working party meeting is outlined below:

1 Outline of the process

2 Objectives of an audit program

3 What should we be looking for at different job sites? Developing an audit tool.

4 Developing an audit process

• How often should it happen?

• Who should be on the team?

• What characteristics do they need?

• How should the sites for auditing be selected?

• What do we do when we fi nd very good practice?

• How should we deal with poor practice?

5 How should we promote the audit process to all personnel?

6 When should the audit process get underway?

7 Next meeting to review protocol and process.

The outcomes of this meeting usually form the basis of the internal audit protocol. A

sample audit protocol is included in appendix D. The main points for discussion in this

meeting are usually:

• Review frequency – this varies from council to council, but is typically one day every six,

eight or twelve weeks

• Audit team structure – again this varies between councils. Some councils may conduct

environment and safety audits on the same day, using the same team. The members of

the team required are therefore:

• the environment specialist

• the safety specialist

• one or two members of the audit working party.

The two operations members of the audit working party could be rotated out of the audit

team after three audits in order to develop auditing skills among as broad a range of

operational personnel as possible.

• Dealing with poor practice – most operational personnel recognise the importance of

dealing with poor practice. They usually recommend that the audit team should identify

the causes as resulting from:

• a lack of knowledge, in which case the audit team recommends training for those who

need it

• a lack of resources, in which case the audit team makes recommendations to

management about the resource support needed by operational teams

• a poor attitude, which is usually reported to supervisors and above.

• Recognition of good practice – it is important that the audit team also identifi es and

praises good practice. A number of councils also initiated ‘operational crew of the year’

awards.



• Site selection – most councils on the day of the audit divide their sites up into those that

are:

• high-risk environmental/safety

• medium-risk environmental/safety

• low-risk environmental/safety

• subcontractor works.

They then select and audit a minimum of two jobs from each category except low-risk

and, if time permits, another job at random. Most audit teams consider it important for the

audit process to take into account the work of contractors.

2 Audit toolsOnce matters like site selection, audit frequency and how to deal with good and poor

practices are decided, you will need to develop an on-site audit tool to use on site visits.

Council may consider reviewing the tools used by their building site auditors or small

business auditors. Other sample audit tools are included in the case study section and in

appendix D.

3 EvaluationIt is important that copies of all internal audit sheets and summary sheets from each audit

cycle are analysed and kept. These audit cycle reports will provide an excellent insight

into the overall success or otherwise of all council’s programs designed to enhance the

environmental management capacity of its operational teams.

ExampleAppendix D outlines a sample audit tool used by a number of councils to guide their

internal audit process.

Case studySee 5.6 Internal environmental audits – Hurstville City Council

Emergency response

OverviewAs part of a comprehensive environment management system your organisation should

put into place a response procedure for pollution spills. The procedure should ensure

that council will be able to combat a pollution incident occurring as a result of a council

operation or other cause. In addition, council should develop concurrently a response

procedure for orphan hazardous waste incidents (i.e. dumped hazardous waste such as

asbestos), as the characteristics of both types of incidents are similar. Pollution incidents

that are unfortunately common for councils include burst hydraulic hoses on heavy

equipment, spilt materials from deliveries such as oils to the depot etc. When councils

develop a pollution response plan they will also generally develop and provide resources

to combat pollution incidents on a large scale where spills occur on council roads and

other assets such as parks. The capacity to respond to an environmental emergency is

required under section 4.4.7 of the EMS requirement of ISO 14001.



RationalePollution spills occur infrequently, although their environmental impacts can be signifi cant.

Therefore, councils need to be prepared for such contingencies to ensure that the

environmental impact of a spill is minimised. Not having a pollution spill procedure and

appropriate resources at hand can place the local environment at serious risk of harm.

All environments need protecting, but in some cases the local environment may be

particularly vulnerable or have a high value placed on it. Not only should council have a

pollution spills procedure, but also the necessary resources to combat the incident and

staff training to ensure effectiveness of response and clean-up measures.

When a pollution spill occurs or orphan hazardous waste is located and reported to

council, council has a role in managing a clean-up response if it occurs in a public place

it owns. Likewise, on a smaller scale, if council’s operations lead to a pollution spill, then

council is required to clean it up.

However, like most things, the situation can be more complex. On roads that are operated

by the Roads and Traffi c Authority the responsibility for pollution clean-up rests with that

authority. Likewise, it is up to DECC to investigate the pollution spill on an RTA road if

required. However in some cases in country areas the RTA contracts the local council to

maintain roads.

On other roads where the asset belongs to council, staff from council can attend the

pollution spill to assist in the clean-up as well as providing a regulatory response.

In many cases, it may be necessary to contact the fi re brigade to render the spill safe. If

council is not sure what has been spilt it is essential that the fi re brigade be called.

MethodologyIn order for council to respond to a pollution spill or orphan hazardous waste incident a

comprehensive program is required. Every council operates differently and, in recognising

that, the following information is a guide to elements of a good program – the actual detail

will differ between councils.

As part of an EMS program, council should ensure that during any of its operations the

necessary pollution spill equipment is available. This often means simply having a basic

spill kit available, such as carrying a 10-litre bag of oil absorbent on a truck. Generally

equipment such as garbage compactors and other mechanical equipment where a burst

hydraulic oil hose could cause a pollution spill may require a pollution kit to be carried.

Basic equipment that could be considered for council vehicles might include:

• oil absorbent/clean-up material

• absorbent booms

• witches hats

• contact phone numbers for assistance.

Resources that your council may have stored ready for use in case of a larger spill would

include:

• bulk absorbent

• sandbags/sand

• shovels/brooms

• street sweeper

• access to trucks to transport staff and resources



• emergency barricades/traffi c control equipment

• personal protective gear – safety vests etc.

• a known in-house procedure

• after-hours contact phone numbers

A point often overlooked is that once an oil absorbing material is placed on a spill, it

needs to be swept up and disposed of appropriately. Do not leave absorbent and oil on

location as it could be swept into the waterways with the next rain.

For larger incidents it is suggested that a coordinator be appointed to oversee pollution

spills and orphan hazardous wastes. As the name suggests, the coordinator will oversee

the implementation and running of clean-ups. In basic terms a council has two roles at an

incident:

• an operational role for assisting in a clean-up

• a regulatory role in investigating the cause and, if appropriate, prosecuting polluters,

unless this role is taken by DECC.

Operational response

ResourcesCouncil will require resources to effectively respond to a spill. In some cases a pollution

trailer may be required. A pollution trailer can contain all the equipment and materials

needed to effectively clean up a spill. For example the trailer may contain absorbent,

brooms, shovels, traffi c signs etc. Having a prepared trailer is a great advantage because

all the necessary equipment is organised and ready to go.

Trained staffIn order for staff to respond to a spill effectively, it is recommended that a training course

be run to ensure that everyone attending the incident knows exactly what is required.

Some critical issues that need to be addressed through training include:

• site safety for pedestrians and traffi c and council staff

• containing a spill and clean up

• safe disposal of waste materials

• coordinating staff.

Site managementIt is important that senior operational staff are trained in site management issues. The site

manager will need to be able to:

• liaise with the fi re brigade and other hazard respose teams

• organise resources

• organise staff

• manage the site to protect the environment

• ensure the safety of their personnel and the public

• organise for the disposal of materials rendered safe.



Regulatory responseCouncil may also have a regulatory role in relation to pollution spills and orphan

hazardous waste incidents. Council offi cers who are authorised with powers under the

POEO Act should attend incidents. Authorised offi cers have two primary jobs: investigate

the circumstances of the pollution spill and effectively ensure that costs associated

with the clean-up can be recovered. Council will also need to look at having tools and

adequate training to support staff in their regulatory responses.

InvestigationCouncil-authorised offi cers should investigate the circumstances around either a pollution

spill or the occurence of orphan hazardous waste, unless this is a DECC role. With the

dumping of orphan hazardous waste, a breach of sections 115, 144 and 147 of the POEO

Act has occurred and needs to be investigated. In relation to a pollution spill, sections

115, 116 and 120 of the Act concern pollution of waterways. If the offender can be found,

then a fi ne can be issued; or if the breach is serious enough, then prosecution might be a

more appropriate option.

Within the POEO Act there are many tools available to ensure the protection of the

environment as well as to recover costs associated with these incidents. Ensure you

are familiar with legal tools such as clean-up orders and notices requiring payment of

reasonable costs and expenses.

Cost recoveryIt may be the case that an incident cannot be attributed an offender. Council-authorised

offi cers will still need to attend an incident to conduct an investigation. DECC administers

the Environmental Trust fund which can assist councils to recover costs. The fund is

able to pay for clean-up costs as well as disposal costs associated with spills or orphan

hazardous waste. It is a good idea to be familiar with the fund procedures and details

prior to any incidents.

ToolsIt is suggested that the coordinator develop a range of tools and training for staff in

relation to regulatory issues. It is important to build capacity within your organisation to be

able to effectively implement a regulatory response to spills and orphan hazardous waste

incidents. Some tools that are valuable while at a spill may be:

• a guide or procedure for regulatory staff

• a phone list of relevant organisations or people who may be able to assist

• provide a ‘key contacts list’ with phone numbers for all appropriate response

personnel in every truck and council vehicle

• the list should also identify whereabouts of council clean-up kits and the most

appropriate way of engaging the people responsible for the use of those kits in

response to an incident

• circulate copies of this list through traditional council education networks including

toolbox talks, noticeboards, store rooms and other outlets

• POEO Act clean-up order book

• pollution sampling requirement guide.



TrainingTraining of staff is important for ensuring a prompt and effi cient response to spills or

orphan hazardous waste incidents. This is particularly important as these incidents are

infrequent in nature and staff can take a long time to become familiar with the response

procedures in circumstances which invariably differ in each case.

It is suggested that authorised offi cers be trained on the job at incidents as well as

formally in procedures and tools developed by the coordinator/council. Hopefully the

training will assist in clarifying the roles of staff as well as ensuring an effective presence

on site.

CoordinationHaving a pollution spill and orphan hazardous waste coordinator will allow for the various

elements of a program to be managed more effectively. The role of the coordinator would

be to facilitate the various elements of the program. The facilitation could include:

• sourcing funding

• working out technical issues and procedures

• providing training

• tracking incidents

• providing information and keeping teams updated.

Many resources are required to implement a comprehensive pollution spill and orphan

hazardous waste incident program. These would include things such as:

• clean-up materials

• public safety equipment

• personal safety equipment

• cameras for pollution investigations etc.

It is recommended that each council carefully consider their own specifi c requirements

and the equipment that would be needed for their particular needs.

The trailer in fi gure 4.3 has been specifi cally designed for carrying materials to a pollution

spill and orphan hazardous waste incident.

Rockdale City Council offi cers place emergency response reminder notes in all the

council vehicles as an effective way of reminding personnel of their responsibilities.

Case studySee: 5.7 Responding to pollution spills and orphan hazardous waste incidents –




Managing subcontractors

OverviewCouncils often use subcontractors to complete selected operational activities. Hiring

subcontractors does not however relieve council of its environmental management

responsibilities.

The provisions of the environmental laws make it very clear that no matter who is carrying

out work on behalf of an organisation, that organisation should have systems in place to

ensure the work is being carried out appropriately.

Section 257 of the POEO Act also identifi es the liability that councils have in relation to

subcontractors on their site. This section reads:

In any proceedings under this Act, the occupier of premises at or from which any

pollution occurs is taken to have caused the pollution, unless it is established that:

(a) the pollution was caused by another person, and

(b) the other person was not associated with the occupier at the time the pollution

occurred, and

(c) the occupier took all reasonable steps to prevent the pollution.

A person is associated with the occupier for the purposes of paragraph (b) (but without

limiting any other circumstances of association) if the person is an employee, agent,

licensee, contractor or subcontractor of the occupier.

There is also an issue of equity in relation to the management of subcontractors.

Some council operational supervisors have expressed concern that subcontractors

did not appear to need to meet the same rigorous standards of environmental and

safety management as council teams. When these council teams are bidding against

subcontractors for the same work, it is important that both groups understand they are

expected to meet the same performance standards.

Figure 4.3 Emergency response trailer



There are very good reasons for putting in place systems that ensure all subcontractors

meet their environmental responsibilities. There is much more to the effective

management of subcontractors than merely inserting a few environmentally focused

clauses in a contract.

MethodologyBefore starting, talk to council’s contracts manager about including appropriate

environmental management requirements in contract documents. It would be important

to point out that whether these conditions are in the contract or not, councils are still

ultimately responsible for ensuring all of their subcontractors act with reasonable care to

ensure the environment is protected. So the development of a system which encourages

appropriate environmental management behaviour in subcontractors certainly makes

sense.

If the contracts manager decides to incorporate appropriate environmental requirements

in each of phase of the contract cycle, they will need support in assessing the claims of

the tenderers. That support should be sought from council’s environmental staff or other

appropriate offi cers.

The main phases of the contract cycle are:

• preparation of contract documents

• preferred contractor/supplier listings

• tendering/expressions of interest

• tender review

• contract completion

• contract review.

The following paragraphs list the actions that some councils have put in place at each of

these phases to ensure good environmental practices.

Preparation of contract documentsEveryone who works regularly with contractors will know that if ‘it is not in the contract’ it

is hard to make it happen. It is therefore important that people responsible for preparing

contracts incorporate appropriate environmental management clauses. Conditions can

be included in either the general conditions of contract, or in the conditions relating to

specifi c contract works.

It is recommended that councils consider incorporating both general and specifi c

conditions. Samples of both are included in Appendix E.

Preferred contractor/supplier listsIn most councils, contracts over a certain value are required to go to open tender.

For contracts below that value, or for routine maintenance activities, a number of

councils have established lists of preferred contractors and suppliers. Such councils

believe the lists provide them with more certainty about the quality of work provided by

subcontractors.



Councils should develop and publicise minimum performance standards for

subcontractors seeking to be included on these lists. Some of these standards could

include:

• appropriately trained personnel

• environmental management systems in place

• environmental management plans for their major facilities and projects

• excellent track record.

Councils can also require contractors to provide copies of all relevant documents as part

of their application for inclusion on the list.

As an extra incentive to ensure contractors manage their projects appropriately, some

councils remove contractors from their preferred lists if council inspections identify

inappropriate practices or incidents that can be directly attributed to the actions of the

subcontractor.

Tendering/expressions of interestCouncils should specify their environmental management requirements in tender

documents. These requirements will vary depending on the nature of the work.

A number of councils link their requirements to the dollar value of the contracts or the

environmental sensitivity of the site where the works are to take place. One council for

example requires that tenderers bidding for work over $100,000 have an environmental

management system in place. They also require the tenderer to provide an outline of an

environmental management plan they would use to minimise the environmental impact of

a particular project.

Another council has similar requirements for contractors bidding to do work in highly

sensitive areas regardless of the value of the activity.

At the very least, tender documents should outline council expectations in relation to

development and management of environmental plans for projects. These expectations

may include:

• skills and experience of contract staff

• risk assessment procedures

• incident response procedures

• ongoing review mechanisms to ensure compliance with council requirements.

Councils introducing these requirements into their contracts should offer briefi ngs to both

existing and new contractors in order to ensure the quality of tenders they receive is up to

standard.

Tender review Contract managers or other offi cers responsible for reviewing tenders are likely to need

specialist advice in relation to assessing the environmental expertise or otherwise

of contractors. That advice could come from council’s environmental specialists who

could be invited to review the contractor’s EMS and environmental management plans

if required. The environmental staff could also be encouraged to talk to some of the

contractor’s previous clients to investigate their on-site performance.



Contract completionCouncil should have a system in place to ensure contractors are meeting all of

their environmental responsibilities. It is important that council offi cers regularly visit

contractor work sites. They should also have a basic site audit tool to formally check the

performance of their contractors and keep a record of their visits.

If the contractor is given a verbal direction to improve on-site practice it is recommended

that this direction be followed up in writing.

As mentioned previously, councils may consider implementing a system that limits the

capacity of contractors to bid for future council work if they have inappropriate practices

on job sites or incidents occur as a result of the subcontractor’s actions.

Contract reviewThere is a performance review phase in many council contracts. It is important that

the review also includes a section for reporting on the environmental management

performance of the subcontractors. Copies of the review reports should be provided to

council management for their information as well.

For further informationDepartment of Environment and Climate Change NSW

Phone: 131 555


The Department’s website regularly lists details of successful prosecutions which

often involve subcontractors. This information can be particularly helpful in convincing

subcontractors and contracts managers of their responsibilities.

Forming links to occupational health and safety

OverviewTo meet the requirements of the Occupational Health and Safety Act 2000, most councils

(and all other organisations) need to have:

• safe work practices in place

• a safety risk assessment process

• OH&S consultation arrangements with employees

• regular safety audits.

As noted earlier, this guide recommends implementing all of these processes with an

environmental as well as a safety focus. Clearly there are parallels between the program

elements required for effective OH&S and environmental management systems.

So it can be useful for the environment and OH&S teams at council to work together if

possible. Some councils have even developed an integrated management system (IMS)

which integrates the organisation’s environmental and OH&S programs.

Such councils have formed the view that integrating the systems can reduce paperwork,

resources and time while promoting a common approach to the critical issues of safety

and environment.



MethodologyYour management review group (section 1.3) may have included a representative of

council’s OH&S team from the beginning.

Even if a representative of that team has not been involved in discussions to date it

is important to start talking to them as soon as possible on the value of an integrated

system.

Some councils have indicated that their OH&S specialists were ‘just not interested’ in

the integrated system. Even so, it is important to talk to your OH&S team at least to

coordinate the timing of environmental and safety activities so that clashes are avoided.

If your council decides to develop an integrated system, you will need to develop project

plans at two levels with your OH&S colleagues:

• pre-planning

• implementation planning.

