Guardians of the green: Why auditors must do more

© Alheit du Toit"I think the world is realizing we can't just be turning all land into cropland, we need the natural parts of it too," maintains Alheit du Toit, environmental consultant (right). He's also involved in the training of auditors, where he aims to convey to them their burden of duty. He feels very strongly about it.

"An auditor's responsibility is so large, they are basically our environmental police out here. I understand the auditor is in a difficult place: the farmer pays you to come out to the farm to conduct an audit, and it's not great when it turns sour. You get those farmers who chase auditors and consultants off the farm. But the auditor is there to come audit farmers against a standard to which they voluntarily subscribed."

As an example, he offers the GlobalG.A.P.'s requirement that a producer hasn't converted virgin land to farmland during the past decade. Very easy to check on Google Earth, he says. Too many auditors, though, simply accept a denial without evidence.

He continues: "It sounds rough, but you just can't take a farmer's word for everything. An auditor should take five minutes to look at the farm on Google Earth or other means, work out the hectares of natural vegetation versus cultivated land, and compare it over time. This is where I like what Rainforest Alliance (RA) and Union for Ethical BioTrade (UEBT) require: ahead of the audit, you upload maps/electronic polygons of your farm. Their GIS specialists go through it, ask for supporting evidence, and if you can't provide it, the audit cannot go ahead except if proof of formal approval from the Department of Environmental Affairs is provided."

If land was cleared without approval, Du Toit explains, proof of a Section 24G of South Africa's National Environmental Management Act (NEMA) is required as proof that the farmer is rectifying the unlawful commencement or continuation of listed activities that require environmental authorization."

Audits are expensive, and since it has to take place during harvest, many producers arrange to complete the audits for various standards on one day. (Producers would love a single standard that encompasses all of the salient points, he remarks.)

This can mean as many as four audits, like GlobalG.A.P., SIZA (Sustainability Institute of South Africa) Social and Enviro, LEAF, with additional add-ons, Albert Heijn, TESCO, GRASP, on a single day.

Tesco's LEAF "a nice one to audit"
He notes that, due to time constraints, auditors may prioritise certain areas during one audit cycle and plan to revisit others in subsequent audits. "It's not that points are intentionally skipped," he explains, but the auditor has a lot to get through, and in the process, important facts can also slip through.

TESCO's new add-on called LEAF has gone some way to address that, he says. The inclusion of LEAF has contributed to longer audit durations, and he likes that. "LEAF is a nice one to audit. It's an environmental assurance standard that puts a bit of pressure on producers. Because they already have the SIZA Environmental, they are largely prepared, but LEAF brings in a few interesting new points."

LEAF and SIZA Environmental expect a farmer to be acquainted with the conservation status of the farm, the possible presence of endangered species or biomes, as well as the existence of archaeological and historical sites. This requires a visit by an ecologist at least once in five years to verify the proffered information.

LEAF's very British focus on birds and their nests is one that resonates with him: South Africa's national bird, the blue crane, is listed as a vulnerable species. It lives and breeds on farms in the Southern and Eastern Cape, and it had been a success story – until 2010, and its numbers have been in decline ever since. "The conservation of something like the blue crane is thrown into the hands of a citrus or a wheat farmer."

Not a requirement yet, at the moment LEAF nudges a farmer in the direction of habitat conservation or habitat creation, recommending that at least 10% of the total farm area is managed as habitat, not active cropland.

For farmers in historically intensively cultivated areas – an apple area like Grabouw comes to mind – this approach necessitates deep-seated changes to a farm.

Listing notices 1, 2 & 3: All a South African farmer needs to know
SIZA asks whether farm management is aware of the relevant legislation because ignorance of the law is no excuse. "But it doesn't help that the producer takes me to the agriculture department's webpage with the link to the legislation. I would rather producers be asked whether they have gone through the listing notices and identified, in advance, the activities they could possibly carry out that would trigger the law."

Listing notices one to three are, he says, "environmental bibles", describing every possible form of activity on a farm (and elsewhere) that triggers the law and calls for environmental authorization, ranging from the general requirements in listing notice 1 down to the localized granular level in listing notice 3.

An activity like clearance of one hectare or more, for instance, in general triggers the law and calls for an impact assessment. The National Spatial Biodiversity Assessment of 2004 identified particular areas as vulnerable, and these are set out in listing notice 3 as they pertain to all manner of activities. For example, a farmer in the Western Cape needs environmental authorization before clearing "a mere" 300 m² (or more) of indigenous vegetation.

Du Toit believes that the law works and that legislation does drive behavioural change. But for that to happen, auditors need to ask the hard questions. "Auditors are at the frontline of protecting the environment on farms. We visit farms year after year, and every year our knowledge base increases. Producers are definitely becoming more environmentally conscious."

For more information:
Alheit du Toit
Email: [email protected]