CHAPTER 6 -

ENVIRONMENTAL
MANAGEMENT
PLAN

DR. NORHUSNA MOHAMAD NOR

 6.1. EMP concept
6.1.1. Concerns and issues about the environment

COURSE 6.1.2. Cleaner production – The Green Line

OUTLINE
6.1.3. Cleaner production – The Bottom Line
6.1.4. Series standard
6.1.5. Schemes for carbon trading
6.1.6. The management of environmental quality
6.1.7. Environmental management tools and Systems
6.2. ISO 14001 – Environmental management
6.2.1. Environmental policy
6.2.2. Planning an EMS
6.2.3. Implementation and operation
6.2.4. Checking and corrective action
6.2.5. Management review
6.3. Monitoring plan
6.3.1. Principles of auditing
6.3.2. Audit procedures
6.3.3. Practical aspects of auditing 2
COURSE LEARNING
OUTCOMES
At the end of this chapter, the students should be
able to:
• Describe the EMP concept which related to
cleaner production, series standard, carbon
trading, and environmental management tools
and systems
• Employ the ISO 14001 – Environmental
management in the EMP report
• Prepare the Monitoring plan which related to
the principles of auditing, audit procedures, and
practical aspects of auditing
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RECAPS ON EIA REPORT
PREPARATION

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EIA
• A decision-making tool to analyze environmental
impacts;
• Identifies alternatives and public consultation
inputs; and

• EIA, along with other studies provides input to

better project design.

Remember! EIA is a Process - Not a Product.

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 STEPS to Prepare EIA Report:
• Provide project brief
• Identify legal & administrative requirement
• Check if the project align to existing policies &
guidelines
• Carry out preliminary stakeholder engagement
• Prepare term of reference (TOR) & environmental
scoping
• Submit TOR to DOE
• Baseline data collection for EIA
• Carry out EIA studies
• Draft the EIA
• Carry out public engagement
• Submit EIA & carry out public display
• Decision by EIA technical review committee
6/16/2022 6
EIA METHODOLOGIES
Source: Department of Environment, “Environmental Impact Assessment
in Malaysia”,2016.

1. Screening
2. Scoping towards formulation of
terms of reference
3. Baseline study
4. Identification of mitigation measures
5. Impact assessment and evaluation of
significance
6. EIA Report preparation
7. EIA Report review
8. Decision making
9. Project implementation and
environmental monitoring
10. Environmental audit
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6.1 EMP CONCEPT
INTRODUCTION
• Continuation process of EIA
• Ensures commitment of project proponent
• Implementation of mitigation measures
proposed
• Implementation of approval conditions
(COAs)
• EMP to be submitted to Department of
Environment (DOE) Malaysia at least 90
days before project is implemented

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INTRODUCTION

• Must be approved by DOE Malaysia before

commencement of project
• Erosion and Sediment Control Plan (ESCP)
as part of EMP for projects involving
earthworks
• DOE Malaysia monitors implementation of
EMP and approval conditions to ensure
compliance

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CONCERNS AND ISSUES ABOUT THE
ENVIRONMENT
• EMP translates the pollution prevention and mitigation measures (P2M2s)
recommended in the EIA Report and the approval conditions (COAs) into action
• To ensure that the EIA approval conditions (COAs) are translated into actionable
items resulting in reduced adverse impacts to the environment

• what actions will be taken,

• what measures will be instituted,
• what structures will be built,
• What will be installed,
• when the actions will be executed; etc.

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EMP - ‘LIVING DOCUMENT’
• Should be improved and adapted throughout the life of the project to reflect
changing conditions
• Be subjected to periodic review to ensure their continued relevance and validity

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EMP - MAIN OBJECTIVES
• Comply with legislation, policy,
guidelines and EIA approval conditions
• Provide support to the planning of
environmental management of the
project, including resource allocation
• Guidance for day-to-day environmental
management of the project
• Systematic reporting of plans and
actions
• Review of current and past practices to
assess effectiveness
• Communicate the environmental policy
and management practices used on the
project to all relevant parties

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GUIDELINES – EFFECTIVE EMP
• WHY: State the objective of the mitigation
measures and why it is recommended;
• WHAT: Explain the specifics of the mitigation
measures and how it will be designed and
implemented:
• Identify measurable performance standards by
which the success of the mitigation can be
determines as according to the EQA 1974
• Provide for contingent mitigation if monitoring
reveals that the success standards are not
satisfied
• WHO: Identify the agency, organization, or
individual responsible for implementing the
measure;
• WHERE: Identify the specific location of the
mitigation measure;
• WHEN: Develop a schedule for implementation. 14
 Environmental Management Plan
(EMP)
Action To Be Taken

Environmental Impact Assessment What Can Be Done?

