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INDIA is the first country in the world
to make environmental audits compulsory. The government of
India, by its gazette notification [No. GSR 329 (E)] of
March 13, 1992, made it mandatory for all industries to
provide annual environmental audit reports of their
operations, beginning with 1992-93. This required
industries to provide details of water, raw materials and
energy resources used, and the products and wastes generated
by them. These audit reports were to be submitted to the
concerned State Pollution Control Boards or before September
30 every year.
Environmental Audit can be defined as a basic management
tool comprising a systematic, documented, periodic and
objective evaluation of how well environmental
organisations, management systems and equipment are
performing. The aim of the audit is to facilitate
management control o environmental practices and to enable
the company to assess compliance with its policies including
meeting regulatory requirements.
This scheme was expected to promote proper monitoring of
industrial activities, adoption of low cost technology and
minimisation of resource consumption. But though it has
been in force for more than two years it has not made much
headway. Out of the lakhs of industries that exist in
India, only 2,995 audit reports were filed by December 1993.
It has also become obvious that the deadline of September 30
is not adhered to . Due to widespread non-compliance, this
deadline has been extended a number of times.
Champions of this regulation fee that the government has
adopted a proactive approach to the conservation of natural
resources, instead of observing the usual command and
control method. Its critics feel that this notification was
hurriedly implemented without the prior creation of
necessary infrastructure/experts which would enable its
appropriate implementation.
This novel concept of environmental audit was distorted ,
surprisingly, by the government, when on April 22, 1993, by
a revised notification [No. GSR.386 (E)] the term Audit
Report was replaced by Environmental Statement.
This change inevitably toned down the impact of the
regulation.
The industries were now to fill a form and submit it to the
concerned Pollution Control Boards (PCBs). It made it easy
for industries to make statements to the effect that they
have taken the requisite steps in compliance with existing
pollution control regulations. These statements might not
be based on actual audit reports. If this becomes a rule,
the whole purpose of the environmental audit regulation
would be defeated.
Industries have a list of grouses against environmental
audits. They are opposed environmental audits. They are
opposed to the disclosure of their modus operandi to the
public, who they feel are not mature enough to follow the
importance of such data. They fear it would lead to legal
wrangles and litigation and that the data would be used by
Pollution Control Boards for prosecution. Publishing
details of raw materials used and processes might reveal
their trade secrets.
Another factors which hampers environmental audits in India
is the lack of specialised environmental auditors. Only
three or four agencies exist which are qualified to conduct
environmental audits. The setting up of an institute of
environmental auditors like the Institute of Chartered
Accountants of India, would have been an apt preamble to the
adoption of this regulation.
Moreover, small industries cannot afford to hire the
services of existing environmental audit agencies. First
time environmental auditing will cost an industry between Rs.
75,000 to Rs. 200,000 and 15 months to complete.
The Pollution Control Boards have no follow up plans. The
reports submitted are not double-checked to find out whether
the forms hold the correct data. One report has been
examined and acted upon till date. The industries do not
get any feedback.
An environment audit programme, if designed and implemented
conscientiously, can enhance an industry’s environmental
performance. If an industry sets up its own system in
compliance with existing laws, then conducting audits would
be a normal and considerably easier procedure. It will
expose problems that require action. It improves the
material and energy efficiency of production processes,
conserves resources, minimises wastes, provides direct
economic benefits to the industry and stimulates growth of
the industry as well as the national economy.
Despite the above most industries are apprehensive about
audit reports since pollution control boards are regarded by
them more as an enforcer, a policeman, than as an advisor.
The government has to assure them that an audit report will
not be used to instigate prosecution or litigation.
There is yet another angle to this gamut of environmental
auditing. We know that industries can be taken to court if
prescribed pollution limits are exceeded. But after
submitting this audit statement the industries may contend
that they cannot be sued since their audit report has been
accepted by the SPCBs. Does the government have any way to
counter this?
Environmental audits are vital not just for a clean
environment but also because their use is the best way to
correct different problems detected at their source and to
minimize wastes and foresee conservation and maintenance
measures needed to prevent major pollution problems.
Industries in developed countries conduct audits as part of
their overall drive for quality assurance to establish a
“green edge” over competitors in environmentally sensitive
markets. Moreover, green audits are asked for by investment
banks before they pour in money. With the Indian economy
opening up, industries have no option but o go green if they
want to remain in the race.
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