Pre-planningThe purpose of the fi rst plan is to:

• identify the need for an integrated system

• promote the benefi ts of an integrated system

• ensure resources and budgets are allocated for the development and delivery of an

integrated system.

Key elements of this project plan will include:

• identifying where council is at with the development and delivery of their environmental

and their OH&S program elements

• identifying the program elements within both programs that could be incorporated into

an integrated system

• developing a communication strategy that targets management and operational teams

to encourage their support of an integrated system

• identifying likely budget and other resource requirements for developing and delivering

an integrated system. It is important within this component to identify a need for

ongoing budget commitments over the life of the project. Those councils with successful

integrated systems indicated a timeframe of three to six years as appropriate.

Implementation planFollowing the development, presentation and acceptance of the need for an integrated

system, a new project plan needs to be put in place. This project plan would include:

• work plans for the development and delivery of each of the integrated components.

Within this part of the plan, clear priorities have to be identifi ed. There will be a number

of elements in the integrated system and not all of them can be introduced at the same

time. The project team working on the development of an integrated system needs to

identify priorities, targeting activities with high OH&S or environmental risks

• clearly identify who has overall responsibility for the projects and who is responsible

for different components of the project. It is important to make someone responsible

for the overall project even if that responsibility has to rotate between OH&S and

environmental specialists

• have a communications strategy that targets all council personnel regularly. It’s not just

a matter of convincing people of the need for an integrated system – they should be

kept up to date with all changes in the system and the benefi ts those changes have

generated

• specify a regular review process.



Over the longer term successful integrated systems, like successful environmental

management and safety management systems, are all about cultural change. Good

plans, effective communications, regular reviews and supportive management and

leaders are all key components of generating that effective long-term change.

Example See panel, this section, Gosford City Council’s integrated management system corporate

policy.

4.3 Becoming a group 4 councilAll of the group 3 council elements do not have to be in place before you consider some

of the group 4 program elements. The distinction between group 3 and group 4 elements

recognises that:

• the incorporation of environmental components in job descriptions is likely to be

successful only when a positive environmental culture already exists within council. In

order for that culture to develop, a number of program elements needed to be in place

• international certifi cation of an EMS should only be sought when many of the key EMS

program elements have been in place and reviewed over a period of time.

These two additional program elements should be developed simultaneously, noting that

they will take some time to implement.

Separate project plans should be developed for each program element.

The journey from group 3 to group 4 is probably the one that will take the most time.

That’s why it is recommended that introductory elements of the group 4 program be put

in place while the group 3 programs are evolving. If you successfully implement both

of these program elements, your operations development program should then have a

permanent home within the core business activities of your council.

Environmental components in job descriptions

Overview‘If you want to really focus people’s attention on improving environmental management

performance make it a part of their job descriptions and accountabilities.’

This was the overwhelming view of offi cers from some group 4 councils involved in the

consultations for this guide. Incorporating environmental components in job descriptions

is not however a simple process. Job descriptions have usually evolved over a long

period and have involved detailed and sometimes delicate negotiations between the

personnel involved, council human resources specialist and often the relevant unions.

You should allow a reasonable amount of time for this project element. It will take time,

energy, expert negotiations, skills and patience. Feedback from councils who have

incorporated environmental components in their job descriptions indicate that this

has consolidated the place of environmental management as a part of council’s core

business.

With that type of outcome, the time, energy and effort required to complete this project

element is certainly worthwhile.



MethodologyThe fi rst step in this project element is to speak with council’s human resources

specialists to confi rm the process for developing or amending job descriptions. All

elements of this process should then be incorporated into a project plan.

You should then work with your management and operational steering committees to

identify:

• top-priority jobs for the incorporation of environmental components

• general environmental requirements which could be incorporated into job descriptions

• specifi c components that could be incorporated into each of the top-priority job

descriptions

• the criteria that will be used to assess the effectiveness or otherwise of the council

offi cer in meeting these new job description requirements

• the consequences if the new job description requirements are not met.

Once the top-priority jobs have been established, negotiations for the incorporation of

environmental components into the relevant descriptions should be initiated. Council

human resources specialists will in most cases guide these negotiations.

Once the changes have been incorporated into job descriptions this project is still only

about half done.

Changing job descriptions can make people suspicious. It is important that any change

to job descriptions be supported by a rigorous communication program. Everyone who is

affected by a change in their job description needs to understand:

• why job descriptions have been changed

• what’s in it for them

• what it will mean to the way they work

• how their performance will be measured

• what will happen if they cannot meet the new requirements as outlined in the job

description.

This is a signifi cant program. Managed well it will generate long-term benefi ts including

the consolidation of an all-important positive environmental culture that recognises

environmental management as a part of council’s core business. Managed poorly it can

generate suspicion and resentment.

ExamplesTypical inclusions in job descriptions for operational personnel could be:

• ‘ensure all activities are carried out in line with council’s environmental policy’

• ‘ensure all activities are carried out in a manner that protects and preserves the local

environment.’

Performance indicators that could be included in job descriptions at any level could

include:

• ‘to demonstrate the contribution through programs or individual activities made to assist

council achieve its environmental goals’

• ‘to demonstrate the contribution through programs and individual activities made to

assist council meet the commitments of its environmental policies.’



Towards certifi cation

OverviewIf you have made it this far, you probably have an excellent operations development

program in place. You would certainly have all the elements of an environmental

management system for your operational activities.

So where to from here?

A number of councils have decided to pursue certifi cation of their environmental

management system (EMS) to International Standard ISO 14001.

Councils with accredited systems maintain this gives them a great deal of depth and

credibility both within the council and throughout the community and business worlds,

and has a signifi cant infl uence on the maintenance of a positive environmental culture.

They are also allowed to use the International Standard ‘ticks’ on all of their relevant

information materials.

Getting the ‘ticks’ is not however a simple process. Councils are required to submit their

EMS to a rigorous certifi cation process. They should also commit to regular ongoing

reviews of their systems.

Those councils who have an excellent EMS in place and have chosen not to pursue

accreditation are of the view that if a system is set up properly it does not need to develop

further. They also argue that the money spent on the certifi cation process could be better

spent on other environmental management programs.

To go through the certifi cation process or not? In the end, it’s up to each council to make

up its mind on the best way to meet its environmental obligations.

MethodologySeeking and obtaining formal accreditation of an EMS through certifi cation is a

challenging, rigorous and detailed process. This proposed methodology is a very

basic outline of what is required. First, nominate an offi cer who should have overall

responsibility for the certifi cation project. Once identifi ed, that offi cer should be

encouraged to attend an EMS/ISO training and information session.

Once the nominated offi cer is familiar with the certifi cation process, the following steps

should be considered:

1 Identify formal certifi cation/accreditation agencies.

2 Organise tender bids from a selection of those agencies. The tender bid should

outline the process and costs associated with taking your council’s EMS through to

accreditation. The tender bid should also include ongoing costs for regular reviews of

your system.

3 Make your business case for accreditation outlining the costs and benefi ts. Be sure to

promote the benefi ts associated with presenting a positive environmental message to

council’s personnel, the community and local businesses. Also be sure to identify the

need for ongoing budget support for the certifi cation program.

4 Develop a project plan (section 3.3).

5 Implement the project plan. Councils have indicated it can take from one to three years

to obtain formal accreditation for an EMS. This depends on many things, including

the systems that are already in place and the resources allocated to the certifi cation

process.



6 Once accreditation is awarded, organise a presentation ceremony with the mayor, the

general manager and all operational personnel. It is important that the achievement of

accreditation is shared.

7 Organise for the placement of the ‘ticks’ logo on all appropriate council material (e.g.

letterhead, council envelopes, stickers on the sides of council trucks).

8 Review the system regularly.

Case studySee 5.8 Towards ISO 14000 certifi cation – Bankstown City Council

ResourcesEnvironmental management systems – requirements with guidance for use (AS/NZS ISO

14001: 2004)

Environmental management systems – general guidelines on principles, systems and

supporting techniques (AS/NZS ISO 14004: 2004)

Guidelines for quality and/or environmental auditing (AS/NZS ISO 19011: 2003)



Gosford City Council

Integrated management system corporate policy

ObjectivesTo provide a high standard of health, safety and wellbeing for employees in the work

environment.

To effectively integrate the principles of ecological sustainability into all council functions

so as to achieve a clean, healthy and ecologically sustainable environment.

Policy statementGosford City Council is committed to:

1 Providing a safe workplace, safe working methods, and safe plant and equipment in

accordance with the objectives of the Occupational Health and Safety Act, Regulation,

and other relevant legislation, at the same time ensuring that the workplace, work

methods, plant and equipment used conform with environmental Acts and associated

legislation. Safety and environmental protection is an integral and vital part of the

successful performance of any council function.

2 Ensuring work practices adhere to all relevant national and international standards and

recognised industry codes of practice, other requirements placed upon the council or to

which the council subscribes.

3 Establishment and maintenance of a set of measurable objectives and targets for

OHS and environmental performance (including prevention of pollution), to ensure

continuous improvement of its integrated management system (IMS).

4 Establishment and maintenance of a formal process of consultation with employees

(and where relevant, contractors and labour hire employees) in respect of the decision-

making processes impacting on workplace OHS and the environment.

5 Ensuring that OHS and environment information is disseminated to all employees (and

where relevant, contractors, labour hire employees and visitors to the workplace).

6 Ensuring that contractors, their employees and labour hire employees comply with

council’s OHS and environmental requirements when working on council premises.

7 Ensuring that all signifi cant OHS and environmental hazards in the work place are

identifi ed, and the risks associated with these hazards assessed. Council is further

committed to controlling these hazards by way of elimination, or where elimination is

not possible, minimisation of the associated risks.

8 Ensuring that all employees, labour hire employees, volunteers, and persons on work

placement programs, are provided with training to enable them to work with minimal

risk to the health and safety of themselves and others, as well as to the natural

environment.

9 Ensuring that contractors and labour hire companies provide adequate training to those

designated by them to work at council sites.

10 Effective implementation of the Occupational Health, Safety and Environmental

Corporate Policy.


Case studies 63

5. Case studies

5.1 Developing an environmental management system – a metropolitan experience

North Sydney Council 64

5.2 Developing an integrated management system – a regional experience

Tamworth Regional Council 66

5.3 Environmental awareness and induction programs

Blue Mountains City Council 69

5.4 The development of safe operational procedures

Rockdale City Council 72

5.5 Risk assessment, an integrated management system and council operations

Port Stephens Council 74

5.6 Internal environmental audits

Hurstville City Council 76

5.7 Responding to pollution spills and orphan hazardous waste incidents

Marrickville City Council 79

5.8 Towards ISO 14001 certifi cation

Bankstown City Council 82



5.1 Developing an environmental management system – a metropolitan experience

North Sydney Council

RationaleCouncil determined that an environmental management system (EMS) should be

developed in order to provide a structured approach for managing organisational

environmental risks and helping to achieve desired environmental outcomes. The EMS

also aimed to:

• defi ne tasks and responsibility for actions

• coordinate environmental management across council

• provide greater operational control

• increase compliance with legal requirements, and improve relations with regulators

• demonstrate due diligence

• enhance public image through encouraging external recognition of environmental

commitment

• demonstrate leadership for other businesses within the local government area

• achieve cost savings

• provide a framework to identify areas for improvement in environmental performance.

MethodologyCouncil fi rst piloted the EMS development process at the North Sydney Olympic

Pool, and expanded the process by stages to include other business areas of council

operations. The specifi c areas targeted across council operations were:

• engineering works

• parks and gardens

• street sweeping

• waste management

• bushland management

• environmental and building compliance.

The steps involved in establishing the corporate EMS included:

• undertaking an initial environmental review

• briefi ng management and councillors

• identifying relevant aspects and impacts through workshops run for council staff

• developing environmental management plans (EMPs) for each business area, including

objectives and targets

• integrating existing programs or elements into these plans

• conducting annual training and awareness sessions

• developing and implementing a corporate environmental induction module

• developing operational control procedures incorporating environmental and

occupational health and safety (OH&S) considerations

• developing an audit checklist and conducting regular audits

• undertaking management reviews

• regularly reporting to senior management and council’s environmental committee.


Case studies 65

Outcomes

Development of a training cultureWhen council ran its initial EMS training and awareness program in 2001, many people

felt it needed to become an ongoing process, and council subsequently committed to

running annual sessions for relevant staff. Council has developed a series of training

modules for different areas, covering general environmental issues, aspects and impacts,

legislation, due diligence, risk assessment, sustainability and EMPs.

Corporate environmental induction Council has introduced an environmental module into its induction program as part of the

EMS. Induction is provided to all new employees, and addresses legislative obligations,

due diligence, ecologically sustainable development and council’s systems and programs.

Risk assessment The development of the EMS has improved the awareness and understanding of risk

assessment, and in particular of the potential environmental impacts arising from activities

and operations. The aspects and impacts workshops, in particular, enabled participants

to clearly see these links and improve their skills in identifying risks associated with work

practices.

Development of environmental management plans The plans developed for the six business areas included in the EMS framework each

have objectives, targets and an action plan. The action plans include operational

safeguards and have incorporated actions from other existing programs in council. For

example, the Olympic pool EMP includes actions from council’s Greenhouse Action Plan.

Operational controls Staff were involved in developing operational controls and work methods to meet ISO

14000 requirements and address identifi ed areas of risk. Controls were developed

for operations in the parks and gardens, pool, and engineering works depot areas.

Operational staff are now working in accordance with the procedures. A waste contract

management plan has been developed to ensure that the waste management contract is

effectively managed to minimise environmental risk.

Integration of OH&S componentsThe process of integrating the EMS and OH&S systems continues as the opportunity

arises. Integration has already occurred in the areas of operational controls, management

system procedures, documentation and some training. Further integration is anticipated

for risk management and training programs.

Lessons learnt• consider having a full-time EMS coordinator

• establish and formalise the steering committee early in the process

• market the EMS to different stakeholders within council

• identify and appoint a director to be the champion of the EMS

• provide key personnel with formal EMS training early in the process.



5.2 Developing an integrated management system – a regional experience

Tamworth Regional Council

RationaleTamworth Regional Council (a body made up of the

amalgamation of fi ve local government bodies: Tamworth City, Barraba Shire (part),

Manilla Shire, Parry Shire (part) and Nundle Shire) decided to integrate its environmental,

OH&S and quality systems because:

• the existing National Safety Council (NSCA) 5 Star Safety System did not have full

organisational support, and was therefore was not fulfi lling council’s needs for OH&S.

This system was also inappropriate for the diversity and complexity of activities

conducted by council

• council had identifi ed that an integrated framework could meet the goals and

performance measures for safety, quality and environmental management in its long-

term 2020 Vision document and annual management plans

• external statutory authorities were increasing pressure on council to lift its performance

in capital works projects requiring quality, safety and environmental management plans

• council needed to meet its obligations under the new OH&S legislation

• council wished to be innovative and lead the region in the emerging trend of integrating

management systems for quality, safety and the environment.

MethodologyThe council’s integrated management system (IMS) was inspired by RTA specifi cations

related to works on state and national highways through the single invitation contract.

The system developed to meet these requirements was adapted for council’s operational

areas as follows:

Initiation • obtaining senior management approval to develop and implement the IMS

• adapting the RTA system for in-house use

• dedicating a team of three staff, each having a specifi c expertise in quality, safety or

environmental management, to coordinate the development and implementation of the

system

Program development• networking with other councils to learn from their examples

• training the project coordinators in the use of IMS

• identifying the scope of the project and developing a program to meet this

Implementation• staging program implementation, initially focusing on the technical services operational

areas as these offered the greatest diversity, risk and exposure

• focusing on OH&S aspects of the system to meet council’s legal requirements

• collating existing documentation and establishing working groups to document work

procedures


Case studies 67

Consultation, program review and documentation• consulting work teams to identify activities and develop standard risk assessments, safe

work method statements and standard work procedures

• developing the IMS manual in accordance with elements of ISO 9001: 2000 Quality

Systems, ISO 14001: 2004 Environmental systems and AS 4801:2001 Occupational health and safety management

• conducting an external audit/gap analysis to identify system defi ciencies

System roll-out• extending the implementation of the IMS to other directorates of council

• holding IMS induction training sessions for managers, supervisors and staff as the

system was expanded throughout the organisation.

Outcomes

Qualifying for WorkCover’s premium discount schemeMeeting the benchmarks set in the WorkCover premium discount scheme has

signifi cantly reduced council’s premium for workers compensation insurance. Better

management of injured workers and the application of safer work practices have also

contributed to lower claims costs.

Change in organisational culture There is evidence of people embracing the IMS with a greater awareness of quality,

OH&S and environmental issues.

Successful defences against litigation In the litigious society that we now live in, councils are often a target. The records that are

maintained though the IMS have been used successfully in defence of council in some

litigation.

Positive relationship with WorkCover A positive working relationship has developed between council and local WorkCover

inspectors because of the safety initiatives and processes introduced through the IMS.

Reduction of waste Environmental programs promoting the recycling of waste materials have diverted

signifi cant quantities of waste from landfi ll.

Increased networking within the regionThere is excellent work being done by other organisations in the region, and sharing of

that knowledge/work can save signifi cant time and resources.

Conformance to legislation Increasingly, we are seeing legislation imposed on our operations, and having a

management system in place makes it much easier to demonstrate compliance.



Lessons learnt• make a start and use continuous improvement to develop the system

• keep it simple – if the system or documentation is too complex people will not use them

• identify the right people to develop, drive and audit the system – fulltime resources are

required

• identify whether the system is being applied to the entire organisation or only certain

directorates/activities, as this will be a factor in deciding where the staff driving the

system should sit in the structure

• combine standard risk assessments, safe work method statements and standard work

practices into a single document linked to other plans and strategies

• risk assessment methodology can help to prioritise decision making but the

methodology needs to be identifi ed from the start

• commitment to IMS principles should part of position profi les or role descriptions for all

staff at supervisor level and above.


