As shown in chapter 2.7, the Environmental Auditing (EA) is divided into three main steps:
This chapter will not detail “pre-audit activities” and “post-audit activities” already described in chapter 2.7 and figure 6 because they are not very specific to the pulp and paper industry. The main difference lies in the “activities at site” step, where special attention must be paid to the particular case of pulp and paper activity. Numerous data that might be useful to auditors are included in previous chapters. They contain a lot of information detailed in the tables, figures, and check-lists as:
A full EA in a pulp and paper industry should normally examine both:
It is also commonly recognized that the following elements need to be audited:
and that EA is an internal management tool which can help companies to:
Four manuals can be of great help to deal with an environmental auditing:
UNEP/IEO. Environmental Auditing. Technical report No 2. 1990.
UNEP/IE. Company Environmental Reporting. Technical report No 24. 1994.
UNEP/IEO. Storage of hazardous materials. Technical report No 3. 1990.
UNEP/UNIDO. Audit and reduction manual for industrial emissions and
waste. Technical report No 7. 1991.
This part of the audit is not particular to the pulp and paper industry. It must include important steps such as:
Selection of the audit team members. Composed of two to eight people, with a team leader, this team must represent all the needed specialities (policy, environmental management, toxicology, operational aspects, etc.) to carry out the audit in good conditions. The team can be from the company or independent. In the case of the Environmental Management System proposed by the European Union (described in figure 7) accredited verifiers from independent institutions have to validate the audit once it is completed.
Scoping of the proposed audit. It is clear that the scope of the audit has to be defined before it begins. The audit can be focused on industrial activities. More rarely it includes raw material production and exploitation. Other goals can be proposed to the audit (hazards, occupational health, spill prevention, toxic control, waste management, etc.). Once the scope of the audit is clearly fixed, protocols also have to be fixed. These protocols must reflect the objectives of the audit, facility characteristics and time constraints and must guide the auditors in determining possible deficiencies of the system.
Collection of background information. In particular, previous audits and copies of all registers where data are recorded and possible administration of a questionnaire to prepare the visit at the site. Sent to the site manager it can include questions such as:
Can you describe the activities or provide a brochure explaining the activities
of your company and your site ?
Does your site have specificity in the company activity ?
Have you already defined a precise environmental strategy ?
Are there environmental policies and systems ?
Are there clear environmental responsibilities at each level ?
Are there regular inventories of inputs and outputs ? To detail for each topic
(raw material, energy, water, air, noise, etc.)
Is there a waste management plan ?
Do you have a precise list of known environmental impacts of your activity ?
Do you know the origin of the problems ?
Do you know the sensitive areas affected ?
Are the transportation an integral part of the environmental analysis ?
Is the production and exploitation of raw material an integral part of the
environmental analysis?
Is there periodic environmental auditing ?
Are there periodic verifications of compliance to legal standards ?
Is there a health and safety plan ?
Is there a risk management plan ?
Is there an accident and emergency response plan ?
Are the employees integrated in environmental management? If yes how ?
Are the local communities integrated in environmental management? If yes
how ?
Do you have any environmental requirements for your suppliers ?
Do you have periodic meetings with environmental NGOs ?
Do you have periodic meetings with environmental consultants ?
Do you have periodic meetings with media about the environmental problems?
Do you know the financial implications of environmental management ?
This questionnaire can be more precise if necessary. It is important to collect the reply before starting the activities at the site, to determine the problems which are to be studied thoroughly, as early as possible.
It is also possible to use software. For example the Environmental Diagnostic software, proposed by Ecobilan company, allows to make a simple diagnostic of environmental management in the plant. In its normal version it is not specific to the pulp and paper industry but can be of great help in this first step of the audit.
The description of the 5 steps of the activities at the site (see figure 6) is extracted following the International Chamber of Commerce method.
“Internal controls might be normally incorporated in the facility's environmental management system. They include the organizational monitoring and record keeping procedures, formal planning documents such as plans for prevention and control of accidental release, internal inspection programmes, physical controls such as containment of release material, and a variety of other control system elements. The auditing team gains information on all significant control systems through elements from numerous sources through the use of formal questionnaires, observations and interviews”. Figure 10 shows the various inputs and outputs to study. It is important to add to the facility audit, forest and transportation controls.
