Presentation of the key findings of the audit and … North-West University Environmental Legal Compliance Audit Presentation of the key findings of the audit and proposed action plan

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North-West University Environmental Legal Compliance Audit

Presentation of the key findings of the audit and proposed action plan

Prof. Johan Nel & Mr. Theunis Meyer Centre for Environmental Management

North-West University

Potchefstroom Campus Private Bag X6001

POTCHEFSTROOM 2520

Tel: +27 (0) 18 299-4279

Fax: +27 (0) 18 299-4266 E-mail: [email protected]

Web Address: www.nwu.ac.za/cem

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Introduction

The Centre for Environmental Management (CEM) was contracted by the NWU to conduct Environmental Legal Compliance audits for: Institutional Office Potchefstroom Campus Vaal Triangle Campus Mafikeng Campus

Process consisted of 5 phases: Phase 1: Pre-audit discovery Phase 2: Audit planning and scheduling Phase 3: Audit execution Phase 4: Reporting Phase 5: Audit follow-up and closure

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Audit process

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Audit objective

To identify any non-conformities to

applicable environmental legal

requirements as opportunities for

improvement;

To celebrate confirmed compliance

to applicable environmental legal

requirements. © CEM

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Audit scope

Audit scope included: The Institutional Office All three NWU campuses;

On campus facilities, activities, products, services, processes and operations;

Off-campus facilities, activities, products, services, processes and operations;

Activities and processes outsourced to contractors and service providers.

The on-site audits were conducted during August, September & October 2012 Audit planning started in January 2012 Audit reporting concluded in January 2013

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Audit Criteria

Audit was conducted against applicable environmental legislation: National environmental legislation;

General environmental legislation (NEMA); Water (NWA); Waste (NEM:WA, Human Tissue Act, National Health

Act); Biodiversity (CARA, NEM:BA, GMO Act); Land Management (CARA, Fencing Act, FFFARSR Act,

Game Theft Act, NVFF Act) Dangerous goods and Hazardous substances (HSA,

OHS Act – HCS Regulations) All environmental authorisations; Applicable provincial environmental legislation; Local environmental by-laws; International environmental laws ratified by SA.

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Audit team

Audit planning Prof. Johan Nel, Messrs. Theunis Meyer & Trevor

Hallat, Mrs. Watsie Ramogola

Audit execution Prof. Johan Nel, Messrs. Theunis Meyer & Reece

Alberts, Dr. Claudine Roos

Audit reporting & follow-up Prof. Johan Nel, Messrs. Theunis Meyer, Reece

Alberts & Trevor Hallat, Dr. Claudine Roos.

Team members are professional environmental auditors SAATCA registered lead auditors, auditors &

provisional auditors.

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Audit Process (1)

The audit was conducted in accordance with ISO 19011:2011 audit process Initiating the Audit

Appointing the audit team; Initial contact with the auditee. Defining audit objectives, scope and criteria; Determining the feasibility of the audit; and Selecting the audit team members.

Conducting the Document Review Identifying and sourcing relevant documents

from the auditee prior to the audit; Studying these in preparation for the audit.

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Audit Process (2)

Preparing for the On-site Audit Activities Preparing the audit plan; Assigning work to the audit team; and Preparing work documents.

Conducting the On-site Audit Activities Conducting the opening meeting; Collecting and verifying information through

physical observation, document reviews and interviews;

Generating audit findings and providing recommendations for best practice;

Preparing audit conclusions and conducting the closing meeting.

Preparing, Approving and Distributing the Audit Report

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Functions or aspects audited

Institutional Office Business and enterprise development; Physical infrastructure and planning; Internal auditing process; Legal advice and internal legal services; NWU compliance support; Tender specification process; Contracting process for research and

innovation; Industrialisation and commercialization of

inventions.

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Functions or aspects audited

Potchefstroom, Vaal Triangle & Mafikeng General duty of care

Environmental authorisations Water use and management

Authorisations Waste management (General and hazardous waste)

Medical waste, kitchen waste, building rubble, domestic waste, hazardous waste.

