10.0  Monitoring & Measuring and Evaluation of Compliance     Rev 3 - May 2/2012   CHANGE LOG

General

Environmental monitoring is required to ensure that regulatory requirements are met, and that objectives and targets are tracked and measured. This section outlines the Coulson Group of Companies’ procedures for monitoring and measuring the key activities of forest operations that can have a significant  impact on the environment.

10.1 Monitoring and Measurement.

Monitoring and measurement is conducted by Managers who monitor Supervisor’s inspection reports and training records which have been designed to monitor implementation of EMS training, Standard Operating Procedures and the investigation of EMS incidents.

The Periodic Internal audits (Section 4.2) and Management Reviews (Section 5.0) are conducted at least once annually to measure implementation of the EMS programs and achievement of related goals, targets and objectives.

The Logging Manager and Supervisors are responsible for monitoring their areas of responsibility for compliance to ensure that environmental impacts are minimized and the highest environmental standards are maintained. Internal Forest Harvesting and Road Construction inspections/audits will be conducted by the Supervisors supplemented by contract staff retained to field verify compliance and provide reports and follow up.

At minimum, CFP foremen, contract supervisors, operational engineers or foresters must complete a pre-work meeting, one progress inspection, and one final inspection on each project undertaken in areas of their responsibility. Smaller concurrent projects may be grouped. Additional inspections and reports should be done on larger complex projects which are more than two months in duration or are suspended and restarted after a duration exceeding two months.
  
Supervisors are responsible for ensuring that records for tracking field crew meeting discussions and EMS inspection reports are completed and forwarded to the logging or forestry manager to be entered into the EMS data base. These records are key operational controls forming the EMS record and are used for management review and internal audit purposes.

Compliance Reports not originating from CFP employees or contractors

CFP worksite supervisors or managers shall review and conduct specific on site inspections to follow-up on any reported non compliance or required action by a government agency or other recognized  NGO.Action required from these inspections will be recorded on CFP inspection forms and tracked in the corrective action log and discussed during management reviews.

10.2  Evaluation of Compliance

The Company will carry out each year, during the Internal EMS Audit, an evaluation of the Company’s compliance with legal, regulatory and other requirements to which the Company subscribes. The results of the evaluation of compliance will be reported in a dedicated section of the Internal EMS Audit Report and discussed during the management review. A full review of the legal and other requirements will be completed over the three year cycle.

Compliance will be evaluated by any or a combination of the following activities: