Element 3 - Control Strategies for Environmental Risk

Element 3 - Control Strategies for Environmental Risk

Overall Aims

On completion of this unit, candidates will have knowledge and understanding of:

approaches to risk control, including the concepts of Best Practicable Environmental Option (BPEO), Best
Available Techniques Not Entailing Excessive Cost (BATNEEC) and Best Available Techniques (BAT)
systems approach to environmental risk management
emergency planning.

Specific Intended Learning Outcomes

The intended learning outcomes are that candidates will be able to:

1. Identify appropriate risk control measures

2. Develop a systematic approach to environmental risk management
3. Participate in the development, monitoring and maintenance of emergency plans for their organisation.

1.0 Risk Control

Having first identified the hazards and estimated the risks, the next stage in the process of environmental
management is to install a series of controls. As we have seen previously, controls can take a number of forms and
may embrace both practical and procedural matters.

By now you will be aware of the environmental hazards and risks associated with a certain business, course of action
or set of circumstances. You will also be aware of the risk evaluation process, and are now ready to look at the
control strategies.

You will be aware that there are several methods used for the evaluation of environmental risk, some of which are
encompassed within legal statutes.

We must look into the appropriate control strategies to reduce the risks to the lowest level possible. These strategies
will be both procedural and physical.

1.1 Assessment to Determine BPEO

In 1988 the Royal Commission on Environmental Pollution produced the following definition of BPEO.

The outcome of a systematic consultative and decision-making procedure, which emphasises the protection and
conservation of the environment across land, air and water. The BPEO procedure establishes, for a given set of
objectives, the option that provides the most benefits or the least damage to the environment, as a whole, at
acceptable cost, in the long term as well as in the short term.

The Report Stresses:

The width of the options to be considered

The evaluation of the options for their environmental effects early in the decision-making process.
That practicable entails the option being in accordance with current technical knowledge and must not have
disproportionate financial implications.
That local derogation to BPEO should not be admitted for social or political reasons.
That it is doubtful whether there is ever a best.

A BPEO Assessment utilises the following framework:

Identification and quantification of all releases

Whether or not releases will comply with statutory emission limits
A screening exercise to identify environmentally significant releases.
 Whether or not releases will comply with statutory environmental quality objectives in the foreseeable future.
A determination of the acceptability of the releases
Identification of the BPEO from a number of environmentally acceptable options.
Identification of the process control and monitoring requirements.

The EPA 1990 enshrined the concept of BPEO as the cornerstone of integrated pollution control (IPC) For processes
that are likely to release substances to more than one medium, the Act sets the objective that `best available
technology not entailing excessive cost` (BATNEEC) should be used `for minimising the pollution that may be caused
to the environment taken as a whole, having regard to BPEO.

BPEO involves the analysis of alternatives. The preferred option is that which minimises harm to the environment as
a whole, taking account of what is affordable and practicable.

The option which for a given set of objectives, provides the most benefit (or least damage) to the environment as a
whole, at acceptable costs, in the long as well as the short term. The concept recognises that in
abating pollution there are often environmental `trade offs` (e.g. combating air emissions may create other wastes),
which need to be considered when establishing the most appropriate option to implement.

1.2 Best Available Techniques (BAT)

Defined as the most effective and advanced stage in the development of activities and their methods of operation
which indicates the practicable suitably of particular techniques for providing the basis from emission limit values
designed to prevent, and where that is not practicable, generally to reduce the emissions and the impact on the
environment as a whole

This implies that BAT not only covers the technology used but also the way in which the installation is operated, to
ensure a high level of environmental protection as a whole. BAT takes into account the balance between costs and
environmental benefits; the greater the environmental damage that can be prevented, the greater the cost for the
techniques. It seems to be halfway between practicable and reasonably practicable as understood in health and
safety law.

Central requirement of the EUs Integrated Pollution Prevention and Control Directive. This requires emission
(release) limit values for installations covered by the Directive to be based on best available techniques.

`Best` refers to the most effective technique in achieving a high level of overall environmental protection;

`Available` means those techniques developed on a scale which allows implementation in the relevant sector under
economically and technically viable conditions;

`Techniques` refers to both the technology used and the way in which the installation is designed, built, maintained,
operated and decommissioned.

An overview of IPPC is available on this link:

http://www.defra.gov.uk/ENVIRONMENT/ppc/ippc.htm

Both BATNEEC and BPEO were replaced by BAT under the IPPC regime during 2007.

Environmental Management Systems

The framework for the ISO 14001: Environmental Management System originated from the initial 14001 standard,
developed in 1996. However, a review of the standard was undertaken and a new 2004 standard issued. The 2004
edition remains, in essence, the same as the earlier standard but aims to clarify the 1996 edition and align it more
closely with the 9001:2000 standard. The 2004 standard incorporates some new definitions and revises others. In a
number of cases, the 1996 standard referred to `establish and maintain` whereas the new standard refers to
establish, implement and maintain` throughout.

1.2.1 Scope

It should be noted that the scope in the 2004 standard has been expanded to include other options for demonstrating
conformity:
 Making a self-determination or self-declaration.
Seeking confirmation from parties who have an interest in the organisation, for instance, customers.
Seeking certification or registration of the Environmental Management System (EMS) by an external
organisation.

