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,