Tanzania: NEMC advances to strengthen environmental governance

Tanzania has strongly framed the Environmental Impact Assessment and Audit Regulations, 2005 which details every aspect required and with proper checks and balances.

However, the audit reports submitted by industries do not reflect the intention as mentioned in the regulations and thus the implementation fails to provide the desired outcomes.

The review of the annual audit report of a few industries highlights insufficient or improper reporting. Thus, the National Environmental Management Council (NEMC) jointly with Centre for Science and Environment (CSE), a Delhi-based think tank, has developed an audit manual to strengthen the existing system.

“The Council has observed that the received self-audit reports are in different formats, lack important information and, in some cases, do not reflect the actual status of the operating facility. To add to that, these reports do not adequately cover the information included in the Environmental Management Plan developed during the environmental impact assessment (EIA). This technical manual is intended to streamline the processes associated with undertaking and review of the environmental audits. The submitted self-audit reports need to be clear, and should be capable of identifying and correcting non-compliances and supporting improvement programmes,” said Samuel Mafwenga, Director General, NEMC.

Environmental audit is a series of activities undertaken with respect to the operations of a facility or an organisation to evaluate its environmental performance, noted CSE. It assesses compliance of the facility with the environmental governing laws and thus recommends corrective measures to manage the negative impacts on the environment or human health.

The self-audit conducted by industries annually is an important exercise as it allows the industries to analyse the ambiguities in implementation of management plans and pushes them to keep improving their environmental performance regularly. In other words, these self-audits are considered to be a tool for achieving the goal of sustainable development.

“These (environmental self-audits) are considered as a methodological examination, involving analyses, tests and confirmations of a facility’s procedures and practices with a goal of verifying whether they comply with environmental and legal requirements” said Nivit Yadav, programme director, industrial pollution, CSE.

According to the Tanzania’s Regulations (2005) and its amendment (2018), projects specified in the Third Schedule of the Act and the on-going projects that have been issued EIA certificate are required to undertake self-monitoring, prepare an Annual Environmental Audit report and submit the same to the Council annually or as may be prescribed by the Council.

The regulations specified that only qualified and authorised environmental auditors or environmental inspectors can undertake the environmental audit. It also elaborated in detail the information required in an audit report including past and present impacts of the project, responsibility and proficiency of the operators of the project, existing internal control mechanisms to identify and mitigate activities with a negative environmental impact and the existence of environmental awareness and sensitisation measures, including environmental standards, and regulations, law and policy, for the managerial and operational personnel.

Challenges with existing audit reporting

While preparing this manual, officials from CSE and NEMC reviewed several annual audit reports from different sectors. Though industries are submitting comprehensive reports, still a lot of vital information was missing, making the reports insufficient, the officials observed.

The information gap limits regulators from taking corrective decisions to improve the performance of industry or nearby receptors. Some of the inadequacies identified includes:

• Only one year data is provided: Foremost observation after the review of audit reports is that the industries have provided data only for last year. Having only one year of data makes it difficult to analyse whether the performance of an industry has improved or deteriorated.
• Lots of irrelevant information: Audit reports have a lot of repetitive information which was already submitted in the EIA report. This includes location of the plants in terms of GIS / GPS coordinates, both in tabular format and maps, detailed process description, among others, making the reports unnecessarily bulky and difficult to review.
• Quantitative information missing: The audit report provides detailed information about industry manufacturing process, type of raw material used, power source, chemicals used. However, little is shared about the quantities. For example, a sugar industry is a water-guzzling industry but its audit report does not provide any information on the quantity of wastewater generated and even its quality.
• Incomplete monitoring information: Industries have provided exhaustive information on protocol adopted to conduct stack monitoring or equipment used for the same. For example, the audit report of a cement industry has provided monitoring data from all the stacks except the main stack which is attached to the kiln. It is this stack which generates the maximum stack emissions in a cement plant and the information about this stack is not available in the monitoring report. Additionally, the parameters selected for monitoring in a bagasse fired boiler included CO2, CO, NO, NOx, SO2 but did not monitor SPM which is a major polluter in bagasse-fired boilers.
• No rationale for site identified for ambient air monitoring: The review of the environmental audit report shows that extensive ambient air monitoring exercises have been done by these industries. However, the rationale for selecting sites for the monitoring has not been provided in the report. Performing monitoring at sites where impact of plant’s operation is not observed does not serve any purpose. Monitoring should be done at locations which are impacted by the plant’s operation.
• Conflicting information: An industry with a high water pollution load has not provided any information on wastewater treatment facilities. However, the cover page of its audit report showcases one of the systems of the wastewater treatment plant. This raises the question whether the industry has installed any treatment facility or not.

“The audit reports are weak in providing necessary information for enforcement. They have only one year’s data, which means the performance of the industry could not be compared with the previous year. The reports have irrelevant information which had already been covered in the EIA reports. While there is enough qualitative information, the reports lack quantitative data,” said Yadav.
NEMC should hand-hold industries, consultants and auditors using manuals and guidelines for ensuring better quality of audit reports, he added.

What needs to be done

Despite the industries submitting audit reports in detailed format, the reports could not be used for regulatory purposes to understand the environmental performance of the unit or to suggest any plans for its improvements in coming years. Thus, CSE proposed few recommendations to strengthen the system:

• Prepare a technical manual detailing the format and information required in an environmental audit report 
• Make water audit mandatory for water-intensive industries 
• Prepare and introduce self-audit guidelines for industries to ensure that they collect relevant data which will assist regulators during audit
• Set up a committee of sector-specific experts who can technically review the audit reports and provide suggestions for improving the environmental performance of the industries
• Introduce a strategy to upload audit reports on the NEMC website – this transparency would help initiate public participation and feedback as well as assess the performance of an industry in terms of public health

“Apart from being of immense use for project proponents and experts in conducting self-audits, this technical manual would also be useful for the Council and other regulatory bodies to review submitted documents” said Menan Jangu, director, NEMC.

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