Stage 2 Planning

Environmental policy (Clause 4.2)

Under the new standard the policy must now be communicated to all persons working for, or on behalf of the
organisation.

Environmental Aspects and Significant Impacts (Clause 4.3.1)

Aspects under the new standard are required to be documented and must be taken into account when establishing,
implementing and maintaining their EMS .

Legal, Regulatory and Other Requirements (Clause 4.3.2)

The new standard requires that the organisation must determine how legal and other requirements apply to
its aspects.

Objective, Targets and Programmes (Clause 4.3.3)

New clause 4.3.3, as above, merges the 1996 clause 4.3.3: Objectives and Targets, and clause 4.3.4: Environmental
Management Programmes.

The targets should be measurable, consistent with legal and other requirements and committed to continual
improvement.

Resources, Roles, Responsibility and Authority

(Clause 4.4.1)

(Previously structure and responsibility)

In the New Standard, management should `ensure the availability of` sufficient resources rather than `provide`
sufficient resources to ensure that it is implemented and maintained. The list of resources must now include
organisational infrastructure.

Competence, Training and Awareness ( Claus 4.4.2)

(Previously `training, awareness and competence`)

In the 1996 standard, this clause related to `all personnel` but now relates to `any person performing tasks for it or on
its behalf` and now includes contractors working on site and other personnel, who might perform an activity that could
cause environmental harm.

Contractors and other persons should be included in training programmes where they are carrying out activities that
could have a significant environmental impact.

It is now a requirement for records to be kept of training, education and experience.

EMS documentation and control of documents (clauses 4.4.4 and 4.4.5.)

A new addition to the requirement is that external documents that are necessary to the system should be identified
and controlled.

Monitoring, Measurement and Review

Stage 4 Checking and Corrective Action

Evaluation of Compliance ( Claus 4.5.2)

The clause was originally contained in clause 4.5.1., but has been separated into its own clause.

The organisation is required to periodically evaluate compliance with relevant environmental legislation and
regulations. The new standard incorporates a requirement to evaluate against other requirements in addition to
legislation and regulations, and to keep a record of the periodic evaluations.

Non-Conformances and Corrective/Preventive Action (Clause 4.5.3)

(Previously clause 4.5.2)

Control of Records (Clause 4.5.4)

(Previously `Records`, Clause 4.5.3.)

A new requirement is that records should demonstrate `results achieved`

Internal audit (Clause 4.5.5)

(Previously `Audits of the Environmental Management System`, Clause 4.5.4)

Key changes here are the requirement that the audit must address the issue of the retention of records and that the
selection of auditors should be considered to ensure objectivity and impartiality.

Stage 5 - Environmental Management Review (Clause 4.6)

The following are, under the new standard, the main inputs to the management review:

Results of internal audits and evaluations of compliance with legal and other requirements.

Communication from external interested parties, including complaints.

The environmental performance of the organisation

The extent to which objective and targets have been set

The status of preventive and corrective actions

Follow up actions from previous management reviews

Changing circumstances including developments in legal and other requirements.

Recommendations for improvement

Outputs include continual improvement, and decisions and actions for necessary changes to:

The policy
Objectives and targets
Any other element of the system

The outcome of a systematic consultative and decision making procedure which emphasises the protection and
conservation of the environment across the land, air and water .. is the definition of.......

1.
A. ? Best Practicable Environmental Option (BPEO)
B. ? Best Available Techniques (BAT)
 C. ? Best Available Techniques Not Entailing Excessive Costs (BATNEEC)

1.3 Risk Reduction Strategy

Factors to be considered in Selection of the Best Solution for an Organisation Based on Relevant Risk Data

The risk reduction strategy taken by an organisation will depend on numerous factors, but will comprise
both human and physical(or engineering) controls. Controls should aim, where the organisation will be complying
with the spirit of environmental law, whose aim is the protection of harm to the environment.

Control Strategies

Control strategies may be procedural or physical.

Some control strategies may be specifically imposed by legislation; others through more general legislation or as part
of EU and UK Government policy.

General Legislation

Legislation covers most areas of environmental management. There is legislation in place to reduce harm to health
and to the environment from air emissions, waste disposal, transport of chemicals, noise and nuisances,
water pollution and protection of wildlife (this list is not exclusive).

Fiscal Strategies

Fiscal strategies are frequently used as a control strategy. Levies and taxes are used as a control strategy, examples
include Climate Change Levy, Landfill Tax and Fuel Tax.

Some control strategies are imposed by policy, both governmental and by companies.

The UK Environmental Policy

The UK environmental policy was first set out in its 1990 paper This Common Inheritance.

The UK policy is in accordance with the EU environmental policy and covers all the major areas of environmental
management, including commitments to the following:

Protecting the physical environment.

Using resources prudently.
Controlling pollution.
Combating climate change.
Improving waste disposal and litter controls.
Improving consumer awareness.
Encouraging sustainable forestry.
Controlling pesticides and increasing the contribution of sustainable energy sources.
Improving transport choice.
Reuse of Brownfield sites.
Landscape conservation.
Wildlife preservation.
Drinking water quality.
Wider issues associated with developing countries and biodiversity, ocean management and protection of
polar regions.