Case studies 69

5.3 Environmental awareness and induction programs

Blue Mountains City Council

RationaleCouncil’s 25-year strategic plan required Operations Branch to improve

resource recovery and waste avoidance by closely examining work procedures

and encouraging a culture of innovation instead of conformity. Management and staff also

needed to develop improved relationships, aiming to create a more democratic approach

to change which would in turn produce better results in line with community expectations.

Council recognised that outdoor staff needed encouragement and to be provided with

the educational support to understand relevant Acts, recognise problems and implement

solutions.

Methodology

Figure 5.1 Methodology adopted for environmental awareness and induction programs in Blue Mountains City Council

Apply learning in the workplace

Tackle projects

Success with positive feelings

New problems emerge

Pull system for additional learning

More savings

More success

Activate learning



The methodology adopted is shown in fi gure 5.1. The fi rst step was to equip staff with the

necessary skills through further education. Their new skills base could then be applied

to devise solutions to everyday problems they encountered. Staff ideas for solutions

were considered and then money made available to put selected solutions in place. This

boosted staff morale by providing a greater sense of ownership and an increasing feeling

of self-worth. Teething problems were dealt with by keeping the system fl exible enough to

overcome diffi culty.

Tapping the existing employee resource base allowed for further education and helped

overcome problems. New recycling strategies resulted in real savings while eliminating

the need for outside consultants. Overall, employees, council and the community gained

benefi ts from having greater motivation participation, awareness and experience.

The project involved a team of personnel from council’s Blue Mountains City Services

Group (CSG), Civil Operations Branch. CSG is council’s preferred internal service

provider for civil construction and maintenance and has 130 outdoor staff. The fi rst

step of the plan was to enrol two groups of 12 employees in a civil engineering course

at Wentworth Falls TAFE, which included looking specifi cally at recycling and reusing

construction waste.

An immediate problem was that few outdoor staff had the basic literacy and computer

skills to complete the online TAFE courses. A higher level of education was also needed

to understand the requirements of relevant environmental legislation, or to question

current management practices and come up with solutions.

To overcome this problem, employees were offered the opportunity to improve basic

computer and literacy skills by fi rst attending a course funded by Workplace English

Language and Literacy (WELL). The registered training organisation was the Western

Sydney Institute of TAFE through its Wentworth Falls Campus, which provided the

enterprise-orientated training to employees. Ongoing skills gap programs, including

numeracy, word processing and use of technologies, were provided by TAFE to ensure

candidates were motivated and coached to the required level to complete their studies.

Blue Mountains City Council supported and contributed fi nancially to the project by having

team leaders and senior managers coordinate the program that linked enterprise goals to

professional development competencies. This included the purchasing of kiosk computer

stations, enabling staff access to council facilities including computers and libraries, and

integrating college studies with Council work.

The council gave employees four hours study leave one day each week and they

contributed an equal amount of their own time. All fi nished with high-level passes, the

majority with distinctions and credits, a result exceeding all expectations. The TAFE

course was completed in 18 months with the students awarded a supervisor’s ticket in

civil engineering.

Some staff are considering progressing to a Diploma in Civil Engineering. The council

believes it will always have a use for the more skilled employees, many of whom now

express greater satisfaction with their career potential.


Case studies 71

Outcomes

Workplace culture transformed Council has accelerated cultural change by providing an environment where staff can

attain skills required for professional and personal development, including uses and

potential for new and emerging technology. This skill is now a transferable asset and a

key element in competitive tendering which is also part of the council’s business plan. In

order for the Civil Operations Branch to be a preferred provider of its services to council

it needs to be competitive. This program has greatly helped in giving them the skills and

attitude to do this.

Blue Mountains outdoor staff often have to work in all weather conditions, requiring

considerable personal commitment and superior team involvement. After the

commencement of this initial program, staff turnover is the lowest it has ever been and

the benefi ts of having a valued, skilled and motivated workforce are clear.

Changes to practiceSome of the changed practices introduced as a result of staff participation include:

• establishing recycling depots, allowing the collection and processing of construction

waste such as asphalt, sandstone, topsoil, bricks and concrete for reuse in council

projects

• construction of roads in environmentally sensitive areas using new low-impact road

design principles

• eradicating traditional paperwork by switching to use of handheld computers for

documenting work

• purchasing ‘dry ice’ cleaning technology that replaces use of toxic chemicals in graffi ti removal and cleaning of plant and equipment.

Lessons learnt• begin the reform process early

• councils should lead the way towards a sustainable society, and should do so with a

strong community base

• councils should take time to listen to the concerns of local residents and develop

solutions

• considerable investment in staff education might be needed before benefi ts will show in

a creative, fl exible and motivated workforce

• empowering local staff to carry out many of the reforms is an effective strategy.



5.4 The development of safe operational procedures

Rockdale City Council

RationaleThis project aimed to integrate OH&S with environmental requirements

under the Protection of the Environment Operations Act 1997 (POEO Act)

in safe operational procedures (SOPs). The purpose of the SOPs is to

ensure that works are carried out:

• effectively to achieve maximum productivity and quality

• to a standard that ensures the safety of the staff and residents within the work area

• to meet legal requirements for minimising the impact on the environment

• to meet council’s policies and commitments.

MethodologySenior management directed that the procedures be developed to meet legislative

requirements and improve work performance by having standard documentation across

teams. To develop the procedures:

• operational staff detailed activities and tasks undertaken as part of their work

responsibilities

• relevant information was collected and written into the procedure under the following

headings for each task:

• name of task

• step-by-step guide to [name of task]

• OH&S risks involved with this task

• what safety controls are needed?

• what personal protective equipment (PPE) is to be worn?

• what qualifi cations are needed to carry out this task?

• what personal responsibilities are associated with this task?

• what training is required?

• what codes of practice/legislation are associated with this task?

• what equipment is required?

• what maintenance does the equipment require?

• what potential environmental impacts are associated with this task?

• what controls are used to minimise this impact?

• are any licences required for this task, and if so, who is the licensing body?

• which council department is responsible for this task?

• what review mechanisms for this SOP are in place?

• distribution date

• last review date/versions

• electronic documentation location

• document version

• draft copies of the procedures were completed and issued to all operational staff for

review and comment. This process was carried out over several months with amended

drafts being issued as required

• fi nal drafts were reviewed by the environmental offi cer (to ensure that all of the

environmental risks were identifi ed) and the OH&S committee (to ensure safety risks

were identifi ed) before being formally adopted by the organisation.


Case studies 73

OutcomesThis approach identifi ed champions within the organisation, focused in the areas of

OH&S and environmental awareness, and ensured direct ownership of SOPs by involving

staff in their preparation. It also allowed:

• training needs to be identifi ed

• legal requirements to be met

• knowledge to be shared.

Lessons learnt• don’t rush into the process – developing all SOPs at once will consume time and

resources

• get it right the fi rst time – know what you are after and plan the outcome

• consider the needs of the operational staff as well as management to make the system

diplomatic rather than autocratic

• be systematic in your approach – any changes to the process may confuse the staff

that have been assisting

• make the whole process as transparent as possible to remove negative perceptions of

the program

• develop a computer-based, rather then a paper-based, SOP system.



5.5 Risk assessment, an integrated management system and council operations

Port Stephens Council

RationaleAfter drafting an integrated management system (IMS), Port Stephens Council found it

still needed processes for:

• ‘plugging in’ the specifi c requirements of quality, safety and environmental systems

• gauging the effects of these requirements on each element of a procedure

• bringing these and other nominated requirements to a single point so that one

comprehensive production plan could be developed

• ensuring that integration took place without compromising the requirements of any

system or regulation.

MethodologyAfter preliminary investigations, council staff decided to consider the risk management

process not in terms of its traditional role in safety but as a simple process that:

• brings together identifi ed elements of safety, quality and environmental systems

• assesses these elements against set criteria

• produces actions as needed.

The benefi t was that each element could be assessed against all the criteria, in terms

of safety, quality and environmental systems that might affect it, while treatments could

be produced to satisfy a number these systems at once with only slight adjustment. This

helped to overcome the problem inherent in traditional three-element systems, which

have requirements that are close enough to be frustrating to workers but different enough

to warrant individual responses by auditors.

Council adopted a process based on AS/NZS 4360:1999, with the steps outlined below.

Identify the output, process or input The fi rst step was to defi ne each procedure or element in terms of outputs, process and

inputs.

Identify each hazard associated with those elementsA practical way to identify hazards is to review existing reports such as reviews

of environmental factors and environmental impact studies, collecting all relevant

environmental aspects. These are then grouped under headings so that operations

personnel can quickly check their areas for potential risks – the book The memory jogger plus (M Brassard, Goal QPC Inc, 1989) was useful in this process. Risks are reviewed

regularly and new groups added as required.

Determine the potential level of risk created by the hazards. The level of risk is assessed using a simplifi ed table of likelihood against impact.


Case studies 75

Develop treatments that remove or reduce the level of riskThe best guide is a treatment hierarchy, which emphasises anticipating risks early in

the process rather than treating the consequences. Having these treatments provided

another very powerful tool within the system to defi ne different responses by various

levels of management in the organisation.

Reassess the level of risk to ensure it is adequately handledTo demonstrate that the treatment proposed will actually work, reassess the risk with the

treatment in place. This is both logical and diligent.

Frequency: nominate the trigger for the treatment where necessaryIt is important to tell people when to do something, such as when staff should uncover

‘fl agman’ signs or conduct a site induction.

Nominate an offi cer responsible for ensuring the treatment is enactedThe responsibility for carrying out the treatment should be part of the duty statement for a

position and the person in the position should be trained in the procedure.

Lessons learnt• nominate a site champion to work with the system coordinator, support the works

coordinators and supervisors, and to develop, document, implement and audit site

procedures

• adopt a risk management approach to ensure proactive environmental management

• develop internal experts or consultants to support the fi eld offi cers and conduct audits

for their particular specialty

• review job instructions (position descriptions) to take into account the risk management

process.



5.6 Internal environmental audits

Hurstville City Council

RationaleCouncil implemented its environmental training and audit program in order to

fulfi l legal and community obligations and take all reasonable steps to prevent or minimise

potential environmental damage from its own operational activities. The methodology

used and outcomes achieved are outlined below.

Methodology

Establishment of an audit steering committee Council commenced the process of developing the internal environmental audit program

(IEAP) by establishing an audit steering committee comprising eight staff drawn from

each major operational area (i.e. parks and gardens, road construction and maintenance,

and depot). The managers of technical services and works were responsible for

identifying these ‘leaders’ from amongst the operational teams.

Development of audit protocol and checklistThe fi rst meeting of the committee aimed to develop the audit protocol. A brainstorming

session, facilitated by a consultant and the environmental sustainability coordinator,

determined the following aspects of the protocol:

• objectives for the audit program

• composition of audit team

• audit frequency and timing

• method for identifying audit sites

• ways to recognise good practice

• process for addressing poor practice

• reporting requirements.

The meeting also reviewed the audit checklist, which was designed to be used on-site in

assessing environmental management practices and the potential for pollution.

Follow-up reviewA follow-up meeting of the committee reviewed the audit protocol and checklist, and made

further changes. At this meeting the fi rst two operational staff to be involved in the fi rst

three rounds of audits were determined. The purpose of having ‘fi xed term’ staff on the

audit working party was to develop auditing skills among as broad a range of operational

personnel as possible.

Briefi ng session to executive Council’s executive team (general manager and directors) were briefed at the outset of

the process and gave in-principle support. However, a subsequent restructure led to the

establishment of a new executive team, requiring a further briefi ng to gain their support

for the program and to rotate operational staff into the auditing process.

Meeting with operational managers All of the relevant operational managers were informed about the development of the


Case studies 77

IEAP through memos and telephone conversations. However, it was important for a

meeting to be convened in order to explain the audit protocol, present the audit checklist

and to gain feedback. The meeting also encouraged the operational managers to support

and own the program.

Notifi cation to staff and contractorsA leafl et attached to payslips informed all operational staff about the IEAP. It explained

that:

• a council audit team would be visiting job sites at any time to make sure that all proper

environmental protection systems were in place

• this would take place about every eight weeks

• fi ve job sites would be visited each time.

The leafl et was signed by the general manager and director of service delivery (who is

responsible for overseeing operational staff) in order to signify formal endorsement of

the program. Letters were also sent to council’s regular contractors because the audit

steering committee decided contractor job sites should also be audited.

Promotion of programPromotion of the IEAP was an important element of the overall project. To promote the

program internally, articles were included in NewsBrief, an offi cial newsletter from the

general manager to all staff.

A further article was placed in the Hurstville Comment community newsletter to inform

the public about council’s efforts to improve environmental management across its

operations. The newsletter was distributed at the same time as an environmental review

of industrial premises operating in the area, highlighting that council was endeavouring to

lead by example.

Furthermore, once the program had commenced the general manager formally

acknowledged the achievements of the fi rst round of environmental audits and the efforts

of the two operational staff involved in carrying them out. This took place at a breakfast

barbecue for all operational staff.

OutcomesThe audits have identifi ed a number of minor and more serious issues, including

signifi cant pollution of stormwater drains. Apart from the need to improve environmental

practices on-site, the audits have also identifi ed that operational staff may not have the

basic equipment necessary to effectively minimise potential environmental pollution at

their job site.

In relation to capacity building, the audits have provided the operational staff with a good

opportunity to develop skills in conducting audits and in identifying and communicating

solutions to environmental issues observed on-site.

The audits have provided an opportunity to reinforce environmental messages covered in

training programs and have allowed operational staff to raise any concerns they have in

this area. The program has also raised the awareness of senior management regarding

the importance of taking a proactive approach to improving corporate environmental

performance.

After each audit, an audit summary report is prepared which includes a review of the

audits undertaken and makes recommendations to address any issues identifi ed. The



executive requires a report on the audit program every four months which provides a

degree of accountability and helps ensure that the responsible managers act on audit

recommendations.

Lessons learnt• get support from both the executive and operational management by communicating

the expected benefi ts of the program

• select staff for the audit steering committee to gain ownership, participation and

acceptance at all levels

• regularly update all relevant managers, staff and councillors to keep them informed

about progress

• be prepared to overcome obstacles in developing and implementing an effective

program

• the issue of where to charge operational staff time for audits may arise – Hurstville

Council decided to charge this to the job site being audited

• remember to acknowledge the good practices being implemented by work crews by

promoting them through staff newsletters, articles in the local newspaper, vouchers etc.


Case studies 79

5.7 Responding to pollution spills and orphan hazardous waste incidents


RationaleIt is important to realise from the outset that a pollution spill and orphan hazardous waste

(PS&OHW) response requires a coordinated, resourced and multidisciplined approach

encompassing both operational and regulatory components.

Council is responsible or partly responsible for the regulatory response to incidents

occurring on council-owned land. Council is then responsible for conducting the legal

investigation into the incident. Council is not the appropriate regulatory authority (ARA)

where an incident occurs on land that is owned by:

• state government authorities, such as State Rail or the Roads and Traffi c Authority

• on premises where an environment protection licence is held by that particular

business.

Every council will need to assess its level of preparedness and the resources it needs

to deal with PS&OHW incidents. Some councils may have little need for such a

response while others such as Marrickville require a moderate level of preparedness

and resources. On average, Marrickville Council has an incident approximately every six

weeks.

Following an incident, hazardous materials are usually left on-site after they have been

rendered safe for council to dispose of. This raises two distinct questions:

• What is the operational response for disposal?

• How can council recover its costs for the disposal?

Having procedures in place allows incidents to be dealt with promptly and effectively.

MethodologyMarrickville Council has a program coordinator to develop the program and have an

ongoing role in maintaining the system (fi gure 5.2).

Figure 5.2 Diagram showing PS&OHW role and incident response process

PS&OHW coordinator• establish procedures• maintain system• training• resourcing• data management.

Operational response• determine preliminary incident response• assist Hazmat as required• site management – traffic and pedestrian• dispose of wastes and leave site clean• ensure resources are maintained.

Regulatory response• investigate breaches of the POEO Act• recover costs• liaise with DECC • determine legal course.



The coordinator roleThe PS&OHW coordinator role should maintain the system. It is very important that this

role should:

• be formally appointed

• not be onerous

• once established, take minimal time to administer.

The PS&OHW coordinator should oversee or manage staff training, such as:

• sending staff to seminars

• participating in other council initiatives

• ensuring that the training offi cer has included incident training on the corporate training

schedule

• providing on-the-spot training for new staff during incidents.

However, it should not be necessary for the PS&OHW coordinator to attend each

incident.

The team responseThe PS&OHW coordinator needs to be multiskilled, preferably being authorised under the

POEO Act. The coordinator needs to be fully conversant with all the legal tools available

to them under the Act. As well, the coordinator needs to have good liaison skills with the

council’s business units and outdoors sections.

Almost every incident will be different and will require a specifi c response. The PS&OHW

coordinator should recognise that the clean-up supervisor is competent and requires no

assistance or direction at an incident. There is little crossover on an incident site between

the POEO regulatory staff and clean-up supervisor, each having their specifi c tasks to do.

However, having partially skilled staff on hand for the incident is an ongoing problem for

the supervisor to manage.

Regulatory staff need to be fully conversant with the POEO Act and the tools available,

including:

• how to give a verbal clean-up direction

• how to issue a clean-up notice

• how to collect evidence that will satisfy a prosecution

• how to use a cost-recovery notice

• how to use notices requiring information and records

• how to access Environmental Trust funds

• how to issue pollution fi nes.

Regulatory staff who can effectively and competently deal with incidents will be a great

asset to their organisation.

Training Adequate resourcing is important for operational and regulatory responses to PS&OHW

incidents. Marrickville Council has a pollution trailer which can be quickly taken to

incidents and it contains all the resources required to effectively assist with various

aspects of an incident, such as traffi c control equipment.