Dangerous goods management Chemicals, Herbicides and pesticides, Hydrocarbons;

(transformers, underground fuel storage tanks, generators); Radio-active sources.

Biodiversity and land management Keeping of animals and game, alien & invasive plants,

veld fires, threatened & protected species, genetically modified organisms, bio-prospecting, etc.

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General observation

Audit was conducted in a good spirit; All auditees were keen to participate and

open and honest about their work; In many areas, it was evident that a lot of

energy has been spent in efforts to meet the relevant legal requirements; Importance of champions.

Major reasons for non-compliance; Lack of knowledge about legal requirements; Lack of ability to interpret and apply the legal

requirements. © CEM

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Good practices observed (1) Green initiatives and awareness raising

across all campuses; Waste management practices

Separation of waste at source at certain areas;

Access control at certain waste storage areas; Sound management of GMO waste on the

Potch Campus; Management and storage of chemicals by:

Biochemistry (BOSS lab) (Potch Campus) Labeling and consideration of compatibility

Pharmaceutical Chemistry (Potch Campus) Access control and tracking & tracing of chemicals

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Good practices observed (2)

Land & biodiversity management Invader plant management by Servest on

Potch Campus; Game management at Vaal Triangle Campus; Permits for keeping protected plant species

at Botanical Garden (Potch Campus); Veterinary management (Mafikeng Campus)

Actions to address audit findings Ceased illegal waste disposal at

Pienaarskamp (Potch Campus); Potch Campus joining the Fire Protection

Association (FPA).

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Key audit findings

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Key findings: Institutional Office

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Function/area Key issues Nr of findings

Infrastructure Development and Maintenance

• Screening of Infrastructure Development & Maintenance projects;

• Consideration of environmentally sensitive areas on spatial plans;

• Controlling contractors & potential environmental risks – building rubble;

• Adherence to legal requirements on energy-efficiency;

• Control of hazardous substances • Asbestos (structures & waste); • PCBs (transformer oils); and • Hydrocarbon storage

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Management of Research

• Management of hazardous substances & dangerous goods (chemicals etc.);

• Control of bio-prospecting & GMO-related research & development.

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Key findings: Potchefstroom Campus

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Management of hazardous substances & dangerous goods

• Compatibility of chemicals; • Availability of MSDSs; • Lack of formal procedures & training; • Containment of potential spills; • Management of hazardous waste.

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Biodiversity & Land Management

• Alien and invasive plant management; • Veld fire management arrangements; • Transportation of indigenous

biological resources; • Management of biological collections.

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Waste Management

• Waste management contractors; • Lack of arrangements to implement

waste hierarchy; • Illegal disposal of building rubble.

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Water management

• Permission for all water uses, especially the non-consumptive uses

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Key findings: Vaal Triangle Campus

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• Storage of hazardous chemicals; • Lack of formal procedures & training; • Containment of potential spills; • Management of hazardous waste.

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• Alien and invasive plant management; • Veld fire management arrangements; • Arrangements for keeping of game; • Threatened & protected species.

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Waste Management

• Lack of arrangements to implement waste hierarchy;

• General & hazardous waste disposal; • Illegal disposal of building rubble.

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Water management

• Permission for all water uses, especially the non-consumptive uses

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Key findings: Mafikeng Campus

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• Storage of hazardous chemicals; • Lack of formal procedures & training; • Containment of potential spills; • Management of hazardous waste; • Isotope management.

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• Alien and invasive plant management; • Veld fire management arrangements.

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Waste Management

• Lack of arrangements to implement waste hierarchy;

• General & hazardous waste disposal; • Illegal disposal of building rubble.

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Water management

• Permission for all (new) water uses, especially the non-consumptive uses.

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Audit conclusion

Evidence of various efforts to meet the relevant legal requirements applicable to the activities, products & services at the NWU; Large percentage are informal best practices.

However, various non-compliances still exist that needs to be corrected before the NWU can claim full legal compliance. These should be addressed & formalised as a matter

of urgency to ensure that the NWU is successful in addressing its environmental challenges & comply with the applicable legal requirements.

