ISO 14001-THE RPPF EXPERIENCE

APFA/QLD EPA/ RPPF ISO 14001 PROJECT

2001 EPA’S SUSTAINABLE INDUSTRIES DIVISION FUNDING3 STAGE PROJECT:(1) SCOPING STUDY ( UNITED NATIONS GROUP FOR CLEANER FOOD PRODUCTION+ ECO-EFFICIENCY REPORT(2) DEVELOPMENT AND CERTIFICATION OF ENVIRONMENTAL MANAGEMENT SYSTEM TO ISO 14001 STANDARD(3) INDUSTRY WORKSHOP AND REPORT

Cover Sheet

Rocky Point Prawn FarmRocky Point Prawn Farm

Environment, Quality & Safety Management System Manual

Prepared byME McKay & Associates Pty Ltd.

Consulting EngineersABN 61010 656 372

PO Box 7855TOOWOOMBA MAIL CENTRE QLD 4352

Ph: 07 4630 1048Fax: 07 4630 1068

E-mail: mgspence@bigpond.net.au

What is EMSand how does it work?

A systematic approach to managing environmental issues

PLAN

DO

ACT

CHECK

What is EMSand how does it work?

Progressive improvement

Zero discharge of water

Reusable or biodegradable

packaging

Use of sustainably produced feeds

Compliance

Maximising energy efficiency

Assess environmental

aspects

Assess significance & identify priorities

Determine control measures &

improvement requirements

Implement checking & corrective action

procedures

First round of audits and review

Documentation

Develop policy, objectives & targets

Staff training

CERTIFICATION

ACCREDITATION PROCESS

EXTERNAL DRIVERS:ADDRESS COMMUNITY CONCERNSJUSTIFY ACCESS TO RESOURCESDEMONSTRATE ENVIRONMENTAL RESPONSIBILITYGAIN/MAINTAIN MARKET ACCESSGAIN PRICE PREMIUMINDEPENDENT AUDITS FOR CERTIFICATION

WHY EMS & ISO 14001?

WHY EMS (cont’d)EXTERNAL DRIVERS:

REGULATORY RELIEFENHANCE REPUTATION FROM TAKING ACTION TO IMPROVE THE ENVIRONMENT

WHY EMS (cont’d)INTERNAL DRIVERS:

EFFICIENT MANAGEMENT TOOL =BETTER PRODUCTION RESULT TRACEABILITY- EASY FOR ORGANIC CERTIFICATION, EU RETAIL BASIC REQUIREMENTREDUCE RISK TO COMPANY AND EMPLOYEES PERSONAL LIABILITY RECORDSTRAINING TOOL/MANUALSDATA-COLLATE AND REVIEW PERIODICALLY

WHY EMS (cont’d)RECORDS

TRAINING TOOL/MANUALS

DATA-COLLATE ,REVIEW, ACT AT SET

TIMES OF THE SEASON

What’s involved in implementing an EMS?

1. Do we understand our farm’s issues?legal,social,environmental

2. Do we know our most significant issues?

3. Are we aware of our legal obligations?

4. Do we have an environmental policy?

5. Do we have objectives & targets for improving our environmental performance?

6. Do our staff know what to do to prevent environmental problems?

7. Do we know how to respond to an environmental problem?

8. How do we know our performance is OK?

9. Do we review our performance?10. Do we keep good records?

Potential impacts – may be outputs, complaints or costs.

Soil Water Air Resource Use Biodiversity Social and Community,

Natural/Cultural heritageSoil compaction Surface and

groundwater contamination

Air emissions (particulates)

Energy Use Loss of biodiversity Light

Soil erosion Nutrification Heat emissions Fuel use Vegetation loss Odour

Soil contamination Nitrification Odour Down-time Increase of biodiversity

Noise

Bulk density changes

Turbidity/ Sediment load

Noise Recyclable or non-recyclable resources

Vermin generation Dust

Water infiltration Heat emissions to water

Dust Waste generation and disposal

(organic and non-organic)

Species composition

change

Vibration

Run-off Run-off Greenhouse gas emissions Packaging

Habitat decline/structural

change

Disease generation

Soil salinity BOD CFC generation Human resources Loss of local species

Vermin generation

Soil acidity Sediment load SOx, NOx etc. generation

Chemical use Introduction of exotic species

Community amenity decline

Acid sulphate soils Water use Spray drift Antibiotic/medicinal use

Buffer zone utilisation

Visual impacts

Organic matter decline

Accessions to groundwater

Financial resources

Chemical Resistance

Neighbour complaints

Soil nutrient decline

Disease transfer Post-harvest treatments (dips, sprays, waxes)