Case studies 81

Regulatory staff need to have the legal tools that can assist them on site, including:

• an incident guide listing important ancillary phone numbers such as the Hazmat

coordinator, Sydney Water (for sewer overfl ows) etc.

• a clean-up order book whereby on-the-spot orders can be issued.

Finally the PS&OHW coordinator should also manage the follow-up work and assist

with fi nal incident problems. For instance, the coordinator should follow through and see

that cost-recovery notices are paid, and should log incident details to a spreadsheet for

reporting.

OutcomesThe model that has evolved at Marrickville Council provides a balanced program. The

coordinator ensures resourcing and maintenance of the program or support where

needed, but this role should not be onerous, once established.

A training package was developed to meet the need for annual training of both

operational and regulatory staff. Adequate training and resources are essential before

staff are exposed to an incident that may place their safety at risk.

Lessons learnt• responding to pollution spills and orphan hazardous waste (PS&OHW) requires a

multidisciplined approach with both operational and regulatory components

• the program coordinator role is useful for both developing the program and having an

ongoing role in maintaining the system

• develop and implement a procedure and program as soon as possible to ensure an

effective response

• train staff with your knowledge and skills in the beginning, and work out issues and

problems with them as you go.



5.8 Towards ISO 14001 certifi cation

Bankstown City Council

Rationale

Reasons for implementing a management systemThe rationale for the implementation of the Quest management system

at Bankstown City Council was initially driven by a major organisational

restructure which resulted in the creation of the Civic Services Group

(CSG).

The management system was developed to assist CSG in consistently delivering high

quality, cost-effective and effi cient services.

The pursuit of certifi cation for our quality, environmental and safety management

systems was seen as an effective mechanism by which to plan, measure and improve

our services. Triple ISO certifi cation of CSG (our quality, environmental and safety

management systems are all certifi ed by SAI Global) has also offered a viable framework

for growth and improvement.

Reasons for certifi cationAlong with demonstrating that CSG is a quality service provider, certifi cation was also

considered to provide the following benefi ts:

• increased marketing capacity – increased availability or access to new market

opportunities such as other councils, other government organisations, etc.

• integration of management systems, certifi cation and surveillance processes

• improved forward planning, better effi ciency, an improved work culture and increased

external revenue without cutting services provided by council or increasing rates

• ability to provide due diligence and comply with all relevant environmental legislation

and requirements.

Figure 5.3 illustrates a model showing how the EMS meets the needs of legislation and

environmental due diligence associated with service delivery and activities.

MethodologyIt is recommended that the following steps be considered when designing an EMS for

certifi cation:

• identify a certifi cation body as a partner that will understand your business and be able

to mentor you through the process

• secure senior management support and involvement in the process

• conduct a gap analysis of the system you have in place now and what you need to do

to bridge the gaps

• undertake a pre-certifi cation audit. The certifying body will see whether you are ready

for certifi cation and what you might need to rectify any problems to comply with the

standard

• undergo the certifi cation audit (the major audit in which your system, procedures,

actions etc. are thoroughly assessed against the requirements of the relevant standard

and environmental legislation)

• undertake a surveillance audit, which ensures you are doing the things you say you

will, that you are addressing any issues identifi ed at certifi cation and are continuing to

comply with legislation and the standard


Case studies 83

• depending on how long it takes to develop and bed down a system, schedule future

surveillance audits periodically (every 3, 6 or 12 months).

Effective project management is the key to the success of the above process:

• tracking progress towards certifi cation

• identifying and monitoring the required resources

• incorporating all the planning, design and resource requirements into the relevant

action/business plans.

The setting and monitoring of timeframes and milestones is critical so that you can

monitor your progress and adopt further opportunities to improve your system. It is

important to raise the awareness of management about EMS – provide managers with

information and examples so that they see their EMS as another business tool and not as

a process that sits outside of their business plan/activities. This will help to improve the

integration of the EMS into existing business practices and adoption of the EMS.

Protection of the Environment Operations Act (POEO) 1997

THE DRIVER

THE SYSTEM

ITS KEY COMPONENTS

HOW IT’S IMPLEMENTED

Environmental management systemISO 14001 Model

CONTINUOUS IMPROVEMENT

Aspects and impacts register (of Environmental Risk Assessments)

Business unit basedenvironmental improvement

program

Environmentalcommittees/teams

(consultation/communication)

Operational controlsSOPs

ProceduresInstructions (safety/environmental)

Inductions – site checklists, etc.Training

Figure 5.3 Relationship of EMS to other programs and controls



OutcomesStaff are now much more aware of how their work practices can impact on the

environment, and what they can do to eliminate or minimise any environmental

impacts. Environmental committees, which run in conjunction with OH&S committees,

have become a valuable forum for discussions and information exchange between

management and staff about environmental issues and their work. Staff now come

to management with new initiatives and push to follow up on ideas for improved

environmental performance.

Lessons learnt• closely integrate environmental issues and strategies with occupational health and

safety right from the start

• defi ne measuring tools and systems for environmental performance more precisely

at the outset to demonstrate to management and staff what improvements have been

made

• keep abreast of what colleagues, other councils, and other organisations are doing,

including non-local government organisations

• understand that it is an ongoing process and that systems need to evolve constantly to

suit the needs of a changing business and regulatory environment.


Appendices 85

App endices

Appendix A: Ten tips for success 86





Note that some of these appendices (marked with W ) may be downloaded from the DECC website, www.environment.nsw.gov.au/stormwater.


Appendix A: Ten tips for success

(From section 1.3 p.9)

1 Plan, plan, plan

2 Recognise there will be barriers

3 Don’t go it alone

4 Develop ownership

5 Make sure you get a budget

6 Learn to prioritise

7 ‘Train’ the people above you

8 Train yourself

9 Recognise good practice

10 Communicate, communicate, communicate



Appendix B: Example framework project plan

Project name Project officer

Project element/title Council

Overview

Rationale and project objectives

Project componentsTask Responsibility Deadline

WW



Specialised skills and resources required Possible sourcesResponsibility foridentification

MethodologyTask Responsibility Deadline

Budget

Specialised skills and resources



Timetable

CommunicationTask Responsibility Deadline

Evaluation/performance indicators

Last updated

Project officer signature

Line manager signature



Appendix C: Sample standard operating procedures

C.1 Road construction and maintenance 91

C.2 Parks and gardens 106

C.3 Depots 118

C.4 Golf courses 130

C.5 Swimming pools 140

C.6 Waste collection and management 146



C.1 Road construction and maintenance

OverviewCouncils aim to keep existing roads to a standard acceptable to the

community, while in outer urban and growing regional areas they

provide new infrastructure to meet the demands of developing areas.

Local government is responsible for the construction and

maintenance of many roads and related infrastructure such as bridges, footpaths and

stormwater channels. Councils are often involved in maintenance activities such as

patching, regrading and street sweeping.

In performing these operations, councils and their employees should meet their legislative

responsibilities under the Protection of the Environment Operations Act 1997 (POEO Act).

Risk assessmentBefore commencing any activity it is important that council operational personnel

complete either a formal or informal environmental risk assessment. This involves the site

supervisor taking into account:

• the potential environmental impacts of the project (these are identifi ed in the procedures

outlined on the following pages)

• the likelihood that these impacts will occur, taking into account site conditions including

slope, local fl ora and fauna; weather conditions; proximity of the site to residential and

business communities and sensitive environmental areas

• the potential environmental consequences of these impacts – if the likelihood of these

impacts and of the environmental consequences are moderate or high, actions should

be taken to reduce the likelihood and/or consequences.

Once the risk assessment has been completed, appropriate controls should be put in

place.

Scope of proceduresThe following twelve issues cover many aspects of environmental management for road

construction and maintenance. Some of the suggested techniques are for everyday use

and some relate more to the need for council maintenance planning:

• earthworks

• storing materials

• bitumen spraying

• asphalt laying

• pavement patching and repair

• concreting

• maintaining unsealed roads

• bridge maintenance

• road line marking and removal

• saw cutting

• drain and sump cleaning

• street cleaning.



Potential impactsThe pollution potential of each activity is indicated by a table such as this:

Activity Pollution potential

WATER AIR NOISE WASTE SOIL

where:

• ‘water’ indicates a potential to cause water pollution

• ‘air’ indicates a potential to cause air pollution

• ‘noise’ indicates a potential to cause noise pollution

• ‘waste’ indicates a potential to generate excessive waste

• ‘soil’ indicates a potential for soil contamination.



C.1.1 Earthworks



BackgroundEarthworks for road construction and maintenance involve clearing vegetation, modifying

the ground surface, bringing in new materials, grading, compacting and other activities.

Earthworks that remain exposed lead to erosion of soil by rain and wind. This may

damage your works and could cost council both time and money to repair, rework and

clean up the damaged areas. Sediment from the eroding soil could enter stormwater

drains and pits causing blockages and fl ooding. When sediment enters waterways it

causes serious problems to the ecosystem. Sediment can smother aquatic life and it

transports nutrients, heavy metals, bacteria, pesticides and other toxic substances that

damage our waterways and cause algal blooms.

Clearing land surfaces can lead to fl ooding, erosion of banks, exposure of acid sulphate

soils, and the loss of vegetation growing near water.

For further information on erosion and sediment control for road construction, see

Managing urban stormwater: soils and construction vol. 2 (DECC 2007).

ActionsIn order to minimise these potential environmental impacts, the following actions should

be considered:

• complete a risk assessment before beginning any works

• carefully select road routes to avoid sensitive areas, minimise cut and fi ll etc.

• if possible schedule construction activities to periods of low rainfall erosivity (low rainfall

months)

• limit the area of land disturbance and avoid disturbance near watercourses, drainage

lines and sensitive areas. These restricted ‘do not disturb’ areas may require clear

identifi cation with barrier mesh, sediment fencing etc.

• consult the council’s services plan before beginning work to avoid damage to services,

water mains etc.

• determine from soil maps whether acid sulphate soils are present and, if they are,

develop a management plan to deal with this

• ensure all downstream drains or waterways are protected by installing and maintaining

appropriate erosion and sediment controls before beginning the work, which could

include:

• ensure drain cross-sections are parabolic (spoon shaped) or trapezoidal (fl at

bottomed) rather than V-shaped, as these profi les are more stable, allowing water

to spread out and minimise erosion

• install site drainage works to convey stormwater away and around the disturbed

site. Where possible, divert clean run-on water from upslope land around the site

while development is taking place. This can be done by using stabilised diversion

drains, earth banks, rock, fallen trees, straw bales, sandbags, gravel or sand

sausages

• disturb or expose areas in stages if possible to minimise the potential for erosion

• install site drainage works to convey stormwater safely through the disturbed site.



Reduce stormwater runoff by keeping gradients as low as possible. Progressive

revegetation will encourage infi ltration of water on the site. Leave the soil surfaces

scarifi ed (e.g. track walking). Install check dams to slow down the water and limit

erosion

• protect batters and embankments by stabilising them with biodegradable blankets,

hydro-seeding or mulch

• transport water down a batter as a temporary measure using a stabilised chute

such as plastic, heavy-duty fl exible corrugated pipe or half-round corrugated metal

or concrete pipes. Install them progressively as construction proceeds. This can

also be done as a permanent measure with concrete or rock

• install sediment retention traps at the low points of major work sites. Materials used

include straw bales, woven geotextile (sediment fence), earth, rock or suitable

crushed concrete products. The minimum number of straw bales to be used is four

and they should be properly embedded into the ground to 100 mm depth to prevent

polluted water passing underneath them. Sediment fencing should be trenched into

the ground, at least 150 mm depth, backfi lled and compacted. Turn up the ends of

the sediment fence equal to the height of the crest to contain water and sediment

• installation all-weather access to the site. The site should be managed such that

sediment is not tracked off the site. The entry/exit point should be restricted to

one location. The stabilised access should be constructed with 200 mm of 40 mm

diameter aggregate. The access should be a minimum of 3 metres wide and

15 metres long

• install sandbags, strawbales, gravel or sand sausages around downstream drains

• stabilise disturbed areas immediately after fi nal grading has been completed by

vegetating and mulching, either temporarily or permanently. Use annuals where

a quick, temporary cover is required and perennials for long-term protection.

Alternatively use mulch or biodegradable blankets such as jute mesh and plant

fi bre matting. Hydro-seeding is suitable if supplementary watering is available to

establish growth quickly

• if the soil is dry, water down the traffi c areas to reduce dust as needed. A watering truck

should be available at all times. Keep the surfaces moist rather than wet

• rehabilitate shoulders and open drains with vegetation rather than with earth or

concrete unless trickle fl ows are expected

• ensure that all trucks and other equipment carrying chemicals or with signifi cant

hydraulic reservoirs carry absorbent spill kits and material safety data sheets (MSD

sheets)

• develop, document and implement a maintenance program with scheduled inspections

– it is important to inspect and maintain erosion and sediment controls regularly

following installation. As development proceeds, changes occur in slope gradients

and drainage paths with their exact form frequently unpredictable before works begin.

At times erosion and sediment controls need to be relocated. After a storm event,

the effectiveness of the established controls can be readily seen, together with any

shortcomings and damage – ineffective controls should be fi xed and damage rectifi ed

• trucks entering and leaving construction sites should be well maintained in accordance

with the manufacturers’ specifi cations and comply with all relevant clean air regulations

• truck movements should be controlled both in relation to times of operation and best

routes to the site if there are houses close by

• select the most suitable equipment based on the particular task required. Select less

noisy equipment wherever possible

• conduct letter drops to residents providing a contact name and number and details

of any proposed work if the work is required to be conducted outside normal hours of

operation or will have other impacts on residents.



C.1.2 Storing materials


WATER AIR WASTE SOIL

BackgroundStockpiles of materials used in road construction and maintenance activities, such as

sand and gravel, can contribute to stormwater pollution if rain or other water passes

through or over them. Many other materials – petroleum products, sealants and paints etc.

– have the potential to pollute stormwater if they are not correctly stored on-site.


be considered:


• locate stockpiles at least 2 metres (preferably 5 metres) away from waterways, roads,

slopes steeper than 10%, and areas of concentrated water fl ow

• locate stockpiles within the sediment control zone

• keep the height of the stockpile below 2 metres

• prevent runoff from washing through storage areas by locating stockpiles high on the

site or diverting runoff around the site or the stockpile areas using diversion drains,

earthbanks, straw bales, sandbags, gravel or sand sausages

• place sediment control structures or bunding immediately down-slope from stockpiles

and provide a cover if possible

• stabilise topsoil that is to be stockpiled for extended periods

• store potentially harmful chemicals in safe, secure, on-site storage facilities and in

accordance with current regulations. Material safety data (MSD) sheets should be

readily available.



C.1.3 Bitumen spraying



BackgroundBitumen spraying is commonly undertaken in order to provide a surface on road

pavements and/or as a waterproof membrane between an asphalt surface and the road

base. This process involves spraying a liquid asphalt binder (asphaltic cement derived

from the distillation of crude oil that has been thinned to a liquid state).

If it rains before the bitumen can cure, liquid bitumen can get into the drainage system

and pollute waterways. It can also enter waterways because of excessive application

rates, over-spraying, spills and inappropriate cleaning practices for equipment.

During the process of chip-sealing (a method for surfacing roads), the binder is generally

combined with an aggregate. The aggregate used in this operation also has the potential

to wash into drains.


be considered:

• always complete a risk assessment before beginning any works

• protect downstream drains or waterways using sandbags or gravel or sand sausages

• select appropriate sealing material for site conditions such as traffi c volume,

temperature, gradient, shade and humidity

• use bitumen emulsion where possible

• try to time spraying so it does not coincide with rainfall during or immediately after

sealing

• ensure correct bitumen application and spray rates to avoid overspraying and waste

• start rolling only after suffi cient curing, to prevent pickup of bitumen on the roller tyres

• ensure the pre-coating on aggregate has cured before placing it on the road

• sweep up loose materials from gutters immediately on fi nishing, and routinely as

required

• remove all waste and debris from the site

• clean all equipment at a stockpile site or other safe site (i.e. one which is least

environmentally sensitive and has pollution controls in place)

• collect spoil from the uncovering of hydrants and manholes and dispose of it correctly

• dispose of all liquids used to clean tools appropriately

• ensure soiled tar paper and pavement marker covers are collected and disposed of

correctly


hydraulic reservoirs carry absorbent spill kits and MSD Sheets

• conduct letter drops to residents providing a contact name and number and details of

any proposed work. Odours and noise levels from this type of activity may be offensive

to some residents, therefore prior notifi cation is often appropriate.



C.1.4 Asphalt laying



BackgroundAsphaltic concrete is commonly used as a surface on main roads and pavements to give

a smooth and sealed fi nish.

When used as pavement, asphalt is generally heated and mixed with aggregate off-site

before being transported in a heated state to the site. The material is then deposited in

layers using special machinery and compacted before curing into a solid mass.

This has the potential to impact on stormwater if runoff occurs before curing, if

compacting is inadequate, or if solvents such as kerosene are used for cleaning tools and

machinery.


be considered:


• install sand bags or gravel or sand sausages next to stormwater inlets which receive

drainage from the site

• select appropriate sealing material for site conditions – traffi c volume, temperature,

gradient, shade, humidity etc.

• try to time the laying so it does not coincide with rainfall during or immediately after

sealing

• sweep up loose metal from gutters immediately following the laying, and routinely as

required

• remove all waste and debris from the site

• clean all equipment at stockpile sites or other safe sites


hydraulic reservoirs carry absorbent spill kits and MSD sheets

• conduct letter drops to residents providing a contact name and number and details of

any proposed work. Odours and noise levels from this type of activity may be offensive

to some residents, therefore prior notifi cation is often appropriate.