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Risk assessment

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Risk Assessment: Institutional Office

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Risks identified Impact rating

Prob rating

Control effective

Res Risk rating

Res Risk descrip-tor

Infrastructure development & maintenance processes

8 0.6 1 4.8 Immediate

action required

Research processes 7 0.4 1 2.8 Monitor

Technology transfer and innovation support

6 0.2 1 1.2 Tolerable

Business and enterprise developments 6 0.2 1 1.2 Tolerable

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Risk Assessment: Campuses

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Risks identified Impact rating

Prob rating

Control effective

Res Risk rating

Res Risk descriptor

Dangerous goods and hazardous substances

8 0.4 1 3.2 Action required

Hazardous waste 8 0.4 1 3.2 Action

required General waste 7 0.4 1 2.8 Monitor

Water use 7 0.4 1 2.8 Monitor

Land management & biodiversity

7 0.4 1 2.8 Monitor

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Prioritisation of issues

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Prioritisation of issues

Prioritised according to: Risk assessment (inherent risk);

Legal transgressions/risk of prosecution; Reputational risk; Risk to staff and students; Risk to environment or resources; Economic/financial threats.

Top priorities: 1. Infrastructural development and maintenance; 2. Waste Management (General and hazardous); 3. Management of Dangerous Goods & Hazardous

Substances; 4. Land & Biodiversity Management.

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Documents submitted

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Series of documents submitted

Environmental Legal Compliance Audit Reports NWU Institutional Office, Potchefstroom, Mafikeng &

Vaal Triangle Campuses (dated 31 January 2013); Summary of audit findings & risk ratings

12 December 2013; NWU Environmental Legal Compliance Action

Plan 13 February 2013;

NWU, Potchefstroom Campus Risk Register & Risk Abatement Strategies April 2013;

Draft Proposed Implementation Strategy for the NWU Environmental Legal Compliance Action Plan.

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Implementation & roll-out of NWU Environmental Legal Compliance Action Plan

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Implementation and roll-out of action plan (1)

Proposed corrective actions are based on audit findings where non-compliances to environmental legal requirements were identified.

Aim of Proposed Implementation Strategy To provide a macro-level roll-out strategy for

an achievable abatement plan to minimise and ultimately eliminate risks related to environmental non-compliances.

Corrective actions proposed also include monitoring or verification actions to complete the “Plan-Do-Check-Act” cycle.

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Due to the generic and related nature of environmental non-compliances, it is proposed that the action plan is rolled-out as an integrated, coordinated approach at all campuses of the NWU. Focusing on the highest risks as top

priorities for implementation; Related actions to be implemented in

parallel; Recommended that the action plan is rolled

out over a period of 18-months.

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8 Priority areas Priority 1: Infrastructure development and

maintenance; Priority 2: Management of general and hazardous

waste; Priority 3: Management of dangerous goods &

hazardous substances; Priority 4: Management of land and biodiversity; Priority 5: Management of water; Priority 6: Management of research processes; Priority 7: Management of technology transfer and

innovation support; Priority 8: Management of business and enterprise

developments. © CEM

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Generic approach Develop formal arrangements to identify

legal & best practice requirements Communicate these arrangements Develop skills to implement these arrangements

Implement formal arrangements Screen existing activities Apply for environmental authorisations where

required Develop inventories & management plans where

required Implement reasonable measures

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Generic approach Include formal arrangements into contracts

Evaluate & select contactors & suppliers

Control contactors & suppliers

Develop & implement awareness campaigns amongst personnel & students

Conduct periodic inspections & audits to verify compliance

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Roll-out per priority area

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Roll-out of action plan

Priority 1: Infrastructure development and maintenance Expected duration: 299 days

