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Overview of Post Compliance Audit in GPCB

An environmental Audit is a tool for management that comprises of documented, systematic, objective and periodic evaluation of the environmental management system of an organisation/company or plant that is performed to prevent and reduce waste accumulation, evaluate compliance with governing requirements and make the information related to environmental compliances public. Gujrat Pollution Control Board, for executing the recognition procedure for the auditor concerning the environmental audit scheme, have instituted an expert technical committee as the Environment Audit Committee from the commencement of the scheme. This committee also provide Gujrat Pollution Control Board recommendations for Environmental Audit Scheme and Post Compliance Audit in GPCB.

Environment Audit Scheme

Gujrat Pollution Control Board have recently made amendments to the Environmental Audit Schemes relating to the collection of samples and measures relating to it.

Environmental Audit Compliance

Gujrat Pollution Control Board have framed a standard format/procedure for carrying out Environment Audit. According to the format, the environmental audit is conducted by Gujrat Pollution Control Board in three phases: -

  1. Phase 1 is Pre- Compliance Audit in GPCB
  2. Phase 2 is On Site- Compliance Audit in GPCB
  3. Phase 3 is Post Compliance Audit in GPCB

Phase 1 is Pre- Compliance Audit in GPCB was stated for developing the audit plan. In this phase, the Compliance Audit team inspect the industries to gain background information.

Phase 2 is On-Site- Compliance Audit in GPCB consists of an in-person meeting of the Compliance Audit team with the respective owner or person in charge of the manufacturing Unit. This phase also identifies the sources of solid and liquid waste and their reasons, along with the location of the wastewater samples and stack monitoring. All the sampling observations are required to be documented. The record maintained by the industries relating to Materials, energy and water used is also analysed.

Phase 3 is Post Compliance Audit in GPCB- Post Compliance Audit in GPCB includes the planning and framing of a report as per the site visit comprising of energy, material, an environment like water, air or Solid/Hazardous Waste quality, along with the safety and health scenarios of the Industries. Industries categorised under Schedule I & II are under obligation to submit the Environmental Audit Report for the preceding calendar year on or before 30th June of the following year.

Environmental Auditors

The team for Environmental Compliance Audit comprises four members who are qualified enough as environmental auditors with proper training and knowledge of the Environmental auditing process. The main functions of environmental Auditors are

1) Auditors shall prepare and submit audit reports as part of the Post Compliance Audit in GPCB on the Environmental Management System of individual units manufacturing/ processing specified products.

2) For the improvement and betterment of the existing environmental management system, the auditors are required to give their recommendations and suggestions. But, such recommendations given by the auditors shall not bind the Gujrat Pollution Control Board in any manner.

Audit Report

An audit Report relating to Environmental Compliances is to be submitted as a part of the Post Compliance Audit in GPCB.

Contents of Audits Report

  1. The industries set up must be compliant with laws like:-
  • The Manufacture, Use, Import, Export and Storage of Hazardous Micro Organisms/Genetically Engineered Organisms or cells, Rules 1989
  • The Water Act, 1974
  • The Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989
  • The Environment Protection Act, 1986
  • The E-waste (Management) Rules, 2016
  • The Hazardous Wastes (Management and Transboundary Movement) Rules, 2016
  • The Air (Prevention and Control of Pollution) Act, 1981
  • The Bio-Medical Waste (Management & Handling) Rules, 1998
  • The Chemicals Accidents (Emergency Planning, Preparedness and Response) Rules, 1996
  • The Noise Pollution (Regulation & Control) Rules, 2000
  • The Ozone Depleting Substances (Regulation & Control) Rules, 2000
  • The Solid Wastes (Management) Rules, 2016
  • The Plastic Waste (Management) Rules, 2016
  1. The Regulation relating to the Consent Certificates or No Objection Certificates issued by Gujrat Pollution Control Board

Other regulations/Policies which are mandated by Gujrat Pollution Control Board:

  1. Application information or regulations framed by the Central Pollution Control Board or Gujrat Pollution Control Board, or any other applicable authority
  2. Data on the Inspection or Examination made by the auditor as well as composite samples collected by the auditor for running batches or running batch along with samples collected on surprise visit comprising of the samples that are collected at different stages of wastewater treatment and their examination report that is prepared by the auditors.
  3. Data on the products or by-products manufactured, Raw material consumed, data on the quantity of the water, electricity or other fuel used or any other material that is prescribed under the Environmental Audit Report format framed by the Environmental Auditors.
  4. In case any complaint is received by the Gujrat Pollution Control Board or the Environmental Auditors.
  5. In case Orders permitted by the Court in respect of any indicated product and or industry or class of specified industries.

