The debate on the what, why and who of environmental compliance monitoring is heating up in South Africa.
There has been a spate of discussion around the country in the last year on Best Practice for Environmental Control Officers (ECOs). A group from the Western Cape and North West University are setting up a national working group, whose aim is to compile the ethics, guidelines and requirements for environmental monitoring in South Africa.
One of the biggest issues raised at a recent IAIAsa workshop is the difference between an ECO and an environmental compliance auditor.
An ECO, although not mandated by the South African national legislation, is generally written into environmental authorisations as a requirement in terms of the Environmental Management Programme (EMPr). In summary, an ECO needs to:
- Conduct ongoing monitoring of a development site to ensure it is meeting the requirements of the environmental authorisation, EMPr and best practice where possible; and
- Assist the site contractors in managing environmental issues on an on-going basis.
An environmental auditor, however, is mandated, as per Section 34 of the EIA Regulations (GN R326 of 2017), and must be independent. Their job is to:
- Ensure compliance with the conditions of the environmental authorisation and the EMPr; and
- Submit an environmental audit report to the relevant competent authority, which provides verifiable findings, in a structured and systematic manner, as per Appendix 7 of GN R326.
The environmental auditor, therefore, should not, and cannot, be the same person as the ECO. As Adrienne Edgson (a KZN independent specialist) recently pointed out – you cannot be the helping-hand and the enforcer for the same site or project.
For more information on the ECO Working Group – contact IAIAsa KZN
KZN Chair: Danielle Sanderson firstname.lastname@example.org
- Understanding independent Environmental Control Officers: learning from major South African construction projects, JA Wessels (2015) https://repository.nwu.ac.za/bitstream/handle/10394/15809/Wessels_JA_2015.pdf?sequence=1&isAllowed=y
- Integrated Environmental Management Information Series: Environmental Auditing https://www.environment.gov.za/sites/default/files/docs/series14_environmental_auditing.pdf
- Singapore Code of Ethic for ECOs https://www.corenet.gov.sg/einfo/Uploads/Codes/RNEA00003.pdf
- Environmental Auditor Guidelines for Conducting Environmental Audits, Victoria Environmental Protection Authority, Australia http://www.epa.vic.gov.au/~/media/Publications/953%202.pdf