Figure 10 : Various inputs and outputs to be studied in the plant during an EA
Various simple check-lists can help the auditors at this stage. They can examine raw material production and exploitation (check-list No 10), industrial activities (check-lists No 11 and 12), transportation activities (check-list No 13) or environmental management (check-list No 14).
| QUESTION | YES | NO |
| Is there a forestry management plan ? | ||
| Is there a system to control forest changes ? | ||
| Is there negative impact on the remaining stands ? | ||
| Are there threatened endemic species in the exploited area ? | ||
| Were there exotic species introduced ? | ||
| Were there particular technical, biological, or social problems associated with these introductions ? | ||
| Are exotic species supposed to be introduced ? | ||
| If yes, are there references on comparable introductions ? | ||
| Do these references indicate that such introductions have produced negative impact ? | ||
| Are those species sensitive to fire ? | ||
| Are there erosion problems in the exploited area ? | ||
| Are there water supply problems in the exploited area ? | ||
| Are there areas of cultural or religious interest for the local population threatened by the exploitation ? | ||
| Are there medicinal plants in this area ? | ||
| Are those species threatened by the exploitation/reforestation ? | ||
| Does this forest produce significant food supply for the local population ? | ||
| Is the project profitable to local communities ? | ||
| Are these communities involved in the exploitation conception ? | ||
| Are the employees involved in the exploitation conception ? | ||
| Is there a health and safety plan for workers ? | ||
| Is there a risk management plan ? | ||
| Is there an accident and emergency response plan ? | ||
| Is there an environmental and safety training programme for workers ? | ||
| Are there environmental and safety responsibilities clearly defined ? | ||
| Other (to detail) |
Check-list 11: Simple assessment of the industrial environmental management. Inputs check-list
| QUESTION | YES | NO |
| Raw material and catalysts | ||
| Is the fibrous raw material produced with environmental considerations (see check-list 12)? | ||
| Is there a clear and periodical inventory of all raw material used in the plant ? | ||
| Is a material balance periodically implemented ? | ||
| Is there a distinction between renewable and non renewable substances ? | ||
| Is there a segregation of hazardous substances ? | ||
| Is there a specific protection and training of employees in charge of those substances ? | ||
| Are there a strategy and actions to reduce raw material consumption ? | ||
| Is there a monitoring programme of raw material stocks and flows ? | ||
| Is there a training programme to reduce raw material consumption ? | ||
| Other (to detail) |
| QUESTION | YES | NO |
| Energy | ||
| Is there an energy efficiency plan ? | ||
| Is there a monitoring programme of energy consumption for each process unit ? | ||
| Are wood wastes recycled to produce energy ? | ||
| Are spent cooking chemicals recycled to produce energy ? | ||
| Is the capacity of the recovery furnace sufficient ? | ||
| Are there plant systems for recovering waste heat ? | ||
| Is co-generation used ? | ||
| Are the energy consumption standards in compliance with new mills performance ? | ||
| Is there a training programme to reduce energy consumption ? | ||
| Other (to detail) |
| QUESTION | YES | NO |
| Water consumption | ||
| Is the water consumption per unit metered ? | ||
| Is the water consumption per unit in compliance with new mills performances ? | ||
| Are all the usage of water registered and quantified? | ||
| Is there periodic mass balance for water usage ? | ||
| Are leaks and spills registered and quantified ? | ||
| Is the water from raw material preparation recycled ? | ||
| Are there other water recycling operations ? | ||
| Are there goals for water use reduction ? | ||
| Did some water supply problems yet occurred ? | ||
| Is there competition for water usage with other users ? | ||
| Is there a training programme to reduce water consumption ? | ||
| Other (to detail) |
Check-list 12: Simple assessment of the industrial environmental management. Outputs check-list
| QUESTION | YES | NO |
| Products and by-products | ||
| Was a life cycle assessment of the products still covered ? | ||
| Other (to detail) |
| QUESTION | YES | NO |
| Noise and gaseous emissions | ||
| Does the plant include in-plant processes to lower noxious emissions ? | ||
| Is there an inventory of the gaseous emitting points ? | ||
| Is there an inventory of the emitted substances ? | ||
| What is the frequency of gaseous emissions analysis ? | ||
