5. Implementation of the Code of Practice

• 5.1 Initial Planning
  • 5.1.1 Analysis of Current Situation
  • 5.1.2 Development of Custom Procedures
  • 5.1.3 Employee Training Plan
  • 5.1.4 Protocol for Auditing the Effectiveness of Custom Procedures
• 5.2 Implementation of the Code
  • 5.2.1 Performance Audit of Improved Procedures

Implementing the Code should result in controlling and minimizing particulate matter and PM_2.5 emissions for the institutions concerned. Successfully achieving this may include an implementation plan and self-monitoring by the facilities, which will have the further effect of facilitating the work of employees affected by the Code. This section does not provide specific recommendations. Instead, it outlines a general approach to developing individual work methods, applying them and following up on them on a regular basis to improve or maintain performance (Figure 5-1). The institution concerned could take a different approach depending on its needs and structure.

Figure 5-1: General Approach to Implementing Best Practices by an Institution Subject to the Code of Practice

Implementing new work methods proposed by a code of practice may become complex in terms of both work relations and expected performance if initial planning is not done carefully. It is therefore advisable to analyze the current situation in the plant in order to carry out individual procedures based on the recommendations of the Code. After the new practices are implemented, it is important to ensure that they are effective and are yielding the expected results. Such analysis should follow a predetermined protocol for auditing on-site activities relating to the new practices.

The purpose of the initial analysis is to obtain not only relevant information and data on the technologies in place, but especially the operating, control and maintenance methods of the plant in question. This information may include photos, operating schedules and diagrams, and conversations with employees. A questionnaire or checklist would also be an appropriate tool for this task. This review should be based on critical PM_2.5 emission activities (operation of an alumina reduction plant, operation of a prebaked anode plant, facilities monitoring and maintenance, gas treatment centres and other scrubbers, materials handling and storage, fuels) and then compared to the recommendations in the Code.

The initial analysis also establishes one or more benchmarks for PM_2.5 emissions to be used as reference points for improvement. These benchmarks can be both quantitative and qualitative. They can be reassessed during audits on the performance of the new practices (Section 5.2).

Based on the results of the initial analysis, opportunities for improvement in reducing PM_2.5 emissions could be identified for one or more of the critical activities concerned. The project manager could thus develop his or her own recommendations (in a custom document) on the basis of recommendations provided in the Code and the plant’s unique characteristics. It is important to mention that the development of custom recommendations may mean adopting practices that are not mentioned in the Code but would nonetheless reduce PM_2.5 emissions, according to the project manager’s analysis. The Code is not restrictive in this regard.

Preferably, the establishment of new procedures should bear in mind the opinions and needs of site employees. Under normal circumstances, consultation should facilitate the implementation of the new procedures at the appropriate time and prevent problems that might arise if employees are not consulted.

From a strategic standpoint, it is advisable to prepare a training plan for employees required to modify or implement new operating procedures. Sharing relevant information with individuals who have a direct or indirect role in relation to PM_2.5 emissions would yield maximum performance. Successful training depends, first and foremost, on properly prepared documents and various training workshops as well as on the standardization of the new procedures.

New or modified procedures should be monitored regularly to ensure they are yielding the desired results. An audit should preferably be carried out using a protocol developed alongside the procedures. The best approach is to prepare a checklist with qualitative and quantitative questions to assess the current situation properly. Where applicable, this checklist should contain the benchmarks established following the initial analysis. This protocol should also provide for a consistent audit methodology.

Following training workshops, new procedures should be used according to a specific schedule to prevent certain problems that may arise as a result of changes. It is to be expected that the results (for PM_2.5 emissions) of new procedures will not be optimal at the beginning and that corrections will probably have to be made after the initial audits. This audit–correction cycle should be applied continuously even when the level of PM_2.5 emissions is deemed minimal according to the project manager’s assessment.

It is recommended that an audit of new procedures be carried out quite frequently at the beginning (e.g., 6–12 months) according to the protocol developed for that purpose (Section 5.1.4) in order to fine-tune procedures. When all the procedures are diligently followed by the staff concerned, audits could be undertaken less frequently. They will nonetheless have to be maintained at a reasonable frequency for quality control purposes.

Referring to the audit report, the project manager will have to make decisions (e.g., based on the benchmarks) on what approaches to take to correct or improve the situation, as the case may be. For all practical purposes, this step will involve making modifications to the procedures, which should be shared with the employees concerned according to the training plan.