C.1.5 Pavement patching and repair



BackgroundFaults in the pavement (e.g. potholes and breaking edges) may be a source of sediments

that can wash out during rain. Pavement patching principally involves patching a spot with

a new surface, or replacing the sub-grade before resurfacing. Repairing pavements can

contaminate stormwater with sediments if waste is not properly disposed of, if compacting

is inadequate, or if runoff occurs before curing.

Sometimes reshaping and stabilisation is needed, requiring the mixing of cement and

lime before moistening, compacting and replacing the surface. This lime and cement can

wash off and enter waterways.

Before patching, the work may require investigation using an auger (boring tool) or by

digging test pits. This can contribute sediments to stormwater if waste is not properly

disposed of, if test pits are left exposed to rain, or if water mains are hit when using an

auger.


be considered:


• ensure downstream drains are protected if required using sandbags, straw bales or

gravel or sand sausages

• monitor roads for potholes and fi x them promptly

• investigate the pavement to identify exactly how much work is needed and how best to

do it; after the investigation, replace and compact soil into any auger holes and test pits,

and seal them the same day

• when stabilising, mix materials during periods of dry weather and little wind, and seal as

soon as possible after dressing

• fi ll and compact soil, gravel and asphalt in layers

• reuse spoil in repairs; otherwise sweep it up

• eliminate ‘edge break’ by fully sealing road shoulders

• dispose of used soil samples and excess spoil at a suitable fi ll site

• use suitable facilities for washing tools, plant etc.



C.1.6 Concreting



BackgroundConcrete residues and wastes can enter waterways in many ways:

• runoff from washing concrete-delivery trucks

• on-site mixing, washing tools, and hosing

• acid cleaning concrete surfaces, such as exposed aggregate, etc.

Concrete waste is also highly alkaline which means that even a small amount can cause

signifi cant problems for local waterways. Note: DECC has released a guideline for

the concreting industry called Environmental best management practice guideline for concreting contractors, available from the DECC website www.environment.nsw.gov.au


be considered:


• ensure downstream drains are protected if required using sandbags, sponges or gravel

or sand sausages – straw bales are not suitable

• avoid mixing or pumping concrete in areas where excess material could enter the

drainage system, or else install containment measures

• have waste concrete taken back to the supplier for reuse – it may be a condition of

councils’ contracts for all concrete suppliers to take their waste back to their depots

• ensure that concrete residue from washing concrete truck chutes and pumping

equipment is either diverted to the area that is being concreted, or deposited in a

contained area on site and allowed to set before disposal

• wash tools in the area that is being concreted, or contain washing water in a drum for

safe disposal later

• when hosing down concreted areas (e.g. exposed aggregate) use minimal water and

allow sediments to settle in an area made with sandbags, sponges or sand sausages.

Larger jobs may need a sandbag dam.



C.1.7 Maintaining unsealed roads



BackgroundMaintaining unsealed roads involves grading, patching and re-surfacing of the road, and

ensuring effective operation of the road drainage system. Each of these activities can

affect the stormwater system through erosion and fl ow of sediments. Unsealed road

shoulders can also be a source of sediments.

Reducing the potential for erosion is the key to minimising the impact on the environment

from unsealed roads. Proper methods of grading, the selection of suitable materials, good

compaction and the provision of good road drainage are the keys to achieve this.

For further information on maintaining unsealed roads, see Managing urban stormwater: soils and construction vol. 2 (DECC 2007).


be considered:


• make busy roads a priority for sealing

• stabilise shoulders and open drains by vegetative or other means

• avoid grading when the road is extremely dry or water down the road, keeping the

surface moist rather than wet

• use compacting equipment when grading

• use road materials that bind easily together to minimise sediment runoff

• for road verges, make sure the fi ll materials are suitably cohesive and thoroughly

compacted

• maintain a structurally sound surface while providing adequate crown and drainage so

that erosion or scattering of gravel is avoided

• implement soil erosion and sediment controls where necessary. Check dams may be

required in the gutters to slow down the water and help prevent erosion. As these are

areas of concentrated fl ow, sediment fences are not to be used, although sandbags

and rock can be used. A spillway should be installed in these structures to avoid water

running around the structure and causing erosion around the sides.



C.1.8 Bridge maintenance



BackgroundBridges that are situated or designed incorrectly may lead to increased erosion of

channels and stream banks, and destruction of important aquatic habitats. Maintenance

materials – such as paints, solvents, and timber preservatives – can pollute stormwater if

they enter waterways by runoff or wind drift.

For further information on bridge maintenance, see Managing urban stormwater: soils and construction vol. 2 (DECC 2007).


be considered:


• regularly inspect bridges over waterways for any erosion upstream or downstream of

the bridge – address the cause of any erosion to the extent practical and install erosion

controls

• when working in creeks or rivers, plan carefully to limit the impact of sediment pollution

occurring because of works. Where possible, divert water (by pipe or bank) around

culverts and/or bridges during construction so that the entire system is stable. Seek

expert advice and take all care when forming temporary dams and draining or pumping

water around the site to control polluted water.

• do works such as sandblasting and timber treatment off-site, if possible

• when cleaning bridges use suspended nets, tarpaulins or a vacuum to capture paint,

rust and other chemicals

• avoid spraying chemicals in windy conditions

• paint the surfaces regularly, so there is less old paint to remove

• use materials that require minimal maintenance (e.g. galvanised or aluminium rails, rot-

resistant hardwood timbers).



C.1.9 Road line marking and removal



BackgroundLine marking is done on new as well as existing roads. Generally it involves applying

either paint or thermoplastic material to the road surface by machine or by hand. Line

marking can have an impact on stormwater if the site isn’t cleaned properly or if marking

is done in the rain.

Line removal generally involves techniques such as grinding and sandblasting, resulting

in residue which can be washed or blown into nearby waters.


be considered:

• always complete a risk assessment before beginning any works

• use water-based paints or thermoplastics rather than solvent-based materials

• avoid using materials while the pavement is wet, during humid conditions, or if rain is

likely

• avoid applying thermoplastics at low temperatures (i.e. below 13°C)

• use a portable drip tray under plant to catch spills when possible

• use a skirt around the blaster to minimise the spraying of material away from the work

site

• coordinate street-sweeping with line removal, so that waste material is picked up before

it can be transported by rain, wind and traffi c• do not leave waste paint on the roadway overnight – it should be swept up and returned

to the depot for appropriate disposal. All spray cans should also be returned to the

depot for appropriate disposal.



C.1.10 Saw cutting


WATER AIR NOISE WASTE

BackgroundSaw cutting of concrete, bitumen and brickwork is periodically done by councils or their

contractors as part of pavement repair, concreting, bricklaying, and footpath repair or

placement. The grinding process produces a fi ne particle residue that combines with the

cooling water to produce a slurry which typically ends up in the stormwater system and

then into waterways.

This slurry, even in small amounts, can have a signifi cant impact upon waterways. All

waste from saw cutting should be collected and disposed of away from the site. No

wastewater should enter stormwater drains.


be considered:


• where a stormwater inlet is next to the work area, that drain should be blocked

completely and controls put in place between the worksite and the next stormwater inlet

• use sandbags, sponges or gravel or sand sausages to slow the fl ow of the water and

allow sediments to settle – for larger jobs a sandbag dam may be needed

• use as little cooling water as possible; switch the water off when the saw is not in use

• prevent cooling water from fl owing across exposed soil or other pollutants by diverting

the cooling water around the exposed areas using sandbags, or gravel or sand

sausages

• confi ne waste water to an infi ltration trench or collect it for disposal off-site

• where sandbags are used, ensure there is enough capacity for materials to settle

before treatment, disposal or reuse. One sandbag will not do the job. You need to dam

the water to allow sediment to settle

• at the end of a job, collect sediment and liquid from behind sandbags and within the

gutter and dispose of it, preferably off-site, where the material will not wash into waters

• consider obtaining equipment that will suck up the waste during cutting.



C.1.11 Drain and sump cleaning


WATER AIR NOISE WASTE

BackgroundThis includes the inspection, cleaning and repair of open and piped drains, sumps,

stormwater pits, treatment devices and outfall structures.

Inappropriate cleaning practices can affect stormwater if materials are transported

downstream. Cleaning sumps and piped drains can put pollutants into the water system.

The cleaning of open drains can have a similar impact, and may also cause erosion by

disturbing the banks and bed of the drain. If pollutant traps are not maintained frequently

they lose their effectiveness.


be considered:


• monitor how waste accumulates in each part of the system and develop a routine

cleaning program

• protect downstream drains or waterways using sandbags, straw bales, sediment or

gravel socks if required

• ensure no hazardous chemicals are put into drains

• clean only those parts of grassed or natural drains that need it and, if possible, leave

existing vegetation intact to act as natural fi lter

• remove all materials from sumps, and use a sucker broom where possible

• ensure that no spillage occurs when transporting waste

• if waste is to be kept on-site for some time (e.g. for drying out), ensure suitable silt

controls are in place, for example by bunding or covering stockpiles. Have regard for

appropriate siting of this material as it may generate offensive odours.



C.1.12 Street cleaning



BackgroundRoads, carparks, footpaths and cycleways are places where pollutants accumulate.

During rain these pollutants often run off into adjacent stormwater drains.

Pollutants include soil erosion particles, nutrients, litter, organic matter, dust (from wearing

of asphalt surfaces), and grease, oils and heavy metals from vehicles.

Inadequate disposal of the waste from street sweeping or fl ushing contaminants into

drains can affect stormwater quality.


be considered:


• ensure street sweeping techniques collect pollutants rather than putting them into

drains

• monitor cleaning areas to determine the ‘hot spots’ for pollutants, and give these areas

more attention

• coordinate street cleaning with other maintenance programs such as grass cutting and

tree pruning

• schedule street cleaning for off-peak periods, as cleaning is easier and more effective

when there are fewer cars

• identify when ‘one-off’ cleaning is required (e.g. special events or road works), and plan

accordingly

• in areas where a mechanical sweeper cannot reach, either sweep by hand or extract

material into a contained area and collect it

• ensure sweepers are well maintained including checking the seals on water tanks

• ensure sweepers are cleaned every day in a designated wash bay where runoff water

can be collected in an oil and water separator

• take waste water to a suitable treatment site.

Emergency response advice to fi eld staffIf you fi nd dumped chemicals or other materials and you are unsure whether it is safe to

collect them and return them to the depot, please contact your supervisor immediately for

advice.

Council has a set procedure for dealing with these situations. Ensure that you are familiar

with that procedure and emergency requirements at all times.



C.2 Parks and gardens

OverviewParks and gardens include public parks, playing fi elds, foreshore

reserves and road verges, plus associated facilities such as

children’s play equipment, picnic tables and barbecues. The

management of these areas requires work practices ranging

from routine mowing, rubbish removal and building maintenance through to specialist

horticultural practices.

These activities are carried out by council employees, private contractors and, in some

instances, community groups. Councils and their employees should meet their legislative

responsibilities under the Protection of the Environment Operations Act 1997 (POEO Act).

The following nine areas cover the various aspects of stormwater management for parks

and gardens. Some of the suggested techniques are for everyday use and some relate

more to the need for council planning.

Risk assessmentParks and Gardens personnel tend to work outside or at facilities like golf courses and

sporting venues. It is important that all fi eld staff complete either a formal or informal risk

assessment before completing each project. This involves the site supervisor taking into

account:

• the potential environmental impacts of the project (these are identifi ed in the procedures

outlined on the following pages)

• the likelihood that these impacts will occur, taking into account site conditions including

slope, local fl ora and fauna, weather conditions, proximity of the site to residential and

business communities, and sensitive environmental areas

• the potential environmental consequences of these impacts – if the likelihood of these

impacts and of the environmental consequences are moderate or high, actions should

be taken to reduce the likelihood and/or consequences.

Once the risk assessment has been completed, appropriate controls should be put in

place.

Personnel working out of facilities should develop environmental management plans for

their routine activities. These should also include spill response procedures.

Scope of proceduresThe following pages describe SOPs for the following activities in parks and gardens:

• mowing and edging

• applying pesticides

• applying fertilisers

• mixing and storing chemicals

• working in garden beds

• collecting seagrass on foreshores

• maintaining buildings, furniture and playgrounds

• maintaining sporting fi elds

• graffi ti protection, management and removal.



C.2.1 Mowing and edging


WATER NOISE WASTE

BackgroundGrass clippings from mowing and edging are generally left on-site by councils to save

on removal costs and because the materials are seen as a natural mulch or fertiliser.

Many grassed areas next to stormwater drains, gutters and paved areas are a source of

grass clippings that may be washed or blown into stormwater drains. Grass clippings can

contribute to water quality problems in waterways.

Mowing can remove vegetation from riparian zones (i.e. from the banks or margins of

waterways). This vegetation can be important for maintaining aquatic habitats and often

acts as a buffer to protect waterways from neighbouring land uses and their pollutants.

With mowing and edging, there is the potential for spills of petroleum products when

decanting fuels and operating machinery.


be considered:

• complete a risk assessment before beginning the work

• remove all litter and debris before mowing and edging

• ensure mowers and edgers project grass clippings away from waterways, drains and

gutters

• use a grass catcher in sensitive areas. If possible, send collected grass clippings to a

composting facility or worm farm (to be recycled for use in gardens)

• use mowers which mulch clippings into smaller particles to help break them down

• mow high and often as this creates smaller volumes of grass clippings which will break

down more easily than larger volumes

• remove clippings from paved areas such as footpaths, driveways, roads and gutters;

this may be easier if mowing is coordinated with street-cleaning operations

• avoid mowing if the ground is very wet, as this can lead to erosion, and tyre tracks can

make paths for water to fl ow down

• wash plant and equipment where waste water will not fl ow into waterways

• remove clods of soil from mowers before going to the next site

• reduce mowing near buffer zones between water and land if possible. The buffer zone

will act as a fi lter for runoff from the park

• when planning parks and gardens use low-growing and slow-growing grass species,

as these require less maintenance, and check that the design includes buffer areas

between water and land

• recolonise buffer zones with native grasses and shrubs which need no mowing

• if possible, refuel on a bunded hard-stand area (e.g. concrete) and mop up all spills

immediately

• if carrying fuels make sure the MSD sheets for those fuels are easily accessible.



C.2.2 Applying pesticides



BackgroundCouncils have a responsibility to control animal pests and weeds in parks and gardens,

and often use a variety of chemicals to achieve this. Pesticides include insecticides (to kill

insects), rodenticides (rodents), herbicides (plants) and fungicides (mould and mildew).

These chemicals may present a risk to organisms other than the target species, and

can cause dramatic changes within ecosystems through direct destruction of organisms

and habitats and, more subtly, through small doses making organisms less resistant

to disease and inhibiting their growth. Aquatic animals in particular are susceptible to

chemicals because they can absorb the pesticides readily from the water and sediments

in which they live.

Chemicals used by councils can be introduced into waterways in a number of ways:

• direct application

• air drift from nearby treatment areas

• migrating organisms

• percolation through the soil

• spills and poor disposal

• surface runoff.

Inappropriate herbicide application can render land susceptible to erosion by killing grass

cover.

The Pesticides Act 1999 places specifi c responsibilities on organisations and individuals

using pesticides. It is important that all offi cers using pesticides are familiar with the

requirements of the Act including those relating to training and notifi cation.


be considered:

• complete a risk assessment before beginning the work

• mix and apply chemicals as indicated by labels

• address all risks to satisfy the Act’s requirements for ‘due diligence’

• use pesticides when needed, not regularly, and use them only where needed, not all

over

• choose plant varieties that are resistant to diseases known to be prevalent in that area,

and match species to a site.

• carry minimum amounts of chemicals on work vehicles and ensure they are safely

secured and contained

• ensure MSD sheets for all chemicals used and spill kits are easily accessible

• don’t use chemicals during unsuitable weather conditions (e.g. windy periods), when

soil is very wet, during rain or when rain is forecast.

• don’t apply chemicals near drains or gutters



• ensure you keep a detailed record of pesticide application as required by the Pesticides

Regulation

• wash chemical containers at the depot where waste water can be appropriately

dispersed

• purchase chemicals from a supplier that recycles empty chemical containers, or follow

label directions for disposal of containers

• monitor sites to ensure that chemicals are having the desired effect, and adjust

accordingly

• ensure all staff are trained in dealing effectively with chemical spills

• ensure all staff are familiar with emergency response procedures.



C.2.3 Applying fertilisers



BackgroundCouncils apply fertilisers to parks and gardens to maintain the vegetation coverage,

appearance and usefulness of these areas. Areas where fertilisers are used include road

verges, ovals, garden beds and prominent parkland locations.

If fertilisers are incorrectly applied or overused, or an unsuitable product is used, they

could end up causing stormwater pollution.

Actions In order to minimise these potential environmental impacts, the following actions should

be considered:

• complete a risk assessment before beginning any work

• use the correct rates and procedures for applying fertilisers

• assess the need for fertilising, rather than applying on a calendar basis without

consideration being given to need

• apply fertilisers during growth periods to help uptake of nutrients by plants

• use controlled release fertilisers wherever possible, as they are less prone to leaching

and causing pollution than soluble fertilisers

• maintain a buffer between the area of application and drains, gutters and waterways

• reduce the need for fertilisers by planting species that do not require additional nutrients

to those naturally present in the soil

• assess the value of applying small doses of fertiliser more frequently rather than larger

doses less frequently, to reduce the chance of runoff

• monitor sites to ensure that fertilisers are having the desired effect, and adjust

accordingly

• dispose of containers properly

• ensure MSD sheets for all chemicals used are easily accessible

• ensure all personnel are familiar with chemical spill and emergency response

requirements.