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1.1. Formal arrangements to screen new developments

and research projects

1.2. Develop skills in-house with regards to screening of developments and projects

1.3. Screen existing activities, facilities and

infrastructure at all campuses

1.4. Apply for environmental authorisation or

rectification of unlawful activities

1.5. Arrangements to ensure that compliance to environmental legal

requirements are written into contractual agreements

1.6. Mechanism to evaluate and select contractors and

suppliers

1.7.1. Revise campus-specific spatial plans and maps to indicate sensitive

environmental features

1.7.2. Instruction stipulating that campus spatial plans

must be used when screening and designing new

developments

1.8. Formal arrangements to

adopt and ensure sustained compliance with the energy

efficiency requirements

1.9. Initiatives to make NWU personnel and students aware of the importance of energy efficient

practices

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Priority 1: Infrastructure development and maintenance (1)

Action Outcome Timeframe Roles & responsibilities

Develop formal arrangements to screen new developments & research projects for applicable legal requirements and the need to apply for environmental authorisation (EA)

Information document with legal requirements & specifications of when to apply for EA

2.5 months* CEM has capacity

Training of selected staff to use information document to screen developments & projects for legal and EA requirements

Trained and skilled staff members 10 days CEM has capacity

Screen existing activities, facilities and infrastructure at all campuses against legal and EA requirements

List of existing activities, facilities & infrastructure (all campuses) for which EA must be applied.

Continuous Trained task team (in consultation with the CEM and pro bono office)

Apply for EA or rectification of unlawful activities, where required

EA from Competent Authority

8 to 12 months

Environmental Assessment Practitioner (not NWU staff)

Develop & implement a policy to ensure that compliance to environmental legal requirements are written into contracts

Implemented policy for inclusion of environmental legal requirements into contracts

1 month

Establish a mechanism to evaluate & select contractors & suppliers in terms of demonstrated environmental performance, in addition to price & BBBEE status

Documented procedure to include demonstrated environmental performance when evaluating & selecting contractors

3 weeks

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Priority 1: Infrastructure development and maintenance (2)

Action Outcome Timeframe Roles and responsibilities

Review and revise campus-specific spatial plans and maps to indicate sensitive environmental features that are protected by law, i.e. wetlands and protected plant or animal species

Updated spatial plans and maps indicating sensitive environmental features

3 weeks

Generate an instruction which stipulates that campus spatial plans indicating sensitive environments must be used when screening and designing new developments

Implemented instruction 3 weeks

Identify requirements for energy efficiency in line with legislation and best practice

Document with energy efficiency requirements 1 month CEM has capacity

Develop formal arrangements to adopt and ensure sustained compliance with the energy efficiency requirements

Policy on how to adopt and ensure compliance with energy efficiency requirements

2 months

Investigate and implement initiatives to make NWU personnel and students aware of the importance of energy efficient practices

Implemented energy efficiency initiatives 2 weeks

Verification audit to ensure that identified actions have been implemented Verification audit 2 weeks CEM has capacity

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Priority 2: Management of general and hazardous waste Expected duration: 342 days

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2.1. Arrangements for the management of general and hazardous waste at

the NWU.

2.2. Arrangements to screen existing and

proposed waste management activities,

facilities and infrastructure

2.3. Generate a waste inventory with the types and amounts of waste

generated per campus and keep up to date

2.4. Develop and implement an Integrated

Waste Management Plans (IWMPs) for each of the

three NWU campuses and the Institutional Office.

2.5. Screen existing and proposed waste

management activities, facilities and infrastructure

2.6. Apply for authorisations or

rectification of commencement of unlawful activities

2.7. Investigate and implement initiatives to

implement the waste management hierarchy in terms of reduction, re-use

and recycling of waste

2.8. Implement measures to ensure access control to waste storage areas

(especially to hazardous waste)

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Priority 2: Management of general and hazardous waste (1)

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Develop formal arrangements to screen existing and proposed waste management activities, facilities and infrastructure to identify applicable legal requirements and the need to apply for an EA (waste management licence)

Document with legal requirements and specifications of when to apply for EA


Develop formal arrangements for the management of general and hazardous waste at the NWU