Human health and safety

Heavy metal contamination

Heat emissions Traffic

Water table changes Leaching Aesthetic Value

Disease build-up Economic

Soil nutrient increase Employment

Waterlogging

(After Spence, M (1998); Caruthers, G. and Tinning, G (2000))

The Water Quality Release Improvement Plan must outline the

following information:

(i) how the holder of this development permit intends to

reduce the mass load of Total Nitrogen per day released into

the receiving environment each year; and

(ii) how the holder of this development permit intends to

actively manage the wastewater treatment ponds to reduce the

mass load of Total Nitrogen per day released into the receiving

environment.

EMP2: Pond Management

Environmental Management PlanEMP2: Pond Management

Environmental Objectives: Operate and maintain ponds in an ecologically sustainable manner

Licence and/or Target Conditions: APFA Code of PracticeLicence

Potential Impacts: The primary impact is elevated nutrients and suspended solids in discharge water. Drained ponds also have the potential to create odours and possible leachates.

Management Strategy/s: AP2-1: Operate pondsAP2-2: Maintain Ponds and CanalsAP2-3: Manage Water Intake and DischargeAP2-4: Manage Pond Spelling and StockpilesAP2-5: Predator ManagementAP2-6: Feed ManagementAP2-7: Maintain Ponds and Canals and Manage Acid Sulfate Soils

Performance Indicators:All key actions have been identified in the Action Plans

Monitoring: Actions identified and documented during annual review and or audits

Overall Responsibility: Quality Manager

Recording and Reporting: Reported in Annual Review document.

Corrective Action/Review: Seek appropriate advice if necessary.

Related Documentation/References Environmental LicenceIEMS Manual: legal

Action Plan: AP2-7: Acid Sulfate Soils (ASS)(EMP2 – Pond Management)

Management Strategy (What to do):

Minimise disturbance of Acid Sulfate Soil (ASS) during construction or maintenance activities, and correctly manage the ASS so as to ensure the protection of the surrounding environment from ASS impacts.

Why do it: Avoid harm to receiving watersAvoid known ASS areas.Where disturbance is unavoidable, ensure ASS is managed on-site to the satisfaction of DNRM and EPA before disposal or dischargeLicence Condition: XXX

References (if applicable): Plan developed by BTEDC Pty Ltd

How to do it: Who to do it: Target Date: Performance Indicators:

AP2-7: Acid Sulfate Soil

1. Include ASS recognition training in Training Program

Training Officer

Jan 2003 Training scheduled and package developed

2. Produce ASS management procedure Farm Manager Completed Procedure written

3. Manage ASS Farm Manager Ongoing Elimination of water discharges from the site below pH 6.5 (see Licence Conditions)

Cost/Benefit: Cost: TimeBenefit: Avoid legal hassles, potential for ASS minimised

Recording and Reporting: Continuous visual monitoring by trained personnel for the signs of ASS presence.Daily pH monitoring of water discharges from the farm

Corrective Action/Review: Immediately stop any release of waterIf necessary, water will be treated with hydrated lime sufficiently to bring pH of the water above 6.5Report to the EPA when required by the EPA LicenceA review of this ASS management plan may be required.

Managing Director – by Program

EMP Ref.

Management Actions/Activities Timing Time Completed

AP1-1(Legal)

All contractors, operators and lessees operating at the site should be aware of their responsibilities regarding any general environmental ‘duty of care’ and any environmental harm that may occur because of their operations or activities.

30 August 2003

ISO 9001 ISO 14001

EMSQA

Common management specifications to QA and EMS

EMS specification onlyQA specification

only

ISO 14001LicenceConditions

LICENCE vs EMP vs ISO EMS

EMP to meet Licence Conditions = EMS

About 85%

5.0 DOCUMENT and data controlResponsibility

Admin/Office

Process/QAManager

FarmManager

Maintenance

ManagingDirector

All

Quality Team

Copy Holders

TrainingOfficer

Reference

Note 1All staff are encouraged tomake submissions. Requestsmay be verbal or written - noform is required.Changes may be in responseto:-Regulatory changes/codes ofPractice-Internal review and audit-Changes reulting fromexternal audit-Procedural modifications; e.g.,changes in the way tasks arecarried out-New equipment purchaseswhich may cause modificationsto the process

Action

Amendment Identified(see Note 1)

Submit to Quality Team(see Note 2)

Quality Environment Safety ManualAmendment Procedures

No

AmendmentRecommended

No

Yes

Stop - adviseproponent of

decision(Note 3)

YesIs it affected by, or affect, anexternal agency?