(EIA)
What Might Happen?

Project Planning Implementation & Construction

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EMP – TYPICAL PREPARATION STEPS

EMP Preparer EMP Preparer EMP Preparer Project Proponent (PP)

2. Translate
1. Study identified
recommended P2M2s and 3. Prepare cost 4. Make
P2M2s and COAs into estimate declaration
COAs executable
actions

Note: The EMP preparer shall be a consultant registered with the DOE

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 CLEANER PRODUCTION – THE GREEN
LINE
• “Cleaner Production is the continuous application of an integrated, preventive environmental
strategy towards processes, products, and services in order to increase overall efficiency and
reduce damage and risks for humans and the environment.”
• “Green-line” manufacturing, in which workers use fewer natural resources, reduce pollution
and waste, recycle and reuse materials, and moderate emissions in their processes.
• Green-line manufacturers research, develop, or utilize technologies and practices to lessen
their impact on the environment

Definition by UNEP 17
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CLEANER
PRODUCTION – THE
BOTTOM LINE
• The bottom line refers to the net
income of a company for a certain
period.
• Triple bottom-line (TBL): The planet,
environmental bottom line, or natural
capital bottom line refers to sustainable
environmental practices.
• A TBL company endeavors to benefit
the natural order as much as possible
or at the least do no harm and minimize
environmental impact.
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BUSINESS STRATEGY TOWARDS CP

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 EMP - SERIES STANDARD
• ISO 14000 is a family of standards related to environmental management that exists
to help organizations:
a) minimize how their operations (processes, etc.) negatively affect the environment (i.e. cause
adverse changes to air, water, or land);
b) comply with applicable laws, regulations, and other environmentally oriented requirements; and
c) continually improve in the above.

ISO 14000 is similar to ISO 9000 quality management in

that both pertain to the process of how a product is
produced, rather than to the product itself.
As with ISO 9001, certification is performed by third-party
organizations rather than being awarded by ISO directly.
The ISO 19011 and ISO 17021 audit standards apply when
audits are being performed.
The requirements of ISO 14001 are an integral part of the
European Union's Eco-Management and Audit Scheme
(EMAS). EMAS's structure and material are more
demanding, mainly concerning performance
improvement, legal compliance, and reporting duties.
The current version of ISO 14001 is ISO 14001:2015,
which was published in September 2015.
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SCHEMES FOR
CARBON TRADING
• Emission trading (ETS) for carbon
dioxide (CO2) and other greenhouse
gases (GHG) is a form of carbon pricing;
also known as cap and trade (CAT) or
carbon pricing.
• It is an approach to limit climate change
by creating a market with limited
allowances for emissions.
• A polluter having more emissions than
their quota has to purchase the right to
emit more. The entity having fewer
emissions sells the right to emit carbon
to other entities.
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THE MANAGEMENT OF
ENVIRONMENTAL QUALITY

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EMS
An Environmental Management System (EMS) is a set of processes and practices that
enable an organization to reduce its environmental impacts and increase its operating
efficiency.
It includes the organizational structure, planning and resources for developing,
implementing and maintaining policy for environmental protection.

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ENVIRONMENTAL MANAGEMENT
TOOLS AND SYSTEMS

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EMP FORMAT
 1 Introduction

2 Policy

3 Organization chart and budget

EMP 4 Environmental requirements

REPORTING
FORMAT 5 Monitoring programme

6 Significant impacts and pollution control

measures

7 Environmental contingency plan

8 Closing
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1: INTRODUCTION

Provide information on:

a. Project layout as approved in the Development Order by Local Authority.
b. Project implementation schedule.
c. Name of the EMP preparer and his consulting firm.