Any industry mentioned above applying for seeking permission or consent for manufacturing/processing items mentioned in Schedule-I or schedule- II is mandated to get its Environment Management System examined by corresponding auditors concerning adequacy and efficacy thereof.

In case an industrial unit is under both Schedule-I and Schedule-II, it shall be treated as a unit falling in Schedule-I for all purposes.

Format of Audit Report

(a) The auditor shall submit an environment audit report in the prescribed format with the following details:

  • Whether the manufacturing Unit or the industry mentioned above fulfil the guidelines laid down by or under the aforementioned statutory provisions, if not, the amount of deviation from the standards;
  • Whether the manufacturing Unit or the above-mentioned industry has fulfilled the regulations (terms and conditions) of the Consent/No Objection Certificate issued by Gujrat Pollution Control Board in favour of the Unit with reference to each term and condition;
  • Whether the manufacturing Unit or the above-mentioned industry has fulfilled the terms and conditions of any general or specific circular/order of the Gujrat Pollution Control Board;
  • Whether the manufacturing Unit or the above-mentioned industry has taken any steps to ensure the safety and prevention of the health hazards to the workers employed in the particular industries, counting their working conditions, and whether the manufacturing Unit or the above-mentioned industry has fulfilled the applicable provisions of the Factories Act and the Rules made there under. For this reason, the environmental auditors shall take into contemplation the performance Statement to be organised by the Labour Commissioner and the Chief Inspector of Factories in discussion with the National Institute of Occupational Health.

(b) For the improvement and betterment of the existing environmental management system, the auditors are required to give their recommendations and suggestions. But, such recommendations given by the auditors shall not bind the Gujrat Pollution Control Board in any manner

Guidelines for analysis of the Air, Water and Hazardous Waste Samples

The Gujrat Pollution Control Board have framed uniform guidelines relating to sampling and analysis that occurs during the environmental audit of the industry. These guidelines are implemented to set analysis parameters by specifying the frequency of water, air and hazardous waste samples collection, the amount of wastewater released and the capability of pollution control devices installed in the industries.

Water Samples

Guidelines for collection of water and wastewater samples

S.No.

Discharge Quantity

Sample Monitoring (In case the industry is discharging final treated effluent into CEPT)

Sample Monitoring (In case the industry is not discharging final treated effluent into CEPT)

1.        

Less than 25 KLD

01 Sample per monitoring

Total 2 Sample per monitoring

2.       

25 to 50 KLD

Total 2 Sample per monitoring

Total 3 Sample per monitoring

3.       

More 50 KLD

Total 3 Sample per monitoring

Total 3 Sample per monitoring

Guidelines for analysis of water and wastewater samples

These given below given parameters have to keep in mind while analysis of Wastewater samples for all remaining seasons:-

  • pH
  • total suspended solids
  • Biochemical Oxygen Demand (BOD) (3 Days at 27 degrees Celsius)
  • Temperature
  • Chemical Oxygen Demand
  • Total Dissolved Solids
  • Ammonical Nitrogen

Air analysis

Guidelines for Ambient Air Quality Monitoring

In GIDC (Gujrat Industrial Development Corporation) Estate:  For industries located in Gujrat Industrial Development Corporation Estate, there is No Ambient Air quality monitoring. So in this situation, the results of NAMP (National Ambient Air Quality Monitoring Programme)/SAMP (State Ambient Air Quality Monitoring Programme) are mandated to be mentioned in the environmental Audit Report.

Outside GIDC (Gujrat Industrial Development Corporation) Estate: The parameters to be followed if the industries are established outside the limits of Gujrat Industrial Development Corporation are: -

S.No.

Total premises Area

Samples Collected

1.        

Less than 5000 square meter

2 Samples to be collected preferably in Winter (One Upward or one in a downward wind direction)

2.       

5000 to 10,000 square meter

3 Samples to be collected preferably in Winter (One Upward or two in a downward wind direction)

3.       

More than 10,000 square meters

At least 3 Samples are to be collected, preferably in 2 seasons (One Upward or two in a downward wind direction)

Ambient Air Quality Monitoring Guideline: -

  • Particulate Matter (PM10)
  • Particulate Matter (PM2.5)
  • Sulfur Dioxide (SO2)
  • Nitrogen Dioxide (NO2)

Guideline for Process Gas Emission

The analysis and sampling of Process Gas Emission monitoring are to be carried out according to the CCA (Consolidated Consent and Authorisation) of The Gujrat Pollution Control Board.

