Understanding independent environment control officers : learning from major South African construction projects
Abstract
An independent industry of Environmental Control Officers (ECOs) is active on various construction sites across South Africa. It forms part of a global network of verifiers, such as Environmental Impact Assessment (EIA) and EIA follow-up verifiers. This network authenticates statements about and the implementation of sustainability commitments made during the planning phase of major construction projects. International studies show that the construction industry is experiencing many challenges to deliver sustainability commitments, including inadequate collaboration between role players, ill defined roles and responsibilities, and insufficient use of environmental governance approaches. On-site verifiers like ECOs may aid in restraining these challenges by bridging ineffective governance approaches, such as classic EIA with new governance approaches, for instance self-responsibility (e.g. Environmental Management Systems
(EMSs)) and involvement of third parties. Moreover, an “independent from all” verification function may be vital in developing countries such as South Africa, where trust between the government, market and public is particularly fragile due to historical injustices. Interestingly, limited learning has been drawn and shared from this function’s real-world experience. There are also differing views on the role, independence and value of ECOs, due to roles, frequent interaction with persons responsible for delivering sustainability commitments, and collaboration with third parties being ill-defined. The overarching purpose of this study is to advance understanding of independent ECOs in major South African construction projects. Three lines of inquiry are followed. The first is to define what the role is, or ideally should be, of an ECO in the South African compliance monitoring and enforcement effort. The second is to identify what factors might influence the independence of verifiers. The third is to appraise how and to what
extent independent EIA follow-up verifiers add value in major construction projects in the developing country context of South Africa. This study’s research assumptions are based on the real world of ECOs and uses a mixed method research approach to draw knowledge from the industry. The strategies of inquiry include a survey, interviews, and multiple case study evaluations. The methods for data collection include literature review, a self-administered survey questionnaire, semi-structured interviews, video material, observations of practice at case studies, and the collection of project documentation. The methods used for data analysis are the categorisation and measuring of opinions and statements of survey participants, the analysis of video material and project documentation, and the nominal categorisation and ordinal scaling of case study results. Three journal articles capture the essence of the research results and form part of the thesis report, as prescribed by the North-West University’s rules for doctoral theses in article format. All three articles were peer-reviewed and published in journals aimed at international audiences. Article 1 of the thesis highlights that an industry of ECOs fulfills numerous roles at various
construction sites across South Africa. The results identify the importance of ECOs functioning independently of all role-players, but warn that obsessing about independence may compromise the ability of ECOs to fulfill their roles. The results also show that industry is in need of competence and the regulation thereof, as well as support from all role players. By drawing from the research results, the thesis defines an ECO. Article 2 of the thesis reiterates that independence is central to internationally acclaimed verification fields and important to ensure the credibility of EIA. The study identifies 18 factors that might influence the independence of EIA follow-up verifiers and divides the factors into five categories: financial, commercial, professional, personal, and other. By identifying and sharing these factors, this thesis aids in anticipating and avoiding potential conflict of interest between environmental role players. Article 3 strengthens the continuum between environmental governance approaches by conceptualising a framework for appraising the value of independent EIA follow-up verifiers. The framework provides for inter-linking principles and objectives of sustainability to the performance areas of EIA, EIA follow-up and the EMS. The appraisal results indicate that independent verifiers add most value when they are involved in screening, checking compliance, influencing decisions, community engagement, and integrating
environmental governance approaches. The study confirms the benefits of adaptable, proactive, experienced, and independent EIA follow-up verifiers, such as ECOs, on major South African construction projects.