How to make a site audit work for you

Contamination issues can lower property values and wreck an otherwise profitable project. Such risks have recently been demonstrated by the Sugar Cube apartments and Honeycomb townhouses which were developed on a large industrial site in Sydney. All 127 dwellings in this development continue to be uninhabited more than 12 months after completion. The main concern is that contamination found on the site has not been properly dealt with even though the land was subject to an environmental site audit.

The local Council has advised that contaminated groundwater, heavy metals, hydrocarbons and asbestos were not cleaned up in accordance with a remediation action plan that was approved by an independent auditor. As the developer went ahead with construction without meeting this development condition the Council is preventing purchasers from inhabiting the site until contamination testing is completed and approved management plans are in place.

It is not entirely clear where remediation activities failed for the Sugar Cube and Honeycomb site, however, close collaboration with a site auditor does help to avoid such a disastrous outcome. If an auditor is brought in early to a project they are able to provide strategic advice from the outset and will ensure compliance issues are well navigated until a final sign off on a site can be achieved.

What is an environmental site audit?

A site audit is an external review of contaminated land documents and remediation activities undertaken by environmental consultants. It can be statutory such as when a local council requires one for a development consent, or voluntary, such as when it is commissioned for due diligence.

An audit can only be undertaken by a highly experienced contaminated land professional who has been accredited by the EPA. At the end of an audit, the site auditor must provide a site audit report which provides details of their review and sets out their findings together with a site audit statement which conveys the outcome of the audit.

Purpose of the site audit

From a legal standpoint, a site audit statement is used to confirm that:

• the land is suitable for a particular use or uses;
• proposed sampling plans and assessments/investigations are adequate to characterise the contamination or support a management plan;
• a management plan has been complied with; or
• a site can be made suitable for a specified use if it is remediated or managed in accordance with a specified plan.

Not just a box ticker

Site audits are essentially a detailed review of contaminated land documents to ensure sufficient data has been collated to adequately define and address the contamination risks of a site. Of course, compliance checks against a myriad of regulations and guidelines is part and parcel of the process and are extensive as they can also encompass remediation and waste contractors.

There is no doubt the process demands acute attention to detail but a good auditor is also outcome focused. This means advice and clear feedback is provided at every stage of an audit to aid smooth and efficient progress towards the end goal, that is, site suitability.

In addition to good communication with stakeholders and an ability to assess proposed investigation and/or remediation strategies, a good auditor has the ability to make evidence-based decisions when a minor non-conformance is detected. Such an outcome oriented approach will acknowledge a minor mistake or omission but won’t let it hold up the audit process unless there is a material impact on the characterisation or safety of a site. Such sound judgement will ensure that requirements for further works are essential and well targeted.

Getting the most out of an audit

Developers often see a site audit as a necessary evil but the Sugar Cube / Honeycomb project illustrates why councils and regulators want added reassurance that a contaminated site is fit for a new use. Granted, environmental compliance can be complex and expensive but an effective audit can counteract low quality reporting or other circumstances that can lead to project delays and, in the worst case scenario, legal disputes and reputational damage.

Whether statutory or voluntary, there are two pieces of advice that will help make an audit go as smoothly as possible and help to save you time and money.

1. Get you auditor involved early – It’s important to take the right approach from the start. A good auditor will provide robust feedback on any deficiencies or compliance issues during the planning process which will ensure all environmental issues are addressed to the satisfaction of the auditor from the start.
2. Communicate with your auditor – An auditor is accountable for any decisions made on a site’s suitability and must justify each decision according to very strict requirements. If a change of strategy is enacted without consultation and the auditor disagrees with the approach, progress may slow or halt until the auditor is satisfied that the new path of action is appropriate.

If you want further details about Geo-Logix’s audit services please contact our EPA accredited auditor, David Gregory at dgregory@geo-logix.com.au