As shown in chapter 2.7, the environmental auditing ea is divided into three main steps: pre audit activities, activities at the site, post audit activities. this chapter will not detail ldquo pre audit activities rdquo and ldquo post audit activities rdquo already described in chapter 2.7 and figure 6 because they are not very specific to the pulp and paper industry. The main difference lies in the ldquo activities at site rdquo step, where special attention must be paid to the particular case of pulp and paper activity. Numerous data that might be useful to auditors are included in previous chapters. They contain a lot of information detailed in the tables, figures, and check lists as: figure 1 in chapter 1.2. Main kinds of activity to be studied during the eia or ea, figure 2 in chapter 2.4. Simplified diagram of a typical pulp and paper process, all tables included in chapter 3 which detail yields, characteristics, inputs, outputs and guideline values for main types of processes.

It must include important steps such as: selection of the audit team members. composed of two to eight people, with a team leader, this team must represent all the needed specialities policy, environmental management, toxicology, operational aspects, etc. In the case of the environmental management system proposed by the european union described in figure 7 accredited verifiers from independent institutions have to validate the audit once it is completed. scoping of the proposed audit. it is clear that the scope of the audit has to be defined before it begins. Other goals can be proposed to the audit hazards, occupational health, spill prevention, toxic control, waste management, etc. These protocols must reflect the objectives of the audit, facility characteristics and time constraints and must guide the auditors in determining possible deficiencies of the system. collection of background information. in particular, previous audits and copies of all registers where data are recorded and possible administration of a questionnaire to prepare the visit at the site.

Sent to the site manager it can include questions such as: can you describe the activities or provide a brochure explaining the activities of your company and your site ? does your site have specificity in the company activity ? have you already defined a precise environmental strategy ? are there environmental policies and systems ? are there clear environmental responsibilities at each level ? are there regular inventories of inputs and outputs. It is important to collect the reply before starting the activities at the site, to determine the problems which are to be studied thoroughly, as early as possible. For example the environmental diagnostic software, proposed by ecobilan company, allows to make a simple diagnostic of environmental management in the plant.

In its normal version it is not specific to the pulp and paper industry but can be of great help in this first step of the audit. The description of the 5 steps of the activities at the site see figure 6 is extracted following the international chamber of commerce method. Ldquo internal controls might be normally incorporated in the facility's environmental management system.

They include the organizational monitoring and record keeping procedures, formal planning documents such as plans for prevention and control of accidental release, internal inspection programmes, physical controls such as containment of release material, and a variety of other control system elements. The auditing team gains information on all significant control systems through elements from numerous sources through the use of formal questionnaires, observations and interviews rdquo. It is important to add to the facility audit, forest and transportation controls. Various inputs and outputs to be studied in the plant during an ea various simple check lists can help the auditors at this stage. They can examine raw material production and exploitation check list no 10 , industrial activities check lists no 11 and 12 , transportation activities check list no 13 or environmental management check list no 14. check list 10: simple assessment of raw material production and exploitation environmental management wisconsin is the united states largest paper producer, and has been for years.

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Pulp and paper companies also constitute the largest manufacturing sector in the state, providing thousands of high paid jobs. The paper industry has been a major source of accumulated toxic chemicals in several rivers in wisconsin, most notably of pcbs to the fox river and green bay system in northeast wisconsin. As a result of recycling pcb containing carbonless copy paper, area mill operations discharged about 250,0 pounds of pcb rsquo s contaminating lower fox river sediment.в according to the u.s. Environmental protection agency epa , an estimated 160,0 pounds of pcb rsquo s have already left the river and entered green bay and lake michigan.в the epa further estimates that on average, 300 500 additional pounds are flushed from the fox river sediment each year.

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District judge griesbach issued a significant ruling finding that the government can require any of the seven companies to do all of the remaining work or any portions of that work.в dredging continued in 2013 with a goal to remove at least 575,0 cubic yards.в capping, which began in 2011, was also expected to continue.в в в the paper industry is a major source of toxic chemical pollution in wisconsin. The federal and state toxic release inventories shows releases of approximately 14 million pounds of known toxic substances in 1996. Modest reductions in chemical use over the years per unit of production seem to be countered by increased production. Many toxic chemicals are used in paper making, especially toxic solvents and chlorine compounds used to bleach and delignify pulp. Additional toxins are used as biocides to prevent bacterial growth in the pulp and finished paper products. In the past, toxic mercury compounds were used as biocides, contributing to wisconsin's mercury contamination problems in fish.