ED2 Sample

Assignment 00072987 RV August 2020
NEBOSH International Diploma

in Environmental Management
Unit IDEM2: Environmental Regulation
[Author name]
[Date]
0
Table of Contents
1. Executive Summary............................................................................................................................ 2
2. Introduction.......................................................................................................................................... 3
2.1. Aims and objectives................................................................................................................... 3
2.2. Scope............................................................................................................................................. 3
2.3. Project Overview.......................................................................................................................... 4
2.4. Methodology................................................................................................................................. 6
2.5. Legal Framework......................................................................................................................... 8
3. Review and Critical Analysis of the Environmental Management System..........................13
3.1. Environmental leadership........................................................................................................ 13
3.2. Environmental objectives and targets.................................................................................. 13
3.3. Identification of significant aspects and associated impacts.........................................14
3.4. Compliance obligations........................................................................................................... 16
3.5. Resource, competence and worker awareness................................................................. 17
3.6. Communication.......................................................................................................................... 18
3.7. The effectiveness of controls................................................................................................. 19
3.8. Environmental performance evaluation............................................................................... 21
4. Evaluation of improvements required.......................................................................................... 24
4.1. Prioritisation of observations for further evaluation of improvement..........................24
4.2. Area of improvement 1 – Identification of significant aspects and impacts...............26
4.3. Area of improvement 2 – Compliance obligations............................................................. 29
4.4. Area of improvement 3 – Effectiveness of controls.......................................................... 31
5. Financial Justification...................................................................................................................... 33
5.1. Principle of cost benefit analysis (CBA)............................................................................... 33
6. Conclusions and Recommendations............................................................................................ 35
Bibliography................................................................................................................................................... 37
1
1. Executive Summary
The Health Safety and Environmental Integrated Management System (HSE IMS) of Boom
Construction Company was certified with the ISO 45001:2018 and ISO 14001:2015
accreditations in April 2020. The systems were found to meet the requirements of the
standards without any major concerns. This report considered various aspects of the
environmental management system implemented in BCC’s central Doha and Corniche
Beautification Project- Package 3 and identifies areas with an opportunity for improvement.
The assessment concentrated on the project’s Environmental Management System
arrangements to meet with the ISO 14001: 2015 Standard requirements and compliance
with relevant national and international environmental regulatory requirements the
organisation has subscribed to. The assessment also used the opportunity to assess the
implementation of environmental management system in the project as identify areas
where improvement can enhance the environmental performance of the project and achieve
organization’s environmental goals
The assessment process provides confidence that the EMS are reliable and shows capability
to identify opportunities for improvement, implement controls and achieve improvements. The
commitment from top management and line managers has helped to improve and to maintain
the systems effectively and reviewed needs for improvement and resources. The gap analysis
conducted on the EMS indicated overall compliance with the ISO 14001:2015 management
system model. However, serious gaps were towards of ISO 14001:2015, including the
identification of significant aspects and impact arising from the project operations as well
failures in compliance to regulatory obligations. The current risk and opportunities procedure
and register was found inadequate as it failed to address some of the environmental aspects
and impacts were not assessed for risk and opportunities. The procedure for environmental
compliance obligations and the effectiveness of implementation was found not meeting with
the requirements of ISO 14001:2015 leading to serious lapses. These gaps in the
assessment of risk and opportunities for environmental aspects could seriously diminish
the environmental performance and affect business decisions.
The lack of arrangement of designated storage area for hazardous waste at the project
laydown area is a direct breach of several local and international compliance obligation and
also serious deviation from established EMS control procedures It is quite alarming to find
that the hazardous chemicals exposed to environmental elements can lead to severe
environmental contamination as well as potential cause for fire and subsequent
environmental damage. The resulting direct and indirect financial losses could be reaching six
figure marks. It is essential to consider the implementation of action recommended for the
construction, staffing and operation of designated waste storage area and timely disposal of
the waste generated.
The finance the organisation has to recourse to facilitate the recommendations of this report
amounts a little over QR140,000 with QR 40,000 on the realization of recommendations
suggested to close gaps identified in the Environmental Management system and QR 100,000
to facilitate the recommendations to construct the hazardous waste storage area to
recommended standards. The investment of AED 145,000 is very reasonable considering the
estimated benefits of QR 600,000 assured in a long run. The recommendations suggested in
this report are with the intention to fill the gaps in the EMS in its compliance towards the ISO
14001:2015 and all applicable regulatory and other compliance obligations. The benefits
include effective business decisions, the fulfilment of compliance towards regulatory
obligations and ISO 14001-2015 requirements and continual improvement of EMS
performance.
2. Introduction
The principal goal of completing the assessment is to review and critically analysis the
Project’s Environmental Management System (EMS) and Construction Environment
Management Plan (CEMP). Evaluate whether the activities, products, and services within
the scope of project operations are conducted in compliance with the applicable local
and international legal requirements, approved project EMS & CEMP, ISO 14001:2015
standards and other requirements as deemed. The gasps identified in the EMS with be
subjected to evaluation for improvement and propose actions for improvement with financial
justification. The final report shall provide the management insight on the issue that require
attention and the benefits this has on the project’s environmental performance
2.1. Aims and objectives
The aim of this assignment was to review of the EMS arrangements for CDCB project sites
and evaluate compliance to identify gaps and propose recommendations for improvement. To
this end, the objectives are to:
▪ Evaluate project EMS and CEMP by referring to the assignment criteria;
▪ Establish gaps with respect to Project EMS and CEMP, ISO 14001-2015, applicable legal
and other requirements;
▪ Identifying a suitable workplace in the project where compliance assessment on EMS
implementation can be assessed;
▪ Critically analysis of gaps identified in the EMS and determine the top three areas for
detailed evaluation;
▪ Propose an action plan based on SMART principle to achieve the recommended
improvements;
▪ Conduct cost-benefit analysis to establish financial justification for the improvements
recommended;
▪ Summaries and conclude with the findings that requires attention and propose
recommendations and a plan to action them in a timely manner.
▪ Complete the assignment report with a brief and precise executive summary which will
provide the management with an outlook on current EMS performance and how
improvements can deliver benefits.
2.2. Scope
The scope of this assignment covers the assessment of Environmental Management System
arrangements for the CDCB Project operations. The following key elements of the EMS were
critically reviewed
▪ Leadership and commitment from the top management on environmental issues;

▪ Environmental objectives and targets for the project;
▪ Significant aspects and associated impacts associated with project operations are
identified;
▪ Level of compliance to Project EMS requirements, ISO 14001:2015 Standards, Legal and
other requirements;
▪ Arrangement of resources; access to competent advice and employee awareness on
environmental control plans;
▪ Communication plan- internal and external;
▪ Environment control procedures and its effectiveness;
▪ Evaluation of project environmental performance;
2.3. Project Overview
Central Doha and Corniche Beautification Project- Package
Project Name 3
CDCBP- 3
Country Qatar
Industry Road and Infrastructure
Contractor BCC
Consultant ITALCONSULT QATAR
Client Public Works Authority (ASHGHAL)
Estimated Project Value USD 200 Million
Project Duration 660 days
Project layout map
2.3.1. Project Scope

Doha Central Development and Beautification Projects Package 3 Project aims to develop the
areas around Grand Hamad Street, through developing and beautifying main streets and
internal neighborhoods in these areas to provide increased mobility for road users and
pedestrians and upgradation utility and drainage networks and landscape.
The Project Includes 10.2 km of surface water drainage network; 11.2 km of foul sewer
drainage network; 4.7 km of underground electricity network; Installation of 515 lightening
poles; Planting
about 3250 trees and about 30,000 square meters of green areas and construction of 35.3 km
long pedestrian and cycling paths
2.3.2. Project Layout
The CDCBP- 3 essentially consists of 2 offices blocks; one for the contractor and the other for
consultant and client representatives. Both two storied building with approximately 1500
square meters of area with all the offices, training rooms, first aid unit, eating and drinking
facilities etc.
The construction works are carried out at various location at the site as shown in the project
layout map, the project also has a laydown which accommodates the stores, material stock
pile, workshops and workers welfare facilities
2.3.3. Project Management

The project director heads operations for the entire project with the project Manager directly
reporting to him. The Project Manager is directly responsible for the management of the
project deliverables with his team of department managers, engineers, supervisors and
workmen.
The Environmental Department for the project is administered by the Environment Manager,
assisted by an Environmental Engineer assigned to monitor compliance to the approved EMS
and CEMP.
Project organogram is defined, documented and communicated as appropriate
2.3.4. Employment profile

The project employs local and foreign workers with the majority of them descend from Middle
East and South Asia. The registered manpower at the time of preparation of the assignment
is as given below
Total Manpower 878

Supervision Staff 81
Site Operatives/ Workers 797
2.3.5. Work Pattern
The project works from Saturday through Thursday with Friday holiday, thus a total of six work
days in a week with a maximum of 48 working hours per week. The project operates in both
day and night with 10 hours in each shift including 2 hours of break time. Extended workhours
can be up to a maximum of 2 hours per day, which is paid with over time rates.
2.4. Methodology
2.4.1. Research
The research stage included the review of available internal and external resources on the
EMS and made use of the information gathered to evaluate compliance to environmental
arrangements and identify gaps. These include but not limited to
▪ ISO 14001: 2015 Environmental Management System;

