Environmental management at our sites
Management of environmental issues is strongly influenced by the legislative culture in North America. These Environmental permits must be regularly renewed and updated and much effort is required to achieve this across all locations.
Risk management
Our consultancy partner, Strata, manages compliance issues across all our sites and ensures that permits are current and their requirements met. For example, permits require the training and periodic testing of employees on compliance knowledge. Copies of all permits are held in a central environmental database that also holds copies of incident and audit reports.
The Laidlaw acquisition has introduced over 500 additional properties to the portfolio. Around 25% of the new properties are in our ownership. We have focused on assessing levels of regulatory compliance across the portfolio since the acquisition. Strata has undertaken a programme of audits, starting with telephone interviews to identify potential high-risk sites and following up with site visits. Any issues identified will be addressed as part of a remedial plan. The details of all new sites will be integrated into the central environmental database.
Our spill response procedures demand central reporting of all incidents and spills. This year a small number of minor spills have occurred. We undertake a root cause analysis for each spill and lessons learnt are shared during safety meetings. Although some of these spills required agency notification under State regulations none of them have led to prosecution.
Utilities usage
To date we have only monitored utilities at a small number of properties owned by First Student. However the three-year plan commits us to setting up a data capture framework to generate data in a pilot study which will cover 20 to 30 properties per region. As part of the plan we will aim to start monitoring utilities in April 2009, with baseline data available in April 2010.