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National Environmental Management Act, 1998 (Act No. 107 of 1998)

Environmental Management Plan : Department of Labour

Chapter 5 : Proposals for Environmental Management

5.2. Co-Operative Governance



5.2.1) Internal Department of Labour co-operation


In order to effectively implement the environmental management initiatives in all the relevant functions of the department, buy-in from all DOL staff is required. All staff members must take responsibility for the implementation, not only one environmental manager or management directorate. Since the staff of the provincial offices, specifically the inspectors, report to the Deputy Director General: Internal Management and Operation, the environmental initiatives and directives will be provided by the national office, to these offices.


5.2.2) Intergovernmental co-ordination


Intergovernmental co-ordination and harmonisation of policies, legislation and actions relating to the environment is urgently required in order to achieve sustainable development within South Africa. Therefore, it is necessary that all EMPS and EIPs developed by all government departments are .compatible such that there are no conflicting strategies or plans and no duplication of efforts. Since the government departments are still in the process of submitting their EIPs and EMPs to the CEC, the DOL cannot yet assess whether their EMP complies with those of other departments. Once the EMPs have been submitted and approved by the CEC sub-committee, the DOL will be able to comment in their annual report to DEAT, on whether the EMPs are compatible as well as the extent of compliance to their EMP, by DOL themselves and other departments.


Some of the links with DEAT EMP are provided in section 6.1, for example those relating to HCS and transboundary transport of dangerous materials.


South Africa has ratified the Basel Convention (Convention on Control of Transboundary Movements of Hazardous Wastes and their Disposals), and although DEAT is responsible for ensuring that the country meets its obligations in terms of this convention, DOL should work with DEAT to ensure:

environmentally sound management of hazardous waste;
establishment of a notification system (authorisation of permits for import, export and transit);
reporting on amount of waste generated annually, including cleaner production and waste minimisation tendencies; and
development of technical guidelines for a variety of hazardous waste.


Other possible areas where links must be made rather than duplicated include:

Integrated Waste Management System and Hazardous Waste Management; and
Emergency Response plans for accidental pollution.


The DOL office that is responsible for the initial development and introduction of the EMP must convene a committee of representatives from the other key government departments that will be impacted on or that will influence the environmental laws, norms and standards that the DOL develops. This committee should meet quarterly to discuss developments within each department. This will ensure that there is no duplication of effort, nor development of contradictory laws, norms and standards, or regulations.


Memoranda of Agreements between the various departments and DOL may be necessary. These could serve to streamline the implementation of the departmental EMPs and to ensure no duplication of functions, such as inspections for compliance with environmental management requirements by the various departments, and to clarify the roles of the departments.


5.2.3) Monitoring of compliance by local government with environmental requirements


Monitoring of compliance by local government with the environmental requirements will be provided for by DOL in the revised policies, laws and regulations, will be done through the inspectorates operating from the provincial offices and labour centres.


5.2.4) Monitoring of EMP implementation


Monitoring of EMP implementation by the various government departments at all levels, is required and must be planned timeously by DEAT, with input from the other departments, and conducted from the outset of the process. In order to work with the other provincial and local departments for the implementation of the initiatives resulting from this EMP, more formal communication structure must be put in place. Currently only ad hoc meetings and liaison occurs. DOL and other government department provincial and local offices must be involved not only for the implementation but also the development and revision of policies and regulations, as discussed in section 5.1.7.