▪ Environmental Protection Law No. 30 of 2002 (Qatar)
▪ Flora of the State of Qatar (Ekhlas M.M. Abdel Bari 2012)
▪ General Secretariat for Development Planning (2008), Qatar National Vision 2030, July
2008
▪ Ministry of Municipality and Environment, 2014. Qatar National Biodiversity Strategy
2015-2025.
▪ Qatar National Development Strategy (NDS) 2018 - 2022
▪ Qatar construction specifications 2014
▪ Air Quality Guidelines (WHO, 2005)
▪ Construction Dewatering Guidelines by PWA, March 2014
▪ Client requirements
▪ Environmental Permit (Ref. No. 2019/300694) November 2019.
▪ Central Doha and Corniche Beautification CP03, Environmental Impact Assessment
(EIA), CDB-P3-PIL-EN-RPT-00002-D00, March 2020 (Parsons)
▪ Client requirements
▪ Qatar Municipalities by MMUP, 2004
▪ Qatar Statistics Authority, 2013
▪ The Climate of the State of Qatar, QP 2011
▪ Environmental best practices
▪ Approved codes of practices
▪ International Environmental Standards
▪ Law No (14) of the year 2004, Qatar Labor Law;
▪ IEMA
▪ IIRSM;
▪ HSE (UK).
2.4.2. Review of documents and records
A thorough review of EMS documents and records were carried out to check the available of
required documents and properly maintained as specified in the standards. Also, to evaluate
the effectiveness of EMS procedures, control plans and operational procedures on the
project’s environmental performance, this include but not limited to
▪ Environmental Policies and ▪ Project CEMP,
Objectives;
▪ HSE Integrated Management
System Manual and Procedures
▪ EMS Procedures
▪ EMS Control Plans
▪ EMS Operational Procedures
▪ Aspect and Impact assessments
▪ EMS Legal Register;
▪ Induction trainings; ▪ Previous Audit reports
▪ HSE training matrix, schedule and ▪ Nonconformance reports
records; ▪ Incident Reports &
▪ Competency records ▪ Investigation Reports
▪ Internal and External Permits; ▪ Waste Management reports
▪ Monthly Environmental Statistics ▪ Environmental Monitoring records
and Key Performance Indicators; ▪ Energy consumption records
▪ Aspect and impact register ▪ Risk & Opportunities register
▪ Compliance Evaluation Records ▪ Meeting Minutes
▪ Environmental Inspection Reports ▪ Emergency Drill records
2.4.3. Interviews
Interviews were conducted for
employees at all level to determine
their understanding on EMS
requirements this included direct staff,
contractors, management
representatives.
Interviews and document review was
carried out on the 17th July 2020.
2.4.4. Direct observation
A joint site visit was conducted with the
project environmental engineer on the
18th July 2020, to evaluate and record
the status of implementation of applicable
EMS arrangements at each work places
and to interact with site operatives and
workmen. The locations inspected are
1) Project Office
2) Construction Sites
3) Stock pile area
4) Project Stores
5) Waste storage area
2.4.5. EMS Gap analysis and
compliance verification
In the first part the EMS for the
project, which is modeled on the
requirements of the ISO 14001:2015
Standards, and applicable compliance
obligations have been critically reviewed
to identify areas of gaps and no
gaps and the second part focused on
the verification of compliance to
existing environment control plans and
procedure; and the effectiveness of its
implementation. With focus given to the
requirements of elements in Section 3:
Review and Critical Analysis of the
Environmental Management System
2.4.6. Prioritisation of
improvement
The prioritisation of areas for
improvements is carried out by
considering the impact of such
aspects and subsequent
consequences if the current status
is to be continued. Based on this
assessment, improvements were
prioritised as Low, Medium and
High.
Low: These are largely acceptable,
subject to reviews periodically;
Medium: Action should be planned
and introduced within a defined time
period.
High: Immediate action is required
as the risk level is high.
Implementation plans were further
developed and incorporated with this
report.
2.4.7. Presentation of assignment
report
The format used for presenting the
report is a combination of text, tables
and graphs to make it simple and easy
for the reader to view and understand.
Tables were used to convey focused
information or comparison of data is
required and graphical representation
were used to convey large amount of
information at a glance.
2.5. Legal Framework
2.5.1. Introduction
The regulation of environmental in the State of Qatar is in accordance with the laws and
regulations of the State of Qatar and the various International or regional protocols and
agreements to which the State of Qatar is a signatory. A comprehensive review of these laws
and regulations was carried out to ensure that the proposed project is executed in an
environmentally benign manner.
2.5.2. Authorities
By virtue of Law No. 16 / 2014, which states the responsibility of each ministry in Qatar,
Ministry of Municipality and Environment (MME) is the authority responsible for managing
and protecting the environment in the State of Qatar.
2.5.3. National Polices and Legislation

Clause/Regulation Article/Chapter Reason for implementation
Law No. 14 of 2004 Article (23) Implemented in line with Boom Construction
Qatar Labour Law Company (BCC) recruitment policy
Law No. 14 of 2004 Qatar Article (99) Health, Safety and Environment (HSE) induction is
Labour Law being conducted for new staff and workers
Law No. 14 of 2004 Qatar Article (100)
Implemented in line with the project CEMP
Labour Law
Law No. 14 of 2004 Qatar Article (103)
Labour Law
Law No. 30 of 2002, The
Article (9) Implemented in line with habitat preservation plan
Environmental Protection Law
(Ref. No. BCC-EMS-ECP-05-Rev.00)
Implemented in line with procedure for
identification of environmental aspects and its
Law No. 30 of 2002, The environmental impacts (Ref. No. BCC-EMS-SP-
Article (16)
Environmental Protection Law 02-Rev.00).
Implemented in line with procedure for action to
address risks and opportunities (Ref. No. BCC-
EMS-SP-01-Rev.00).
Implemented in line with generic environmental
Article (20) management plan (EMP), the generic construction
Environmental Protection Law
environmental management plan (CEMP) and/or
the health, safety and environmental (HSE) plan.
Shipment of hazardous waste is not applicable to
Boom construction company (BCC) workplace
activities. However, waste generated during the
activities of BCC in each workplace is managed in
Environmental Protection Law Article (24)
line with Solid Waste Management and Control
(Hazardous Wastes and
Plan (Ref. No. BCC-EMS-ECP-03-Rev.00), the
Substances)
Wastewater Control Plan (Ref. No. BCC-EMS-
ECP-04-Rev.00) and the procedure for hazardous
substance (Ref. No. BCC-EMS-OP-03-Rev.00)
MME issued CTO permit and transportation permit
is available for the hazardous generated from BCC
workplace activities which is being sent for
(Hazardous Wastes and
treatment in Boom Waste Treatment Company
Substances)
(BWTC) facility.
MME permit issued and its conditions is being
implemented in applicable BCC workplace. Air and
noise monitoring is being implemented in line with
(Protection of the Air
the environmental monitoring procedure (Ref. No.
Environment from Pollution)
BCC-EMS-OP-22-Rev.00) and mitigated with the
implementation of the Air quality and Dust control
plan (Ref. No. BCC-EMS-ECP-01-Rev.00) and
Noise and Vibration Control Plan (Ref. No. BCC-
EMS-ECP-02-Rev.00).

