34 EIA Consultation Accreditation Scheme

Sunil Mittal

1. Introduction
2. Genesis of Scheme for Accreditation of EIA Consultant Organizations
3. About QCI and NABET
4. Scheme of EIA Accreditation
5. Scope and coverage of the Scheme
6. Eligibility for accreditation
7. Accreditation Process
8. Benefits of accreditation

1. Introduction to EIA

The process of EIA formally started in India with notification on 27th January 1994 as EIA Notification 1994. The notification continued till 2006 and during these 11 years, the notification was amended 13 times. The notification initially mandated EIAs for 29 categories of developmental projects and one more sector was added to the list in January, 2000. In suppuration to the EIA notification 1994, new notification EIA 2006 was issued by the Govt. of India under Ministry of Environment Forest and Climate Change (MoEFCC) on Sep 14, 2006. As per the notification, the various categories of projects were initially listed in the Schedule of the notification as Category “A” and Category “B”. Category ‘B’ was further divided into ‘B1’ and ‘B2’ by an amendment depending upon the extent of impacts on environment, resources and human health. The notification was applicable for the following project:

a. All new projects listed in the Schedule II to EIA Notification, 2006

b. Expansion and modernization of existing projects or activities listed in Schedule.

c. Any change in product-mix in an existing manufacturing unit included in Schedule.

As per provisions of the said notification, Category ‘A’ projects are considered at the level of Central Govt. and Category ‘B’ projects are considered at State level.

2. Genesis of Scheme for Accreditation of EIA Consultant Organizations

Till the end of year 2009, there were no mandatory rules regarding the expertise of environmental consultant, laboratory facilities available, quality of reports etc. It was felt in the Ministry that there was a need to enhance the quality of EIA Reports as the Consultants generally, undertake preparation of EIA / EMP Reports in many sectors and in some instances without requisite expertise and supporting facilities like laboratories for testing of samples, qualified staff etc. The good quality EIA Reports are pre-requisite for improved decision making. Throughout this period, experts were of the opinion that EIA essentially involves multi-disciplinary studies where inputs are required from the relevant industry/sector specific experts. The EIA consultants should have expertise and knowledge in areas such as land use, air quality, water quality, noise, ecology, socio economic aspects, risks and hazard management etc.

Keeping in view of the requirements, the Government of India, MoEFCC issued office memorandum (dated December 2, 2009) regarding accreditation of the EIA Consultants with Quality Council of India (QCI)/ National Accreditation Board of Education and Training (NABET). The following decisions were taken in the memorandum:

• All the Consultants/Public Sector Undertaking (PSUs) working in the area of EIA would be required to get themselves registered under the scheme of Accreditation and Registration of the NABET/QCI.
• Consultant would be confined in the consultancy only to the accredited sectors and parameters for bringing in more specificity in the EIA document.
• The QCI would put in place detailed procedure for registration of Consultants for taking  up  the  assignments  in  category  ‘A’  and  ‘B’  projects  as  detailed  in  EIA Notification, 2006. The QCI would maintain full transparency on accredited Consultants, procedure followed for accreditation, feedback and evaluation mechanism for Consultants for quality of EIA / EMP Reports.
• After accreditation, the Consultants would need to include a Certificate in this regard in  the  EIA/EMP  Reports  prepared  by  them  and  data  provided  by  other Organizations/Laboratories including their status of approvals etc.

All the further contents of this chapter are based on the information contained in Scheme for Accreditation of EIA Consultant Organizations: Version 3; National Accreditation Board for Education and Training, Quality Council of India, June, 2015 available at (nabet.qci.org.in/environment/Accreditation_EIA_Consultant_organizations.pdf).

3.   About QCI and NABET

The Quality Council of India (QCI) was setup in Feb 1996 jointly by the Government of India and three Indian industry associations i) Associated Chambers of Commerce and Industry of India (ASSOCHAM); ii) Confederation of Indian Industry (CII); iii) Federation of Indian Chambers of Commerce and Industry (FICCI). The objectives of setting up the QCI were to establish and operate national accreditation structure and promote quality through National Quality Campaign. The chairman of QCI is appointed by the honorable Prime Minister on the recommendation of the Industry to the Government. National Accreditation Board for education and Training (NABET) is one of the Boards of QCI. The NABET covers the areas of Education, Environment, Skill Certification, Skill training, MSME.

