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7. Validation/Verification
This section provides guidance on external validation and verification
of the data reported to various environmental agencies. It provides some
background information on third party verification and some existing
practices in the Canadian Base Metals Smelting Sector.
7.1 Third Party Verification
Third party verification of release data is often obtained to validate
self-reported data and confirm the accuracy of the values.
The Ontario Ministry of the Environment requires both Falconbridge Sudbury
and Inco Copper Cliff to have third party verification of their reported
annual SO2 releases. For example, Paragraph 19 of the Verification
Control Order calls for Falconbridge to retain an independent consultant
to design an audit protocol, and perform and report on procedural audits
of the SO2 emissions from the complex.
Noranda Brunswick's Approval requires a yearly audit of the sulphur
dioxide continuous emission monitors to verify the accuracy of the concentrations
and mass discharges of the sulphur dioxide.
The European Eco-Management and Audit Scheme (EMAS)53 is
a voluntary initiative to encourage business to improve their environmental
performance. There is a requirement in Article 5 of the EMAS Regulation
(EEC No. 1836/93) to prepare an Environmental Statement. To ensure that
third parties can have confidence in the information supplied, EMAS requires
that the statement be validated by an accredited, independent third party
verifier.
Australian Minerals Industry Code for Environmental Management Interim
Guidance Note on Environmental Reporting, August 199854 indicates
that while third party verification is not expected by the Code for Environmental
Management, "independent reporting or verification of internally
produced reports increases the credibility of report and has been strongly
suggested by environmental non-government organisations." The Guidance
Note also indicates that "If this is completed, it would be beneficial
to include full statement from the third party describing the parameters
used and their recommendations."
7.1.1 Recommendations for Validation Verification
It is recommended that facilities identify data that has been validated
by an external third party in their reporting documents.
Third party verification should be conducted as frequently as required
by regulations. Since a key consideration in obtaining third party verification
is cost, it is therefore, recommended that the release data be subject
to an external audit at least every three years, where more frequent
verification is not a regulatory requirement. However, when significant
changes to process inputs, processes or calculation methodology have
occurred, the subsequent calculations should be subject to external verification.
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53 Eco-Management and Audit Scheme
EMAS www.emas.org.uk.
54 Australian Minerals Industry
Code for Environmental Management Interim Guidance Note on Environmental
Reporting, August 1998 www.minerals.org.au.
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