1.4 Effects of Government Policy on Control Strategies

It is government policy to encourage waste reduction and recycling. There is a hierarchy of controls; reduce, reuse,
recover and dispose introduced as part of a waste strategy under Section 92 of the Environment Act 1995. For this
reason, Recycling and Recovery targets were imposed under the Producer Responsibility Obligations
(Packaging Waste) Regulations 1997, amended 2005. This means that companies are required by law to recycle
to a certain degree, and produce documentary evidence that they have done so. Waste and Producer Responsibility
are covered in more detail later.

1.5 The Environment and Insurance

Most environmental matters will normally be managed through a public liability insurance policy. However, since
1991 these policies do not give cover for incidents unless they are sudden and accidental. The ABI (Association of
British Insurers) wording is:

This policy excludes all liability in respect of Pollution or Contamination other than caused by a sudden, identifiable,
unintended and unexpected incident, which takes place in its entirety at a specific time and place during the Period of
Insurance.

In practice this means that pollution from leaking tanks, or run-off from contaminated land would not be covered by a
general insurance policy. Further, many policies only cover third party damages and do not cover own site clean up,
or regulatory authorities orders to clean up rivers or third party land.

This means that work is required to ensure that these incidents do not occur and insurance companies may also
require or recommend controls to reduce the risk of incidents.

1.6 Policies

Companies may also impose control strategies in the form of an Environmental Policy. These policies should be
backed up by management systems, appropriate control procedures and associated information and training.
Companies may further develop specific policies to cover particular areas, such as policies on purchasing, transport,
or the use or elimination of certain chemicals which are known to harm the environment, such
as CFCs (Chlorofluorocarbons).

Dependant on the circumstances, a combination of procedural and technical control strategies will be necessary.
Technical knowledge of the chemicals, machinery, etc. is essential before embarking on a risk reduction strategy. In
practice, a review or audit of the process is necessary as a precursor to determining a control strategy. The subject
of reviews and audits is discussed later in the course.

Physical Controls

In the same way that physical controls can reduce the risk to operators and others in the field of health and safety,
so can they be used to protect the environment.

Here are some examples of physical controls:

Leaks in bulk storage tanks can be contained within a bund.

Spillages can be prevented from reaching a sensitive receptor by spill containment devices and equipment.
Abatement equipment can be used to collect and treat air emissions.
Effluent treatment plant can be used to prevent untreated effluent reaching the drains.

Human Factors

Information, instruction, supervision and training are human strategies for controlling risk. Providing adequate
explanations is essential why something should be done, rather than a straight instruction is usually the most
successful.

1.7 Practical Measures for Risk Control

Control strategies for environmental risks follow a similar pattern and approach as for health and safety risks. Any
hazardous material released into the workplace may also present a risk to the environment. As we have seen in the
preceding sections, the environment also presents additional problems due to individual surroundings and
sensitivities. However, there are broad strategies of approach to be considered.

In general, the following strategy should be adopted:

Elimination is where the substance used or the process can be stopped, shut down or an alternative, less
hazardous process substituted. As an example, it may be possible to eliminate detergent from a vehicle cleaning
process.

Substitution is where a less harmful substance is used and requires an awareness of potential conflicts between
health and safety, and the environment when carrying it out.

Reduction of emissions and changes to the process may be possible by making adjustments and using the same
substance, but in smaller quantities.

1.8 Strategy Applied Specifically to the Environment

The Waste Hierarchy is used as a waste management risk reduction strategy; the Environment Act 1995 uses the
following:

The correct hierarchical order of the waste strategy is...

1.
A. ? Reduce, re-use, recycle, recovery
B. ? Re-use, recycle, reduce, recover

C. ? Recover, re-use, recycle, reduce

2.0 Systems Approach to Environmental Risk Management

Most organisations adopt a systematic approach to the management of their day to day operations. Over the years,
the different elements of such systems have become more defined, and standardised approaches have been
developed to help organisations to manage certain functions, for example quality.

In the early 1990s, work was initiated by the British Standards Institution (BSI) to develop an EMS specification,
which was first published as BS 7750 (BSI, 1992). National EMS standards were also published in Spain and
Ireland .

At around the same time, the European Commission (EC) was developing the Eco management and Audit Scheme
(EMAS), which was similar to BS 7750, but included some additional requirements. The requirements of EMAS were
published as Council Regulation 1836/93 in 1993 (EC, 1993).
Following publication of BS 7750, the International Organisation for Standardisation (ISO) developed ISO 14001
Environmental Management Systems Specification and Guidance for Use (ISO, 2004).

Its adoption as a European Standard by the European Committee for Standardisation (CEN) meant that in Europe, all
similar national standards were required to be withdrawn.

More recently, a new British Standard, BS 8555 for the phased implementation of Environmental Management
Systems has been published (BSI, 2003). It provides a staged way for organisations to implement an EMS and
achieve accredited certification to ISO 14001 and registration to EMAS; it is primarily (but not exclusively) aimed at
small and medium sized enterprises.

Any organisation that has more than a few employees needs to have management systems in place in order to
conduct its affairs rationally. The ISO 14000 set of standards and guidelines defines a core environmental
management system, and the auditing procedures necessary for verification. Accompanying the standards is material
that defines how conformity to the standards will be assessed. ISO 14000 standards do not define the specific
environmental performance goals that an organisation should attain. These are left to the organisation itself.