| Are the emissions rates in compliance with national or international standards ? | ||
| Is there an employee and exposed communities health monitoring ? | ||
| Is there an inventory of affected areas (toxic and odours) ? | ||
| Are the meteorological conditions well known around the site ? | ||
| Is there an emergency plan for employees and local communities in case of accident ? | ||
| Does the plant include in-plant processes to lower noise emissions ? | ||
| Is the site equipped with noise protection systems ? | ||
| Is there an inventory of the noise emitting points ? | ||
| Is there a quantification of the noise emissions ? | ||
| Are the employees working in noisy conditions equipped with earmuffs ? | ||
| Is there, for these persons, a monitoring of ear diseases ? | ||
| Other (to detail) |
| QUESTION | YES | NO |
| Liquid wastes | ||
| Are there maps of all the liquid waste systems of pipes and storage ? | ||
| Is there an inventory of the discharge points ? | ||
| Is there an inventory of the emitted substances ? | ||
| What is the frequency of waste water analysis ? | ||
| Does the plant include in-plant processes to lower liquid wastes ? | ||
| Is there significant water recycling ? | ||
| Does the plant include processes for lower liquid wastes toxicity ? | ||
| Does the future plant include chemical recovery ? | ||
| Does the bleaching phase include non chlorine processes ? | ||
| Does the bleaching phase produce dioxins or furans ? | ||
| Are there separate drainage systems for sewage and rain water ? | ||
| Is there a waste water treatment plant ? | ||
| Are the discharge rates in compliance with national or international standards ? | ||
| Is there a spill monitoring ? | ||
| Is there an employee and downstream communities health monitoring ? | ||
| Is there an inventory of affected areas (downstream or underground) ? | ||
| Have accidents (e.g. dead fish) already occurred with discharges in natural waterbodies ? | ||
| Have accidents (e.g. intoxication) already occurred with occasional discharges in the plant ? | ||
| Is there a system for storing hazardous liquid wastes ? | ||
| Are the warehouses designed with all security requirements (see UNEP Report No 3) ? | ||
| Is there a system for recycling hazardous liquid wastes ? | ||
| Is there a health monitoring of people in charge of toxic substance maintenance? | ||
| Other (to detail) |
| QUESTION | YES | NO |
| Solid waste | ||
| Is the quantity of solid waste known ? | ||
| Is the composition of solid waste characterized ? | ||
| Are there treatments of those wastes ? | ||
| Are the wastes valorized ? | ||
| Is there a plan to reduce waste production ? | ||
| Is there a landfill for the solid waste ? | ||
| Are the dumpsites established in secure areas ? | ||
| Has land or water contamination already occurred ? | ||
| Has the remediation of dumpsites already occurred ? | ||
| Is there a health monitoring of exposed groups ? | ||
| Is there a monitoring of water quality around the dumpsite ? | ||
| Other (to detail) |
Check-list 13: Simple assessment of the impacts of transportation
| QUESTION | YES | NO |
| Is the transport network affected by the industrial activity ? | ||
| Are the traffic conditions suitable ? | ||
| Did transportation include alternatives : road/rail/shipping ? | ||
| Is there a precise management of fuel/hazardous products storage, risks, transports, etc. ? | ||
| Are there significant communities affected by transportation issues ? | ||
| Are there special facilities for protecting communities from transports emissions ? | ||
| Are there special facilities for protecting the environment from transports emissions ? | ||
| Is there accident monitoring ? | ||
| Is there a special training course, related to environment protection, for drivers and mechanics? | ||
| Other (to detail) |
Check-list 14: Assessment of environmental management
| QUESTION | YES | NO |
| Is there a company environmental policy ? | ||
| Are environmental responsibilities clearly defined ? | ||
| Is there an environmental action plan ? | ||
| Is there a health and safety plan ? | ||
| Is there a risk management plan ? | ||
| Is there an accident and emergency response plan ? | ||
| Are the risks involved with the activity cross referenced with site sensitivity ? | ||
| Others (to detail) |
The second step of the International Chamber of Commerce method : “involves evaluating the effectiveness of management control systems in achieving their objectives. In some cases, regulations specify the design of control system. For example, regulations may list specific elements to be included in plans for responding to accidental releases. More commonly, team members must rely on their own professional judgement to assess adequate control.”