The QCI took the initiative for evolving the process of accreditation of EIA consultants in 2007 through NABET. Initially it was voluntary and only few consultant organizations adopted it. But when it was made compulsory by the MoEFCC memorandum in 2010, a well-defined scheme was launched by the NABET. To implement the Scheme, NABET is guided by a group of eminent professionals in the field of environmental management and allied subjects. Depending on the expertise required the NABET Secretariat is structured into five groups as follows:

Ø     Technical committee (TC) –5-7 experienced professionals with proven track record.

Ø    Accreditation committee (AC) – comprises 5-7 eminent persons with vast experience in the field.

Ø    NABET assessors –group of eminent professionals with long standing experience in relevant field for, carrying out technical assessment of the applications as well as for conducting office assessment/interaction with experts.

Ø    NABET secretariat – comprises a mix of senior professionals and young energetic technical staff.

Ø    Specialists –guidance of specialists for certain aspects of assessment where it does not have expertise.

4.   Scheme of EIA Accreditation

The Scheme operated by QCI/NABET has accredited about 170 consultant organizations under the scheme. The scheme has evolved in three phases as Versions 1 to 3 in the last 7 years as described below:

a)  Version 1– Jan, 2010 containing the Initial Accreditation (IA) process, which was earlier recognized as Rev 6 of the scheme.

b)  Version 2 – Aug, 2011 containing the IA and Surveillance Assessment (SA) processes, which was earlier recognized as Rev 9 of the scheme.

c)  Version 3 – June, 2015 containing  the  IA,  SA,  Re-accreditation  processes  and  the ‘Rationalization of Functional Areas as per Sectors’. This is the current version operative since 2015. The current version (Version 3) of the Scheme incorporates following –

i)   All the three processes – Initial Accreditation (IA), Surveillance Assessment (SA) and Reaccreditation (RA)

ii)   Clarifications issued on the Scheme since the last version (Version 2/Rev. 9, August 2011)

iii) Rationalization of requirements of the functional area experts.

5. Scope and coverage of the Scheme

The Scheme covers EIA-EMP reports of all projects listed in the Schedule of EIA notification 2006 and its amendments. Currently the schedule has 40 sectors and further in some cases their subsectors. It covers the Scheme’s requirements of human resource, quality management systems and procedures to be followed, integrity of primary data, the assessment process, the accreditation criteria and other relevant requirements of the Scheme.

6.  Eligibility for accreditation

Any organizations meeting the eligibility criteria of this Scheme can apply for accreditation. These organizations can be government bodies, private organizations and public sectors undertakings, Research and education Institutes like including IITs, CSIR labs, other labs, Universities etc. who fulfills the requirements of the Scheme. As per the scheme, there are following 6 essential requirements for accreditation:

a)      Human resource

b)      Field investigation and laboratory arrangement

c)      Quality management system (QMS)

d)     Quality of EIA reports

e)      Organizational commitment

The detailed qualifications, experience & function of experts are described in Appendix A of the Scheme for Accreditation of EIA Consultant Organizations: Version 3; National Accreditation Board for Education and Training, Quality Council of India, June, 2015. (nabet.qci.org.in/environment/Accreditation_EIA_Consultant_organizations.pdf)

However for the sake of convenience and education of students, these are discussed here in brief.

a)   Human resource

EIA is a multi-disciplinary activity and hence experts having knowledge of different sectors are required for the purpose. The expertise is required in various fields of environment like land use, air pollution control, water pollution control, ecology, socio economic aspects, risks and hazard management etc. The qualifications, experience & function of experts in brief are enlisted in table-1.

b) Field investigation and laboratory arrangement

The collection of baseline data is one of the most important step for preparing EIA reports.

The baseline data is collected in respect of:

Ø  Physical environment like air, water, soil, noise etc.,

Ø   Biotic environment

Ø   Socio-economic environment including issues of resettlement and rehabilitation

In order to get the baseline data, laboratory arrangements are must for monitoring physical environment. For the purpose, the applicant organizations (AO) or accredited consultant organizations (ACO) should have an in-house laboratory or agreement/MOU/Work Order with one or more external laboratories. Laboratories engaged in the baseline data collection must be NABL accredited, MoEFCC recognized and or GLP certified. The scope of accreditation/ recognition/certification should cover relevant parameters required for collecting baseline data of physical environment for conducting EIA studies for the following –

Ø   Ambient air quality

Ø   Stack emissions

Ø   Water and waste water quality

Ø   Soil characteristics

Ø   Noise

As per provisions of this scheme, in specific cases, in-house laboratories of a university/ research institute may also be considered, provided their work is akin to that for EIA studies and assessed by the assessors to be appropriate. Wherever such data generation includes collection of samples at the site by the AO/ACO followed by analysis of the same at the laboratory, a detailed written procedure should be followed for collection, preservation and transportation of such samples to the laboratory.

Field investigation for biotic environment and socio-economic data

To collect the biotic and socioeconomic data in/around the project site, the search should be from relevant and reliable secondary sources. The EIA team should be experienced enough and acquainted with the existing ground realities. The team has to visit the site to prepare detailed work plan which includes sampling locations, protocol for ecological studies, questionnaire/other methodologies for collecting socio-economic data etc.

c) Quality management system (QMS)

One of the objectives of this Scheme is to produce good quality reports with data presented in proper and standard way. The scheme mandates the consultant organizations to have their own EIA preparation manual. The consultants are also encouraged to enrich the reports with from their learning’s’ over the years. To facilitate the above, the applicant organization must maintain a Quality Management Systems (QMS) based on the current version of ISO 9001 standards. Although it is not mandatory that the organization should be ISO 9001 certified, but the QMS must address the requirements of ISO 9001 and the specific requirements of the Scheme..

d) Quality of EIA reports

As per the scheme, the EIA consultant organizations should prepare good quality reports. The report should include all the base line data, site description, analysis and interpretation with accuracy. The report should address the identification of potential impacts and mitigation measures reported in best way.

e)  Organizational commitment

The objective of the Scheme is to identify credible EIA consultant organizations who should contribute towards improving the quality of EIAs in the country. To achieve this objective, a commitment is required from the accredited consultants for the continuous improvement of EIA.

7. Accreditation Process

a.  Application assessment process: This is the first step after receiving the application of the consultant organizations. The process completes with checking of the application at 2 stages as follow:

Ø    Stage I– Checking completeness of the application by NABET secretariat

Ø     Stage II – Technical review of documents

b.    Office assessment process: This is the next step for processing the application received after preliminary checking and technical review. It involves assessment of an application for the following six aspects:

Ø  Quality and performance of personnel

Ø  Quality management system

Ø   Field investigations and laboratory systems to ensure data integrity

Ø   Quality of EIA reports

Ø   Organizational evaluation/commitment

Ø  Compliance to conditions of accreditation/ improvements achieved

c. Assessment

The application after passing through the above two processes comes for the assessment in terms of marks. As per the Scheme, marks have been allocated for the above aspects. The table 2 enlists the marks for Office Assessment.

d)   Decision making process

On completion of above process, a joint report prepared by the Principal Assessor (PA) and Co-Assessor (CA) is submitted to NABET secretariat. The NABET secretariat checks the report for its completeness and may ask additional clarifications/information as required for the purpose. The case is then put before the accreditation committee by the NABET secretariat for its consideration, review and decision on accreditation. The committee accesses the application on the basis of the marks obtained in the above process and take final decision as follow.

Ø  Accredited – in case the applicant clears the assessment and accreditation processes successfully with marks more than 40%.

Ø  Not approved – if marks are less than 40% in the office assessment or does not fulfill any other requirements of the Scheme, the accreditation is not granted.

Ø  Incomplete applications – If an AO submits an incomplete application in which requisite details are not provided or it does not meet the requirements of the Scheme in respect of eligible candidates for EC and FAEs, QMS, Laboratory details etc., the same is put in the ‘incomplete applications’ list. NABET intimates the AO of the deficiencies in the application. If it is an application for IA, the same is processed further once all requirements are fulfilled.

8.        Benefits of accreditation

a)     For EIA consultant organizations

Ø  Use of QCI- NABET logo – a mark of quality

Ø   Recognition of competence and capability

Ø   Periodic assessment by NABET paving the way for continual improvement

Ø   Publicity through QCI and MoEFCC websites and publications

Ø   Growth in business through reputational benefits.

Ø   Competitive edge.

b)  For project proponents and other stakeholders

Ø  Availability of a list of capability verified consultants for different sectors.

Ø   Checks on performance of the consultants through NABET website.

Ø   Reduced risks on investments by project proponents choosing capable EIA consultants.

Ø   Enhanced acceptability of developmental projects by all stakeholders.

Special Note: The purpose of this module is entirely for education/teaching to the students purpose and not for any legal use. The contents of the module are bases on the Scheme for Accreditation of EIA Consultant Organizations: Version 3; National Accreditation Board for Education and Training; Quality Council of India; June, 2015.

References

• (nabet.qci.org.in/environment/Accreditation_EIA_Consultant_organizations.pdf)