Training and communication

Training requirements

The GED applies to every person who is engaged in activities that may give rise to risk of harm to human health or the environment. Hence, you must ensure that appropriate training is provided to all personnel engaged in such activities that may give rise to risk of human health or the environment. Section 25(4)(e) of the Act requires you to provide information, instruction, supervision and training to any person engaging in the activity to enable those persons to comply with the GED.

Provision of appropriate competency-based training to your personnel is critical for successful implementation of your environmental controls. The level and nature of the training should match the roles of each person and their responsibilities as identified in the RMMP. In so doing, the training should:

  • identify the necessary competence for personnel doing work that is controlled by the RMMP and can have an impact on the environment;
  • ensure that personnel are competent on the basis of education, training or experience;
  • determine the training needs to ensure that personnel understand the risks to human health and the environment that are presented by the activity they are undertaking; and
  • provide the necessary competence (training or mentoring) and check the effectiveness of that training.

The training can range in formality from one-on-one demonstration of an action to formal presentations with competency checks. Depending on the nature of the role, and the capability of the person in that role, you should provide refresher training to ensure an adequate level of competency is maintained.

You must keep a register of the training provided to your personnel. This will enable you to keep track of what training has been provided and the skills each person has attained from that training. You may be asked to make this information available to the Authority.

Communication

The overall objective of environmental communication is to provide internal and external interested parties with information on your environmental issues, their management and performance. Your RMMP should include details on what to communicate, when to communicate it, to whom and how.

Some larger organisations maintain a specific communications procedure. Depending on the organisation, the communications procedure can specify everything from use of emails, to issue of press releases by the public relations manager, to liaise with regulatory authorities, to calling of emergency services. The communications process must incorporate details on reporting of incidents and emergencies identified above.

Internal communications

Your internal interested parties may include:

  • top management, who are responsible for ensuring the overall environmental management program is implemented;
  • section managers who are responsible for communicating the environmental responsibilities;
  • personnel who conduct the environmental monitoring;
  • operators who implement the operational controls.

Internal communications will include distribution of relevant environmental management information through the management levels in place at your facility. This information might include distribution of operational control procedures, reporting of monitoring results, contributions to risk assessment workshops, provision of training, notification of process changes, internal reporting of incidents and emergencies, and reporting of environmental performance to top management.

External communications

External communications regarding environmental management are usually more closely controlled as they can involve sensitive issues and require adherence to corporate protocol. Such communications require logs to be kept and may require follow-up action by nominated personnel.

External communications may include:

  • engagement with the local community;
  • maintenance of a company website and social media information sites;
  • liaison with regulatory authorities;
  • participation in industry bodies or other professional organisations;
  • receipt of community complaints and enquiries;
  • reporting of incidents and emergencies; and
  • routine environmental reporting obligations such as

Abbreviations

CEMS continuous emission monitoring system

ERS environment reference standards

GED general environmental duty

NGER National Greenhouse and Energy Reporting

NPI National Pollutant Inventory

PIPS Permission Information and Performance Statement

RMMP risk management and monitoring program

SCADA supervisory control and data acquisition (a system for controlling plant and equipment)

SFARP so far as reasonably practicable

Updated

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