Implemented procedure for the management of general & hazardous waste

1 month CEM has capacity

Develop and implement a policy that require adherence to the of the waste management procedure in all waste management contracts

Implemented policy for inclusion of requirements into contracts

3 weeks

Generate a waste inventory with the types and amounts of waste generated per campus and keep up to date

Waste inventory per campus 1 month

CEM has capacity Potential for student involvement

Develop and implement an Integrated Waste Management Plans (IWMPs) for each of the NWU campuses & the Institutional Office

Approved Waste Management Plans for all campuses

2 months CEM has capacity

Screen existing & proposed waste management activities, facilities & infrastructure for legal requirements & need to apply for EA

List of activities for which EA must be applied Continuous

Trained task team (in consultation with the CEM & pro-bono office)

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Priority 2: Management of general and hazardous waste (2)

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Apply for authorisations or rectification of unlawful commencement of activities


8 to 12 months


Investigate & implement initiatives to implement the waste management hierarchy in terms of reduction, re-use and recycling of waste

Documented actions & action plan for implementing the waste management hierarchy

1.5 months CEM has capacity

Develop and implement a waste management awareness campaign among students & personnel to highlight the importance of sound waste management and implementation of the waste management hierarchy

Implemented initiatives to raise awareness 2 weeks

Implement measures to ensure access control to waste storage areas (especially to hazardous waste)

Access controlled waste storage areas 1 month

Conduct periodical audits and inspections ascertain implementation of identified actions and compliance to identified requirements

Inspections and verification audits 2 weeks CEM has capacity

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Priority 3: Management of dangerous goods Expected duration: 365 days

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3.1. Formal arrangements for the management of

hazardous substances and dangerous goods at the NWU

3.2. Formal arrangements to screen existing and proposed

activities, facilities and infrastructure related HS&DG

management

3.3. Inventory of the types and quantities of hazardous substances and dangerous

goods

3.4. Screen existing and proposed facilities and

infrastructure for the for the storage and handling, of

dangerous goods

3.5. Screen existing and proposed facilities,

infrastructure and activities related to the storage and use of

flammable substances

3.6. Apply for authorisations or

rectification of commencement of unlawful activities

3.7.1. Generate a work instruction or

operational procedure to elaborate on the

contents of training on HCS and DG

3.7.2. Train personnel and students involved

in the handling of hazardous substances and dangerous goods

3.8. Develop a central Safety Data Sheet (SDS)

database for each faculty that uses

hazardous substances

3.9. Investigate and implement measures for

the upgrade or expansion of hazardous

substances storage areas

3.10. Formal reporting procedure for

recording, investigating and reporting

emergency incidents involving hazardous

substances

3.11. Formal arrangements for the

management of asbestos

3.12.1. Formal arrangements for the

management of isotopes

3.12.2. Resolve current investigations relating to disparities between

current isotope management practice

and the requirements of authorisations

3.12.3. Contract between the university

and the appointed RPO, to outline the duties and

responsibilities of the RPO

3.13.1. Formal arrangements for the

management of herbicides and

pesticides

3.13.2. Register the person appointed for

the application of herbicides and

pesticides as a PCO

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Priority 3: Management of Dangerous Goods (1)

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Action Outcome Timeframe

Roles and responsibilities

Develop formal arrangements to screen existing & proposed activities, facilities & infrastructure related HS&DG management to identify applicable legal requirements and the need to apply for an EA



Develop formal arrangements for the management of hazardous substances and dangerous goods at the NWU

Implemented procedure for the management of HS&DG


Generate an inventory of the types and quantities of hazardous substances and dangerous goods (per faculty) stored and used by the NWU and keep up to date

HS&DG inventory per faculty for all campuses 1 month


Screen existing and proposed facilities and infrastructure for the for the storage and handling, of dangerous goods against the lists of activities requiring an EA

List of activities for which EA must be applied

Continuous

Trained task team (in consultation with the CEM and pro bono office)

Screen existing and proposed facilities, infrastructure and activities related to the storage and use of flammable substances against local by-laws to identify the need for applying for flammable substances permits