The international business community has been at the forefront of the development of the ISO 14000 series of
standards, and has been sought to develop standards for environmental management that are compatible with those
previously developed in ISO for quality management (the ISO 9000 series).

If a standard for the environmental management systems was to be accepted by the business community, it must be
compatible with ISO 9001. The two standards (ISO 14001 and ISO 9001) show great compatibility as regards the
management systems principles: plan, do, check, act.

The Denning circle, as these principles are so called, basically ensure good control of critical business activities
according to plan, check whether the predetermined requirements are met and where necessary, make corrections.

2.1. The Drivers Behind the Development of ISO 14001:

There were two drivers behind the development of ISO 14001:

In 1992 the United Nations Conference on the Environment and Development (UNCED: the Earth Summit) and the
Business Council for Sustainable Development (BCSD) came to the conclusion that the International business
community would need to develop International Standards on environmental performance to ensure that companies
operating around the world could do so on a level playing field.

The Committee Platform ISO Providers for Consumer Interests (COPOLCO) wanted harmonisation of product eco
labelling at an International level.

ISO established the Strategic Advisory Group on Environment (SAGE) to investigate all areas of environmental
management and performance where the development of International standards might be beneficial to the business
community.

SAGE recommended to ISO the establishment of a technical committee.

1993 ISO set up a new technical committee ISO/TC207 Environmental Management to develop standards proposed
by SAGE and to investigate the possibility of developing further supporting standards. The committee consisted of six
subcommittees and one working group ISO/TC207 and therefore the scope of the ISO 14000 series covers

`standards in the field of environmental management tools and systems`.

The structure of ISO 14000 series of standards is as follows:

Explicitly excluded from this scope are the setting of environmental performance levels, the standardisation of
products, setting limit values regarding pollutants and effluents, and test methods for pollutants (because they are
dealt with by other technical committees).

ISO 14000 series will not interfere with any national environmental legislation, but should aim to control their
environmentalaspects and improve their environmental performance.

Of central importance in the ISO 14000 series are the environmental management system standards ISO 14001 and
ISO 14004.

CORE REQUIREMENTS - ISO 14001

ISO 14001 is the most widely used EMS standard, and is one of a broad range of environmental management
standards in the ISO 14000 series. ISO 14001 is currently being revised. The purpose of the revision is to provide
clarification of the original text and to ensure, as far as possible, compatibility with the ISO 9000:2000 quality
management system standards.

A revised edition of ISO 14001 has been published. An EMS is defined in the revision to the standard (ISO, 2004)
as:

'Part of an organisation's management system used to develop and implement its environmental policy and manage
its environmentalaspects'.

Note 1 to the definition states, 'A management system is a set of interrelated elements used to establish policy and
objectives and to achieve those objectives'.

Note 2 states 'A management system includes organisational structure, planning activities, responsibilities, practices,
procedures, processes and resources'.

ISO 14001 provides an organisation's management with a structured framework for identifying, evaluating, managing
and improving its environmental performance. The 14000 family of EMS standards uses the term 'organisation' to
describe the entity that falls within the scope of an EMS . 'Organisation' is defined as 'company, corporation, firm,
enterprise, authority or institution, or part or combination thereof, whether incor porated or not, public or private, that
has its own functions and administration'. This gives a great deal of flexibility over where the boundaries of the EMS
can be set.

A proactive approach to environmental management, implementing an Environmental Management System (EMS)

enables companies to reduce their risks and liabilities, whilst enhancing their corporate image with the public,
customers and investors. The elements required for an EMS are embodied in environmental quality standards BS
7750 or more probably ISO 14001.

2.2 ISO 14001

This standard specifies the requirements for an environmental management system ( EMS ) against which and
organisation may be certified by a third party. This includes:

1. The development of an environmental policy

2. Identification of environmental aspects

3. Establishment of relevant legal and regulatory requirements

4. Development of environmental objectives and targets.

5. Implementation of an Environmental Management System (EMS) including training, documentation, operational

control and emergency preparedness and response.

6. Monitoring and measurement of operational activities, including record keeping.

7. EMS audit procedures

8. Management review of an EMS to determine its continuing suitability, adequacy and effectiveness

2.3 The Development of an Environmental Policy

An organisation should define its environmental policy. The Environmental Policy is the documented statement of
commitment from top management. This policy sets the overall EMS intentions of the organisation and contains a
commitment to prevention ofpollution and to continuous improvement.

Each Environmental Policy is unique to an organisation, is communicated to all employees and is made available to
the public. This Policy is the starting point for setting the organisation's EMS objectives and targets. It must be:

Appropriate to nature, scale and environmental impacts of the organisation.

Related to activities, products and services
Commitment to continual improvement and prevention of pollution
Compliance with laws, regulations and other subscribed-to requirements
Framework for setting and reviewing environmental objectives and targets
Documented, implemented, maintained and communicated to all employees
Made available to the public

Central to an EMS is the environmental policy. The environmental policy is a decla ration of the organisation's overall
aims and principles with respect to the environment, as defined by its senior management. It must include a
commitment to the continual improvement of environmental performance and to compliance with environmental, legal
and other requirements. The policy must also be publicly available.