Guideline for Flue Gas Emission

If the cleaner fuel lies LNG, LPG, PNG, NG etc. is used in that case, no flue gas sampling and analysis need to be carried out.

If any other fuel from the approved list is used, then in that case: -

S.No.

Boiler capacity (In case of approved fuels are used) 

Frequency 

1.        

Less than 5 Thermic Fluid Heater   

One season frequency (Preferably Winter)

2.       

5 to 10 Thermic Fluid Heater  

Two seasons sampling 

3.       

More than 10 Thermic Fluid Heater   

All three season sampling 

 

Guideline for D.G. Set

S.No.

KVA Capacity 

Stand By DG Sets 

Continuous Operational D.G Sets 

1.        

Less than 500 KVA 

Exempted from monitoring during Environmental auditing 

1 season monitoring (One sample in a season)

2.       

500 to 1000KVA 

1 season monitoring (One sample in a season)

2 season monitoring (One sample in each season)

3.       

More than 1000 KVA 

2 season Monitoring (One sample in each season)

3 season monitoring (One sample in each season)

Guidelines for Noise Monitoring

S.No.

Industries

Noise Monitoring Sample

Seasons preferable

1.

Small Scale Industries

One set of sample

During only one season

2.

Medium and large-scale Industries

At least two sets of samples

During only one season

Guidelines for Hazardous Waste Sampling

Analysis and sampling of the sludge from wastewater treatment will not be carried out in the case of chemical sludge. However, in case of sampling and analysis of process waste/ hazardous waste during one season only (if process waste generation is more than 10 MT per month) 

Standards for Waste Analysis:

  • pH
  • Calorific Value
  • Moisture Content
  • Chloride
  • Moisture Content

Frequently Asked Questions

Post Compliance Audit in GPCB includes the planning and framing of a report per the site visit comprising energy, material, and an environment like water, air or Solid/Hazardous Waste quality, along with the safety and health scenarios of the Industries. Industries categorised under Schedule I & II are required to submit the Environmental Audit Report for the previous calendar year on or before 30th June of the succeeding year.

The main functions of environmental Auditors are that Auditors shall prepare and submit audit reports on the Environmental Management System of individual units manufacturing/ processing specified products, and For the improvement and betterment of the existing environmental management system, the auditors are required to give their recommendations and suggestions. But, such recommendations given by the auditors shall not bind the Gujrat Pollution Control Board in any manner.

Data on the Inspection or Examination made by the auditor as well as composite samples collected by the auditor for running batches or running batch along with samples collected on surprise visit comprising of the samples that are collected at different stages of wastewater treatment and their examination report that is prepared by the auditors.

The audit report should also contain information on Whether the manufacturing Unit or the above-mentioned industry has taken any steps to ensure the safety and prevention of health hazards to the workers employed in the particular industries, counting their working conditions, and whether the manufacturing Unit or the above-mentioned industry has fulfilled with the applicable provisions of the Factories Act and the Rules made there under. For this reason, the environmental auditors shall take into contemplation the performance Statement to be organised by the Labour Commissioner and the Chief Inspector of Factories in discussion with the National Institute of Occupational Health.

The Gujrat Pollution Control Board have framed uniform guidelines relating to sampling and analysis that occurs during the environmental audit of the industry. These guidelines are implemented to set analysis parameters by specifying the frequency of water, air and hazardous waste samples collection, the amount of wastewater released and the capability of pollution control devices installed in the industries.

In GIDC (Gujrat Industrial Development Corporation) Estate: For industries located in Gujrat Industrial Development Corporation Estate, there is No Ambient Air quality monitoring. So in this situation, the results of NAMP (National Ambient Air Quality Monitoring Programme)/SAMP (State Ambient Air Quality Monitoring Programme) are mandated to be mentioned in the environmental Audit Report.

The analysis and sampling of Process Gas Emission monitoring are to be carried out according to the CCA (Consolidated Consent and Authorisation) of The Gujrat Pollution Control Board.

Analysis and sampling of the sludge from wastewater treatment will not be carried out in the case of chemical sludge. However, in case of sampling and analysis of process waste/ hazardous waste during one season only (if process waste generation is more than 10 MT per month)

Standards for Waste Analysis

  • pH
  • Calorific Value
  • Moisture Content
  • Chloride
  • Moisture Content

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