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2: POLICY

Provide information on:

a. Company’s corporate policy statement on environmental management and protection.
b. Commitment by the top management on the mainstreaming of environmental agenda
and instilling of self regulation in the development project and on ensuring continuous
compliance with the environmental regulatory requirements.

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3: ORGANIZATIONAL STRUCTURE
Provide information on:
a. Organization chart of the company’s top management with responsibilities on environmental
management and protection (provide names, positions, mobile phone contact numbers and e-
mail addresses).
b. Name, mobile phone contact number and e-mail address of environmental manager,
environmental officer (EO), engineering consultant, contractor, site supervisor and competent
person* (wherever relevant and available).
(*Note: Competent person is a person certified by the DOE through the certification program
administered by the Environment Institute of Malaysia, EiMAS)
c. Name of environmental consultant and accredited laboratory conducting environmental
monitoring, analysis of environmental samples and submitting reports to the DOE.

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TRAINING REQUIREMENT
Provide information on:
a. Plan for staff training in order to develop competency to discharge responsibilities
on environmental requirements and compliance.
b. The training areas shall include maintenance and performance monitoring of all
P2M2 (LD-P2M2, IETS, APCS, STS, management of scheduled waste), wherever
relevant.

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4: ENVIRONMENTAL REQUIREMENTS
• Provide information on:
• a. EIA Approval Conditions (COAs)
• b. LD-P2M2 document
• c. Pollution prevention and mitigation
measures (P2M2) to be implemented
as in the Table 6.1.

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4: ENVIRONMENTAL REQUIREMENTS
d. Water Pollution Control (Effluent treatment, Temporary sludge and sewage treatment,
Permanent sludge and sewage treatment, etc.)
e. Control of Air Pollution and Noise
f. Materials And Waste Management (Raw materials and stockpiles, Solid waste,
Biomass, Spoils/dredge materials/construction waste, Open burning, Housekeeping.)
g. Scheduled Waste Management

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5: MONITORING PROGRAM
• Initial baseline information for reference
• Sampling locations and parameters, with justifications of site selection
• Effluent discharge, air emissions, waste noise and vibration monitoring
• Sampling methods and monitoring frequency
• Time-frame for reporting to DOE Malaysia

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6: SIGNIFICANT IMPACTS AND
POLLUTION CONTROL MEASURES
• Identified significant impacts should be addressed; mitigation measures incorporated
into detailed design and contract documents
• Pollution control equipment and operational procedures
• Site abandonment plan if project delayed or permanently abandoned
• Closure or rehabilitation plan

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7: ENVIRONMENTAL CONTINGENCY
PLAN
• Emergency Response Plan (ERP):
• Outline actions to be taken in case of emergency (e.g., landslide, oil or chemical spill, failure of
pollution control equipment)
• Organizational roles and responsibilities
• Chain of command
• Communication channels clearly defined
• List of relevant agencies involved (e.g., Police, Fire and Rescue Dept., Local
Authority, DOE, DOSH, etc.)

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8: CLOSING - ABANDONMENT AND
CLOSURE PLAN
• EMP will facilitate in terms of planning, monitoring, control and protecting the
environment as well as enforcement implementation by the DOE Malaysia.
• Should have provisions for adjustments and modifications if necessary due to future
change in requirements, as yet unanticipated.

• In a particular case where the project proponent intends to abandon a

project whether it is in the construction stage or after it has started
operation, an abandonment and closure plan shall be prepared.

• Decommissioning and closure plan is especially relevant to extractive

industries such as minerals mining and oil and gas exploration and
extraction.