All organisations have, to some extent, an effect on the environment. The policy should recognise this, giving
emphasis to those effects that are the most significant. The policy should also be used to communicate aims and
objectives to employees and other interested parties including shareholders, customers and suppliers.
In the case of a multi-site operation there may be a number of group or divisional operating statements which, when
combined, represent the view of the company as a whole. The organisation's environmental policy may be integrated
with its other policies (e.g. health and safety, quality) or it can be a standalone document.

In order to demonstrate the commitment of senior management to the environmental policy, it is often signed by the
organisation's chairman or chief executive. The following environmental policy example below is taken from
Greenacres and Company, carpet manufacturers:

Which of the ISO standards was developed for Environmental Management systems?

1.
A. ? ISO 1400
B. ? ISO 1300

C. ? ISO 900

2.4 Planning & Identification of Environmental Aspects & Impacts

An organisation should formulate a plan to fulfil its environmental policy.

At the stage where the requirements which an organisation must meet are determined, objectives and targets are
set, and a programme to achieve the targets and objectives are developed.
Environmental Aspects

Environmental aspect: Element of an organisation's activities, products or services which can interact with the
environment. A significant environmental aspect can have a significant environmental impact.

Environmental impact: Any change to the environment, whether adverse or beneficial, wholly or partially resulting
from an organisation's activities, products or services.

An organisation needs to review their operations, activities, products and services to identify which may have an
interaction with the environment. This identification of the environmental aspects includes those which occur during
normal business operations, abnormal conditions, incidents and future activities. When the aspects are identified, the
organisation needs to determine whichaspects have, or can have, a significant impact on the environment. The key
points are:

1. What are the environmental aspects of the organisation's activities, products and services? .
2. Do they create any significant environmental impacts?
3. Is there a procedure for evaluating impacts of new projects?.
4. Does the location demand special consideration?
5. How will changes affect aspects and impacts?
6. How significant or severe are potential environmental impacts should a process failure occur?
7. How often could a scenario lead to the impact?
8. What are the significant aspects considering impacts, likelihood, severity and frequency?
9. Are the significant environmental impacts local, regional or global in scale?

The organisation should:

Step 1 select activity or process - large enough for examination', small enough to be understood
Step 2 identify aspects - as many as possible
Step 3 identify impacts - as many as possible', actual or potential', positive and negative
Step 4 evaluate significance of impacts

A key element of an EMS is the process of identifying and evaluating the organisation's impacts on the environment,
and its activities, products and services that cause them environmental impacts may be positive or negative,
beneficial or adverse. They are referred to as 'environmental aspects' in ISO 14001. The evaluation is important as it
ensures that the EMS is focused on the environmental issues that really matter (those that are most significant) and
that resources and management time are concentrated on controlling and improving them.

The identification of significant environmental aspects needs to take account of the legislative, regulatory and other
environmental requirements that affect the organisation. These may be pollution control permits, laws and regulations
relating to the disposal ofwaste, or contractual requirements that specify environmental criteria required by customers
of the organisation.

For each of these significant environmental aspects, it is important that the EMS is set up to provide assurance to
management and others who might have an interest (e.g. environmental regulators and customers) that these are
being properly managed and the organisation is able to comply with the requirements. It is good practice to consult
with key stakeholders to identify what their expectations are for your environmental performance. They might have
useful infor mation and the consultation process might help to prioritise the most important issues to address in your
EMS .

When establishing an EMS , many organisations undertake an environmental review. The environmental review is a
systematic process to:

determine the impacts the organisation has on the environment, and which of them are significant;
understand which of its activities, products and services cause the significant impacts;
know which of its activities, products and services are covered by environmental legislation and regulations,
whether it is complying with them and whether this can be sustained on an ongoing basis;
know the extent to which it is controlling its significant environmental aspects and whether effective controls
are already in place; and
be in a position to develop objectives and targets for environmental improvement and implement additional
operational controls where they are necessary.

An easy way to get started on the environmental review is to map out the boundaries of the EMS and highlight areas
where there are environmental considerations. These could include internal and external drainage plans, chemical
storage points, location ofwaste skips, chimney stacks from boilers and the nearest neighbours. Alternatively, if the
EMS doesn't lend itself to being identified on a map (this is particularly the case for service organisations), a process
flow diagram highlighting inputs and outputs might be more appropriate.

The EMS should address your direct and indirect environmental aspects. Direct aspects are those caused as a direct
result of the organisation's operations, whereas indirect aspects are those over which the organisation has influence,
but no direct control. Examples of environmental aspects include:

emissions to air;
releases to water;
disposal of waste and contamination of land;
use of energy, raw materials and natural resources;
land use and habitat loss;
disposal of the organisation's products by customers; and
environmental performance of contractors and suppliers.

Consideration should be given to impacts caused during normal and abnormal oper ating conditions and
periods of maintenance and shutdown, and to significant environ mental impacts that could occur during
emergencies. Once impacts have been identified, their significance should be evaluated.

The company environmental policy is

1.
A. ? Communicated to all employees
B. ? Unique to the orgnisation
C. ? Made available to the public

D. ? All of the above

2.5 Assessing Significance

Assessing the significance of an environmental impact is one of the most difficult parts of environmental
management. There are many different tools and techniques and, frequently, more than one approach can be used
for a given situation. In many circumstances, professional judgement will play an important role in determining how to
address significance and this can be helped through consultation with appropriate stakeholders. The significance of
an environmental impact can be assessed through consideration of:

size, nature, frequency, likelihood and duration of the environmental impact;

the sensitivity of the receiving environment and the extent to which the impact is reversible;
the extent to which the impact (or the activity, product or service which causes it) is
covered by environmental laws and regulations, or contractual requirements; and
the importance of the impact to interested parties for example employees, neigh bours, regulators.

It is important that the criteria for evaluating significance are clearly defined and that the procedure and outcome are
capable of being replicated by someone else. Some organisations develop risk matrices to help them evaluate the
significance of an environmental impact and to prioritise its relative importance; however, care should be taken to
ensure that all significant impacts are identified and that there is a robust means of allocating the scores.

2.6 Establishment of Relevant Legal & Regulatory Requirements

The organisation must identify and have access to legal and other requirements which apply to the organisation's
environmentalaspects. Identify and have access to legal and other requirements applicable to environmental aspects

Development of environmental objectives and targets.

The results of the environmental review and the evaluation of the significance of the environmental impacts are used
to identify operational control measures and to set objectives and targets for environmental improvement. Objectives
and targets need to relate to the organisation's environmental policy and its environmental aspects. All significant
environmental aspects will require operational controls to ensure that actions are carried out as planned and some of
them will require objectives and targets for improvement, within the EMS .

Objectives are broad based environmental goals that the organisation sets itself for environmental management and
improvement. They may relate to a specific environmental issue, for example:

to reduce the overall amount of solid waste produced over the next five years by 25 percent; or
to manage issues that will help to deliver the policy for example to ensure that all employees receive
appropriate environmental training by the end of the financial year.

Targets are detailed performance requirements that need to be met in order to achieve the objectives. A number of
targets might be required to achieve a particular objective. In some cases, objectives and targets might relate to the
need for further research and analysis on how to achieve improvements. Where possible, objectives and targets
should be SMART specific, measurable, achievable, relevant and time related. This will help to track progress and
ensure that achievements are being realised.

The environmental programme turns the environmental objectives and targets into practical actions that can be taken
to improve the organisation's environmental performance. The programme should identify individual responsibilities
and the means to achieve the defined objectives and targets within the specified time scales. It should translate the
commitment to continual environmental improvement set out in the environmental policy into practical actions.

2.7 Implementation of an Environmental Management System (EMS)

The organisation's management will need to assign tasks to people so that everyone knows what has to be done. It is
vital, if the system is to operate effectively, to know who does what, how, when and with what authority.

Whatever the size of the organisation, the activities of all employees will have an impact on the environment. Directly
or indirectly, significant or small, everyone can contribute positively by innovating with new ideas, changing behaviour
and involving other people.

This will require information, training and the development of new skills. Different people in the organisation will need
different types and levels of training: some will require general environmental awareness training; others training as
auditors; the design team might need training on how to integrate environ mental considerations into new product
designs. The key is to make sure that people are given the knowledge and skills to fulfil their roles in the EMS and to
be able to achieve the environmental targets and objectives they have been assigned responsibility for.

Roles, responsibilities and authorities of personnel whose activities have, or may have, an impact (directly or
indirectly) on the environment need to be defined, documented and communicated throughout the organisation. The
organisation must provide adequate resources for the implementation and maintenance of the EMS .

One or more individuals need to be appointed by top management as the Management Representatives. Irrespective
of other responsibilities, the Management Representatives are given the responsibility and authority for ensuring that
the EMS complies with ISO 14001 and for reposing the performance of the EMS to top management.

The organisation needs to identify training requirements of personnel whose work may create a
significant impact upon the environment and ensure that these personnel have received appropriate training.
Awareness is required for all personnel throughout the organisation of the Environmental Policy, the EMS program
and procedures, and the actual or potential impact of their activities on the environment.

The competence of personnel performing activities, which might have significant environmental impacts, needs to be
determined by the organisation through education, appropriate training and/or experience, as required.

All relevant personnel to receive appropriate training

Train on requirements of the system and on potential consequences of denature
Competency, based on education, training or experience
The organisation needs to identify its potential for accidents and emergency situations. The organisation must have
procedures for the appropriate response to accidents and emergency situations which include the prevention and
mitigation associated with the environmental impact. Emergency plans and procedures need to be developed,
communicated and tested to help the organisation in ensuring that any unexpected incidents are effectively and
efficiently responded to by internal and external personnel.

An EMS relies on good communications for it to be effective. Internal communication needs to ensure that people are
kept up to date with how progress is being made against environmental objectives and targets, and that they are able
to influence the development of the EMS and environmental improvement programmes. External communications
help to ensure that stakeholders are kept informed of the organisation's progress and can be engaged in the
improvement process.

The EMS must be documented and procedures need to be established to ensure that everyone knows how the
system operates and what is required. Documents should be kept up to date and controlled so that only the most
recent versions are available for use. Procedures should be established to ensure that activities are carried out in the
appropriate manner.

ISO 14001 doesn't require extensive documentation. Long narrative procedures may be required in some
circumstances, but a flow diagram might be equally effective in ensuring that a task is carried out properly. Wherever
possible, organisations should build on existing systems and integrate environmental issues into them, rather than
developing them separately.

For the Environmental Management System (EMS) to operate effectively it is vital to assign tasks to people so that
everyone knows who does what, how, when and with what authority..