Environmental Protection Article (31) Implemented in line with Air quality and dust
Law (Protection of the Air control plan (Ref. No. BCC-EMS-ECP-01-Rev.00)
Biological
Diversity: Implemented in line with habitat preservation plan
Law No. 19 of 2004
Federal/Royal (Ref. No. BCC-EMS-ECP-05-Rev.00)
Decree/National
Radiation/Radio
Implemented in line with the procedure for
active Materials:
Law no. 31 of 2002 hazardous substance (Ref. No. BCC-EMS-OP-03-
Federal/Royal
Rev.00)
Decree/National
Archaeology: Implemented in line with generic environmental
Law No. 2 of 1980 on
Federal/Royal management plan (EMP), the generic construction
Antiquities- State of Qatar
Decree/National environmental management plan (CEMP)
Implemented in line with the Solid waste
Environmental Protection Article (32)
management and control plan (Ref. No. BCC-
Law (Protection of the Air
EMS-ECP-03-Rev.00)
Law No. 30 of 2002, The Implemented in line with generic environmental
Environmental Protection Article (39) management plan (EMP), the generic construction
Law (Protection of the Air environmental management plan (CEMP) and/or
Environment from Pollution) the health, safety and environmental (HSE) plan.
Law No. 4 of 2005 –
General: Local Implemented in the Project contract requirements
Executive By Laws- for the
Law/Ministerial and incorporated in applicable projects CEMP.
Environmental Protection
Order Refer to BCC generic CEMP.
Law (Law No. 30 for 2002)
Endangered
Law No. 5 of 2006 to regulate
Species: Implemented in line with habitat preservation plan
trade of endangered species
Federal/Royal (Ref. No. BCC-EMS-ECP-05-Rev.00)
and their products
Decree/National
Law No. 21 of 2007
Air Pollution: Implemented in line with the procedure for
Regarding the Control of
federal/Royal hazardous substance (Ref. No. BCC-EMS-OP-03-
Substances Depleting the
Decree/National Rev.00)
Ozone Layer
Implemented in line with habitat preservation plan
Law No. 32 of 1995
(Ref. No. BCC-EMS-ECP-05-Rev.00), the Solid
“Regarding Prevention of Flora: Local
waste management and control plan (Ref. No.
Damaging Plant Law/Ministerial
BCC-EMS-ECP-03-Rev.00) and procedure for
Environment and Its Order
flora and fauna management (Ref. No. BCC-EMS-
Contents
OP-15-Rev.00)
Law No. 4 of 2005 Executive
Waste: Local management and control plan (Ref. No. BCC-
by Laws of the Environmental
Law/Ministerial EMS-ECP-03-Rev.00) and the procedure for
Protection Law of 2002
Order waste management and recycling (Ref. No. BCC-
EMS-OP-01-Rev.00)
Law No. 4 of 2005 Executive Hazardous
EMS-ECP-03-Rev.00), the Chemical and
by Laws of the Environmental Waste: Local
hazardous material control plan (Ref. No. BCC-
Protection Law of 2002 Law/Ministerial
EMS-ECP-07-Rev.00) and the procedure for
Order
waste management and recycling (Ref. No. BCC-
EMS-OP-01-Rev.00)
EMS-ECP-03-Rev.00), the procedure for waste
Environmental Protection Article (41)
management and recycling (Ref. No. BCC-EMS-
Law (Protection of Ground
OP-01-Rev.00) and the procedure for surface
and Surface water)
water and drainage management (Ref. No. BCC-
EMS-OP-14-Rev.00)
Civil Defense Law No. 9 of Fire Safety
2012 Handbook
CDD (Civil Defense Fire Safety
Department) Handbook
Implemented in line with the BCC generic CEMP,
Emiri Decree No. 30 (2002) General:
the environmental control plans and the
The Environmental Federal/Royal
environmental systems and operational
Protection Law Decree/National
procedures.
Implemented in line with habitat preservation plan
Emiri Decree No. 4 of 2002 (Ref. No. BCC-EMS-ECP-05-Rev.00), the Solid
Hunting:
“Organization of Wild waste management and control plan (Ref. No.
Federal/ Royal
Animals, Birds and Reptiles BCC-EMS-ECP-03-Rev.00) and procedure for
Decree/National
Hunting” flora and fauna management (Ref. No. BCC-EMS-
OP-15-Rev.00)
Implemented in line with the environmental
Law No. 18 OF 2017 Public Hygiene cleaning and rehabilitation plan (Rev. No. BCC-
EMS-ECP-09-Rev.00)
Waste: Implemented in line with the environmental
Emiri Decree No. 20 of 1995 Federal/Royal cleaning and rehabilitation plan (Rev. No. BCC-
Decree/National EMS-ECP-09-Rev.00)
Waste: EMS-ECP-03-Rev.00), the procedure for waste
Emiri Decree No. 8 (1974)
Federal/Royal management and recycling (Ref. No. BCC-EMS-
“General Cleanliness Law”
Decree/National OP-01-Rev.00) and the environmental cleaning
and rehabilitation plan (Rev. No. BCC-EMS-ECP-
09-Rev.00)
Emiri Decree No. 16 (2009) Institutional:
Determining Ministries Federal/Royal Noted in line with BCC generic CEMP and ECP.
Specialties Decree/National
The General Environmental General:
Law of the Gulf Cooperation Regional Noted in line with BCC generic CEMP and ECP.
Council of 09/05/2000 Convention
State of Qatar Environmental
Protection Standards (Law Ambient Air Implemented in line with Air quality and dust
No. 4 of 2005) – Annex 3 Quality Criteria control plan (Ref. No. BCC-EMS-ECP-01-Rev.00)
(First)
Implemented in line with the procedure for control
of contamination of water resources (Ref. No.
State of Qatar Environmental Wastes and
BCC-EMS-OP-12-Rev.00), procedure for
Protection Standards (Law Hazardous
contaminated land management (Ref. No. BCC-
No. 4 of 2005) – Chapter 4 Materials
EMS-OP-13-Rev.00), and the Wastewater control
plan (Ref. No. BCC-EMS-ECP-04-Rev.00) and
State of Qatar Environmental Implemented in line with noise and vibration
Protection Standards (Law control plan (Ref. No. BCC-EMS-ECP-02-Rev.00)
Noise
No. 4 of 2005) – Annex 3 and the environmental monitoring procedure (Ref.
(Fifth) No. BCC-EMS-OP-22-Rev.00)
Section 11
Part 1.01
QCS 2014 Implemented in line with the project CEMP
(1.1.2.4),
(1.1.2.6),(1.1.5),
(1.1.9), (1.1.7)
10
Section 11
QCS 2014 BCC health, safety and environment policy
Part 1.01 (1.1.3)
Implemented in line with the project CEMP and the
Section 11
QCS 2014 traffic management plan (Ref. No. BCC-EMS-
Part 1.01(1.1.10)
ECP-08-Rev.00)
Section 11 Implemented in line with Air quality and dust
QCS 2014
Part 1.02(1.2.9) control plan (Ref. No. BCC-EMS-ECP-01-Rev.00)
Implemented in line with noise and vibration
Section 11 control plan (Ref. No. BCC-EMS-ECP-02-Rev.00)
QCS 2014
Part 1.02(1.2.13) and the environmental monitoring procedure (Ref.
No. BCC-EMS-OP-22-Rev.00)
Section 11
QCS 2014 hazardous substance (Ref. No. BCC-EMS-OP-03-
Part 2.3.02
Rev.00)
Section 11
Part 1.01
Implemented in line with noise and vibration
Section 11 control plan (Ref. No. BCC-EMS-ECP-02-Rev.00)
QCS 2014
Part 1.02(1.2.10) and the environmental monitoring procedure (Ref.
No. BCC-EMS-OP-22-Rev.00)
Section 11
Part 1.04(1.4.6)
Implemented in line with Site electricity operations
Section 11 plan (Ref. No. BCC-EMS-ECP-11-Rev.00) and
QCS 2014
Part 1.05(1.5.3) procedure for energy management (Ref. No. BCC-
EMS-OP-05-Rev.00)
Section 11
Part 10.2.5
Section 11
Part 1.2.2
environmental emergency preparedness and
Section 01
QCS 2014 response (Ref. No. BCC-EMS-SP-04-Rev.00) and
Part 10(10.3)
environmental emergency response plan (Ref. No.
BCC-EMS-ECP-12-Rev.00)
Implemented in line with the environmental
Section 11
QCS 2014 incident response plan (Ref. No. BCC-EMS-ECP-
Part 1.06(1.6.2)
11-Rev.00)
environmental emergency preparedness and
Section 11
QCS 2014 response (Ref. No. BCC-EMS-SP-04-Rev.00) and
Part 1.06(1.7.1)
environmental emergency response plan (Ref. No.
BCC-EMS-ECP-12-Rev.00)
Implemented in line with procedure for
identification of environmental aspects and its
environmental impacts (Ref. No. BCC-EMS-SP-
Section 11
QCS 2014 02-Rev.00).
Part 2.4.01
Implemented in line with procedure for action to
address risks and opportunities (Ref. No. BCC-
EMS-SP-01-Rev.00).
Section 01
Part 16(16.1.2)
ECP-08-Rev.00)
Section 01
Part 16(16.1.3)
ECP-08-Rev.00)
1
2.5.4. International Conventions and Agreements
Development projects similar to the current subject project must not violate the conditions of
any international or regional convention to which Qatar is a signatory. The State of Qatar is a
party to some international conventions.,those which are of most relevance to this project are
listed below:
1. 1972 Convention concerning the protection of the World's Cultural and Natural Heritage
(UNESCO);
2. 1985 The convention for the protection of the Ozone layer (Vienna Convention);
3. 1989 Basel Convention on the Control of Trans boundary Movements of Hazardous
Wastes and their Disposal;
4. 1991 The Arab Declaration on Environment and Development;
5. 1992 Agenda 21 and the Rio Declaration on Environment and Development;
6. 1993 Convention on Biological Diversity (Rio de Janeiro);
7. 1999 International Agreement to Combat (CCD) in Countries Suffering from Bad Drought
or Desertification, particularly in Africa;
8. 2001 Convention on International Trade in Endangered Species of Wild Fauna and Flora
(CITES), accessed by the State of Qatar on 8th May 2001 which became a Party to
CITES on 6th August 2001;
9. 2003 Convention on the Conservation of Wildlife and Natural Habitats in the Countries of
the Gulf Cooperation Council, (GCC, 2003); and
10. 2005 Kyoto Protocol (accessed by Qatar on 11th January 2005).
2.5.5. Applicable general standards for all project components
1. Qatar Construction Specifications (QCS), 2014;
2. Transportation Master Plan for Qatar (TMPQ), 2008;
3. Guidance to Planning Roads in Qatar; and
4. MME Typical Cross Section and Utility Corridors, January 2012.
5. The Global Sustainability Assessment System (GSAS) and the Qatar Sustainability
Assessment System (QSAS).
3. Review and Critical Analysis of the Environmental Management System
3.1. Environmental leadership
The organisation has established a procedure to define environmental leadership at all levels.
The leaders shall monitor and ensure compliance of the projects EMS, legislative, regulatory
and other requirements. The procedure requires the leaders to ensure that any required
changes to ensure compliance to environmental requirements are implemented.
Demonstration of top management commitment to has been witnessed with a well-established
Environmental Policy document is maintained, reviewed and communicated to employees at all
levels. The policy statement was displayed at prominent location and accessible for staff
through company intranet and others through company website
The Chief operating officer has been assigned as the environmental champion responsible for
promoting positive environmental culture in the organisation; Emails, circulars and Minutes of
board meetings were witnessed confirming top management representative commitment to
environmental issues.
The EMS and Project CEMP clearly defines roles and responsibility for environmental leaders
at all levels of the organisation. The project organisation chart and HSE organisation chart were
found displayed at notice boards and in project CEMP. The roles and responsibilities and
including reporting hierarchy has been found addressed in section 5.3 of the CEMP in order to
meet the system and project management requirements.
The site execution team at different levels discuss various environmental topics and retains
documented information, this include pre-task briefings, HSE Meetings, campaigns etc. The
Project Director addresses environmental related issues during the monthly HSE meetings and
records of which are witnessed.
The policy shows commitment from top management to comply with relevant environmental
legislations, regulations and other requirements including an intent for continual improvement of
environmental performance. Records of environmental compliance reports were generated on
monthly basis reviewed by management is witnessed.
The organisation established a detailed procedure to identify and manage environmental risk
and opportunities register addressing those aspects arising from the project operation which
has an effect on the environmental performance of the project.
The project Environmental engineer generates Monthly EMS statistics and compliance
assessment records and report top management on or before 5th day of every month. The
corporate Environmental Manager, COO and CEO reviewed these reports and subsequent
direction given as required. EMS communication procedure and evidence of two-way
communication was witnessed during the assignment
3.1.1. Summary Findings
1. Positives:
1) Management System has clear procedure to define Environmental Leadership at all levels
of the organisation and their roles and accountability towards compliance obligations
2) Clear visibility of top management commitment towards environmental issues
3) Compliance to
▪ HSE Leadership Procedure- BCC-HSE-IMS-SP-05-Rev-00
▪ Clause 5.1 of ISO 14001: 2015, Leadership and commitment
3.2. Environmental objectives and targets
The organisation has procedure in place to identify, prioritize and establish the environmental
objectives and several plans to achieve them; consistent to the environmental policy. The
corporate HSE policy provides the framework for setting out project specific environmental
objectives and targets. Corporate level environmental objectives and targets were identified
and communicated to all relevant personnel (Documents and records witnessed)
Environmental objectives and targets with key performance indicators are established both
(leading and lagging) set to continuously monitor and evaluate achievement of objective and
targets and decide on actions, when required, however a plan to achieve project specific
objectives and targets were not presented during the assessment.
Communication of environmental objectives and targets including the leading and lagging
indicators are communicated but with opportunities for improvement; monthly HSE review
meeting discuss progress of action to achieve objectives and targets
Positives:
1) EMS has procedure in place to establish, review and communicate environmental