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Scenario Planning for Environmental Management

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6.2. ISO 14001 –
ENVIRONMENTAL
MANAGEMENT
ENVIRONMENTAL
POLICY
• ISO 14001 defines criteria for an EMS.
• It does not state requirements for environmental
performance but rather maps out a framework that a
company or organization can follow to set up an
effective EMS.
• It can be used by any organization that wants to
improve resource efficiency, reduce waste, and reduce
costs.
• Using ISO 14001 can provide assurance to company
management and employees as well as external
stakeholders that environmental impact is being
measured and improved.
• ISO 14001 can also be integrated with other
management functions and assists companies in
meeting their environmental and economic goals.
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ISO 14001:2015
• ISO 14001:2015 – 3rd edition revised in 2015.
• Generic management system standard, meaning that it is relevant to any organization
seeking to improve and manage resources more effectively. This includes:

✓ single-site to large multi-national companies

✓ high-risk companies to low-risk service organizations
✓ the manufacturing, process, and service industries, including local governments
✓ all industry sectors, including public and private sectors
✓ original equipment manufacturers and their suppliers

• The basic principles of ISO 14001 are based

on the well-known Plan-Do-Check-Act
(PDCA) cycle.
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PLANNING AN EMS
Establish objectives and processes required

• Initial review or gap analysis of the organization's processes and products is

recommended, to assist in identifying all elements of the current operation, and if
possible, future operations, that may interact with the environment, termed
"environmental aspects".
• Environmental aspects can include both direct, such as those used during
manufacturing, and indirect, such as raw materials.
• This review assists the organization in establishing their environmental objectives,
goals, and targets (which should ideally be measurable); helps with the development
of control and management procedures and processes; and serves to highlight any
relevant legal requirement, which can then be built into the policy.

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IMPLEMENTATION AND
OPERATION
• During this stage, the organization identifies the resources required and works out those
members of the organization responsible for the EMS' implementation and control.
• This includes establishing procedures and processes, although only one documented
procedure is specifically related to operational control.
• Other procedures are required to foster better management control over elements such as
documentation control, emergency preparedness and response, and the education of
employees, to ensure that they can competently implement the necessary processes and
record results.
• Communication and participation across all levels of the organization, especially top
management, is a vital part of the implementation phase, with the effectiveness of the EMS
being dependent on active involvement from all employees.

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CHECKING AND CORRECTIVE
ACTION
• During the "check" stage, performance is monitored and periodically measured to
ensure that the organization's environmental targets and objectives are being met.
• In addition, internal audits are conducted at planned intervals to ascertain whether
the EMS meets the user's expectations and whether the processes and procedures
are being adequately maintained and monitored.

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MANAGEMENT REVIEW

• After the checking stage, a management review is conducted to ensure that the
objectives of the EMS are being met, the extent to which they are being met, and
that communications are being appropriately managed.
• Additionally, the review evaluates changing circumstances, such as legal
requirements, in order to make recommendations for further improvement of the
system.
• These recommendations are incorporated through continual improvement: plans are
renewed, or new plans are made, and the EMS moves forward.

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CONTINUAL IMPROVEMENT
PROCESS (CI)
• ISO 14001 encourages a company to continually improve its environmental
performance.
• Apart from the obvious – the reduction in actual and possible negative
environmental impacts can be achieved in three ways:
• Expansion: Business areas increasingly get covered by the implemented EMS.
• Enrichment: Activities, products, processes, emissions, resources, etc. increasingly get managed
by the implemented EMS.
• Upgrading: The structural and organizational framework of the EMS, as well as an accumulation
of knowledge in dealing with business-environmental issues, is improved.
• Overall, the CI concept expects the organization to gradually move away from merely
operational environmental measures towards a more strategic approach on how to
deal with environmental challenges.
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Sample Footer Text 2/7/20XX 55
ISO 14001 - Environmental Management System 🌱

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6.3. MONITORING
PLAN

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MONITORING PLAN
PERFORMANCE
MONITORING (PM)
• Description of performance
monitoring (PM) program for
all pollution prevention and
mitigation measures (P2M2)
proposed for the project.
• A tabulation of relevant PM
parameters, recommended
limits, monitoring locations
and frequencies, and
instrumentation and personnel
required shall also be
discussed.
COMPLIANCE
MONITORING (CM)
• A description of compliance
monitoring (CM) program for
all pollution prevention and
mitigation measures (P2M2)
shall be included in this
subchapter.
• A tabulation of relevant CM
parameters, discharge or
emission standard, monitoring
locations and frequencies, and
instrumentation and personnel
required shall also be
presented.
IMPACT MONITORING (IM)
• The requirement on impact monitoring
(IM) shall be evaluated on a case-to-case
basis.
• The general consideration is that IM is
required only in cases where pollution
prevention and mitigation measures
(P2M2s) conforming to the category of
best available technologies (BATs) cannot
be clearly identified or there exist
uncertainties in the long-term impact to
the receptors.
• If IM is required, a description of the IM
program, monitoring parameters,
monitoring locations and frequencies
shall be described.
• A discussion of how long the IM program
will be carried out, instrumentation and
personnel required shall also be
presented. 58
ENVIRONMENTAL MONITORING