1.
A. ? True

B. ? False

2.8 Monitoring & Measurement of Operational Activities, Including Record Keeping

Information on the environmental performance of the organisation is essential if it is to track progress against its
environmental objectives and targets. Without reliable and robust data, it cannot be sure that it is in control of its
environmental performance, or that performance is improving as intended.

In many cases the organisation will already be carrying out measuring and monitoring activities, for example as a
requirement of apollution control licence, and should build on these in its EMS .

One of the important requirements in ISO 14001 is for organisations to carry out a periodic evaluation of legal
compliance. This is a key task, which will help to inform the organisation on its performance against environmental
laws and regulations and provide information on whether it is adhering to its environmental policy. The frequency with
which the organisation carries out the periodic evaluation should depend on the potential environmental impacts of
the activity, with the most significant being checked more often than those of lesser importance. However, it is
advisable to ensure that compliance checks are carried out at least on an annual basis.

2.9 MS Audit Procedures

Auditing helps to determine whether the planned elements of the EMS are being implemented as intended and that
the EMS is functioning as planned. It also provides information to management on the overall performance of the
system.

A Management review of an EMS is undertaken to determine its continuing suitability, adequacy and
effectiveness.
The EMS operates as a cyclical process of identifying, improving and checking. Periodic reviews by management
ensure that the EMS is achieving the desired outcomes and that the environmental policy is being implemented. It
will also provide a means for management to review the organisation's environmental performance trends to ensure
that performance is being improved.

2.10 EMS Certification & Accreditation

Organisations may decide to have an external body confirm that their EMS meets the requirements of ISO 14001;
this is known as certification. Certification is not mandatory - ISO 14001 does allow organisations to self declare that
they have met all of the requirements of the standard. However, there are a number of benefits that can be gained by
an organisation having its EMS externally certified, including:

confidence that the EMS meets recognised requirements and standards;

a means of maintaining momentum and helping to keep the EMS 'alive' and dynamic and driving forward the
process of continual improvement;
a fresh pair of eyes to review the EMS and the way that it functions; and
the potential for recognition for their achievements from third parties, such as customers and environmental
regulators.

While organisations use ISO 14001 as the specification for the EMS, certification bodies use ISO Guide 66 (ISO,
2003) as the specification for how they should operate. This is published as ISO 17021: Conformity Assessments -
Requirements for Bodies Providing Audits & Certification of Management Systems.

In order to ensure that certification bodies undertake their EMS assessments in a similar and comparable way and
that certificates issued by different certification bodies are equivalent, a process of accreditation has been
established. National accreditation bodies undertake assessments to ensure that certification bodies carry out their
assess ments appropriately and use competent people. In the UK, the United Kingdom Accreditation Service (UKAS,
2004) is the national accreditation body.

An International Accreditation Forum (IAF) has been established to ensure consistent standards between
accreditation bodies, which is achieved through a process of peer review. The IAF has published guidance to help
participating accreditation bodies undertake their work (IAF, 2001). Accredited certification to ISO 14001 is usually the
only form of recognition that is given by customers and regulators, so you should check that your certification body is
accredited through the IAF process.

Diagrammatic Representation of ISO 14001: Environmental Management System

2.11 ISO 14004

This standard was developed by ISO to provide additional guidance for organisations on the design, development
and maintenance of an EMS. This was not intended to be certified against.

ISO 14004 acts as a stepping stone to the specification for many organisations. It includes details of:

Internationally accepted principles of environmental management and how they can be applied to the design
and development of all the components of an EMS .

Practical examples of issues an organisation will need to ensure that they have addressed in the design of
the EMS, including guidance on how to identify the environmental aspects associated with their activities,
products and services.

Practical help section to provide an organisation with assistance in navigating the various stages of an EMS,
design, development, implementation and maintenance.

Support tools needed to ensure that the environmental management system meets the requirements of the
organisation, is properly implemented, and that the desired outcomes are achieved.

14004 Environmental Management Systems/Guidelines on Principles, systems and Supporting Techniques provides
assistance to organisations initiating, implementing, or improving an EMS. This document outlines the elements of an
and provides practical advice on implementing or enhancing such a system. The EMS principles include identification
of applicable regulatory requirements, commitment to continual improvement and evaluating environmental
performance on a regular basis.

There are also standards on environmental auditing and one on environmental performance.

2.12 Auditing Standards

The following is an example of an auditing standard:

ISO 19011:2002 - Guidelines for environmental auditing - General principles.

This standard replaced the previously used 3 standards:

ISO 14010 auditing guidelines

ISO 14011- auditing procedures

ISO 14012 Guidance on minimum qualification criteria for environmental auditors.

These are support tools allowing an organisation to monitor whether its EMS conforms to planned arrangements to
monitor its effectiveness and suitability and suggest how the data gathered during an audit may be formatted for
presentation to management.

The environmental audit is an independent verification of whether the environmental management system conforms
to specified criteria. This is usually conducted by a third party within a framework of a certification procedure.

The main requirements are:

Definition and documentation of the organisational structure

Drawing up an inventory of releases, wastes, energy; raw materials usage to be documented.
Inventory of legislative and regulatory requirements
Environmental effects assessment
Setting objectives and targets
Environmental management plans
Management, documentation and records
 Environmental audits; audit plan plus reports and follow-ups
Verification and testing
Personnel factors of awareness, training and qualifications.