(see Note 5)

Seek relevantapproval

ApprovalReceived

Yes

No

Relevant RiskAnalysis

(see Note 4)

Training NeedsAnalysis

(see Note 6)

Note 2Relevant Manager responsibleto pass to Quality Team. QualityTeam to record all submissions.Quality Team meetings heldwhen required or at direction ofManaging Director/QAManager.

Note 3Relevant Officer is usually theQA Manager but may bedelegated to the Farm Manager,Consultant etc as applicable.

Note 4Risk Analysis to be undertakenof changes as per relevantsystem; eg, QA, Environment,Safety .

AmendmentAuthorised

Issue Amendment Note 5This affects, e.g., SAFE FOODQLD, DPI; EPA QLD forEnvironmental Licence.Relevant Managers to advise.This may be a regiulatoryrequirement.

Note 7Additional copies for distributionto customers etc. may beobtained from theAdministration Manager ornominee and shall be identifiedas an "UNCONTROLLEDCOPY" on the front cover.

Note 6Training Officer to be notified ofchanges and to decide on anytraining required as a result ofthe amendment.

No

Yes

Stop - notamended

(see Note 7)

Amend each copyof Manual(Note 8)

RecordAmendment usingForm 7 (see Forms

Register)

Controlled Copy

Note 8QA Manager to sign allamended pages.Inserts new section/s andremoves each redundantsection/sPlace redundant section inamendments file (one copy)

Arrange typing andproduction

Flowchart QESIssue Date: XXXXXXXIssued by: Quality ManagerAuthorized by: Quality Manager

Policy: It is the policy of Rocky Point Prawn Farm tocontrol the authorisation, issue, amendment and re-issueof all key documentation, and to ensure that onlydocuments of current status are available at all requiredlocations.Accordingly, Rocky Point Prawn Farm exerts control overthe following documents:(i) External documents e.g. Acts, Regulations, Codes ofPractice and ISO 9000/14000 series documents.(ii) Internal documents:· Forms listed in the Forms Register· Procedures documented in the relevant Manuals.· Elements of the ISO manual.

E x t r a c t W a t e r

S i t eP r e p a r a t i o n

P o n d / C a n a lC o n s t r u c t i o n

P u m p & F i l lP o n d s

S t o c k P o n d s

H a r v e s tP r a w n s

C o n t r o lP r e d a t o r s

F e e d P r a w n s

E m p t y P o n d s

P u m p W a t e r D i s c h a r g eW a t e r

C o l l e c t P o n dS o l i d sS p e l l P o n d s D i s p o s e o f

S o l i d s

O p e r a t eM a c h i n e r y &

V e h i c l e s

O p e r a t eP o n d sA e r a t e P o n d s

T r e a t W a t e r

S t o r e F e e d

G r o w P r a w n s

O p e r a t i o n a l O v e r v i e w

D a t e : I s s u e d B y : A u t h o r i s e d B y :

P r o c u r e F e e d

M a i n t a i nW a t e r L e v e l

M a i n t a i nV e h i c l e s &E q u i p m e n t

P r o v i d e P o w e r

A d m i n i s t r a t i o n

G r a d i n gP . j a p o n i c u s

P a c k i n g S h i p p i n g

P o n d / C a n a lM a i n t e n a n c e

P r o c u r e P LS t o c k

P o n d S e c u r i t y

F u e l S t o r a g e

S i t eM a i n t e n a n c e

G r a d i n gP . m o n o d o n

P a c k i n g S h i p p i n g

P r o c e s s -c h i l l i n g /c o o k i n g

C h e m i c a lS t o r a g e

W a s t e ( n o tp o n d s o l i d s )

M a n a g e m e n t

P u r c h a s e o fG o o d s a n d

S e r v i c e s

P r a w n F a r m O p e r a t i o n s - S i m p l i f i e dO v e r v i e w o f A c t i v i t i e s

Compliance checklist for SR2231 and DA009:- Rocky Point Prawn FarmThis checklist is designed to help Rocky Point Prawn Farm maintain compliance with the conditions of environmental authority SR2231 and development approval DA009. The conditions referred to in the checklist are limited to those that require a defined action to be undertaken (eg: monitoring / reporting / checking). Conditions that involve a management decision (eg: change to operations or farm layout), or are administrative or general in nature are generally not included. Note that RPPF is ultimately responsible for all issues, but BTEDC isincluded where they perform specific duties. Note also that there is considerable duplication of conditions between SR2231 and DA009.

