Page:Niger Delta Ecosystems- the ERA Handbook, 1998.djvu/240

Human Ecosystems: Okoroba-Nembe Environment
 * realise protection of the environment through preventive and curative measures; pertain conservation measures to minimisation of emissions, effluents and wastes which are known to have a negative impact on the environment;
 * strive at continuous improvement of efficiency in the use of natural resources and energy; *implement the environmental policy by means of the Environmental Management System.

The policy is defective in a number of obvious ways: for instance, it seems to deal primarily with health and safety so as to satisfy insurance requirements, while the environmental issue has been tacked on at the end. The last item of the statement does refer to the Environmental Management System, which may or may not exist, but which certainly does not work in practice. In practice, ERA's experience suggests that Shell does not take seriously any of the three items referring to the environment which precede the reference to an environmental management system. The stated policy should not be taken as anything more than a piece of cynical public relations which is not meant to bear any relation to operational practice.

We have asked Shell to let us have a description of the Environmental Management System (October 1996).

Shell's lack of a pro-active environmental policy which can be easily implemented in the field as part of its operational practice, means that the company has a fire-fighting approach to environmental issues, which is of no use to either itself or to the local people amongst whom it works.

Thus ERA maintains that Shell must have a realistic environmental policy which it can translate into action. Such a policy would be a part of operational practice rather than just tacked onto the health and safety policy. For every activity in which Shell is involved either as the operator or major partner, the policy would include: 238
 * undertaking an EIA in participation with the community and making such an EIA a public document which is readily available to the public;
 * undertaking all the mitigations arising from the EIA;
 * evaluating with the community the real costs of the mining activity to the community and assisting the community to use compensation paid to its best advantage;
 * monitoring, with the community, the implementation of the mining activity and of the mitigations recommended by the EIA; and
 * working with the community to clear up after mining activity has ceased.