Abstract

Keywords

Paper

There are many approaches to environmental management in Australia but only some of these are auditable to a recognised standard. Many approaches are not actually management systems even though the proponents describe themselves as doing EMS. There are also other things that industry needs to comply with, such as Occupational Health and Safety, Quality, Food Safety and the Codes of Practice. In addition,there are also overseas requirements for exporters. These can and should all be integrated into one simple system.

I certainly have a problem with the concept of Best Management Practices because it is only the ‘best’ that they have come up with at that time. Further, it can actually inhibit people looking for continual improvement because it is hard to improve on the ‘best’.

There are real, tangible benefits to even a small business from having a management system in place with documented procedures and a feedback loop. This is where a business actually saves money as well as helping the environment, their workers and the consumers of their food. A system builds business efficiency.

I would agree wholeheartedly that the cost of having an external auditor is prohibitive for many small businesses however there are very real benefits of having a deadline and an independent auditor arriving is certainly that deadline! Additionally certification adds an extra layer of rigor and feedback to the environmental management system. It is important that the export sectors have an environmental management system in place and that this is independently audited to a recognised standard as an entry requirement into most EU markets.

It is very difficult for an owner of any farm or other business to objectively audit their own business even though internal audits are a very useful internal management tool. There is both a major conflict of interest and the loss of the opportunity to learn from a fresh point of view. Ideally you need a trained auditor who understands the system and is independent of the farm involved. The auditor does not need to come from that industry. An auditor who has experience in intensive animal culture can effectively audit poultry, piggeries or fish farms. The processes are essentially similar.

Having said this, I must comment that the auditing profession has a big responsibility to audit well. There are still some examples of former quality auditors without real environmental expertise, who need to develop a better environmental understanding and not just try to extend Quality into Environmental Management.

Recognition of the standards and industry standards

Auditors themselves need to step up and improve their service. They need to be trained both as auditors and importantly they need to be trained as environmental auditors rather than being quality auditors with only two days of environmental training.

The Auditor is being paid to provide a valuable service and they should be approached this way. Working well with an auditor can be a great learning experience. They cannot consult but they can ask pointed questions and be extremely helpful. They bring a lot of experience and a fresh pair of eyes to a business ,providing very useful feedback. Having an independent external auditor can help a business demonstrate that they do take due care. A third party audited system provides greater certainty both to regulators and to markets.

There are also some auditors and consultants who like to use jargon which is understood within their industry but which is NOT essential to understanding, implementing and maintaining a robust and effective management system. Personally I prefer to use terms like cause and effect rather than the auditor favoured aspect and impact because it is more meaningful to the entire workforce. Similarly I do not use words like non-conformance. I used that once on a fishing boat and was asked “what the **** does that mean”. Never again! There is nowhere like the deck of a fishing boat to bring you down to earth.

An industry association can have its own audit of members which is helpful to the business if the auditors are properly trained, but this will not be officially recognised. This is potentially cost effective. In other cases the association can become certified which requires a sampling program of members. This saves money but the risk is that one business may let the others down and lose or threaten the entire certification. Often small individual businesses don’t get third party certification unless they are exporting. They rely on internal auditing.

There are several different certifications available. ISO 14001 is the only internationally recognised EMS (Environmental Management System). Some Certifying Bodies offer scaled down version of ISO 14001 certification for small businesses. One example is Enviro Cert.

There is a role for checklists and self assessment as an introductory stage but industry independence at an external assessment stage would be of benefit to the industry. Note that the assessment of checklists is really inspection, rather than auditing. It needs to be recognised, however that both the checklist and best management practice approaches do not bring the very real benefits that having a straightforward and effective system in place on each farm can bring to that farm.

Some organisations are discussing setting up their own Australian or Industry Standards. I feel that this is a big mistake because setting up a Standard is very costly and if businesses are going to make the commitment to being certified, it should be to a Standard that is recognised worldwide. A specific industry “Clean Green” from Australia carries no recognition overseas.

There are additional standards such as the Marine Stewardship certification which applies only to wild catch fisheries. The World Wildlife Fund and a British supermarket chain jointly set this up for certifying the sustainability of wild catch fisheries. It is a fishery wide certification, very similar to the Australian Commonwealth Government’s EPBC or Environment Protection Biodiversity and Conservation Act. This does not apply to any industry other than wild catch fishing and is much more expensive to certify in Australasia because there is a far greater diversity of fish off the Australasian coast in than the North Sea where this standard was designed. In Australia, with the EPBC Act in place, Marine Stewardship could be seen more as a marketing tool.

The Marine stewardship certification does not build a management system onto every vessel and every business so the businesses involved do not get the benefits that flow on from identifying their own risks and building a system to manage them. It does not include management of the fishers’ work-practices or what takes place in their sheds.

Yet another standard is EurepGAP. Eurep represents the Euro- Retailer Produce Working Group and GAP stands for Good Agricultural Practice. This is a necessary commercial reality for many Australian horticulturalists supplying export markets, particularly the United Kingdom. This is an integrated assurance standard, developed with strong input from European retailers. The Good Agricultural Practices advocated in EurepGAP cover food safety, OH & S and environmental aspects of farming. The market dominance of retail chains is increasing and standards like EurepGAP and Marine Stewardship are being demanded by some of the supermarkets.

While EurepGAP integrates the varying aspects of farming practices, it is not really a system and does not deliver the full on farm benefits of a true EMS or an integrated ISO system.

An additional certification is Organic. While organic farmers are very mindful of the environment and have some specific requirements, there is no systematic risk analysis for potential environmental impacts and the organic standard is a food standard not an environmental one.

Conclusions

An environmental management system is just that – a system. Farmers, like other businesses will find that there are very real benefits and cost savings from having a system that adds feedback and puts them in a cycle of continual improvement. This is very much more effective that merely having management plans, codes of practice and others because it goes on working and improving over time and it saves time and money while it does so.

Auditors add a layer of rigor and feedback that is very helpful to a business but they have a responsibility to ensure that the service they provide is well done. At present there are some who do not do this well.

There are a wide range of standards already in existence and suggestions about developing further Australian Standards should be avoided because of the lack of recognition.

If you find this wide range of certification options confusing, so do the business managers who need to make decisions on what path to take. As many of their advisers also find this area confusing I hope this paper provides some clarification.