Condition* Required Action Responsible Entity

Compliance CommentsYes No

2A3 / A8 Advise EPA within 28 days if species other than prawns stocked (unless used for bioremediation purposes).

RPPF

2A11 / A6 Monitoring equipment to be appropriately calibrated, operated and maintained.

RPPF / BTEDC

2B1 / B1 Dust minimisation / control measures. RPPF

2B2 / B2 Odour minimisation / control measures. RPPF

2C2 Intake from I2 (original intake in Bremerhaven) only allowed in emergency situations.

RPPF

2C3 Water release from W2 (original outlet in Bremerhaven) only in emergency situations.

RPPF

2C4 / C6-7 Water discharge to be controlled to avoid erosion or vegetation damage (limit 0.30m3/s).

RPPF

2C7 / C8-10 Preparation of Water Quality Release Continual Improvement Report.

RPPF / BTEDC

2C11 / C13 Check water discharge for visual evidence of pollution (eg; oil, scum, litter, plume, etc).

RPPF

2C12 C14 Minimise erosion of pond walls. RPPF

Condition* Required Action Responsible Entity

Compliance CommentsYes No

2C13 / C15 Release times limited to 30 minutes after local high water until 2 hours before local low water.

RPPF

C16 Maximum discharge of 7,560m3 in 24 hours from W1. RPPF

2C14 No discharge from ponds allowed between 14/6 and 1/11 unless from kuruma ponds or for maintaining bioremediation organisms.

RPPF

2D1 / D1 Clean up spills so that waste material isn’t released to waters.

RPPF

2D2 / D2 Fuel / chemicals to be stored in bunded area. RPPF2D5 / D8 Store unwashed empty drums on concrete, with

closures (bungs, etc) in place.RPPF

2D6 / D9 Washing, servicing,/maintenance of vehicles, engines, etc to occur in area where any spilt oil, etc cannot contaminate environment.

RPPF

2D9 / D12 Ensure any drainage from pond sludge disposal areas drains to growout ponds or wastewater treatment system.

2D10-12 / D13

Acid sulphate soil investigation required prior to earthworks.

RPPF / BTEDC

2D13-15 / D19-25

Acid sulphate soil to be properly managed. RPPF / BTEDC

2D16 Install appropriate erosion control measures prior to any clearing or construction on site.

RPPF

2D17 Collect stormwater runoff samples (for stormwater leaving site). – TSS limit of 50mg/L

RPPF

Condition* Required Action Responsible Entity

Compliance CommentsYes No

2E1 /E1 No release (or potential release) of contaminants to land to result in environmental harm.

RPPF

2F1 / F1 Minimise noise generation (lessen risk of .noise complaints)

RPPF

2F2 / F2 Ensure scare guns and/or firearms do not cause unreasonable intrusive noise.

RPPF

2G1 / G1 No waste from site to be burnt (on site or off site).

RPPF

2G2 / G2 No improper release, storage or disposal of waste material.

RPPF

2G3 / G3 Record details of on site waste disposal (other than pond sludge used for pond maintenance).

RPPF

2G4 / G4 Maintain records of regulated waste or pond sludge removed off site.

RPPF

2H1 / H1 Maintain Complaints Register RPPF2H2-3 / H2-3 Water quality samples to be taken in accordance

with EPA Manual, by suitably experienced and qualified person.

RPPF / BTEDC

2H5-6 / H6-8 Intake and release volumes to be recorded. RPPF2H7-13 / H9-13

Water quality monitoring to be conducted as per Attachment 1.

RPPF / BTEDC

H14-15 Monitor sediments in Sandy Creek as per Attachment 1.

RPPF / BTEDC

2H14-17 Calculate volumes of contaminants released. RPPF / BTEDC

2H27 / H24 Maintain status as “participating member” in regional monitoring study.

RPPF

Condition* Required Action Responsible Entity

Compliance CommentsYes No

H27-28 Undertake photographic monitoring as per Attachment 1.

RPPF / BTEDC

2H29 / H29 Maintain appropriate records of chemicals used in ponds and/or treatment system.

RPPF

2H30-33 / H30-33

Noise monitoring to be conducted if required due to valid noise complaint.

RPPF / BTEDC

2H34 / A16 Monitoring results to be included with each Annual Return.

RPPF / BTEDC

2H35-36 / H34-35

EPA to be notified ASAP by phone or fax in event of non-compliant contaminant release resulting from emergency or incident.