List of activities for which flammable substances permits must be applied

Continuous


Apply for authorisations or rectification of commencement of unlawful activities


8 – 12 months


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Apply for authorisations or rectification of commencement of unlawful activities

EA from Competent Authority 8 – 12 months Independent Environmental Assessment Practitioner (not NWU staff)

Generate a work instruction or operational procedure to elaborate on the contents of training on HCS and DG according to the requirements of the Occupational Health and Safety Act

• Work instruction on contents of HCS and DG training for NWU staff and students

• Standard slide deck to be used for training

3 weeks CEM has capacity

Train personnel and students involved in the handling of HS&DG on sound management, as prescribed by the Occupational Health and Safety Act

Trained personnel and students

Continuous at beginning of semester/year

Develop a central Safety Data Sheet (SDS) database for each entity that uses hazardous substances (must be accessible to all relevant personnel &students at the point of use)

Comprehensive SDS data base per faculty for all campuses

2 months

Generate and implement a formal reporting procedure for recording, investigating and reporting emergency incidents involving hazardous substances

Implemented procedure for recording, investigating and reporting emergency incidents involving HCS


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Investigate and implement measures for the upgrade or expansion of hazardous substances storage areas as far as containment and clean-up of hazardous chemical substances spillages are concerned

• Identification of storage & containment infrastructure requiring upgrade

• Documented measures for the upgrade or expansion of storage areas and containment measures (infrastructural)

• Implementation plan for upgrade of storage and containment infrastructure for HS and DGs.


Develop formal arrangements for the management of asbestos (which must include identification of asbestos-containing materials and areas, an asbestos-phase out plan,

• Implemented procedure for the management of asbestos

• Spatial map indicating areas where asbestos and/or asbestos containing materials are used/stored/part of infrastructure

• Asbestos-phase out plan

2 months CEM has capacity to develop procedure

Draft a contract between the NWU and appointed RPO, regarding the duties & responsibilities of the RPO as far as the management of Group IV hazardous substances are concerned

Contract between University and RPO outlining duties 2 weeks

Develop formal arrangements for the management of isotopes (which must include reporting duties to notify SAPs and the Director General if any isotope are lost, missing or stolen)

Implemented procedure for the management of isotopes 1 month CEM has capacity

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Current investigations relating to disparities between current isotope management practice and the requirements of authorisations must be closed-out to limit any potential liabilities

Confirmation from competent authority that issues have been resolved and closed out

1.5 months

Develop, communicate and implement formal arrangements for the management of herbicides and pesticides at the NWU

Implemented procedure for the management of herbicides and pesticides


Register the person appointed for the application of herbicides and pesticides as a Pest Control Officer (PCO) or work under the supervision of the PCO

Proof of registration of person responsible for application/supervising application of herbicides and pesticides as PCO

2 months

Verification audit to verify implementation of identified actions and compliance to identified requirements

Verification audit 3 weeks CEM has capacity

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Priority 4: Management of land and biodiversity Expected duration: 299 days

© CEM

4.1. Formal arrangements for the management of land

and biodiversity

4.2. Formal arrangements to screen biodiversity and land management related

projects and activities

4.3. Screen existing and proposed land and biodiversity related

projects and activities

4.4. Inventory of protected plant species on all NWU

properties 4.5. Inventory of all existing

alien and invasive plants

4.6. Apply for the necessary permits to

conduct activities involving protected species and keep

live game or operate an exotic captive species breeding operation for

game

4.7. Measures for protection of the veld

against deterioration and destruction

4.8. Alien and invasive plant control and

monitoring programme for all of the campuses

4.9.1. Establish and maintain firebreaks

4.9.2. Conduct an inspection or audit on

Protection Services' fire fighting equipment

4.9.3. Train responsible personnel for efficient fire

fighting

4.9.4. All three campuses join an operational Fire Protection Association

(FPA).

