3. Implementation (PHASE II)
It is possible to subdivide the implementation of an EMSP into six distinct activities:
- identifying the decision-making and outcome-reporting procedures;
- write-up of the EMSP specifications for submission to the authorities concerned;
- write-up of the request for proposals and selection of the consultants who will carry out the program;
- training the employees who will perform the work;
- performing the monitoring and surveillance activities;
- if applicable, triggering the contingency plan.
This implementation sequence obviously must be approved by the responsible authorities concerned.
3.1 Identification of Outcome Reporting Mechanisms and the Decision-making System (Activity 5)
During the implementation of the EMSP, the decision-making and outcome-reporting procedures must be clearly identified and it is important to do this before the work begins. If necessary, these procedures can be posted in the appropriate places. It is important to specify the importance of properly documenting the EMSP’s activities and outcomes and maintaining documentation and logbooks for all the monitoring and surveillance activities. This documentation must be easily accessible and shared among the different stakeholders. Dissemination of the monitoring reports to the public is important and must be based on a multi-media communications plan (newspapers, Internet, workshop, conference, etc.).
The decision and communication chain must expressly include the following information:
- the name of the person responsible for communicating the outcomes;
- how the outcomes will be communicated;
- the names of the persons to whom the outcomes will be communicated;
- the time when these outcomes will be communicated;
- the name of the person responsible who can authorize implementation of the planned responses.
Since the responses can entail a modification of the work, temporary or even permanent shutdown, it is important that the chain of command be known in advance and approved by all stakeholders (proponents, contractors, consultants, government departments).
3.2 Writing the Specifications of the Monitoring and Surveillance Program (Activity 6)
Once all EMSP stages and components have been drafted and all the requirements of the sampling and analysis plan have been defined in detail, the EMSP specifications must be drafted. These specifications, which serve as the basis for the request for proposals, must at a minimum contain the description of the problem and the presentation of the objectives of the EMSP, the physical, chemical and biological characterization plan, the contingency plan and the decision-making and outcome-reporting procedures.
3.3 Invitations to Tender and Selection of the Consultant for Performance of the Program (Activity 7)
When a proponent wishes to delegate responsibility for the performance of the EMSP to a consultant or firm, an invitation to tender should be issued. Depending on the number of bids received, the proponent has the task of choosing the consultant or the firm that will best meet the needs set out in the specifications. This choice must be based, in particular, on the firm’s expertise and experience, the expertise and experience of the personnel assigned to perform the work, the proposed methodology and the fees requested.
3.4 Employee Awareness and Training Programs (Activity 8)
Before commencing the dredging or sediment management work, the person responsible for performing the EMSP must inform the operators and other assigned workers about the required response measures for the protection of the environment. The responsibilities of each stakeholder must be specified to ensure quick and effective implementation of the contingency plan, if needed. The responsible person must inform employees about the project’s potential repercussions and the importance of adopting environmental best practices during every phase of the work.
3.5 Performance of Monitoring and Surveillance Activities (Activity 9)
Once all the preceding stages are completed, the work and the monitoring and surveillance activities can begin. As soon as the outcomes of the analyses performed in situ or by the external laboratories are available, they must be compiled, interpreted and communicated to the stakeholders concerned in accordance with the mechanisms established in section 3.1. To facilitate interpretation of the outcomes by these stakeholders, graphic presentations are preferred. This allows for the quick detection of any possible overruns of the predefined action thresholds. It is important that the person responsible for the performance of the EMSP maintain, throughout the program, a data logbook describing the work accomplished, the weather conditions, any anomalies observed and the responses established.
3.6 Triggering the Contingency Plan (Activity 10)
The contingency plan can be activated based on the outcomes obtained during the monitoring and surveillance activities (section 3.5). This can lead to changes in certain aspects of the EMSP or the establishment of new impact mitigation measures (section 2.4).