Each port is free to either adopt the overall NPA's environmental policy verbatim, or to integrate the NPA policy statement into a policy specific to the port in question, to better reflect local circumstances.
Determination of Significant Aspects
In addition to the significant aspects noted in this policy guideline document, individual ports should examine their own particular circumstances to determine whether there are significant aspects because of specific local conditions, that also need to be incorporated into their Environmental Management Systems (EMSs).
Determination of Legal and other Requirements
This will be dealt with centrally by the NPA's head office so far as national and provincial legislation is concerned, by subscription to a reputable legal update service. Individual ports will be updated by the NPA's head office when such legislation is amended. The NPA's head office will also deal with overall "other aspects" such as requirements imposed generally by Transnet and other stakeholders. It is the responsibility of each individual port to remain abreast of local legislation and to advise NPA head office of any changes that may occur, as well requirements that may be imposed on the individual environment management systems, for instance as a result of agreement with local authorities, local environment interest groups, and other stakeholders.
Objectives and Targets and Environmental Management Programme
Each port authority will set its own objectives and targets, with due regard for the requirements of ISO 14001, and will devise an appropriate environmental management programme in order to achieve them. Both the objectives and targets, and the accompanying environmental management programme, are to be ratified by the EXCO of the individual ports.
Implementation and Operation of the EMS
The actual implementation of the EMS is the responsibility of the individual port authorities.
This is essential in the following way:
- Determination of the roles and responsibilities within the EMS.
- The structure of the EMS, within the existing port authority management structure, including lines of reporting.
- The environmental characteristics of key positions in the EMS, and the competencies required for such position, and the undertaking of a training needs analysis to determine which competencies need to be developed.
- A general employee environmental awareness programme, to develop awareness amongst employee and stakeholders of the generic environmental issues associated with ports, the specific environmental issues in the port in question, the benefit of responsible environmental management system requirements.
- Implementation of the agreed environmental management programme, incorporating all of the above, including monitoring of progress, especially achievement of key milestones.
- Communication within the organization with regards to the EMS, as well as with outside organizations. The procedures regarding communications with outside instances should be uniform between port, in order to prevent confusion with external agencies communicating with more than one port.
- The format and content of the EMS documentation should, so far, as is sensible, be uniform between ports, for ease for mutual auditing. So far as is reasonable, the EMS documentation should be integrated with existing Quality Management and Health & Safety systems.
- Document control procedures can easily be standardized between ports as with Quality Management Systems.
Operational control procedures should be based closely on the issues in this policy guideline document, together with unique operational issues that may exist at individual ports. Stipulations on tenants and terminal operations should be incorporated into lease and operating agreements, which should be uniform, so far as is appropriate, between ports. Specific requirements should be imposed on tenants and operators to pass on the requirements of their lease or operating agreements, to subcontractors and other suppliers of goods and services.
Monitoring and Measurement
Each port will develop a comprehensive system of key environmental performance indicators and appropriate monitoring strategies to monitor and measure them. Such key environmental performance indicators may include:
- Harbour water quality
- Number of environmental incidents or accidents
- Achievement of specific milestones, for instance the storage tank inventory, followed by achievement of milestones regarding 'legalization" of illegal tanks (e.g. leaking tanks)
- Census figures for key plant or animal populations in protected areas
- Legal compliance (periodic monitoring of legal compliance is a specific requirement of ISO 14001)
Key environmental performance indicators will be discussed at the environmental steering committee meetings, to ensure uniformity of approach between the ports and the exchange of knowledge between port authority personnel.
Checking and Corrective Action
A uniform methodology for addressing EMS non-conformities and for the undertaking of audits will be agreed by the environmental steering committee, for implementation in all ports. This will ensure that if environmental staff from one port are utilized to conduct an audit on another, they will be familiar with the audit system and the expected actions in case of non-conformities.
Every port develops its own system for the safe retention of apprpriate environemtal records, in accordance with clause 4.5.3 of the ISO 14001 standard.
Environmental Management System Audits
EMS audit methodologies and protocols should be common, so far as is appropriate, between ports, to facilitate inter-port benchmarking. (As a general principle, persons conducting an audit should be independent of the system being audited. Hence, port environmental managers should not audit their own systems).
Management reviews at port levels will take place as determined by port authority management, but in accordance with the requirements of clause 4.6 of the ISO 14001 standard. The findings of the management review will be forwarded to the EXCO of the NPA, for review at corporate level, as will any unusual incidents or audit findings that may have a corporate implication.