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Priority 4: Management of Land and Biodiversity (1)

© CEM


Develop formal arrangements to screen biodiversity and land management related projects and activities to identify legal requirements and the need to apply for an EA



Develop formal arrangements for the management of land and biodiversity

Implemented procedure for the management of land and biodiversity


Generate an inventory of all protected plant species on all NWU properties and keep up to date to ensure that the species receive the necessary protection (the location of protected species should also be mapped and included in NWU spatial plan)

• Protected plant species inventory for all campuses

• Protected plant species indicated on spatial plans and maps

1 month# CEM has capacity Potential for student involvement

Generate an inventory of all existing alien and invasive plants (especially category 1, 2 and 3 invaders) on all NWU properties and keep up to date

Alien and invasive plants inventory for all campuses 1 month#


Screen existing and proposed land and biodiversity related projects and activities to identify applicable legal requirements and the need to apply for an EA or permit

List of land and biodiversity related projects and activities (at all campuses) for which environmental authorisation must be applied

Continuous Trained task team (in consultation with the CEM and pro bono office)

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Apply for the necessary permits to conduct activities involving protected species and keep live game or operate an exotic captive species breeding operation (for game such as gemsbok)

Permits from Competent authority(ies)

8 to 12 months

Independent Environmental Assessment Practitioner (not CEM or pro bono office, due to possible conflict of interest)

Develop measures for protection of the veld against deterioration and destruction (measures include utilising the veld concerned in alternating grazing and rest periods, etc.)

Implemented measures for the protection of the veld against deterioration and destruction


Develop, communicate and implement an alien and invasive plant control and monitoring programme for all of the campuses

Alien and invasive plant control and monitoring programme

3 weeks CEM has capacity Potential for student involvement

Establish and maintain firebreaks on the NWU side of boundaries between properties belonging to the NWU and adjacent properties

Established and maintained firebreaks

2 weeks (before commencement of Winter)

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Conduct an inspection or audit on Protection Services' equipment to ensure that adequate fire-fighting equipment and protective clothing are made available for extinguishing veld fires on all NWU properties

Inspection/audit 1 week CEM has capacity

Train responsible personnel for efficient fire fighting Selected personnel to be trained 2 weeks

All three campuses to join an operational Fire Protection Association (FPA)

Proof of joining FPA 3 weeks



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Priority 5: Management of water Expected duration: 299 days

© CEM

5.1. Formal arrangements for the management of water

5.2. Formal arrangements to screen water related projects

and activities

5.3. Register of all water uses as defined in Section 21 of the

National Water Act across all NWU

campuses

5.4. Screen and investigate all potential

unauthorised water uses, especially non-

consumptive uses

5.5. Register water uses on the WARMS system

where required

5.6. Apply for water use licences where required

5.7. Establish whether or not the current water-use

quantities correlate with water-use authorisation

thresholds

5.8. Apply for amendments to current authorisations, if

current water-use quantities do not correlate with water-

use authorisation thresholds (if reasonable grounds for such amendments exist)

5.9. Water-saving initiatives for all

campuses

5.10. Water management awareness campaign among students and

personnel of the NWU

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Priority 5: Management of Water (1)

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Develop, communicate and implement formal arrangements to screen water related projects and activities to identify legal requirements and the need to apply for a water use licence



Develop, communicate and implement formal arrangements for the management of water

Implemented procedure for the management of water

1.5 months CEM has capacity

Develop a register of all water uses as defined in Section 21 of the National Water Act across all NWU campuses

Register of water uses per campus 2 months

Screen and investigate all potential unauthorised water uses, especially non-consumptive uses (including the storage of water and the impeding of water courses) to ascertain if the NWU needs to register or apply for any Water Use Authorisations

List of existing and proposed water related projects and activities (at all campuses) for which environmental authorisation must be applied

Continuous


Register water uses on the WARMS system where required

Confirmation of registered water use on WARMS

4 – 6 months

CEM has capacity to support

Apply for water use licences where required Water use licence(s) from Competent authority

8 – 12 months

Environmental Assessment Practitioner (not NWU)

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Priority 5: Management of Water (2)

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Establish whether or not the current water-use quantities correlate with water-use authorisation thresholds