C.2.4 Mixing and storing chemicals



BackgroundThe chemicals, such as pesticides, needed for parks and gardens maintenance are

often stored on-site. They need to be stored properly and mixed carefully to reduce the

potential for stormwater pollution.


be considered:

• complete a risk assessment

• store and mix chemicals in a covered, bunded area, with an impervious surface,

ensuring that all uncontaminated stormwater is directed away from the bunded area

• ensure that facilities are available for disposing of any waste collected in the bunded

area and any uncontaminated bund water should be used benefi cially on-site if

practicable

• mix chemicals according to the manufacturer’s specifi cations

• inspect bulk storage containers regularly, and replace them if rusted or damaged

• if storing products classifi ed under the NSW Occupational Health and Safety Act 2000 (OH&S Act), store them in a manner which complies with the requirements of this Act

• store empty drums and containers undercover on impervious surfaces, and have them

removed as soon as possible

• make sure there is a spill plan and that staff are trained to deal with spills; a spill kit

containing dry absorbent spill material should be clearly identifi ed and easily accessible

• ensure MSD sheets for all stored chemicals are easily accessible

• ensure somebody is responsible for regularly updating MSD sheet folders.

Building and maintaining an effective bundEffective bunding is very important when dealing with chemicals – see activity C.3.4.



C.2.5 Garden beds


WATER WASTE

BackgroundCouncils maintain garden beds in prominent locations for aesthetic reasons. They feature

shrubs, trees and other plants.

Exposed gardens beds can cause sediment pollution if they are near drains or impervious

surfaces and are not adequately mulched. They may contribute organic pollution, for

example shrubs shed leaves near drains, or weeds and prunings that are not removed

after maintenance activities. Mulch material may also become a pollutant if it is washed

from garden beds.

The high density of garden beds, combined with the tendency to create areas of

monoculture, makes them susceptible to pest attack. Also many introduced plant species

have requirements regarding soil, water and nutrients that are conducive to weed growth,

requiring more herbicides.


be considered:

• select pest-resistant plants that suit the site (pH in soil, moisture retention, rainfall,

sunlight)

• select and plant trees and shrubs that don’t drop a lot of leaves

• have low-maintenance groundcovers near drains and watercourses

• mulch garden beds to prevent soil erosion or install garden bed borders to contain soil

• remove excess prunings, soil and weeds after maintenance activities.



C.2.6 Seagrass on foreshores


WATER WASTE

BackgroundMany coastal councils remove decaying seagrass (wrack) which has been pushed by

wind or currents onto the foreshore and into water inlets. The machinery used can impact

on the riparian zone (near the water’s edge) and on aquatic habitats if the operation is

carried out below the high-water mark. It may also affect the food chain.

The Fisheries Management Act 1994 requires that councils obtain a permit for the

removal of live seagrass.


be considered:

• complete a risk assessment before beginning work

• only remove seagrass where it is causing a public nuisance (e.g. swimming areas,

picnic areas)

• remove it from above the high-water line only

• avoid damaging riparian habitats with machinery

• ensure all collected seagrasses are appropriately disposed of

• ensure all heavy machinery with hydraulic oil reservoirs have appropriate spill response

equipment available.



C.2.7 Buildings, furniture and playgrounds



BackgroundMaintaining facilities such as playground equipment, park furniture, barbecues, amenity

blocks and community buildings requires the use of chemicals that may impact on

stormwater quality. Activities such as painting and paint removal, graffi ti removal and the

use of preservatives to protect timber can contaminate stormwater.


be considered:

• complete a risk assessment before commencing work

• use the least toxic products for the given purpose

• sweep paved areas clean rather than hosing

• ensure all MSD sheets for chemicals used are easily accessible

• develop and use procedures to prevent and manage chemical spills

• direct waste water to vegetated areas and away from drainage channels and gutters

• ensure all solvents and other chemicals used for maintenance are collected and

disposed of appropriately

• ensure all waste paint is disposed of appropriately

• ensure all chemical containers are disposed of appropriately.



C.2.8 Sporting fi elds


WATER WASTE SOIL

BackgroundMany maintenance activities for sporting fi elds can affect stormwater quality. These

include marking lines, installing posts, maintaining cricket pitches, controlling weeds

and pests, fertilising, removing graffi ti, applying top soil, and maintaining clubhouses,

canteens and amenity blocks.

Problems often arise with hosing of amenities blocks, disposing of wastes such as

cooking oils from canteens, inadequate waste collection facilities, using toxic chemicals,

and using poor methods of application for chemicals.


be considered:

• complete a risk assessment before doing any work

• assist sporting clubs to understand and minimise stormwater impacts by showing them

best practice techniques (e.g. no hosing of hardstand areas – use a broom instead)

• spread and screed topsoil into turf to avoid overland fl ow paths, and leave a buffer

between topsoiled areas and drains

• ensure all chemicals are stored appropriately (see C.4.2 Mixing and storing chemicals

for more information)

• ensure all people applying pesticides are properly trained (see C.4.4 Applying

pesticides for more information)


• ensure appropriate spill response equipment is available. Regularly check spill

response equipment as part of EMP for the site

• ensure all personnel using chemicals are appropriately trained in spill response.



C.2.9 Graffi ti protection, management and removal



BackgroundGraffi ti has been an environmental issue for a long time. Councils across the state are

adopting different approaches including establishing designated graffi ti walls, immediate-

removal programs and a use of a range of coatings that claim to be ‘graffi ti proof.’

Most councils however have recognised that any programs designed to manage graffi ti need to approach the problem with a mix of three broad approaches:

• protection

• management

• removal.

An overview of these approaches is outlined below. Also outlined below are some

basic environmental management considerations when implementing a graffi ti removal

program.

Actions

ProtectionProperties can be made more resistant to graffi ti by using various techniques. They

include:

• textured surfaces

• high density, low absorbency materials, such as hard burnt brick, tiles, etc

• improved lighting

• landscaping to break up large surfaces

• appropriate colour schemes

• legal art opportunities

• appropriate fencing or grilles

• anti-graffi ti coatings.

ManagementA number of councils have developed ‘graffi ti fl ying squads’, based on the view that

people paint graffi ti so ‘tags’ are seen by the wider community. The longer the graffi ti stays in place, the more effective the graffi ti artists appear to believe their work has been.

The fl ying squad covers or removes the graffi ti as soon as possible thereby minimising

the impact of the tag.

RemovalPrompt removal of graffi ti provides a disincentive for further graffi ti. Various products are

available for removing graffi ti. Graffi tists use a variety of markers, most commonly aerosol

paints and felt-tip pens. Ease of removal depends on the type of surface and how the

graffi ti was applied. Test a small area fi rst to see whether any of the methods of removal

indicated below will work on your surfaces.



The three main ways of removing graffi ti are:

• paint-out

• chemical

• mechanical.

Paint-out – if the graffi ti is on a painted surface, paint over it after removing as much

of the graffi ti as possible – some graffi ti markers tend to ‘bleed’ through the new coat of

paint, so use a sealer coat as needed before painting the whole surface. Also:

• match gloss levels as well as colour for a more professional paint-out and prevent the

need to repaint the entire surface

• choose darker colours to paint out graffi ti. The marks are less likely to show through,

and the colour may make the site less attractive to other graffi tists

• record all paint types and colours used on your property to simplify the matching

process. Keep excess paint if possible to ensure true match of colours.

Chemical – the simplest chemical method is liquid laundry or dishwashing detergent, which

will remove felt-pen graffi ti from glass, aluminium, terrazzo, smooth cement and similar

surfaces. Liquid cleanser, eucalyptus oil and mineral turpentine may also be effective. The

best household product for removing paint from these surfaces is oven cleaner.

If the graffi tist has used aerosol paint on an unpainted surface, act swiftly where possible.

Paint will quickly penetrate absorbent surfaces like brickwork and can be very diffi cult to

remove. Try a solvent, such as mineral turpentine, or a chemical paint remover, like caustic

soda or a commercial paint stripper. For best results agitate the paint stripper with a scourer

pad or stiff bristled brush to break up the graffi ti and allow the chemical to penetrate better.

(Gloves and protective eye wear are important for graffi ti removal processes)

Whatever chemical you use follow the safety procedures recommended by the

manufacturer.

Mechanical – removing extensive aerosol graffi ti from an unpainted surface may require

soda or water blasting. (Hot or cold water may be required in different circumstances.)

For smaller areas, try scrubbing the graffi ti with an abrasive cleaner. In diffi cult cases, you

could call a specialist contractor with access to specialised products.

Environmental management considerationsAll appropriate care should be taken to ensure the local environment is protected when

graffi ti removal programs are implemented. If hazardous chemicals have been used as

part of the graffi ti removal program it is important to:

• complete a risk assessment before beginning work

• use all chemicals as per the instructions on the labels

• ensure all MSD sheets for those chemicals are available on-site

• build an impervious bund around the treatment area to capture all waste liquid. Any

waste liquid should then be vacuumed into containers

• seek advice from the local sewer authority as to the appropriate disposal for this liquid.

If water blasting is being used to remove the graffi ti it is important to:

• protect all downstream drains with sandbags or gravel sausages

• direct all runoff water from the cleaning site to grassed areas and away from stormwater

drains, after it has been fi ltered through sandbags or gravel sausages.

It is also important that the site be left completely clean following treatment. All used

drums should be removed, and all waste paint should be swept up and placed in a bag

for appropriate disposal.



C.3 Depots

OverviewA council depot is rather like an industrial estate. In many cases

a depot will bring together a range of facilities and services:

mechanical workshops, painters and signwriters, carpentry

workshops, bricklayers, chemical suppliers, nurseries, truck

washers, landscapers and gardeners. The range and size will vary depending on the

council.

Depots which tend to have the best environmental performance are often those at which

one manager, based at the depot, is responsible for the environmental performance of

the whole depot. Sometimes there are also managers or supervisors in each section of

the depot responsible for their individual sections. All operations staff should be trained

in stormwater management and pollution prevention techniques. This environmental

responsibility should form part of a job description, performance agreement or

employment contract.

Councils and their employees should meet their legislative responsibilities under the

Protection of the Environment Operations Act 1997 (POEO Act).

Risk assessmentDepots should have an environmental management plan (EMP) in place. The EMP

should be developed following an extensive audit/review of all depot activities that rates

the risks associated with all activities carried out at the depot as high, medium or low. The

plan should then identify appropriate environmental management controls for each of the

medium and high-risk activities.

The plan should also include appropriate incident and emergency response procedures.

Scope of proceduresThe following eleven issues cover many aspects of stormwater management for depots.

Some of the suggested techniques are for everyday use and some relate more to the

need for council management planning:

• general provisions

• bulk materials storage

• storing and decanting chemicals

• bunding

• refuelling areas

• mechanical workshops

• nurseries

• painting and signwriting

• equipment storage and parking

• wash bays

• waste storage and disposal.



C.3.1 General provisions



BackgroundIn order to minimise the overall environmental impact of the depot it is strongly

recommended that an individual offi cer trained in this area is allocated responsibility for

monitoring all aspects of depot operations.

A series of checklists should be developed for that offi cer to provide them with a guide

as to what is required. There should also be a formal incident reporting and incident

response system initiated within council in order to give the person in charge of that

responsibility a level of authority.

ActionsIn order to minimise the overall impacts of depots, the following actions should be

considered:

• stencil stormwater drains to indicate that they are not to receive solid or liquid waste

• adopt an environmental policy which includes a documented stormwater management

plan

• formulate a spill prevention and clean-up plan for liquids, powders, and solids

• provide staff with regular environmental training.



C.3.2 Bulk materials storage



BackgroundSand, soil, woodchips and so on from bulk storage areas should be prevented from

entering the stormwater system.

Actions In order to minimise these potential impacts, the following actions should be considered:

• divert runoff around storage areas so it does not carry materials into drains. Impervious

‘speed bump’ type structures could be used

• grade storage bays so that the entrance is the highest point, with drainage through a silt

arrester

• keep stockpile levels below the level of surrounding walls to reduce windblown dust

• cover storage areas permanently or temporarily (e.g. during rain or after hours) where

possible

• spray or cover stockpiles on dry windy days to reduce dust; trees may be planted as a

windbreak for permanent stockpile areas

• if a bay is to be established for the temporary storage of dumped material make sure it

is bunded and covered. If the dumped material is considered hazardous make sure it is

stored in line with Work Cover requirements

• provide, if possible, a grassed area between the storage bay access area and the

stormwater system to act as a fi lter

• decide which areas are ‘dirty’ and which are ‘clean’, depending on what they are used

for, then keep them as separate as possible

• make sure dirty areas drain to a sediment removal device and/or are swept regularly

• ensure trucks have sediment removed from tyres (using a wheel shaker, wash-down

area etc.) before entering the street or any area that drains to the stormwater system

and does not have a sediment removal device attached.



C.3.3 Storing and decanting chemicals



BackgroundThe NSW WorkCover Authority should license storage of dangerous goods, and storage

of any hazardous materials should be in accordance with current legislation.

Actions In order to minimise these potential impacts, the following actions should be considered:

• store any chemicals classifi ed under the NSW Occupational Health and Safety Act 2000

to comply with the requirements of the Act. Work Cover NSW can provide information

on these requirements

• ensure containers are in good shape (e.g. not rusted or split)

• keep lids on all containers when not in use

• store empty drums and containers in a covered or bunded area; have them recycled as

soon as possible

• protect drums and tanks from possible collisions with vehicles and equipment

• keep spill containment kits in the chemical storage area, and ensure all staff are

properly trained in their use and disposal

• store and decant chemicals in a bunded area so that any spills or leaks cannot travel to

a stormwater drain; this is advisable even if only small containers are being stored

• ensure MSD sheets are easily accessible for all stored chemicals

• make it someone’s responsibility to ensure that all MSD sheet fi les for all chemicals

used by council are kept up to date and distributed to all users

• ensure all staff are familiar with emergency response procedures

• avoid storing chemicals on pervious surfaces, as spills can cause soil contamination.



C.3.4 Bunding



BackgroundEffective bunding is extremely important when dealing with chemicals.

ActionsIn order to build effective bunding, the following information should be considered:

• construct bunds for strong fl ammable and combustable liquids to comply with Australian

Standard AS1940: 2004 The storage and handling of fl ammable and combustible liquids

• construct the walls and fl oor of the bund with impervious material

• use reinforced concrete walls; mortared brick walls are not considered adequate for

bund walls around above-ground storage tanks

• size the bund to hold a volume equivalent to 110% of the largest container

• if fi re protection is provided, size the bund capacity to retain the fi rewater as well as the

spilled substance

• if possible provide a collection sump in the bund fl oor for removal of liquids

• make drain valves leakproof and place outside the bunded area

• if possible provide a roof to stop rainwater getting in, but always check with WorkCover

NSW regarding safety considerations before installing a roof over bunded chemicals

• ensure bunds are regularly inspected and documented as part of the depot’s routine

maintenance program.



C.3.5 Refuelling areas



BackgroundRefuelling is an important depot activity which should be well managed so that spills are

avoided.

Actions In order to minimise the potential environmental impacts of refuelling areas, the following

actions should be considered:

• clean up spills immediately using dry methods; absorbent materials should be readily

available for this purpose and staff should be trained in spill management. A full spill kit

should be accessible at all times.

• an emergency stop button should be installed on all pumps

• record the quantity of fuel drawn from underground storage tanks; balance these

amounts with the amount of fuel delivered, as unexplained fuel losses may indicate that

underground tanks are leaking

• include a test for water in the tanks as part of the depots routine maintenance. Water in

the tank will also indicate leaks.

• ensure refuelling areas are concrete (bitumen deteriorates from fuel or oil spillage) and

covered; divert runoff from elsewhere and install a ‘blind’ pit or bund to prevent spills

from fl owing out of the area.

• ensure that fuel bowser hoses can not reach outside the bunded area

• if the refuelling area cannot be covered, divert runoff to a treatment device capable of

removing fuel products. Minimise the catchment area with bunding to stop stormwater

running into and through the forecourt refuelling area

• ensure regular inspections of bunds, blind pits and treatment devices are conducted

and documented

• investigate a fuel card system to supply vehicles with petrol at service stations; this may

remove the need for fuelling at depots

• ensure all appropriate staff are familiar with council’s emergency response procedures

particularly in the refuelling area.



C.3.6 Mechanical workshops



BackgroundRegular cleaning, effective design and other measures can make workshops effi cient and

safe.

ActionsIn order to minimise the potential environmental impacts of mechanical workshops, the

following actions should be considered:

• workshop areas should be indoors or in covered bunded areas and no maintenance

should be done outside these areas

• adopt and promote a policy of immediate clean-up of all spills

• workshops should drain to the sewer, with treatment as required by a trade waste

agreement

• fl oors should be swept regularly, rather than washed down; if washing is necessary,

water should fl ow to the sewer not the stormwater system

• oil, waste oil, coolants, lubricants and any other liquids should be stored in an area

bunded or graded so that spills cannot reach the stormwater system

• liquid wastes such as oils, solvents, oil fi lter and radiator coolant should be recycled,

where possible, or disposed of through a licensed waste contractor

• batteries should be stored in a covered and bunded area

• hands should be washed over a basin draining to the sewer, and not under outside taps

near stormwater inlets

• drainage systems, sumps and traps should be regularly maintained

• dry absorbent material for cleaning up spills should be clearly identifi ed and easily

accessible

• MSD sheets for all chemicals should be easily accessible

• ensure all staff are familiar with councils emergency response procedures.



C.3.7 Nurseries



BackgroundNurseries can be an area of concern because of the use of fertilisers and other

chemicals.