At this stage it can be very useful to conduct a material balance. The complete procedure is described in the UNEP Technical report No. 7: Audit and reduction manual for industrial emissions and wastes. Figure 11 shows the main steps to be followed in conducting a material balance.
Figure 11 : Simplified diagram of a material balance (Source: UNEP)
| PHASE 1 PRE- ASSESSMENT | Preparation - divide process into unit operation - construct process flow diagrams linking unit operation (see figure 8) | ||
| ↓ | ↓ | ||
| PHASE 2 MATERIAL BALANCE | Process inputs - determine inputs - record water usage - measure current levels of waste reuse/recycling | Process outputs - quantify products (by products) - account for wastewater - account for gaseous emissions - account for off-site wastes | |
| ↓ | ↓ | ||
| Derive a material balance - assemble input and output information - derive a preliminary material balance - evaluate and refine material balance | |||
| ↓ | |||
| PHASE 3 SYNTHESIS | Evaluate the findings and Propose recommendations | ||
Phase 3 is normally included further in the audit procedure. Thus it is not detailed in this chapter.
For each step of the audit, quantities have to be recorded as shown in Table 33 and 34.
Table 33: Example of audit records
| Raw material | Quantity used | Quantity purchased | Type of storage used in production | Average length of storage | Estimated annual raw material losses |
| Logs | |||||
| Chips | |||||
| Recycled paper | |||||
| Etc. |
Source: UNEP
Table 34: Example of audit records
| Water Usage | Cleaning | Steam | Cooling | Other |
| Debarking | ||||
| Pulping | ||||
| Bleaching | ||||
| Etc. |
Source: UNEP
The findings of the material balance are generally linked with characterization of waste problems and identification of waste reduction possibilities.
Over the material balance it is also important to analyze the overall environmental management of the company and to validate its efficiency or deficiency.
In this step of the method, “the team gathers evidence required to verify that the controls do in practice provide the result intended. Team members follow testing sequences outlined in the audit protocol which have been modified to consider special conditions at the site. Examples of typical tests include review of a sample of effluent monitoring data to confirm compliance with limits, of training records to confirm that appropriate people have been trained, or of purchasing department records to verify that only approved waste disposal contractors have been used. All of the information gathered is recorded for ease of analysis and as a record of conditions at the time of the audit. Where a control element is in some way deficient, the condition is recorded as a finding.” Table 35 shows example of findings.
Table 35: Example of matrix to organize the findings
| Gaseous emissions (monthly average) | Particulate (mg/m3) | SO2 (mg/m3) | H2S (mg/m3) | Etc. |
| Recovery boiler | 140 | 900 | 9.5 | |
| Power boilers | 180 | 1 100 | ||
| Lime kilns | 325 | 45 | ||
| Etc. |
In this example all the gaseous emissions are in compliance with typical modern emissions limits (see Table 27) excepted 1 100 mg/m3 SO2 from power boilers because the monthly average limits are 500 to 800 mg/m3
“After the individual controls have been tested and team members have reached conclusions concerning individual elements of the control system, the team meets to integrate and evaluate the findings and to assess the significance of each deficiency or pattern of deficiencies in the overall functioning of the control system. In evaluating the audit findings, the team confirms that there is sufficient evidence to support the findings and summarizes related findings in a way that most clearly communicate their significance.”
“Findings are normally discussed individually with facility personnel in the course of the audit. At the conclusion of the audit, a formal exit meeting is held with facility management to report fully all findings and their significance in the operation of the control system. The team may provide a written summary to the management which serves as an interim report prior to preparation of the final report.”
Post-audit activities are described in figure 6. They include:
For the preparation of the action plan there are several manuals which can be of great help to EA team in proposing technical solutions:
Environmental Solutions for the Pulp and Paper Industry, edited by K. Ferguson (1991) which describes successively :
Solid waste handling and minimization.
Cleaner Production in Pulp and Paper Industries in the framework of the UNEP IE/PAC Cleaner Production Programme edited by the Technical Research Centre of Finland (1992) which includes:
