♦ Environmental Compliance
As a “large emitter” under Australian National Greenhouse and Energy Reporting (NGER), IPL is required to report annually on energy and GHG emissions associated with more than 50 sites across Australia. Direct and indirect emissions from our Australian operations are reported to the Government under this national initiative, which began in 2009. Assurance was obtained over our Australian GHG emissions, energy consumption and production figures for the period 1 July 2017 to 30 June 2018. The third party issued an unqualified opinion over our reported emissions, energy production and energy consumption.
We report environmental release and discharge data to the National Pollutants Inventory in Australia, the Toxic Release Inventory in the United States, the National Pollutant Release Inventory in Canada and the Register of Pollutant Release and Transfer in Mexico. As required in New South Wales (NSW), Australia under the Protection of the Environment Operations Act 1997, holders of Environment Protection Licences who undertake pollution monitoring as a result of a licence condition must publish monitoring data on their corporate website. Of the five Environment Protection Licences which we hold for our NSW sites, there was one which required us to undertake pollution monitoring during 2018 (Kooragang Island) and we continued to publish this data on our website.
We are subject to environmental regulation under the jurisdiction of the countries in which we operate including Australia, United States of America, Mexico, Chile, Canada, Indonesia, Papua New Guinea and Turkey. These environmental laws and regulations generally address the potential aspects and impacts of our activities in relation to, among other things, air and noise quality, soil, water, biodiversity and wildlife. We operate under a Global Health, Safety and Environment Management System which sets out guidelines on the Group’s approach to environmental management, including a requirement for sites to undertake an Environmental Site Assessment. In certain jurisdictions, the Group holds licences for some of our operations and activities from the relevant environmental regulator. We measure our compliance with such licences and report statutory non-compliances as required.
Continuous improvement during the 2018 financial year was focused on improved product handling, compliance management and risk management.
Highlights included the following:
• The development of an engineering framing assessment model to identify engineering and operational opportunities to improve environmental outcomes.
• The Introduction of iAuditor across the fertiliser distribution business to conduct daily site photo logs. In the first three months, 321 daily photo logs identified 568 potential issues.
• Environmental Site Assessments at 32 sites across North America.
• The continued auditing of spill prevention, control and countermeasure plans across North America, and the use of visual management tools and lean processes, particularly 5S, to increase loss of containment awareness globally. This has resulted in increased operational control of product and a reduction in environmental risks associated with product tracking and spills.
• The maintenance of the Environmental Incident Frequency Rate (EIFR) below 1 at just 0.35 and the setting of a new target of Zero Significant Environmental Incidents for 2019.
In May 2017, the Land and Environment Court of New South Wales ordered a subsidiary of the Company to pay a fine of $460,000 and costs of $72,750 in connection with an incident at the Group’s Warkworth manufacturing facility in New South Wales involving an inadvertent release of waste water during
remediation works on site in 2015. Following an appeal in December 2017, the fine was reduced to $360,000. For the 2018 financial year, the Group received two penalty infringement notices issued by a regulatory authority arising from the overflow of a site containment pond in Queensland, Australia, which resulted in fines totalling $25,230. The Group also received a fine of US$250,000 for untimely reporting of an inadvertent release of anhydrous ammonia into the air at a site in the USA.
In accordance with Standard 16 of the IPL Global Health, Safety and Environment Management System, all incidents, including near misses, are reported immediately to the Manager of the Site and elevated to Senior Leadership, Legal and/or external authorities based on the event potential consequence and outcome. All incidents are recorded and investigated according to the IPL Incident Reporting, Investigation and Root Cause Analysis Procedure. Incident investigations identify and prioritise corrective and preventative actions, in order to eliminate or reduce the risk of the incident recurring.