objectives and targets
2) Project specific environmental objectives and targets were defined in line with corporate
objectives and targets
3) Leading and lagging indicators were defined to measure and monitor whether the
objectives and targets were achieved or need improvement
Improvement area:
1) The awareness of environmental policy, objectives and targets was poor among workmen
interviewed during site inspection
2) A plan to achieve and track progress of environmental objectives and targets in a timely
manner was not developed
3) Non-Compliance to
▪ Procedure for HSE Objectives and planning to achieve them, BCC-HSE-IMS-SP-04-
Rev-00
▪ Clause 6.2 of ISO 14001: 2015, Environmental objectives and planning to achieve
them
▪ Procedure for HSE Objectives and planning to achieve them, BCC-HSE-IMS-SP-04-
Rev-00
▪ Clause 6.2.1 of ISO 14001: 2015, Environmental objectives and planning to
achieve them
3.3. Identification of significant aspects and associated impacts
The Project CEMP has established a detailed procedure for identify and record and update
environmental aspects and impacts, which is in line with company EMS procedure. The
procedure defines screening of aspects and impacts and how information is made available to
the management to make decisions.
Environmental Aspect Impact register and Risk and opportunities register was found in place.
The Aspect impact register addressed most of the significates aspects and impacts arising from
the project activities under normal, abnormal and emergency conditions. In the development of
the aspects, impacts and risk register, the quantity, frequency, control level, legal, likelihood and
severity of the environmental impacts were considered to determine mitigation measures.
The Project has a number of potential environmental aspects which includes the following
environmental categories:
▪ Air pollutants; ▪ Water pollutants;
▪ Solid waste generation both ▪ Effluents;
hazardous and non-hazardous; ▪ Noise;
▪ Energy (Electricity) consumption; ▪ Dust emission;
▪ Water consumption; ▪ Terrestrial Ecology
▪ Fuel (diesel & petrol) consumption; ▪ Slurry generation
▪ Removal of flora; ▪ Paper use;
This EMS has procedure to ensure
relevant environmental risks and
opportunities are identified, assessed
and controlled within the project scope. A
risk and opportunity register were used to
identify the risk and opportunities with
respect the environmental impacts and
develop control measures to manage
them.
Risks
▪ Poor from
performance construction
of activities
▪ Purchase
Environmenta of
l non-recycled
management made
system and materials and
controls plans packaging
▪ Permit ▪ Fugitive dust
breaches emission (e.g.
and from
regulatory excavations,
non- grading, cut
compliance. and fill
▪ Poor activities,
management vehicle
of changes movement on
▪ Slurry unpaved
generation roads, storage
▪ Energy of stockpile
Consumption
(wastage)
▪ Waste
generation
(hazardous
and non-
hazardous)
▪ Damage to
flora
and
fauna
▪ Exhaust in the compliance
monitoring
▪ Business
emissions / workplace continuity
black ▪ Inappropriat ▪ Professiona
▪ Material
smoke from e storage of l, conservatio
construction and overflow highly n
machinery of skilled ▪ Reduce,
▪ Generation groundwater and Reuse and
of excess /wastewater motivated recycling of
concrete and site staff. waste
▪ Workers effluent. ▪ Environmen ▪ Procureme
exposure ▪ Leaks/spills tal nt,
from awareness delivery
of fuels
asphalt from ▪ Water and use
fumes storage and of
emission handling Energy sustainable
▪ Generation and materials
of noise disposal, conservatio ▪ Technologic
and refueling n methods al
and Advanceme
vibration
maintenance nts
from
of workplace
machinery These are Non-fulfillments of clause 6.1
plant,
and equipment – Action to address risks and
equipment and vehicles opportunities of ISO 14001-2015.
Risks and opportunities register is in

place however Environmental
implications of company’s significant
risks were not clearly recognized and
addressed in the register. Environmental
risks at the project site were addressed.
However Major risks that the business
faces from external issues, internal
issues compliance obligations, needs
and expectations of interested parties
not taken into consideration. Specific
risks arisen from breach of duty of care,
legal requirements and related direct
and indirect cost were not considered.
The risk and opportunity profile not
examined the nature and level of the
threats faced by company, the likelihood
of adverse effects occurring, the level of
disruption and costs associated with
each type of risk, the effectiveness of
controls in place to manage those risks.
More over the following current
opportunities not been addressed and
assessed in the existing risks and
opportunities register.
▪ Environme ntal
Positives:
1) Project CEMP has procedure in place to identify, record and communicated environmental
aspects and impacts; aspect/impact register available
Improvement area:
1) Environmental implications of company’s significant risks were not clearly recognized and
addressed in the register, hence Risks and Opportunities were not assessed; which has
serious impact on the project’s environmental performance and have the potential effects
on the organization’s business decisions
2) Non-Compliance to
▪ Procedure for action to address Risks and Opportunities, BCC-EMS-SP-01-Rev-00
▪ Procedure for identification of Environmental aspects and its Environmental Impacts,
BCC-EMS-SP-02-Rev-00
▪ Clause 6.1 of ISO 14001: 2015, Actions to address risks and opportunities
▪ Clause 6.1.2 of ISO 14001: 2015, Environmental aspects
3) Possible Breach of
▪ Law No. 30 of 2002, The Environmental Protection Law
▪ Law No. 4 of 2005 Executive by Laws of the Environmental Protection Law of 2002
▪ QCS 2014 Section 11, Part 2.4.01- Identification of environmental aspects and its
environmental impacts and procedure for action to address risks and opportunities
3.4. Compliance obligations
The EMS has a robust procedure for identifying and updating the legal and other requirements
applicable to the environmental aspects of the project. The procedure applies to environmental
aspects of offices, project site, laydown area, workers accommodation of BCC and its suppliers
and sub-contractors. The compliance obligation for the project are maintained as documented
information in the environmental compliance obligation register. (updated records witnessed)
The main compliance obligations and its application to project requirements are as extracted
from the project compliance obligation register as included in Section 2.5 Legal Framework
The risk and opportunities register addresses the organisation environmental compliance
obligations include but not limited to EMS compliance, regulatory compliance, Permit breaches
and regulatory non-compliance etc. and develop control plans as required. (inclusion of
compliance obligation in risk and opportunities register witnessed)
The Environmental department will refer information on legal and other requirements from
various sources to review and update the environmental compliance obligations that has impact
on the project’s operation. Compliance obligation register should be reviewed annually by the
environmental department and is updated when regulation changes require revisions
The project has established a compliance assessment program where the environmental
engineer conducts periodic evaluation of environmental legal and other requirements, including
a review of environmental records and a physical assessment of environmental conditions at
the workplace. however
During the inspection of external permit logs the MME permit for tree removals was expired, the
site inspection witnessed unauthorized removal of trees by contractor which is a clear violation
of environmental regulations, the permit for dewatering lagoon constructed in the site was also
found expired; the Environmental engineer responded that the renewal of permits is in process
and are experiencing technical delays. This indicates the compliance obligation procedure is
ineffective. Major violation of environmental and regulatory compliance
Positives:
1) The Project CEMP and EMS has procedure in place to identify, record and communicated
environmental compliance requirements; a permit tracker is used to this end.
(Excavation permits; haulage permits; hazardous and non-hazardous waste disposal
permits; dewatering permits; land lease permits and other permits were found available)
2) Legal register is maintained with applicable regulatory requirements identified for the
environmental aspects of project operations.
3) The environmental compliance assessment is carried out continuously through a variety of
inspection and assessments and report is generated on monthly basis.
4) The compliance assessment report is communicated to project management and top
management. (records witnessed)
Improvement area:
1) Some of the Environmental permits required as part of environmental compliance

obligations were found expired or not available during the assessment and the work within
the conditions of permits were found being carried out at site; this is a major violation of
compliance obligation and ineffectiveness of environmental compliance procedure and its
implementation
2) Non-Compliance of
▪ Environmental risks & opportunities procedure, BCC-EMS-SP-01-Rev-00
▪ Procedure for evaluation of compliance, BCC-HSE-IMS-SP-17:00
▪ Clause 6.1 of ISO 14001: 2015, Actions to address risks and opportunities
▪ Clause 6.1.3 of ISO 14001: 2015, Compliance obligations
3) Possible Breach of
▪ Executive order (by-law) for the Environmental Protection Law (Law No. 4 of 2005)
▪ Law No. 32 of 1995 “Regarding Prevention of Damaging Plant Environment and Its
Contents
▪ PWA’s Circular No.59/2019 with Respect to Environmental Permit Requirements
3.5. Resource, competence and worker awareness
The organisation has adequate resources to manage its environmental performance with
provision for environmental leaders assigned at all levels to provide competent advice. The
corporate level team includes HSE Director, Environmental Manager (Management Systems),
Sr. Environmental Engineer to advise to all projects sites including the one selected. The HSE
Director oversees the overall operation of the HSE department and the Environmental Manager
and Sr. Environmental Engineer regulate the implantation of EMS and provide adequate advice
in terms of ISO 14001-2015 Standard. The organisation has also access to external agencies
for environmental consultation, environmental monitoring and third-party trainings etc.
The Environmental Department for the project is administered by the Environment Manager,
assisted by an Environmental Engineer assigned to monitor compliance to the approved EMS
and CEMP. All environmental personnel are having recognized Environmental qualifications and
work experience as per Qatar Construction Specifications 2014 as well as client requirements.
However, the environmental manager assigned for the project is available only twice a week,
when the contract requires full time. The project director responded that the last environmental
manager resigned recently and they are in the process to recruit a new manager.
The project CEMP and EMS has procedure for Competence, Training and Awareness to
ensure to that all project personnel are trained appropriate to the requirements of
Environmental Management System including those whose work may create a significant
impact / Risk on the environment and safety.. Training and competency matrices, training
schedule, training materials and training records witnessed during the assessment.
All contractor employees are undergone the induction training and job specific training etc. as
per the procedure and schedule and records are found up to date. (records witnessed) however
subcontractor employees were not included in the monthly training programme.
Training records shows that office staffs were found not included in environmental emergency
preparedness and response training programmes
Positives:
1) Procedure in place to establish, review and communicate environmental objectives and

targets
2) Project specific environmental objectives and targets were defined
3) Leading and lagging indicators were defined to measure and monitor whether the
objectives and targets were achieved or need improvement
Improvement area:
1) Full time environmental manager not deployed; visiting environmental manger found
attending to project environmental matters.
2) Environmental training programmes did not include sub-contractor employees
3) Training on emergency preparedness and response not conducted for office staff
4) Noncompliance of
▪ HSE Leadership Procedure- BCC-HSE-IMS-SP-05-Rev-00
▪ Clause 7.2 of ISO 14001: 2015, Competence
▪ Procedure for competence, training & awareness, BCC-HSE- IMS-SP-11:00-Rev-00
▪ Clause 7.1 of ISO 14001: 2015, Resources
▪ Clause 7.3 of ISO 14001: 2015, Awareness
3.6. Communication
The company EMS has established procedures for effective communication of environmental
issues and based on the that project specific communication plan has been developed and
included in the CEMP. The communication plan defines internal and external communication
requirements including those with regulatory agencies, recommended modes of
communication, documents of communication records etc.
The communications arrangement in the project include formal meetings both internal and
external at all levels including Pre-task briefings; Coordination Meetings and Progress Meetings
(internal and with consultant and client etc.); Management Review Meeting. The issues
communicated include Status of current objectives and targets; Project issues; Regulatory
changes; environmental inspection findings; audit results; Environmental Incidents; Employee
concerns.
Evidence of communication of information both internal and external as per the existing
procedure including Notice board, Induction & Trainings records, E-mails, Circulars, Minutes of
meetings, Audit Reports, Management review meeting minutes were witnessed during the
assessment.
There is a system in place to register and respond to internal and external complaints regarding
environmental issues; The assessment witnessed immediate response to external complaints
but internal complaints were not addressed adequately.
Repeated complaints of leaking water tap in the project rest rooms were found in the
complaints register, although records show repair was carried out but there was no action to
identify and address the cause of continuous leaks even after repair are carried out. This
shows gaps in communication between maintenance team and environmental department.