Indication of discrepancies between water-use quantities and water-use authorisation thresholds

3 weeks CEM has capacity

Apply for amendments to current authorisations, if current water-use quantities do not correlate with water-use authorisation thresholds (if reasonable grounds for such amendments exist)

Amended water use licence(s) from competent authority(ies)

8 – 12 months

CEM has capacity to support

Investigate, implement and maintain water-saving initiatives for all campuses, i.e. repair all water leakages, utilise water-efficient taps and investigate water-efficient irrigation schedules and techniques

• Identification of water-saving initiatives

• Documented measures for saving water

• Implementation plan for water-saving initiatives

3 weeks

Develop and implement a water management awareness campaign among NWU students & personnel

Implemented initiatives to raise awareness 3 weeks



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Priority 6: Management of research processes Expected duration: 310 days

© CEM

6.1. Formal arrangements to screen both current and potential research proposals for any actual and/or potential activities that may be considered as bio-prospecting

activities

6.2. Screen current and potential research proposals and actual or potential activities for the need to apply for a bio-prospecting/export

permit

6.3. Apply for Environmental authorisation for activities involving bio-prospecting

6.4. Apply for bio-prospecting/export permits when the university plans to transport indigenous biological resources,

for the purpose of bio-prospecting or any other research, within South

Africa and outside the borders

6.5. Formal arrangements to ensure that GMO research is

conducted in accordance with the prescribed norms and standards

for GMO good practice

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Priority 6: Management of Research Processes (1)

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Develop formal arrangements to screen both current and potential research proposals for any actual and/or potential activities that may be considered as bio-prospecting activities

Implemented procedure for screening current and potential research proposals


Screen current and potential research proposals and actual or potential activities for the need to apply for a bio-prospecting/export permit

List of existing and proposed research proposals for which bio-prospecting/export permit(s) must be applied

Continuous


Apply for Environmental authorisation for activities involving bio-prospecting

Bio-prospecting permit from Competent Authority

8 – 12 months


Apply for bio-prospecting/export permits when the university plans to transport indigenous biological resources, for the purpose of bio-prospecting or any other research, within SA & outside the borders

Bio-prospecting/export permit from Competent Authority

2 – 3 months (as and when required)

Develop, formal arrangements to ensure that GMO research is conducted in accordance with the prescribed norms and standards for GMO good practice

Implemented procedure for the management of GMO research 1 month



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Priority 7: Management of technology transfer and innovation support Expected duration: 23 days

© CEM

7.1. Develop, communicate and implement formal and structured arrangements to ensure that all considered technologies and innovations are consistently screened for their possible

applicable environmental legal requirements

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Priority 7: Management of technology transfer and innovation support

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Develop formal and structured arrangements to ensure that all considered technologies and innovations are consistently screened for their possible applicable environmental legal requirements

Implemented procedure for the screening of technologies and innovations for possible legal requirements

3 weeks


Verification audit 1 week CEM has capacity

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Priority 8: Management of business and enterprise developments Expected duration: 25 days

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8.1. Develop, communicate and implement formal arrangements to

screen candidate businesses, enterprises and licence holders for

any potential environmental risk exposures and legal requirements before they are appointed by the

NWU

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Priority 8: Management of business and enterprise developments

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Develop formal and structured arrangements to screen candidate businesses, enterprises and licence holders for any potential environmental risk exposures and legal requirements before they are appointed by the NWU

Implemented procedure for the screening of candidate businesses, enterprises and licence holders for possible legal requirements

3 weeks


Verification audit 1 week CEM has capacity

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Conclusion

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Way forward

Prioritisation of corrective actions

Review by Institutional Management

Allocation of budget and resources

Development of formal arrangements

Approval of formal arrangements

Implementation formal arrangements

Verification of formal arrangements

© CEM

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Important considerations

Identify existing best practices At NWU or other similar institutions

Involve existing champions/ interested parties At NWU or outside parties

Investigate opportunities for synergies Co-ordinate initiatives

© CEM