Quarry Southern Africa March 2019 | Page 34

ENVIRONMENT IN FOCUS ADVICE FROM AN ENVIRONMENTAL AUDITOR ON DUSTFALL MONITORING AND REPORTING By Alan Cluett (Pr. Sci. Nat.; FIQ; LMGSSA), founder of Cluett Consulting Most surface mines in South Africa must conduct dustfall monitoring and reporting, either as a condition in their approved environmental management plan (EMP), or through a directive issued by an authority, or through an agreement with stakeholders. Whatever the reason, it must comply with the requirements published in GN 827 National Dust Control Regulations (1 November 2013). 32_QUARRY SA| MARCH/APRIL 2019 D uring my 27 years as an environmental manager and consultant in the surface mining, aggregate, cement, ready-mix, and waste management industries, I have inspected dustfall monitoring installations and reviewed numerous dustfall monitoring reports from a number of industry service providers — reports sent to their clients as well as to the authorities in terms of the legal requirement. Some of the monitoring and reports reviewed are excellent, complying with the prescribed requirements fully or as close to fully as to be acceptable. Sadly, or should I say frustratingly, a high percentage of service providers perform well below acceptable standards, often interpreting the legal requirements to suit their own requirements, abilities, or simply to win the contract by submission of the lowest quote. In the field, I have seen the following: very poor practices; non-compliant monitoring equipment; incorrect sample collection and management; and, cut and paste reports. I have seen identical reports at two different clients — one in the Western Cape, the other in Limpopo. In fact, in several cases in reports submitted to the industry, the information contained therein is inaccurate, incorrect, and often misleading or false! This is not only a disgraceful performance from the service provider, but also a very poor reflection on the operations management and environmental responsible persons who, in a number of instances, neither read nor understand the report content. Desiccated algae found in a dustfall bucket shortly after the service provider had completed sample collection on the site. Consequences of inaccurate reporting So, what are the possible consequences of this poor service delivery and inaccurate, incorrect, misleading, or false monitoring and reporting? Besides the waste of client money, it also has more serious repercussions that include: • Your operation may be initiating expensive corrective action where none is necessary; • Your operation may need to initiate corrective action as the reports are under-determining actual dustfall levels; • Your operation may be misinforming neighbours, communities, and community forums; or • Your operation may be vulnerable to non-compliance with sections of various legislation, including NEMA, NEM:AQA, and the MPRDA. Let us consider, for a moment, some sections of South African legislation that spell out the consequence of supplying ‘inaccurate, incorrect, or misleading or false information’ to the authorities: The MPRDA, section 47(1)(d) reads: “47.(1) … the Minister may cancel or suspend any reconnaissance permission,