RPPF / BTEDC

2H37 / H36 From 2H35-36, notify EPA in writing within 14 days of incident and actions taken to remedy incident at time of incident and to prevent reoccurrence.

RPPF / BTEDC

2H38-39 / H37-38

Non-compliant monitoring results to be reported to EPA within 28 days of analysis.

RPPF / BTEDC

2J1 / J1 EPA to be notified of any declared disease outbreak or mortality requiring treatment and possible pond drainage.

RPPF / BTEDC

2J2 / J2 Dispose of diseased organisms only in agreement with EPA.

RPPF

J3 Maintain records with respect to J1 and J2. RPPF

Attachment 1: RPPF –SR2231 and DA009 Monitoring Conditions

Parameter Sampling Point When* Who Limit NotesIntake Outlet

Water quality monitoring

pHSW1 Fortnightly

BTEDCN/A INTAKE:

Take on incoming tide, when intake pumps are running.DISCHARGE:Must be taken on outgoing tide at estimated time of maximum flow rate from outlet.Must be undertaken during drainage of pond contents at least twice during the season.NOTESD.O. samples to be taken within one hour of each other to determine background.Ensure pump run times are recorded so that pumping volumes can be determined.Intake and outlet samples are to be taken on the same day.SW1 – Mouth of Sandy Creek where it meets main channel – BOAT requiredSW2 – Immediately downstream of Release PointSW3 – Middle of main channel out from mouth of Sandy Creek – BOAT required

SW1/SW2 Fortnightly 7 – 9.0

D.O. (mg/L)SW1 Fortnightly

BTEDCN/A

SW1/SW2 Fortnightly 4.0

Susp. Solids (mg/L)

SW1 First and third week of each month whilst intaking

BTEDC

N/A

SW1/SW2 First and third week of each month whilst discharging

30 nett (80th percentile)40 nett (maximum)

SW3 Monthly while discharging

Total N (mg/L)

SW1 First and third week of each month whilst intaking

BTEDC

N/A

SW1/SW2 First and third week of each month whilst discharging

Average seasonal load must not exceed 7kg N/day

SW3 Monthly while discharging

Total P (mg/L)

SW1 First and third week of each month whilst intaking

BTEDC

N/A

SW1/SW2 First and third week of each month whilst discharging

0.2 nett (80th percentile)0.4 nett (maximum)

SW3 Monthly while discharging

Chlorophyll “a”(µg/L)

SW1 First and third week of each month whilst intaking

BTEDC

N/A

SW1/SW2 First and third week of each month whilst discharging

N/A

SW3 Monthly while discharging N/A

Parameter

Sampling Point When* Who Limit NotesIntake O

utlet

Photographic monitoring

Photographic Monitoring

SW1, SW2 and SW5Banks of tidal waters into

which wastewaters are released

Monthly at mid ebb tide whilst discharging

BTEDC

Adjacent to the channel from both banksLooking downstream from the aquaculture facility inlet/outlet structure in the tidal waters

For ALL sites:General overview photos in each direction, focal length 50mm, a measuring stick in the foreground for scale. BOAT required.Close up of both banks of the tidal watersSW4

Impermeable bund Both sides of the bund

Sediment samplingAmmonia (mg/L)

The bottom of Sandy Creek beneath sampling points SW1, SW2 and SW4 as illustrated on Map 3 in Schedule K of DA009.

In any one aquaculture season, one sample prior to discharge of wastewater, and one sample taken 6 months later.

BTEDC

N/ANOTESSediment samples are to be collected from the left, right and centre of channel at each sample location and mixed well to form a single, composite sample.SW1 – Mouth of Sandy Creek where it meets main channel –BOAT requiredSW2 – Immediately downstream of Release PointSW4 – 100 metres downstream of inlet/outlet structure – BOAT required

Oxidised Nitrogen (mg/L)Organic Nitrogen (mg/L)Total Nitrogen (mg/L)Filterable Reactive Phosphorus (mg/L)Total Phosphorus as P (mg/L)

BenefitsDemonstrates that good environmental performance is important at your farmHelps prioritise environmental issuesConfidence when communicating with external bodiesReduced legal liabilityGets you organised!Potential for regulatory relief through self-regulation

Training staff-personal legal liabilityTraining manual-procedures,processes set outBusiness risks-scan Aust newsIncreasing “green tape” CM news scanImproved bottom lineMarket access-M&S, SainsburysMarket premium-JapanBottom line economic & environmental performance not mutually exclusive eg save feed, FCRCompliance checklist tools