ActionsIn order to minimise the potential environmental impacts of nurseries, the following


• mix chemicals on an impervious area fi tted with a collection sump to capture any spills

• ensure runoff from the nursery area is collected and reused, or discharged through an

approved treatment device. Runoff from the nursery should not be allowed to reach the

off-site stormwater system

• use controlled release fertilisers that minimise the leaching of nutrients

• mix fertiliser into the potting medium when planting, to minimise spillage later

• add zeolite or clay to potting mix to increase the retention of soluble nutrients

• maintain watering systems so they deliver uniform water quantities

• when using overhead sprinkler systems, collect pots into irrigation bays, and minimise

the area between pots so that irrigation water is less likely to fall between them

• re-pot plants into bigger containers; this will increase the amount of stored water in the

pot and allow for longer periods between watering, saving water and the potential for

leaching

• water plants and apply liquid fertilisers using drip irrigation or sub-irrigation systems

(sub-irrigation systems deliver water to the bottom of pots); these two methods can

provide water savings of up to 75% compared to fi xed sprinklers



C.3.8 Painting and signwriting



BackgroundPainters and signwriters traditionally use solvents and oil- and water-based paints. They

also conduct their work both in paint shops, spray booths and outside. The potential for

this type of work to pollute the environment is signifi cant.

Actions In order to minimise the potential impacts in painting and signwriting, the following actions


• store all paints, solvents, liquid wastes and empty containers appropriately – see C.3.4

• ensure spray painting is carried out within an approved spray booth, with drainage to

collect spills

• dispose of solvent and paint waste only through a licensed waste contractor

• consider using solvent recovery units; these reduce the amount of used solvents that

need to be disposed of

• have dry, absorbent spill clean-up material clearly identifi ed and easily accessible in

spray booths and workshops.

• have MSD sheets for all chemicals used in the painting and signwriting areas easily

accessible

• ensure all staff are familiar with councils emergency response procedures

• ensure all equipment is cleaned in a designated environmentally safe area

• ensure all cleaning liquids are appropriately disposed of

• ensure all rags and other material used for cleaning are recycled or appropriately

disposed of

• designate an area for painters and signwriter for handwashing in order to minimise the

amount of paint washed into the sewer system.



C.3.9 Equipment storage and parking



BackgroundLeaks from equipment, vehicles and plant, and spills from refuelling are signifi cant

contributors to stormwater pollution from depots.

Actions In order to minimise the potential impacts of equipment, storage and parking, the

following actions should be considered:

• regularly sweep parking areas; otherwise keep them clean of waste

• ensure that earthmoving equipment is washed in a designated wash bay before storage

• try to ensure parking areas for vehicles likely to contribute debris and residues

to stormwater pollution (e.g. garbage trucks) are bunded; alternately, ensure that

stormwater inlets that drain such parking areas are fi tted with a treatment device

• ensure parking areas discharge to the stormwater system via an approved treatment

device to capture litter and sediment; where oil contamination is likely, treatment should

also include oil separation

• promptly report oil and fl uid leaks from vehicles and plant to enable repairs to be done.

Designate the same parking spots for all major equipment every day in order to identify

which pieces of equipment may be leaking

• ensure noise at start-up is kept to a minimum in order to minimise impact on neighbours

• maintenance work should not be carried out in the equipment storage and parking area.



C.3.10 Wash bays



BackgroundA designated area for washing vehicles should be established with hose lengths limited

so that staff cannot wash vehicles outside that area.

ActionsIn order to minimise the environmental impacts of wash bays, the following actions should

be considered:

• wash bays should be covered, bunded, and have a treatment device connected to the

sewer, particularly if detergents and high-pressure hoses are used; ensure that you

have a trade waste agreement with the authorities for discharges to the sewer

• the treatment device (oil and water separator) and bunding should be maintained.

Inspections and other actions should be documented

• ensure that the vehicle is parked within the bunded area and no overspray or

wastewater can leave the bunded area (signs to advise drivers should be installed)

• for wash bays used only to remove soil from vehicles, without the use of detergents or

high pressure hoses, the area could drain to a suitable sediment removal device

• ensure the area within the wash bay is paved with concrete

• use only quick-break degreasing compounds, to reduce the emulsifi cation of oils and

other hydrocarbons

• ensure the wash bay area is cleaned at the end of every day.



C.3.11 Waste storage and disposal



BackgroundCouncils are often required to store material dumped in parks and other areas before

disposal. It is strongly recommend these materials should if possible be taken directly to

land fi ll or a licensed transfer station.

Council also generates a lot of its own waste from workshops and other areas. This waste

also requires attention.

ActionsIn order to minimise potential impacts of waste storage and disposal, the following actions


• store disused car and truck batteries under cover and in a spill tray or bund

• store radiators awaiting disposal or exchange under cover within a bunded area

• drain used oil fi lters of excess oil and store them under cover in an impervious container

awaiting collection for recycling

• store all potentially polluting wastes under cover where possible. If they have to be

stored outside, keep them in an impervious waste container; in bunded areas with a

drain leading to a dead-end sump made of impervious material such as concrete. This

should be covered if possible

• recycle waste oils, coolants and solvents wherever possible.



C.4 Golf courses

OverviewManaging a golf course in an environmentally responsible way

requires councils to balance the needs of golfers with those of the

wider community and the surrounding environment. Council could

let the members or clients of the club know of its intention to change

practices to become more environmentally sustainable and what

they can do to help. A leafl et in the pro shop of the club can explain the reasons for the

changing appearance of the course and signage on the course near wetlands and areas

of rough will explain the role they play in protecting local waterways. Articles in local

newspapers can inform the community of what council is doing, in this regard.

Best management practices can mean, for example, changing or lowering the amount of

fertiliser used, developing wider areas of rough particularly around waterways, planting

more native species which require less fertiliser, and building ponds or lagoons on the

golf course which act as nutrient traps or stormwater reuse ponds.

The document Improving the environmental management of NSW golf courses

(Australian Golf Course Superintendents Association, 2003) is a useful resource – call

(03) 9548 8600 or visit www.agcsa.com.au. Councils and their employees should also

meet their legislative responsibilities under the Protection of the Environment Operations Act 1997 (POEO Act).

Risk assessmentGolf courses should have an environmental management plan (EMP) in place. The EMP

should identify the potential impacts of all routine maintenance activity and the controls

that should be put in place to minimise the environmental risks associated with these

activities. It also should include an emergency response procedure.

The EMP should also identify high-risk or environmentally sensitive areas within the golf

course that need extra attention when work is being completed in or near them.

Scope of proceduresThe following eight issues cover many aspects of environmental management for golf

courses. Some of the suggested techniques are for everyday use and some relate more

to the need for council planning:

• bulk materials storage

• mixing and storing chemicals

• earthworks

• applying pesticides

• applying fertilisers

• irrigation

• mowing

• vehicle and equipment washing.



C.4.1 Bulk materials storage



BackgroundGolf courses need to store sand, soil, gravel and other landscaping materials in bulk

storage areas. They should be established and managed in a way that minimises

potential fl ows from the areas into the stormwater system.

ActionsIn order to minimise these potential impacts, the following actions should be considered:

• locate material stockpiles at least 2 metres (preferably 5 metres) from waterways,

roads, slopes steeper than 10% and areas of concentrated water fl ow

• divert run-on water around storage areas by placing diversion banks up-slope and with

sediment control structures placed immediately down-slope to protect other lands and

waterways from sediment pollution

• grade storage bays so that the entrance is the highest point with drains through a silt

arrester or grass fi lter area

• keep stockpile levels below the level of surrounding walls to reduce windblown dust. If

you do not have surrounding walls then the height of the stockpile should be less than 2

metres

• for long-term stockpiles where regular access is required, bund the area on three sides

with concrete, brick or timber walls

• cover temporary stockpiles with a weighted down plastic sheet. Such stockpiles

could be protected with straw bales, sandbags or other similar sediment controls as

necessary

• minimise noise impacts from machinery on surrounding residents by timing operations

appropriately.



C.4.2 Mixing and storing chemicals



BackgroundThe chemicals needed for parks and gardens maintenance, such as pesticides, are often

stored on-site. There is potential for stormwater pollution if they are not stored properly

and mixed carefully.

ActionsIn order to minimise these impacts, the following actions should be considered:

• store and mix chemicals in a covered, bunded area, ensuring that all stormwater is

directed away from the bunded area to a dead-end collection sump. All stormwater

should be directed away from the bunded area

• prepare a spill plan and train staff to deal with spills

• keep a spill kit and clear instructions near where chemicals are stored

• mix chemicals according to the manufacturer’s specifi cations

• inspect bulk storage containers regularly, and replace them if rusted or damaged

• store products classifi ed under the NSW Occupational Health and Safety Act 2000

(OH&S Act) to comply with the requirements of this Act; depending upon the quantity

stored, licensing by the WorkCover Authority may be required

• store empty drums and containers under cover, and have them removed as soon as

possible

• ensure MSD sheets for all stored chemicals are easily accessible

• ensure somebody is responsible for regularly updating MSD sheet folders.

Building an effective bundEffective bunding is extremely important when dealing with chemicals – see activity C.3.4.



C.4.3 Earthworks


WATER WASTE SOIL

BackgroundA comprehensive erosion and sediment control plan or soil and water management plan

should be put in place for any major earthworks undertaken on the golf course.

The potential for erosion should fi rstly be minimised by limiting the extent and duration of

land disturbance and protecting areas once exposed.

The amount of runoff from the site should be controlled by keeping fl ows on-site and

impeding fl ows. Sediment should be retained within the site. For further information see

Managing urban stormwater: soils and construction vol. 1 (Landcom 2004).


• develop a comprehensive erosion and sediment control plan to a level of detail

consistent with the works being undertaken

• ensure all downstream drains or waterways are protected by installing and maintaining

appropriate erosion and sediment controls. Install site drainage works to convey

stormwater away from the site

• where possible, divert clean run-on water from lands upslope around the site while

development is taking place by using stabilised diversion drains, earth banks, rock,

fallen trees, straw bales, sandbags, gravel or sand sausages

• install site drainage works to convey stormwater safely through the site. Reduce

stormwater runoff by keeping gradients as low as possible. Encourage infi ltration of

water on the site using progressive revegetation. Leave the soil surfaces scarifi ed by

track-walking. Install check dams to slow the water down and limit erosion

• install sediment retention traps at the low points of major work sites using materials

such as straw bales, woven geotextile (sediment fence), earth, rock or suitable crushed

concrete products

• place sandbags, straw bales, gravel or sand sausages around downstream drains

• if the soil is dry and dust is active, water down the traffi c areas to reduce dust

• ensure someone is responsible for checking that the erosion and sediment control

devices remain in place and are maintained throughout the life of a job. Document

these inspections and actions that have been taken

• if possible schedule activities to periods when rainfall erosivity is lowest (e.g. low rainfall

months)

• limit the area of land disturbance and avoid disturbance near watercourses, drainage

lines and sensitive areas. These restricted ‘do-not-disturb’ areas may require clear

identifi cation with barrier mesh, sediment fencing etc.

• stabilise disturbed areas immediately after fi nal grading has been completed. This can

be done with vegetation and can be either temporary or permanent restabilisation.



C.4.4 Applying pesticides



BackgroundGolf course managers have a responsibility to control animal pests and weeds in

golf courses, and often use a variety of chemicals to achieve this. Pesticides include

insecticides (to kill insects), rodenticides (rodents), herbicides (plants) and fungicides

(mould and mildew).

These chemicals may present a risk to organisms other than the target species, and

can cause dramatic changes within ecosystems through direct destruction of organisms

and habitats and, more subtly, through small doses making organisms less resistant

to disease and inhibiting their growth. Aquatic animals in particular are susceptible to

chemicals because they can absorb the pesticides readily from the water and sediments

in which they live.

Chemicals can be introduced into waterways in a number of ways:

• direct application

• air drift from nearby treatment areas

• migrating organisms

• percolation through the soil

• spills and poor disposal

• surface runoff.

Inappropriate herbicide application can render land susceptible to erosion.

The Pesticides Act 1999 places specifi c responsibilities on organisations and individuals

using pesticides. It is important that all offi cers using pesticides are familiar with the

requirements of the Act.


be considered:

• mix and apply chemicals as indicated by labels

• address all risks to satisfy the Act’s requirements for ‘due diligence’

• use pesticides when needed, not regularly, and use them only where needed, not all

over

• choose plant varieties that are resistant to diseases known to be prevalent in that area,

and match species to a site

• carry minimum amounts of chemicals on work vehicles and ensure they are safely

secured and contained

• ensure MSD sheets for all chemicals used and spill kits are easily accessible

• don’t use chemicals during unsuitable weather conditions (e.g. windy periods) when soil

is very wet, during rain or when rain is forecast

• don’t apply chemicals near drains or gutters

• ensure you keep a detailed record of pesticide application and staff are appropriately

trained as required by the Pesticides Regulation



• wash chemical containers at the depot where waste water can go to the sewer

• purchase chemicals from a supplier that recycles empty chemical containers, or follow

label directions for disposal of containers

• monitor sites to ensure that chemicals are having the desired effect, and adjust

accordingly

• ensure all staff are trained in dealing effectively with chemical spills

• ensure all staff are familiar with emergency response procedures.



C.4.5 Applying fertilisers



BackgroundCouncils apply fertilisers to golf courses to maintain the vegetation coverage, appearance

and usefulness of these areas. Areas where fertilisers are used include road verges,

ovals, garden beds and prominent parkland locations.

If fertilisers are incorrectly applied or overused, or an unsuitable product is used, they

could end up causing stormwater pollution.


be considered:

• use the correct rates and procedures for applying fertilisers

• assess the need for fertilising, rather than applying regularly

• apply fertilisers during growth periods to help uptake of nutrients by plants

• use controlled release fertilisers wherever possible, as they are less prone to leaching

and pollution than soluble fertilisers

• maintain a buffer between the area of application and drains, gutters and waterways

• reduce the need for fertilisers by planting species that do not require additional nutrients

to those naturally present in the soil

• apply small doses of fertiliser more frequently rather than larger doses less frequently,

to reduce the chance for runoff

• monitor sites to ensure that fertilisers are having the desired effect, and adjust

accordingly

• dispose of containers properly


• ensure all personnel are familiar with emergency response requirements.



C.4.6 Irrigation



BackgroundGolf courses use a lot of water. Timing water use and different methods of application can

minimise the amount of water required and it can also help to reduce stormwater fl ows

from the course.

ActionsIn order to minimise the environmental impact of irrigation, the following actions should be

considered:

• develop an irrigation plan which considers the relative costs of different types of

irrigation equipment

• time irrigation so that plants make best use of water

• check equipment regularly to ensure accurate, effi cient and reliable metering and

dispersal

• ensure that there is no concentrated runoff causing erosion

• install soil moisture monitoring equipment, which can improve irrigation effi ciency

• consider having a stormwater harvesting and reuse scheme for irrigation (see

Managing urban stormwater: harvesting and reuse, DEC 2006).



C.4.7 Mowing


WATER NOISE WASTE SOIL

BackgroundMowing on golf courses should be completed to a plan.

There is a potential for grass clipping runoff from fairways in some rough areas to enter

waterways, which adds to the nutrient load in those waterways.

Species selection will also infl uence the type and frequency of mowing on golf courses.

ActionsIn order to minimise the potential impact of mowing on golf courses, the following actions


• remove all litter and debris before cutting grass

• ensure the mower projects grass clippings away from waterways, drains, gutters etc.

• maintain a buffer adjacent to waterways by reducing mowing near these areas

• use a grass catcher near sensitive areas such as creeks and wetlands

• remove grass residue from paved areas such as footpaths and driveways

• if feasible, send grass clippings to a composting facility or worm farm

• consider creating ‘no-go’ mowing areas and recolonise the area with native grasses and

shrubs, particularly adjacent to watercourses and wetlands.

Species selectionSelect turf grasses with consideration of their suitability for the local climate. Species

grown outside their optimum climate range may require greater inputs for their

management.

Turf grasses with a healthy root mass in healthy soil are less likely to develop disease or

come under attack from pests. The use of ‘organic’ products generally aims to facilitate a

lively soil microbiology, high nutrient availability, high water retention and high root mass,

thereby keeping the need for chemical additives to a minimum.



C.4.8 Vehicle and equipment washing


WATER SOIL

BackgroundA range of different equipment is used on golf courses, all of which needs to be

washed and maintained. There is a signifi cant potential for pollution in the washing and

maintenance of that equipment.


• always wash down equipment in a designated bunded wash bay and collect wash water

for reuse or appropriate disposal

• select chemicals for cleaning of equipment having minimal environmental impact

• all MSD sheets for cleaning and maintenance should be easily accessible



C.5 Swimming pools

OverviewLocal government commonly plays a key role in providing swimming

pool facilities to the community. Keeping pool water quality to a

standard compatible with public health requirements is particularly

important. It includes fi ltration, disinfection, pH adjustment, and

recirculation of treated water.

Different pools use different techniques to achieve these functions, particularly for

disinfection. While some pools rely solely on chlorine, many newer ones also use ozone

and bromine technology. The environmental impact of swimming pools largely depends

on these disinfection methods.

Risk assessmentCouncils should develop environmental management plans (EMPs) for their swimming

pools. The EMP should identify the potential environmental impacts of all routine

maintenance activities and the controls that should be put in place to minimise those

impacts, focusing particularly on high-risk activities. The EMP should include an

emergency response procedure and should note how any regulatory requirements will be

met.

Scope of proceduresThe following fi ve issues cover many aspects of environmental management for

swimming pools. Some of the suggested techniques are for everyday use and some

relate more to the need for council maintenance planning:

• water runoff

• using chemicals

• fi lter backwash water

• emptying the whole pool

• pool structure.



C.5.1 Water runoff


WATER SOIL

BackgroundRunoff from ‘hardstand’ areas at the sides of pools typically goes into stormwater inlets

around the pool perimeter. A major source of this runoff is ‘splash’ from the pool and the

‘dragging’ of water as people leave the pool.

Pool water may encourage algal growth around the pool and in the stormwater system.

Regular maintenance work is required to remove the algae, commonly using agents such

as concrete cleaner, acid and chlorine. This, in turn, adds pollutants to the runoff.