Positives:
1) The EMS has procedure in place to establish effective communication at all levels,
both external and internal
2) The CEMP has defined a communication plan suitable and sufficient to
effectively communicate environmental related information at all levels and
record keeping.
Improvement area:
1) The latest revision of aspect & impact register was not communicated to top management
(communication records not witnessed)
2) Lack of follow up towards internal environmental complaints; repeated complaints of
leaking pipes from same location witnessed but reason for repeated complaints not
addressed revels gaps in the communication between maintenance team and
environmental department.
3) The communication procedure and plan are not revised to include the use of virtual
meetings.
▪ HSE MS Communication Procedure, BCC-HSE-IMS-SP-13-Rev-00
▪ Clause 7.4 of ISO 14001: 2015, Communication
3.7. The effectiveness of controls
The EMS has procedure defining the requirement of operational procedures for the
management of environmental aspects relation construction activities, supplier and
subcontractor management, maintenance and associated business activities. The
operational controls required are developed to achieve environmental objectives and
targets, comply with applicable legal requirements and manage its significant
environmental impacts.
EMS PROCEDURES
01 BCC-EMS-SP-01 Procedure for action to address Risks and Opportunities: -
02 BCC-EMS-SP-02 Procedure for action to address Risks and Opportunities: -
Procedure for identification of compliance obligations
03 BCC-EMS-SP-03
applicable to environmental aspects
Procedure for Operational Control of Significant
04 BCC-EMS-SP-04
Environmental aspects
Procedure for planning and dealing with Potential
05 BCC-EMS-SP-05
Environmental emergencies
EMS OPERATIONAL PROCEDURES
01 BCC-EMS-OP-01 Procedure for Waste Management & Recycling
02 BCC-EMS-OP-02 Procedure for Wastewater & Sewage Management
03 BCC-EMS-OP-03 Procedure for Hazardous Substances Management
04 BCC-EMS-OP-04 Procedure for Paper Management
05 BCC-EMS-OP-05 Procedure for Energy Management
06 BCC-EMS-OP-06 Procedure for Water Management
Procedure for Used Batteries and Accumulators
07 BCC-EMS-OP-07
Management
08 BCC-EMS-OP-08 Procedure for Oil Waste Management
09 BCC-EMS-OP-09 Procedure for Electrical and Electronics Waste Management
10 BCC-EMS-OP-10 Procedure for Bio and Clinical Waste Management
11 BCC-EMS-OP-11 Procedure for Erosion and Sedimentation Management
12 BCC-EMS-OP-12 Procedure for control of contamination of water resources
13 BCC-EMS-OP-13 Procedure for contaminated land management
14 BCC-EMS-OP-14 Procedure for surface water and drainage management
15 BCC-EMS-OP-15 Procedure for flora and fauna management
Procedure for terrestrial ecology and landscape
16 BCC-EMS-OP-16
management
17 BCC-EMS-OP-17 Procedure for rehabilitation management
18 BCC-EMS-OP-18 Procedure for Construction / Asbestos Waste Management
19 BCC-EMS-OP-19 Procedure for Scrap Management
20 BCC-EMS-OP-20 Procedure for Laydown Management
21 BCC-EMS-OP-21 Environmental Inspection Procedure
22 BCC-EMS-OP-22 Environmental Monitoring Procedure
23 BCC-EMS-OP-23 Environmental Reporting Procedure
Environmental requirements for procurement of products
24 BCC-EMS-OP-24
and services
ENVIRONMENTAL CONTROL PLANS
01 BCC-EMS-ECP-01 Air quality and dust control plan
02 BCC-EMS -ECP-02 Noise and Vibration Control Plan
03 BCC-EMS -ECP-03 Solid Waste Management and Control Plan
04 BCC-EMS -ECP-04 Waste Water Control Plan
05 BCC-EMS -ECP-05 Habitat Preservation Plan
06 BCC-EMS -ECP-06 Fuel Storage and Refueling plan
07 BCC-EMS -ECP-07 Chemical and hazardous material control plan
08 BCC-EMS -ECP-08 Traffic Management Plan
09 BCC-EMS -ECP-09 Environmental Cleaning and Rehabilitation Plan
10 BCC-EMS -ECP-10 Site Electricity Unit Operations Plan
11 BCC-EMS -ECP-11 Environmental Incident Response Plan
12 BCC-EMS -ECP-12 Environmental Emergency Response Plan
The Environmental Aspect Impact register identify and record environmental aspects and
impacts arising from the project activities under normal, abnormal and emergency conditions
and carry out detailed Risk and opportunities to assess and develop control measures to
manage them.
The project considers engineering controls in its risk and opportunities assessment developed
to effectively manage the environmental aspects and associated impact arising from project
operations, including the use of automatic sprinkler system for dust control at material stock
piles, multistage sedimentation tanks to improve the quality of dewatering effluent discharged to
the rain water drainage system; replacing fluorescent lights with LED lights in the offices to
improve energy efficiency etc.
The project CEMP has identified all foreseeable emergency scenarios and developed mitigation
plan to effectively prepare and respond to emergency conditions, however the emergency drill
records shows lack of participation from office staff.
The inspection of site witnessed excessive generation of dust from site haulage roads;
arrangements for dust supersession including spraying of water in the haulage roads were not
witnessed
20
During the inspection of the storage area, it was observed that a large quantity of empty paint
containers, paint thinner cans, oil filters etc were dumped outdoors without arrangement for
proper storage, segregation and containment. Empty containers with hazardous waste may
contaminate the surrounding ground and may reach the rain water drainage systems leading to
water contamination and subsequent effects on water quality and marine life.
During site visit it was observed that vehicles and heavy machinery was left switched on, even
when not in use leading to unnecessary wastage of fuel and energy.
Positives:
1) The EMS has procedure in place to develop and review environmental control plans and
procedure to effectively manage and control environmental aspects and associated
impacts
2) Use of engineering controls to manage environmental aspects and associated impacts to
reduce risk and improve opportunities witnessed.
3) The project CEMP has identified environmental emergencies and developed
emergency response procedures.
Improvement area:
1) Poor participation of staff in environmental emergency drills

2) Dust suppression not carried out of site haulage roads creating nuisance to road users
(witnessed during site visit)
3) Vehicles and heavy machinery was left switched on, even when not in use leading to
unnecessary wastage of fuel and energy.
4) Large quantity hazardous waste was stored outdoors without arrangement for proper
storage and spill prevention. Possible chance of contaminate the surrounding environment
and reach the rain water drainage systems etc. This is a major violation
5) Non -Compliance to
▪ Procedure for Operational Control of Significant Environmental aspects - BCC-HSE-
IMS-SP-13-Rev-00
▪ Procedure for planning and dealing with Potential Environmental emergencies, BCC-
BCC-EMS-SP-05-Rev-00
▪ Clause 8.1 of ISO 14001: 2015, Operational planning and control
▪ Clause 8.2 of ISO 14001: 2015, Emergency preparedness and response
6) Possible breach of
▪ Law No. 4 of 2005 Executive by Laws of the Environmental Protection Law of 2002
▪ Law No. 9 of 2019 on the Transport of Hazardous Materials
▪ 1989 Basel Convention on the Control of Trans boundary Movements of Hazardous
Wastes and their Disposal;
▪ PWA’s Circular No.59/2019 with Respect to Environmental Permit Requirements
▪ QCS 2014 Section 11, Part 2.3.02- Waste Management
▪ QCS 2014 Section 11, Part 1.06(1.7.1)-Environmental emergency preparedness and
response
3.8. Environmental performance evaluation
1
The environmental management system of the organisation has defined procedures the
monitoring and evaluation of significant aspects and impacts from the project activities. This
include but not limited to
Monitoring
Scope Indicators Frequency
Aspect
Overall No visual excessive emission of dust. Daily
Management PM10. Wind speed and wind direction Monthly
Dust emissions from No visual excessive emission of dust. Daily
vehicle movements Traffic speeds Weekly
Dust emissions from
construction activities
No visual excessive emission of dust Daily
(excavations. grading, cut
Air Quality
&Fill)
Dust emissions from No visual excessive emission of dust Weekly
sand/soil stockpiles No visual excessive emission of dust Weekly
Gases emissions from No visual excessive emission of dust and
Weekly
operation of fuel black smoke.
consuming vehicles and
Maintenance Record. Monthly
machinery
No excessive noise observed / identified. Weekly
Emission of noise from Traffic Speed Weekly
Noise operation of vehicles and Maintenance
Monthly
construction machinery Record.
Noise level standard Monthly
Light and Over Illumination of No over illumination of Project site Weekly
Visual project area and activities No material, Stockpile or waste piled up at
Amenity obstructing surrounding a high level or stored outside the Weekly
area boundary.
Trend of quantity of waste generated (per
Non• hazardous Waste week). Monthly
Any increase of waste without justification
Waste
Trend of quantity of waste generated (per
Management
week).
Hazardous Waste Monthly
Any increase of waste without
justification.
No sewage overflow from septic tank. Monthly
Sign of stagnant water. Any sudden
Effluent Quantity before discharge increase /decrease of Wastewater without Monthly
justification
Sign of leak Weekly
Sign of leak Weekly
Soil & Contamination of soil and
Housekeeping Status. Weekly
Groundwater groundwater
Sign of Leak Daily
Size of construction foot print, and any
Terrestrial Status of flora and fauna unnecessary damage to existing Weekly
Ecology habitats vegetation.
Sign of Wild life/impact on wild life Daily
Status of archaeological Sign of unauthorized entry to the Weekly

site (heritage well) on site delineated archaeological site
Cultural
Heritage Identification of potential
Sign of items of potential archaeological Weekly
archaeological
significance
significance
Active monitoring techniques such as site inspections, walk through, environmental sampling,
were conducted to evaluate compliance to environmental control plans and procedures. The
EMS have established procedure to conduct audit to evaluate the performance and identify
gaps
in environmental compliance obligations. The frequency of inspection and audits has been
clearly defined in the project CEMP. Records of Monitoring, measurement, analysis and
performance evaluation has been reviewed and found satisfactory
Management review procedure witnessed during the assessment which clearly states the
agenda points to be discussed in the review meetings and expected output. Frequency of the
review is every 12 months. The first review is yet to be conducted
Environmental statics reports and compliance assessment reports are generated on monthly
basis by environmental engineer and submitted to management for review. Moreover, monthly
HSE meeting discuss the key environmental performance indicators to evaluate trends and to
take further action for improvements.
During the review of monitoring records, it was observed that the test result for the quarterly
quality test for drinking water used in the office facility was not available; as per the environment
engineer the sample has been sent to third party laboratory, awaiting results. The water test
results for previous years were available also the calibration certificated for dust monitoring
devices was found expired
While reviewing the report of last environmental audit carried out by the client representative, it
was observed that the close out evidence for some of the observation raised in the audit has
not been recorded.

Positives:
1) The EMS has established a procedure for the evaluation and monitoring of environmental
performance
2) The project CEMP has detailed plan to carry out environmental monitoring and
performance evaluation of significant environmental aspects and recommend actions for
improvement.
3) The evaluation of environmental performance includes inspections and audits as per the
plan to identify issues and action to control them, records witnessed
4) The EMS system defined procedure for management review of environmental
performance.
Improvement area:
1) Calibration certificated for dust monitoring devices was found expired

2) Quarterly Quality test report for drinking water used in the project was not witnessed
during the assessment
3) Close out action for some observation for a previous audit has not been recorded.
▪ HSE Performance Monitoring and Measurement - BCC-HSE-IMS-SP-16-Rev-00
▪ HSE audit procedure, BCC- BCC-EMS-SP-20-Rev-00
▪ HSE Management Review Procedure, BCC- BCC-EMS-SP-21-Rev-00
▪ Clause 9.1 of ISO 14001: 2015, Monitoring, measurement, analysis and evaluation
▪ Clause 9.2 of ISO 14001: 2015, Internal audit
▪ Clause 9.3 of ISO 14001: 2015, Management review
4. Evaluation of improvements required
The areas for improvement identified after the critical analysis of the EMS and effectiveness of
compliance were listed and the top three areas for evaluation of improvement has been
determined by assessing the aspect and its impact on environmental performance. The
identified improvements were prioritised as Low, Medium and High.
Low (L): These observations are largely acceptable, subject to reviews periodically;
Medium (M): Action shall be planned and introduced within a defined time period.
High (H): Immediate action is required as the risk level is high.
QUANTITY (Q)
3 2 1
Excessive Medium Low
FREQUENCY (F)
5 4 3 2 1
continuous or 24/7 several times weekly once a year or
once / week once a month
or once per day none
CONTROL LEVEL (CL)
4 3 2 1
control is available but controls are effective and
No effective control control is not properly
implementation compliance with legal
measures implemented
inconsistent requirements
LEGAL (L)
4 3 2 1
no applicable regulation or
non-compliance with major non-compliance minor non-compliance applicable regulations are
the regulation with regulation with the regulation available and being
implemented
IMPACAT ASSESSMENT SCORE = Quantity X Frequency X Control Level X Legal
LOW MEDIUM HIGH
1-29 30- 144 145-240
4.1. Prioritisation of observations for further evaluation of improvement
Critical
S. N
Evaluation Improvement areas identified Q F CL L Score Rating
Criteria
The awareness of environmental
Environmental
policy, objectives and targets was
1 objectives and 2 3 4 2 48 M
poor among workmen interviewed
targets
during site inspection
A plan to achieve and track progress
Environmental
of environmental objectives and
2 objectives and 2 3 4 2 48 M
targets in a timely manner was not
targets
developed
Environmental implications of
COVID 19 protocols implemented in
the project were not identified and
Identification of addressed in the company
significant Aspect/Impact register hence Risks
3 aspects and and Opportunities were not 3 5 4 3 180 H
associated assessed; which has serious impact
impacts on the project’s environmental
performance and have the potential
effects on the organization’s
business decisions
Removal of trees as part of
construction enabling works without
approved permit for MME, which is a
major violation of regulatory
Compliance requirements. Further the tree
4 3 4 4 4 192 H
obligations removal shall be carried out by MME
authorized subcontractors only and
the tree shall be replanted at an
MME approved site; which was not
complied with
Resource, Full time environmental manager not
competence and deployed; visiting environmental
5 2 4 2 3 48 M
worker manger found attending to project
awareness environmental matters.
Resource,
Environmental training programmes
competence and
6 did not include sub-contractor 2 3 3 2 36 M
worker
employees
awareness
Resource,
Training on emergency
competence and
7 preparedness and response not 3 3 4 3 108 M
worker
conducted for office staff.
awareness
The latest revision of aspect &
impact register was not
8 Communication communicated to top management 3 3 3 3 81 M
(communication records not
witnessed)
Lack of follow up towards internal
environmental complaints; repeated
complaints of leaking pipes from
same location witnessed but reason
9 Communication for repeated complaints not 3 4 3 3 108 M
addressed revels gaps in the
communication between
maintenance team and
environmental department.
The communication procedure and
10 Communication plan are not revised to include the 2 3 3 2 36 M
use of virtual meetings.
Effectiveness of Poor participation of staff in
11 3 3 3 2 54 M
controls environmental emergency drills
Dust suppression not carried out of
Effectiveness of site haulage roads creating nuisance
12 3 4 3 3 108 M
controls to road users (witnessed during site
visit)
Large quantity of empty paint drums
was stored outdoors without any
Effectiveness of
13 arrangement for proper storage and 3 4 4 4 192 H
controls
spill prevention may contaminate the
surrounding environment and reach
the rain water drainage systems etc.
This is a major violation
Quarterly Quality test report for
Environmental
drinking water used in the project
14 performance 2 3 3 3 54 M
was not witnessed during the
evaluation
assessment
Environmental Close out action for some
15 performance observation for a previous audit has 2 3 3 3 54 M
evaluation not been competed
4.2. Area of improvement 1 – Identification of significant aspects and impacts
The evaluation of environmental risks and opportunities register has identified areas for
improvement. The risk and opportunities register available in the project was found inadequate
to meet the requirements of EMS risks and opportunities procedures, Management system
requirements and ISO 14001:2015.
Some environmental aspects and impacts were not assessed for risk and opportunities, these
gaps in the assessment of risk and opportunities for environmental aspects could seriously
affect the environmental performance and business decisions. Improvement of issues
identified can lead to fulfilment of compliance obligations, ISO 14001-2015 requirements and
continual improvement of EMS performance.
4.2.1. How will the effective implementation be achieved?

▪ Review and existing risks and opportunities procedures and format and ensure it is
appropriate to conduct the risk and opportunities assessment and develop controls
▪ Revise the risk and opportunities procedure to address the requirements of 6.1 of ISO
14001-2015;
▪ The procedure shall consider methods to identify and record aspects and impacts and
assess risk and opportunities following a change, planned or new development, abnormal
and emergency conditions.
▪ Constitute a competent team to conduct Environmental aspect and impact assessment.
▪ Identify and consult members from all relevant departments and section whose activities
may have an impact on the organizations environmental performance
▪ Provide training based on the existing updated procedures and formats;
▪ Then assess the identified risks and opportunities by considering its effects on the
environmental performance of the organisation as well as moral, legal and financial
implications
▪ Ensure that all significant risks and opportunities are identified, assessed and appropriate
controls identified to reduce the risk and enhance opportunities
▪ Implement and maintain the risk assessment in order to achieve the intended outcomes.
▪ The shall be reviewed at regular intervals
▪ The risk and opportunities arising environmental aspects and impacts shall be
communicated
4.2.2. Who will be responsible for implementing actions?
The implementation of the action requires participation, consultation, communication,
support and co-operation of
▪ Top management including CEO, COO, Corporate HSE Director
▪ Project director
▪ Project Manager
▪ Construction managers and process owners
▪ Environmental Manager and Environmental Engineer
▪ HSE Manager
▪ Document Controller
4.2.3. Training requirement

▪ External training on ISO 14001: 2015 EMS
▪ Internal training of exiting EMS manual and procedures
▪ Internal training for the implementation of the revised procedure and forms
▪ Internal trainings for execution team on the implementation of additional controls identified
in the revised risk and opportunities register
▪ Cost of training is estimated at QR 9000
4.2.4. What resources will be required for the implementation
There are two training is required in terms of the risk register. One is risk assessment
training and second is implementation training. The objective of the training to make
competent of the risk assessors and effective implementation of the updated risk register.
The following resources shall be provided for ensuring competence and training of
employees in order to improve in risk register.
▪ Human resources
▪ Computer, laptops
▪ Internal and external trainings
▪ Meetings
▪ Handouts including risks and
▪ Training rooms;
opportunities procedure and format;
▪ Training materials
▪ Implementation plans;
▪ Refreshments
▪ Updated risk register;
▪ Cost of resources required of implementation is estimated at QR 11000
4.2.5. What are time scales for implementing actions?
▪ The review of risk and opportunities procedure and the recommended training for the
team identified to carry out the assessment completed within 3 weeks from this
assignment report.
▪ The opportunities and risk register shall be updated with all significant environmental
aspects and impacts and subsequent risk and opportunities should be ready within 5
weeks positively.
▪ The review of risk and opportunities register and its communication for
implementation of the controls identified in the risk register shall be completed
within 6 weeks positively.
▪ The implementation effectiveness including the achievement of the intended
outcomes shall be ensured within 8 weeks from the date of assignment.
4.2.6. How effectiveness will be measured; monitored and reported
▪ Effectiveness of implementation to be monitored through active monitoring technics
such as compliance assessment, inspections, audits, environmental monitoring,
bench marking, surveillance etc.
▪ Review of number of environmental issues, NCRs received (Internal and External),
environmental incidents and other leading and lagging indicators
▪ Aspect and impact register and risk and opportunities register maintained as
documented information.
▪ Availability of Environmental control plan and procedures and its effective
implementation
▪ The communication of the revised aspect and impact register and risk and
opportunities register to interested parties and records of communication.
▪ The result is to be discussed in the monthly HSE review meeting and compared
against standards and planned outcomes; minutes maintained
▪ The achievement of the intended outcomes shall be communicated as per the
communication plan and records maintained.
4.2.7. How will lessons be learned
To understand the changes (positive and negative) achieved, Pre-evaluation has to be
done prior to the revision of risk and opportunities procedure and register and the
implementation training to the relevant personnel. A post evaluation also to be done to
gauge the effectiveness of the implementation of recommended actions.
4.3. Area of improvement 2 – Compliance obligations
During the assessment it was observed the project has major noncompliance towards
environmental regulatory obligations. Although the project CEMP defines procedure for
environmental compliance obligation the adequacy of the procedure and its effectiveness of
implementation was found not meeting with the requirements leading to serious lapses.
The inspection of external permit logs the MME permit for tree removals was expired, the site
inspection witnessed unauthorized removal of trees by contractor which is a clear violation of
environmental regulations, The permit for dewatering lagoon constructed in the site was also
found expired; the Environmental engineer responded that the permit application is in process
of approval and the trees were removed to expedite works, This indicates the compliance
obligation procedure is ineffective, lacks review and . Major violation of environmental and
regulatory compliance
▪ Review environmental compliance obligation procedures to ensure that it is appropriate to
conduct the risk assessment;
▪ If not, update the procedure and format by considering the requirements clearly stated in
clause 6.1.3 of ISO 14001-2015;
▪ The compliance obligation register should have a supplementary permit tracker document
to ensure the availability and validity of the permits are recorded
▪ The compliance obligation register and permit tracker should have a verification section for
the environmental manager to complete
▪ The compliance obligation register shall include a schedule to ensue renewal of permits
are initiated well in advance of its expiry (anticipating delays in the approval process)
▪ Records of monitoring of compliance obligations shall be retained;
▪ The monthly HSE review meeting shall include a section to discuss permits and other
regulatory compliance requirements and the status of existing permits available.
▪ The compliance obligation register and permit tracker should be submitted to top
management for review
▪ The status of permits shall be available to the execution team; suitable communication
methods shall be established to ensure this.
▪ Awareness training shall be conducted to employees at levels and section of the
organizations to ensure applicable compliance on permit requirements are
The implementation of the action requires participation, consultation, communication,
support and co-operation of
▪ Top management including CEO, COO, Corporate HSE Director
▪ Project director
▪ Project Manager
▪ Environmental Manager
▪ Environmental Engineer
▪ Document Controller
▪ External training on ISO 14001: 2015 EMS
▪ Internal training of exiting EMS manual and procedures
▪ Internal training for the implementation of the revised procedure and forms
▪ Human resources
▪ Updated environmental compliance
▪ Internal and external training (ISO
obligation register
14001: 2015) ▪ Permit tracker
▪ Handouts environmental compliance
▪ Implementation plans;
obligation procedure and register
▪ Consumption of energy and
▪ Revised environmental compliance
consumables for office operations
obligation procedure
▪ Revision of monthly HSE meeting
▪ Meetings
agenda
▪ Training rooms;
▪ Training materials
▪ Cost of resources required for implementation is estimated at QR 18000

▪ The review of environmental compliance obligation procedure and the recommended
training for the environmental team shall be completed within 2 weeks of submission.
▪ The revised compliance register and permit tracker shall be developed and established
within 3 weeks from the submission of report
▪ The environmental compliance obligation register and permit tracker shall be updated with
all the environmental compliance obligation and permit requirements within 4 weeks
positively.
▪ The review of environmental compliance obligation register and its communication for
implementation shall be completed within 5 weeks positively.
▪ The improvements or the effectiveness of the implementation to be ensured through active
monitoring technics such as review of compliance obligation reports, inspections, audits,
environmental monitoring, bench marking, sampling, environmental surveillance etc.
▪ Training and feedback records
▪ Feedback from personnel documenting the compliance obligation register and permit
tracker on its easiness of use and effectiveness to monitor and record environmental
compliance obligations
▪ Review of lagging indicators like Violation, NCRs, Enforcement notices, prohibition
notices, environmental incidents etc.
▪ Timely renewal of environmental permits and its availability is ensured to interested parties.
▪ Revised environmental compliance register maintained as documented information.
▪ The communication of the revised environmental obligation register is communicated to
interested parties and records of communication maintained
▪ The status of environmental obligation compliance discussed in the monthly HSE review
meeting and action taken; minutes maintained
▪ The achievement of the intended outcomes of environmental compliance obligations and
its effectiveness shall be reported as per the communication plan and record maintained.
done prior to the revision of environmental compliance procedure and forms and the
30
30
4.4. Area of improvement 3 – Effectiveness of controls
The project CEMP and company EMS has established clear procedure for the storage and
handling of hazardous waste in the project and plans to minimize the amount of waste stored
and removal and disposal of waste by licensed contractor, but it was observed during the
inspection of the storage area, that a large quantity of empty chemical containers were stored
outdoors without arrangement for proper storage and spill prevention. Empty containers were
containing left-over chemicals may contaminate the surrounding environment and reach the
rain water drainage systems etc. This is a major violation of regulatory obligations as well as
deviation from the environmental control plan and procedure defined by project CEMP and
company EMS requirements.
▪ Develop storage area plan with a designated waste storage area
▪ Designate waste storage area with proper demarcation and the waste storage area shall
serve the following
1) Proper labelling and packing appropriate for safe storage (if required)
2) Arrangements for the segregation of waster received.
3) Designated areas for the storage of hazardous and nonhazardous wastes
4) The hazardous waste storage area shall be secure and protect from environmental
elements
5) Located away from drainage area
6) Bunded areas with an impervious base for storage of liquid hazardous waste
7) Decontamination area for personnel handling waste
▪ Arrange licensed contractor for the removal and disposal of waste generated including
hazardous and non-hazardous and ensure timely removal of waste material and maintain
waste transfer notes
▪ Maintain updated inventory of hazardous and nonhazardous waste
▪ Maintenance waste transfer records;
▪ Hazardous Substance Register and disposal records shall be maintained
▪ Implementation emergency control procedures including equipment for firefighting, spill
prevention and Eye wash station.
▪ Provide training for personnel training in the storage yard; including emergency response
▪ Personal Protective Equipment
▪ Project Manager
▪ Store in charge
▪ Environmental Engineer
▪ HSE Manager
▪ Contractor for waste disposal
▪ Site operatives
▪ External training on fire prevention and protection
▪ External training on hazardous waste management
▪ External training for first aider
▪ Internal training on proper handling, storage and segregation of waste.
1
▪ Training on controlling spills and use of spill kits
2
▪ Human resources
▪ Firefighting equipment
▪ Internal and external training
▪ Spill kits
▪ Contractor for waste management
▪ First aid boxes and eye wash station
▪ Construction of waste storage area for
▪ Consumption of energy and
hazardous and nonhazardous wastes
consumables for office operations
storage
▪ Construction of decontamination area
▪ Meetings
and storage arrangements
▪ Arrangement of skips for waste ▪ Training rooms;
segregation ▪ Training materials
▪ Labelling and packing equipment and ▪ Refreshments etc.
consumables
▪ Cost of resources required for implementation is estimated at QR 92000

▪ The additional manpower and supervision required for the implementation of the
recommendation shall be arranged within 1 week from the submission of the report.
▪ The internal training requirement identified shall be completed within1 week from the
submission of the report
▪ The provision of first aid boxes, eye wash station and spill kits shall be provided within 1
week of submission of the report
▪ The hazardous and nonhazardous waste shall be segregated and the inventory for waste
management shall be updated within 2 weeks.
▪ The internal and external training requirement identified shall be completed within 2 weeks
from the submission of the report
▪ Arrangement with the waste management contractor to remove the waste material within 3
weeks form the submission of the report
▪ The construction of the waste storage area and including arrangements for firefighting and
spill prevention shall be completed within 8 weeks from the submission of report
▪ The improvements or the effectiveness of the implementation to be ensured through active
monitoring technics such as review of compliance assessment reports, inspections, audits,
environmental monitoring, employee awareness, sampling, environmental surveillance etc.
▪ Training and feedback records
▪ Review of lagging indicators like Violation, NCRs, Enforcement notices, prohibition notices,
environmental incidents records etc.
▪ Review of inventory for hazardous and nonhazardous waste
▪ Review of disposal notes
▪ The management of hazardous and nonhazardous waste discussed in the monthly HSE
review meeting and action taken; minutes maintained
done prior to the revision of environmental compliance procedure and forms and the
5. Financial Justification
The financial justification is to secure top management commitment to provide resources to
action the proposed recommendations the three areas identified for improvements in order to
improve the environmental performance of the organisation. Also, the CBA will provide insight
on how, breach of applicable compliance obligations could lead to penalties, enforcement
actions, prohibition notices, compensations etc. from clients which have significant financial
implications.
While the potential benefits of implementing action to improve the environmental performance
of the organisation include but not limited to
▪ Understanding the environmental aspects and associated impacts from the project
activities, products and services
▪ Carryout risk and opportunity assessment and develop appropriate control plans
▪ Ensure environmental compliance obligations are met with.
▪ Avoidance of enforcement actions
▪ Avoidance NCs from certification bodies;
▪ High level ISO 14001-2015 MS compliance;
▪ Improvement in organizations environmental performance
▪ Reduction in the consumption of resources including water and energy
▪ Reduction in waste generation
▪ Maintaining good will of the company;
▪ Business consistency and further improvements.
▪ Contribute to sustainable development
5.1. Principle of cost benefit analysis (CBA)

A fundamental rule in carrying out a business activity is that the benefit obtained from it should
exceed the cost of it. The gains can be of actual cost savings, but often include intangible items
such as high level regulatory compliance, reduced consumption of resources, sustainable
development etc. There are costs involved with all incidents, losses or non-compliances.
Benefit, B = BI - CI
Quantifying the cost of implementing = CI
The total cost of implementing considers the cost of resources and training requirements
required to implement the recommendations identified in the evaluation of improvement of each
of the three areas identified for improvement
▪ Aspect and Impact 20000
▪ Compliance obligation 25000
▪ Effectiveness of controls 100000
Quantifying the benefit of implementing = BI
The total benefit of implementing considers the overall cost saved from overall improvement of
environmental performance of the project
▪ Reduced Environmental administration: QR 11,000;
▪ Reduced Incident investigation: QR 12,000;
▪ Reduced First aid and medical costs following spill or fire: QR13,000;
▪ Reduced Training required as corrective action following an incident: 10000
▪ Reduced Enforcement actions: QR 400,000
▪ Reduced costs from damage following environment incident: QR 100,000
▪ Reduced insurance premiums: QR 50,000
▪ Reduced Loss of goodwill: QR 25,000
Cost of Benefit of Benefit
S.N Improvement of
implementing CI implementing BI B
Aspect/ Impact & Risk and
1 20000
Opportunity Procedure
2 Compliance obligation 25000 721000 606000
3 Effectiveness of controls 100000
Potential financial cost for all the three improvements would be QR 115,000 however the
potential long-term benefits would be QR 421,000 in addition to the fulfilment of regulatory
compliance and EMS requirements (ISO 14001-2015) for continual improvement of
environmental performance of the organisation
Cost Benefit Analysis
Benefit of implementing BI 721000
Cost of implementing CI 145000
100000 200000
0 300000 400000 500000 600000 700000 800000
Cost of implementing CI Benefit of implementing BI

