What makes a good Environmental Aspects Register?
I’ve just finished putting together an Environmental Aspects Register for a client and it has brought home, yet again, that this is not easy to do well. There is no formula that fits every organisation. But let me try to describe how this task might be approached.
Firstly, a good register must, of course, capture all environmental aspects that might be assessed to be “significant”. Secondly, it needs to be fairly compact because it will be used as a checklist in many of the EMS procedures. Thirdly, what we choose as our “aspects” needs to be well thought-out. And fourthly, the structure of the register needs to be practical and suit its use.
The first two qualities are fairly self-explanatory, so let me concentrate on the other two.
How do we choose our environmental aspects?
Firstly, what is an aspect? The 14001 standard defines an aspect as an “element of an organisation’s activities or products or services that interacts or can interact with the environment”. That leaves it pretty open. For example, is the aspect “electricity use”, or “electrical lighting” or “lighting in office area”?
Let’s ask another question: why are we compiling our aspects? I suggest two reasons: firstly, to build a risk register, and secondly to build a checklist to help with (among other things) deciding training topics, developing monitoring activities, identifying possible emergency situations etc.
It makes sense to group, as an aspect, activities that share the same impacts and require similar risk controls. For example, you might group together truck loading, unloading and even truck cleaning operations because they all may give rise to spills to stormwater. Similarly, it may be efficient then to group together “chemical tank operations” rather than to list each tank or each tank-operation. This can create a compact Register that will serve the functions listed in the previous paragraph. We have also seen registers that group aspects with common performance indicators (eg. electricity usage for each electricity meter).
Another option is to split up aspects according to who has responsibility for the corresponding risk controls. If this responsibility is assigned area-by-area within a site, then arrange the Register so aspects are grouped according to area (eg. lighting in offices separated from lighting in warehouse to match the role responsible).
How do we structure our environmental aspects register?
Let me suggest a structure and you can add or subtract as you like. The main question is: what information do we want in the Register? We include, as a minimum: aspects, impacts, hyperlinks to applicable compliance obligations, lists of key operational controls, and the outcome of the risk assessments (consequence, likelihood and the resulting risk rating).
The risk assessment can be split into “inherent” risk assessment (ie. risk without any controls in place) and “residual” risk assessment (risk with controls working effectively). However, we do not recommend “inherent” risk assessment because is it impossible to objectively assess “likelihood” of a given consequence without any controls in place (and what does “without controls” really mean anyway?).
In conclusion, when building your environmental aspects register, consider multiple options, seek the opinions of others, and give careful thought to how the register will be used.