In pool amenity blocks it is standard practice to use an industrial-grade disinfectant,

and occasionally sodium hypochlorite combined with water from a hose on the fl oor, to

maintain hygiene. The hosing of these areas combined with the use of chemicals can

cause pollution problems if water fl ows to the stormwater system rather than the sewer.

ActionsMinimising the impact of water runoff at swimming pools requires a systematic

management approach. The following actions should be considered:

• sweep the hardstand and amenities areas instead of hosing or washing

• use biodegradable disinfectants

• change the drainage system so that runoff from the amenities blocks drains to the

sewer (subject to approval from the water authority).



C.5.2 Using chemicals



BackgroundOperating swimming pools involves unloading, storing and handling a large number of

potentially harmful chemicals and materials, including chlorine compounds and acids. If

they are not properly managed there is the potential for spills.

Due to the corrosive nature of chemicals such as chlorine compounds and acids, spills

are likely to occur if materials are not stored in suitable containers. The corrosive qualities

of these materials may also result in the degradation of storage and bunding structures.

This is especially the case where brickwork is used in the bunding of bulk acids and

chlorine compounds.

Most chemicals are applied with automatic dosing, thus minimising the potential for spills

from handling. In some cases, however, manual handling is undertaken and there is the

potential for spills and runoff into stormwater.

ActionsThe use of chemicals at swimming pools requires a systematic approach. The following


• ensure all staff are familiar with SOPs for handling chemicals (see section C.3)

• ensure all staff are familiar with spill response procedures

• ensure all appropriate MSD sheets are available at storage and application sites

• ensure appropriate spill response equipment as outlined in the MSD sheets is available

• design chemical storage areas that can contain spills, allowing particularly for corrosive

chemicals

• use bunding at the spot where bulk fi lling of chemicals is done, or isolate this area so

that spilt chemicals do not fl ow to the stormwater system

• use correct labels for hazardous and other materials, and store them in appropriate

containers

• store spill response equipment in a clearly marked container close to where the

chemicals are used and stored so that the equipment is easily accessible

• the bunded areas should be able to contain 110% of the volume of the largest container

within the bund.



C.5.3 Filter backwash water


WATER WASTE SOIL

BackgroundOver time, materials accumulate in pool fi lters. This reduces the effectiveness of the fi lter,

so it should be cleaned by reversing the fl ow of water for a short time (backwashing).

The backwash water, which contains high levels of suspended solids and other pollutants,

cannot be discharged back into the pool untreated, so it should be either treated for reuse

or discharged to the sewer (subject to water authority approval).

ActionsThe management of fi lter backwash water requires a systematic approach. The following


• treat backwash water for reuse or irrigation

• discharge it to the sewer system. Contact your local water and sewer supply service

operator to discuss their requirements

• treat the water to meet required water quality requirements.



C.5.4 Emptying the whole pool


WATER SOIL

BackgroundMunicipal pools are often emptied to conduct routine maintenance work and/or for the

winter close-down period. It has been common practice to discharge this wastewater to

the stormwater system.

The regulations in relation to the discharge of swimming pool water are changing

regularly. It is strongly recommend advice be sought from DECC before completing any

discharge to stormwater.

The chemicals in swimming pool water can strongly affect the environment, but especially

when large volumes of water are discharged. The water generally contains high

concentrations of a disinfectant/oxidising agent, total nitrogen and total dissolved solids.

Furthermore, water fl ow is affected by large volumes of water discharged in short periods.

ActionsThe emptying of pool water requires a systematic approach. Recommended actions

include:

• avoid draining a pool unless necessary

• consider using maintenance products that can be applied to water in the pool

• if discharging to the environment, allow water to stay in the pool for a time so that

chlorine can dissipate (add sodium thiosulphate if necessary) and for pH to adjust to

that of the receiving waters (chemically modify if necessary).

• monitor chlorine levels and pH before discharging the water

• if approved for discharge to stormwater, discharge the water at a slow rate to avoid

erosion in the receiving water body

• prior to the pool water being released, the water temperature should be given time to

return to the ambient temperature

• swimming pool operators should investigate options for the reuse of pool water.



C.5.5 Pool structure


WATER SOIL

BackgroundWater from municipal pools can continually leak into the environment from faults in

the pool structure, as a result of broken pipes, or as a result of faulty fl oat valves and

inadequate balance tank design.

This means that chlorinated water can leak into the groundwater and/or nearby surface

waters, with a resulting impact on aquatic ecosystems and soil microenvironments.

ActionsMinimising the impact of the pool structure on the local environment requires a systematic

approach. The following actions should be considered:

• undertake routine maintenance of fi lters, pipework and valves

• routinely test for signifi cant water losses and investigate the source of losses; this

involves checking water consumption fi gures and stormwater pits, and switching off

fi lters and water for a period

• identify leaks and repair sources of signifi cant water leakage; fi nding leaks can involve

a high degree of investigative work and may require specialist help

• quantify other sources of water use, such as evaporation and splash water.



C.6 Waste collection and management

OverviewWaste management can involve:

• garbage collection

• litter management programs

• domestic and industrial waste reuse and minimisation programs

• kerbside recycling

• public place recycling

• public place waste minimisation

• domestic and industrial collection services.

Council operations personnel can be involved in this broad range of waste minimisation

activities. Managed well, these activites will help to reduce the environmental impact of

waste. Managed poorly they can add signifi cantly to the pollution load in our parks and

gardens, in our stormwater channels and our rivers and waterways.

Any council developing programs for waste minimisation and management can utilise a

broad range of excellent resources. Some resources are available from

• Department of Environment and Climate Change NSW at www.environment.nsw.gov.au

• Sustainability Victoria at www.sustainability.vic.gov.au

These guidelines and publications provide important information and advice to councils

planning to minimise the environmental impact of their waste collection and litter

management services.

The key message is that council personnel should accept responsibility for spilt or littered

rubbish within their areas. Council offi cers or contractors involved in collection of waste

should ensure all waste in and around the bin is collected and not just the waste in the

bin. It is the responsibility of their personnel or their contractors collecting the rubbish or

recyclable materials to ensure that areas where they work are kept clean at all times.

Scope of proceduresThe following issues cover key aspects of environmental management for waste

collection and management:

• rubbish collection and removal

• waste and recyclables collection and management.

Councils may also develop other procedures for:

• collecting unwanted household chemicals

• management of illegally dumped waste

• management of waste from retail, commercial and industrial premises



C.6.1 Litter reduction


WATER WASTE SOIL

BackgroundLitter can be a continual stormwater problem where there are inadequate facilities for

waste disposal and collection.

In retail areas, entertainment venues and sporting fi elds, litter bins can provide a

continual source of pollutants if the type of bin, its location and frequency of emptying is

not suitable.

Actions

In order to minimise these potential environmental impacts, the following actions should

be considered:

• consider the types of rubbish receptacles used including their size and how well

designed they are to adequately contain the intended waste materials, where they are

located and how often they are emptied

• provide separate bins for waste/rubbish and recyclables

• look at collection, transport and disposal of receptacles

• monitor litter ‘hotspots’ to ensure that receptacles are being placed effectively

• develop and implement a system to deal with ‘unknown disposed rubbish’. This system

should discourage council personnel from handling this type of rubbish until they are

sure of what it is and the most effective way of dealing with it. Contact appropriate

authorities if dumped waste or spilt material cannot be readily identifi ed.



C.6.2 Waste and recyclables collection and management



BackgroundKerbside waste collection and recycling collections generate considerable amounts of

pollution through spillage and the collection and emptying processes. The amount of litter

created is related to windy conditions, lack of care by recycling and garbage operators

and householders, and the type of collection systems used. Other issues creating litter

can include spillage from unstable smaller bins, dogs scavenging and the regularity of the

collection operation.

ActionsMinimising the environmental impact of waste and recyclables collection and

management requires a systematic approach. The following actions should be

considered:

• ensure all trucks and other vehicles used to collect waste materials are properly

maintained, particularly in regard to the hydraulic mechanism used for lifting – ensure

that a scheduled maintenance program is developed

• ensure all trucks and other vehicles used to collect waste and recyclables are checked

for leaks every morning before leaving the depot

• use only vehicles fi tted with lifting and emptying mechanisms which minimise the risk of

spillage

• require council personnel or contractors involved in collection to immediately clean up

all spillage of waste or recyclables

• ensure that all trucks carry an adequate supply of dry absorbent materials and other

necessary equipment for use in the event of a spillage

• require council personnel or contractors to immediately notify council of the location of

any spilled material not resulting from the collection operation

• ensure all machinery and equipment is stored on hard stand areas

• ensure all staff are familiar with spill response procedures

• wash garbage trucks and public rubbish bins in areas where facilities are available for

the collection and appropriate disposal of the resulting waste water

• rotate times for rubbish removal activities in residential areas to minimise the continual

early morning noise impacts on any one site of residents

• provide facilities for the collection of chemicals, and inform residents of the availability

of these.



Appendix D: Example environmental audit tool for council work sites

The following checklist can be used to assess erosion and sediment controls on councildevelopments, from major construction sites to routine maintenance activities. Councils can adaptthe checklist as required. An electronic copy can be found atwww.environment.nsw.gov.au/stormwater.

Council name

emiTetaD

Auditors on site

Job address

Street

Suburb

Staff on site

Name

Name

Name of supervisor and activity type

Name

Type of activity

Machinery/truck/vehicle (including registration numbers)

:geR:elciheV

:geR:elciheV

Overall assessment (to be completed at the conclusion of the audit)

WW



A. Major construction or maintenance activities (planning)

QUESTION YES / NO COMMENT

1a) Is there a formal erosion and sedimentcontrol plan for the site?

If no go to Q 2 *Please note if not necessary

1b) Are the requirements of the plan inplace?

1c) Have there been any significantamendments to the plan since theproject began?

2) Has the project manager developed aninformal plan for erosion and sedimentcontrol on the site?

3) Do you think the project should havebeen the subject of a formal erosion andsediment control plan?

B. All sites (on-site practices)

Minimising erosion


1) Are any measures in place to divertwater around the site?

*Please note if not necessary

2) Are there any measures in place tominimise the impact of rainfall on theexposed soil (e.g. mulching?)


3a) Are there any stockpiles on sitecontaining materials that could add toerosion from the site? If no go to

Q 4

3b) Is there any up-slope or down-slopeprotection of the stockpiles?

3c) Are stockpiles covered?


4a) Is there a single stabilised entry/accesspoint to the site?

If no go to

Section C *Please note if not necessary



4b) What material is used in the accessway?

4c) Does the access point drain to thesediment fence or other sedimentcontrol devices?

Managing sediment loss


1) Is there a possibility that sediment orany other material can be washed fromthe site?

2) Are the downstream drains protectedand if so in what way?

3) What type of protection is in place?

Sediment socks

• are they an effective barrier?

Straw bales

• are they dug into the soil?

• are they stabilised?

Sandbags

• will they be effective?

Sediment fence

fabric buried in 150 mm?

stakes placed at 3 m intervals?

construction along contour?

turnbacks installed?

fence at least 2 m from slope?

Other

4) Will these devices be effective atcontrolling runoff from the site?

5) How long do the devices need to stay inplace after the project?

6) What arrangements has the managermade to ensure the devices remain inplace?



C. Maintenance


1a) Are the erosion and sediment controlstructures being maintained?

1b) Is this part of an overall plan?

D. Site impacts


1) Are there any indications of litter,sediment or other material from the jobsite in the downstream drains?

2) Is there a specified area for wastestorage on-site?

3) Is this disposal area well maintainedand positioned away from any drains?

4) Is there any indication of litter, sedimentor other materials on the roads aroundthe site?

E. Hazardous materials management


1) Are hazardous materials used on site? PetrolOilRoundupPaintsOthers _____________

2) Can the staff identify where the material safety data sheets can befound?

3) What procedures are in place to deal with chemical spills?

4) Are the tools and equipment for spillresponse available on site?

5) Is there any evidence of chemical spills on site?




1) Is this disposal area well maintained and positioned away from any drains?

2) Have arrangements been made for theremoval/transport of any waste generated from the site?

3) Are these arrangements in line withcouncil procedures?

G. Air pollution


1) Is there the potential for air pollution (dust, smoke or chemicalfumes) at the job site?

2) Are you satisfied with the efforts to control air pollution?

H. Noise pollution


1) Are you satisfied with efforts to control

noise pollution?

I. Flora and fauna


1) Is there the potential for local flora and fauna to be affected by this project?

2) Are you satisfied with the efforts to protect flora and fauna?

3) Is the work being completed on or near areas of critical habitat?

4) Are you satisfied with the extra efforts

required to protect the critical habitat?

F. Site management / waste management



H. Heritage


1) Is there the potential for local heritage tobe affected by this project?

2) Are you satisfied with the efforts to protect heritage?

3) Is the work being completed on or near a heritage site or precinct?

4) Are you satisfied with the extra effortsrequired to protect the heritage values?



Appendix E: General contract conditionsThe general conditions of contract from a NSW council designed to guide appropriate environmental management of sites are outlined below.

Clause ‘X’ Environmental systems planningThe Contractor shalla) Comply with all requirements of the Contract and statutory requirements for protection

of the environment.b) Ensure that each of its Subcontractors and Consultants comply in like manner.c) Demonstrate to the Principal by mutual inspection and/or documentation whenever

requested that requirements of the Contract and statutory requirements for the protection of the environment are being met.

d) Prior to the commencement of work, provide the Principal with certification that the requirements of the Contract and statutory requirements of the protection of the environment are capable of being met by the Contractors’ organisation and management.

e) If the period of the contract exceeds three months the Contractor is to provide the Principal with a monthly certifi cation that the requirements of the Contract and statutory requirements for protecting the environment are being met.

f) The Contractor is responsible for and must at its own cost make good any damage to the environment caused by the execution of the works.

Where inappropriate or inadequate provision of environmental management by the Contractor or Contractor’s Subcontractor results in costs, losses or damages incurred by the Principal or claims by third parties against the Principal for either or consequential costs, losses or damages, the Contractor shall be liable for costs, losses or damages associated with any claim including but not limited to administration costs incurred by the Principal in resolving such claim.

From ‘Special conditions of contract’

SC1 Environmental protectionThe Contractor has an overall responsibility within the limits of the work to protect and preserve the existing environment and to avoid pollution.

The Contractor shall take all necessary measures to remove or minimise any impact by the works on the existing environment to the satisfaction of the Superintendent and where appropriate the Protection of the Environment Operations Act, the Pesticides Act and any other relevant legislation or sound practices.

The Contractor shall ensure that polluted stormwater runoff and/or silt and soil does not enter the drainage system.

The Contractor shall also take all steps necessary to suppress any atmospheric dust and shall, whenever directed, dampen the work with a water cart or other approved means. The Contractor shall be on call at weekends and holidays to carry out this work, if so required by the Superintendent.

Noise generating machinery shall be properly muffl ed and/or silenced to current standards and shall be located as far from residences as is practicable.

W


In the event that council’s staff are ‘called out’ to rectify any non-compliance by the

Contractor, all costs thereof will be charged to the Contractor.

In general the Contractor shall at all times comply with the requirements of all

environmental legislation in force in New South Wales. No variation in costs will be

considered due to having to meet these requirements.

Where appropriate or inadequate provision of environmental management by the

Contractor or Contractor’s Subcontractor results in costs, losses or damage incurred

by the Principal or claims by third parties against the Principal for either direct or

consequential costs, losses or damages, the Contractor shall be liable for costs, losses

or damages associated with any claim including but not limited to administration costs

incurred by the Principal in resolving such claim.

Specialist contract conditions Council may consider incorporating special conditions in relevant specialist contracts.

Examples of these conditions are outlined below.

a) For planning operations and maintenance activities

‘The impact of any activity of asset construction and/or maintenance must take into

consideration the issue of stormwater quality and include treatments and operational

features to minimise the pollution of the stormwater. (Potential techniques are

contained in the Managing urban stormwater: soils & construction and Treatment techniques documents.)

b) For street cleaning

‘Sweeping shall be carried out in accordance with the specifi ed schedule and no dirt,

debris, paper, rubbish or waste shall be swept into any drainage system.’

c) For open space management

‘Prior to grass cutting, all loose litter, rubbish or debris shall be cleared from the

mowing area.’ (Performance criterion: Absence of litter, rubbish or debris).

‘All grass clippings and other debris to be swept or cleared from adjoining paths,

gutters, paved surfaces and garden areas.’ (Performance criterion: No clippings or

other debris after cutting operations.)

d) For waste collection

‘Clearing of bins – The Contractor should empty litter bins at the frequency specifi ed

in the schedule. Notwithstanding that a collection frequency for litter bins has been

specifi ed, the contractor should ensure that the litter bins are useable by the public

at all times and that the volume of matter in the litter bin never exceeds seventy-fi ve

percent (75%) of the capacity of the bin.’

‘Spilt litter – At the time of emptying the litter bin, the contractor should clean up any

spilt litter within a radius of two (or three) metres of the litter bin whether the spillage

was caused by the contractor or others.’

e) For site management

‘All sites must be kept neat and tidy at all times. For long term sites the contractor is

responsible for ensuring the cleanliness of the site at the end of every workday.’

f) For roadworks

‘All machinery must be checked for fl uid leaks on a daily basis.’

g) For swimming pools

‘All chemicals must be stored in line with environmental responsibilities and the

requirements of WorkCover, and the material safety data sheets for chemicals must be

readily available at the site.’



h) For parks and gardens ‘All contractors must ensure that all work is managed in line with council’s waste

minimisation and management policy.’i) For all areas using machinery ‘Contractors are responsible for ensuring all equipment is maintained in line with

manufacturer’s specifi cations. Copies of service records for machinery must be kept by the contractor.

‘Equipment cleaning is only to be carried out in a way that minimises environmental harm. This may include establishing bunded cleaning areas or ensuring all equipment is cleaned in a dedicated bunded area.’

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