Series1 145000 721000
5.1.1. Source of internal and external information considered for determining

costs:
▪ Internal staffing data - salary, training and overtime costs;
▪ External supplier data and estimates - purchase, fabrication and installation costs;
▪ Past balance sheets - lost production figures;
▪ Supplier estimates of running and maintenance costs;
▪ Projected accident figures - savings from reduction in accidents;
▪ Past claims experience - estimate of reduction in civil claims;
▪ Insurance premium trends - projected reduction in insurance premiums;
▪ Internal productivity figures - cost per unit.
6. Conclusions and Recommendations
The overall environmental performance of the project was found good. The critical review of
environmental management system shows that it mature, effectively founded on ISO 14001:2015
principles, and provides a platform for the management of environmental aspects and associated
impact arising from the projects operations. The objectives identified for the assessment is
successfully achieved, including the critical analysis of the EMS with respect to Project EMS and
CEMP, ISO 14001-2015, applicable compliance obligations and other requirements; and determine
the top three issues which have significant impact on the environmental performance of the
organisation and propose recommendations which are realistic and cost effective and a plan to
achieve them in time.
Noteworthy practices
▪ Clear visibility of top management commitment towards environmental issues; Environmental
Leadership visible at all levels of the organisation and their roles and accountability towards
environmental performance and compliance obligations defined
▪ EMS has procedure in place to establish, review and communicate environmental objectives
and targets also project specific environmental objectives and targets were defined in line with
corporate objectives and targets with leading and lagging indicators defined to measure and
monitor whether the objectives and targets were achieved or need improvement
▪ The organisation have adequate resources for environmental management including access to
competent advice on environmental related issues
▪ Competency and training needs for the project are analyzed; individual competency matrix and
training programmes/plans.
▪ The organizations emergency preparedness and response procedures were found to be of
reasonable standards and training records of mock drills conducted were retained.
▪ Audits and Management review are consistent with the organization’s commitment to continual
improvement
Major areas for improvement
The current risk and opportunities procedure and register was found inadequate as it failed to
address some of the environmental aspects and impacts were not assessed for risk and
opportunities, these gaps in the assessment of risk and opportunities for environmental aspects
could seriously affect the environmental performance and business decisions. It is recommended
that the current risk and opportunities procedure and register need to be reviewed and updated to
meet the requirements of ISO 14001:2015 EMS Standards and risk and opportunities shall be
assessed based on the revised procedure by competent team to identify and control environmental
risk and opportunities. The implementation of the actions recommended would cost the
organisation close to QR 10000 but the benefits include effective business decisions, the fulfilment
of compliance obligations, ISO 14001-2015 requirements and continual improvement of EMS
performance.
Obligation to ensure regulatory compliance is a critical area of organizations environmental

performance measurement. The procedure for environmental compliance obligations and the
effectiveness of implementation was found not meeting with the requirements leading to serious
lapses. It is recommended that the current compliance obligation procedure and register need to be
reviewed and updated to meet the requirements of ISO 14001:2015 EMS Standards and a
supplementary permit tracker shall be used along with the environmental compliance register. A
periodic review of the compliance obligation register by the Environmental manger to ensure the
register is updated to the latest compliance obligation requirements. The implementation of the
actions recommended would cost the organisation close to QR 25000 but the benefits include
fulfilment of compliance obligations, ISO 14001-2015 requirements, avoid enforcement action form
regulatory bodies and serious financial implications.
The lack of arrangement of designated storage area for hazardous waste at the project laydown
area is a direct breach of several local and international compliance obligation and also a serious
deviation from the company environmental performance objectives and controls in place to achieve
them. The indiscriminate dumping of waste has severe impact on the environment and is a serious
violation of permit conditions and harsh regulatory implications this should be immediately
corrected. It is recommended that the laydown area has a designated area for storage of waste
material with the facility to segregate and store waste material based on their classification and
properties. It is also recommended to ensure the timely removal of waste material by a qualified
contractor and records of waste management inventory are maintained. The storage area
should have effective emergency arrangements including firefighting, spill prevention and
equipment to attend to medical emergencies. The management have to designate competent
staff and address to their training requirements. The implementation of the actions
recommended would cost the organisation close to QR 100000 but the benefits include fulfilment
of compliance obligations and avoid enforcement action form regulatory bodies, prevent
environmental contamination and other incidents like fire leading to severe environmental
damage, which can be estimated to QR 400000
Other opportunities for improvement

▪ The project shall develop a plan to achieve and track the progress of environmental objectives
and targets specific to the project; the awareness of environmental policy, objectives and
targets among workmen shall improve.
▪ A visiting environmental manger was found attending to project environmental matters,
deployment of full time environmental manager shall be expedited
▪ Environmental training programmes are suitable and adequate however coverage and
participation of these trainings shall be improved, especially among office staff and sub-
contractor employees
▪ The communication procedure and plan should be revised to include procedure for virtual
meetings; the gaps identified in the communication of environmental reports to top
management and environmental complaints register shall be addressed.
▪ Effective implementation of control plans shall be ensured where deviations were observed
including poor dust suppression in site haulage roads, vehicles and heavy machinery idling
even when not in use.
▪ Calibration certificated for environmental monitoring devices were found expired and quarterly
water quality test results were not witnessed, which need improvement.
▪ The assessment also witnessed close out action pending for observations for a previous audit,
which has to be addressed and close out recorded to avoid nonconformance.
Lastly, it is appreciated that the project is effectively implementing the EMS system within its scope
and reach. If the gaps identified are filled, the current system would be more effective and would
lead to attain the organization’s environment objectives and targets and would help in attaining
environmental sustainability.
Bibliography
QCS, 2014. Qatar Construction Specifications. Doha: Ministry of Municipality and Urban Planning.
Air Quality Guidelines (WHO, 2005)

Construction Dewatering Guidelines by PWA, March 2014
Environmental Management System; ISO 14001:2015
Environmental Protection Law No. 30 of 2002 (Qatar)
Flora of the State of Qatar (Ekhlas M.M. Abdel Bari 2012)
Law No. 9 of 2019 on the Transport of Hazardous Materials
1989 Basel Convention on the Control of Trans boundary Movements of Hazardous Wastes and their
Disposal;
PWA’s Circular No.59/2019 with Respect to Environmental Permit Requirements
General Secretariat for Development Planning (2008), Qatar National Vision 2030, July 2008
Ministry of Municipality and Environment, 2014. Qatar National Biodiversity Strategy 2015-2025.
Qatar National Development Strategy (NDS) 2018 - 2022
Central Doha and Corniche Beautification CP03, Construction Environmental Management Plan, BCC
Central Doha and Corniche Beautification CP03, Environmental Impact Assessment (EIA), CDB-P3-PIL-EN-
RPT-00002-D00, March 2020 (Parsons)
Central Doha and Corniche Beautification CP05, GEOTECHNICAL INTERPRETATIVE REPORT, CDB-P5-PIL-
GEO-RPT-00002 D01, March 2020 (Parsons)
Environmental Permit (Ref. No. 2019/300694) November 2019.
Qatar Construction Specifications, 2014
Qatar Municipalities by MMUP, 2004
Qatar Statistics Authority, 2013
The Climate of the State of Qatar, QP 2011

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Assignment 00072987 RV August 2020

NEBOSH International Diploma

▪ Leadership and commitment from the top management on environmental issues;

Industry Road and Infrastructure

Consultant ITALCONSULT QATAR

Client Public Works Authority (ASHGHAL)

Estimated Project Value USD 200 Million

Project Duration 660 days

Project layout map

2.3.1. Project Scope

2.3.2. Project Layout

2.3.3. Project Management

Project organogram is defined, documented and communicated as appropriate

2.3.4. Employment profile

Total Manpower 878

▪ ISO 14001: 2015 Environmental Management System;

2.5.3. National Polices and Legislation

Law No. 30 of 2002, The

1) EMS has procedure in place to establish, review and communicate environmental

Risks and opportunities register is in

1) Some of the Environmental permits required as part of environmental compliance

1) Procedure in place to establish, review and communicate environmental objectives and

3.6.1. Summary Findings

1) Poor participation of staff in environmental emergency drills

3.8. Environmental performance evaluation

Status of archaeological Sign of unauthorized entry to the Weekly

3.8.1. Summary Findings

1) Calibration certificated for dust monitoring devices was found expired

4.1. Prioritisation of observations for further evaluation of improvement

4.2. Area of improvement 1 – Identification of significant aspects and impacts

4.2.1. How will the effective implementation be achieved?

4.2.3. Training requirement

▪ Cost of resources required for implementation is estimated at QR 18000

4.4.5. What are time scales for implementing actions?

5.1. Principle of cost benefit analysis (CBA)

3 Effectiveness of controls 100000

Cost Benefit Analysis

Benefit of implementing BI 721000

Cost of implementing CI 145000

Cost of implementing CI Benefit of implementing BI

5.1.1. Source of internal and external information considered for determining

Obligation to ensure regulatory compliance is a critical area of organizations environmental

Other opportunities for improvement

Air Quality Guidelines (WHO, 2005)

Environmental Management System; ISO 14001:2015

Environmental Protection Law No. 30 of 2002 (Qatar)

Flora of the State of Qatar (Ekhlas M.M. Abdel Bari 2012)

Law No. 9 of 2019 on the Transport of Hazardous Materials

PWA’s Circular No.59/2019 with Respect to Environmental Permit Requirements

Environmental Permit (Ref. No. 2019/300694) November 2019.

Qatar Construction Specifications, 2014

Qatar Municipalities by MMUP, 2004

Qatar Statistics Authority, 2013

The Climate of the State of Qatar, QP 2011

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