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PRINCIPLES
(extracted from ISO 19011:2002)
OF AUDITING
An environmental audit is a type of evaluation intended to identify environmental
compliance and management system implementation gaps, along with related
corrective actions.

• There are five (5) main principles of environmental auditing:

1. Ethical conduct: the foundation of professionalism Trust, integrity,

confidentiality and discretion are essential to auditing.

2. Fair presentation: the obligation to report truthfully and accurately Audit

findings, audit conclusions and audit reports reflect truthfully and accurately
the audit objectives. Significant obstacles encountered during the audit and
unresolved diverging opinions between the audit team and the auditee are
reported. 60
PRINCIPLES OF AUDITING

3. Due Professional Care: the application of diligence and judgement in auditing

Auditors exercise care in accordance with the importance of the task they
perform, and the confidence placed in them by audit clients and other interested
parties.
4. Independence: the basis for the impartiality of the audit and objectivity of the
audit conclusions. Auditors are independent of the activity being audited and are
free from bias and conflict of interest.
5. Evidence-based approach: Audit evidence is verifiable. The appropriate use of
sampling is closely related to the confidence that can be placed in the audit
conclusions.

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AUDIT PROCEDURES

1
• An environmental audit has three (3) main
Pre-Audit
phases:

2
On-Site
Audit

3
Post-Audit

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PRACTICAL ASPECTS OF AUDITING

Benefits of Conducting Environmental Audits

• Promotes self regulation
• Reduce burden of enforcement
• Ensures compliance with legislation
• Measures environmental performance
• Initiates a process of continuous improvement
• Improves relationships with interested parties

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COMPETENCY OF
ENVIRONMENTAL AUDITORS
A competent auditor:
• Registered under the Environmental Audit Registration Scheme
• Is qualified and experienced;
• Is unbiased and independent;
• Always abides by the good principles of auditing;
• Uses appropriate techniques and tools for auditing;
• Is always systematic and consistent;
• Can highlight noteworthy efforts and areas for improvement.

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SUMMARY OF EMP

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REGISTRATION OF
EIA CONSULTANT
1. Certified Environmental Professional in
EIA (CePEIA),
2. EIA CONSULTANT (CePEIA) – Min. 5 years
in environmental management, 5 EIA reports
approved.
3. SUBJECT CONSULTANT – must highly be
competent in the selected field, able to
perform detailed study which may include
modeling.
4. ASSISTANT CONSULTANT – 1 year in
environmental management.

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BENEFITS OF
EFFECTIVE EMPS
• Increase in environmental awareness of all parties
• Increase in training opportunities
• Consistent, regular monitoring
• Progressive action plans that respond dynamically
to change
• Opportunity to document changes and update
approaches as necessary

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 EMP – THE
CHALLENGES
• Regardless of the EIA’s findings, the challenge is
to adopt techniques into the EIA process that
enables economic, social, and natural resource and
environmental objectives to be satisfied; helping to
identify development projects which are consistent
with, and which facilitate environmental objectives
and strategies.
• The quality of EIA reports in Malaysia depends on
the quality and experience of the EIA consultants.

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EMERGING THE
CHALLENGES
• New challenges imposed by globalization
• Environmental impacts becoming larger, more
complex
• Increasing difficult to predict and mitigate
• Higher in Public Expectation

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THANK YOU!
Dr. Norhusna Mohamad Nor
Centre of Chemical Engineering
UiTM Cawangan Pulau Pinang

+6016-441 6151
norhusna8711@uitm.edu.my

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