Print9.4.1 Application to an Environmental Problem
Compliance with environmental regulations is an important part of the job nearly every day, and especially at surface mining sites. As with safety and health, mere compliance with the regulations is not sufficient if you are thinking in terms of sustainable development. All of the guidance given in this lesson applies to environmental as well as safety and health considerations. To illustrate this, let’s “talk through” a risk management problem related to protecting the environment, and you will soon see that the process is the same regardless of whether we are examining a safety, health, or environmental risk.
The Bedrock Quarry is located in a rural valley with no close neighbors. One neighbor of note is a large state-operated fish hatchery, which sits a few miles from the quarry. This is of note because the quarry discharges several hundred thousand gallons of water per day, and this discharge feeds into the stream feeding the hatchery. Interestingly, the fish hatchery loves the mining operation because the water they discharge is of higher quality than the normal stream water! It’s not often that a mine has a neighbor who loves them! Of course, there is a potential downside to this scenario: if the mine’s discharge should be contaminated, it could wipe out the entire hatchery. Think about the ensuing public relations disaster!
This is the kind of problem that you would tackle with your risk management tools. It is understood that you are operating with an EPA approved storm water pollution prevention plan (SWPPP), and as part of this plan, your company will have identified the day-to-day activities required to remain in compliance with the requirements of the Clean Water Act. Here we are not talking about redoing this plan or setting it aside. Instead we are going to take a fresh look to determine if we are doing everything that we reasonably can to protect the water supply. Remember, compliance alone may not be sufficient to prevent a mishap, and if we are truly mindful of staying within the bearable and viable regions of the sustainability diagram, we need to go above and beyond compliance!
As the first step of any risk management exercise, we need to put together a team. The team should include people with unique knowledge to contribute to the process, and at a minimum should include someone from operations management, an engineer, a safety or environmental staffer, and one or more miners. With the team duly constituted, there are some steps to be taken to help the individuals on the team to function as a team. These are beyond the scope of this discussion, but please realize that you can’t throw five people together, call them a team, and expect that they will function successfully as a team!
The Plan-Do-Check-Act paradigm, which was illustrated in Figure 9.3.4, provides a good road map for the team. As part of the planning, the team will define the objective, which is to ensure that the discharge water is always pure; and then they will define the tasks they believe need to be completed. The tasks will include reviewing the existing SWPPP, auditing the quarry’s performance under the existing plan, conducting a site assessment, performing a risk analysis and a risk mitigation/elimination study. The site assessment will involve several subtasks. Assignments for completing these tasks should be made and a schedule adopted. The person(s) accountable for completion of the tasks should be identified. Once these tasks have been completed, the risk management study can be conducted. The risk assessment matrix can be used to prioritize the risks that will be investigated, and then BTA or another tool of the team’s choosing, can be used to identify needed controls and recovery measures.
Once the controls and recovery measures have been identified, they need to be evaluated for practicality. Some of these may require design and construction, such as swales and rip rap lined ditches. Others may require adoption of operating procedures, such as regular inspections of fuel storage tanks and the prompt use of sorbents in the maintenance shop to cleanup spills. The monitoring and sampling program may require modifications. The “Do” stage of the paradigm, i.e. implementing the findings from the planning phase can be substantial, involving multiple personnel and requiring a period of time and significant resources to implement. This must be carefully scheduled and resourced.
All of the effort expended to reach the end of the “Do” stage will be wasted if a formal effort to verify that the risk management measures have been implemented. Moreover, the controls as implemented should be assessed to determine whether or not they are performing as expected. Of course, if the “Check” stage reveals gaps or shortcomings, they must be acted upon. This “Act” stage should not be treated as an afterthought; rather, the need to “close the loop” must be anticipated and built into the team’s charge. Adequate resources must be provided for this stage as well.
While the primary purpose of this environmental example was to illustrate the applicability of the management system approach, it should be noted for completeness that the Plan-Do-Check-Act paradigm is really an ongoing process, and the next key action would be to perform regular audits, as mentioned earlier.