2.13 Environmental Improvement Targets - Essential for Spurring Change & Measuring Achievement

A good target has five elements:

1. Quantifiable allowing measurements of progress, and clearly defined completion

2. Defined time-scale preferably no more than a year or two

3. Defined responsibilities achieving a target has to be someones job;

4. Integration with the main business planning cycle this ensures that environmental targets dont get trampled by
commercial priorities;

5. Publication a target which can be swept under the carpet is worse than useless. Publication brings commitment
and focus.

Certification audits are conducted at an advanced stage in the development and implementation of EMS. They
include a detailed review of the internal audit programme but are not intended to duplicate the internal audit which
has its own important purpose in checking that the EMS has been properly implemented and maintained.

EMS certification audits are traditionally conducted in two phases in accordance with the guidance specified by UK
accredited services. These phases may be combined: however, they have distinct purposes - `do as required` and
`do as you say`.

Phase 1: An organisation, or site for EC Eco-Management Audit Scheme (Regulation 1836/93) (EMAS) is expected
to comply with specified requirements as set out in ISO 14001 or EMAS and with current legislation.

Phase 2:

Auditing Standards

14013 Management of Environmental Audit Programs.

14014 Initial Reviews.

14015 Environmental Site Assessments.

14020 Goals and Principles of All Environmental Labelling.

14021 Terms and Definitions for Self Declaration of Environmental Claims.

14022 Symbols.

14023 Testing and Verification Methodologies.

14024 Environmental Labelling - Practitioner Programs - Guiding Principles, Practices and Certification Procedures
of Multiple Criteria Programs.

14030 Environmental Performance Evaluation (EPE) Standards.

14031/32 Evaluation of the Environmental Performance of the Management System and its Relationship to the
Environment.
14040/43 Life Cycle Assessment (LCA) General Principles and Practices - Inventory
Analysis/impact Assessment/interpretation.

Continue
14050 Glossary.

2.14 The Benefits of Environmental Management Standards

Operational

Identify and correct problems internally before they are discovered externally.
Will cut down on ''bureaucracy'' by eliminating conflicting national standards and replace them with one
internationally accepted standard.
Provide efficiency, discipline and operational integration with ISO 9000.
Ensures greater employee involvement in business operations.
Easier to obtain operational permits and authorisations.
Aid in developing and transferring technology.
Will help to reduce pollution.
Meet industry dopier pressure'' to obtain registration.
Create a benchmark of current practices with consistent methodology.
Aids in creating a high quality workforce.
Provide evidence of due diligence.

Marketing

Demonstrates to customers that the organisation is meeting environmental expectations.

Public relations benefit by being able to communicate a commitment to providing a safer, cleaner, healthier
environment for all concerned parties.
Meets potential national and international government purchasing requirements.
Gain awareness, recognition and understanding in worldwide markets.
Profit from marketing ''green'' products.
Provides a competitive marketing tool.
Improve international competitiveness.
Enhancing market share.
Enhancing image.

Financial

Improves relationship with insurance companies resulting in obtaining pollution-incident coverage at best
possible rates.
Elimination of costs associated with meeting conflicting national standards.
Process cost savings by reduction of input materials and energy.
Satisfying investor/shareholder criteria.
Help to reduce liability and risk.
Improved access to capital.

Regulatory

Demonstrates a commitment to governmental authorities that the organisation is moving beyond compliance
and pursuing continual improvement.
Have a probative and improved environmental programme.
Potential benefits include:

- Reduction or elimination of compliance audits.

- Reduction or elimination of costs associated with compliance audits.
- Recognition of due diligence - reduction or elimination of fines associated with environmental violations.
- Preferred government supplier status.
- Reduced monitoring and reporting requirements.
- Faster track for authorisation/consents etc.
Certification Benefits

Communicates evaluation and acceptance by an accredited, third-party professional organisation.

Negates 'conflict of interest'' claims associated with organisations that ''self declare'' the status of their
programmes.
Validates the integrity of an organisation's claims.
Provides organisations with an en-biased review of their programmes, policies, etc.
Addresses an anticipated requirement between customers and suppliers.
Addresses an anticipated requirement to compete in international markets.
Addresses an anticipated requirement of international and national and local government purchasing
departments.

Debate continues about the role of management systems in improving environmental performance.

It is true that the ISO EMS standards do not set or require standardised performance values. It is also true that two
companies who implement and are registered to ISO 14001, and who have the same certificate to show to their
customers, may be performing two quite different performance standards.

It is true that the continual improvement required by ISO 14001 is improvement of the management system itself and
not of environmental performance.

It is also true that proponents of the ISO 14000 series justify this approach by claiming that a systematic approach
will necessarily result in improved performance and that an improved system will improve performance yet again. If
the real goal is environmental performance improvement, it can only be achieved if the indirect approach of ISO
14000 succeeds.

ISO 14000 can succeed in what it sets out to do, However, it does not set out to do everything. It must be
complemented by a mechanism that sets performance requirements - whether that mechanism is voluntary or
mandatory.

The standards as written require as a minimum a commitment to comply with regulatory requirements. Thus,
although two registered companies may be meeting different performance standards they are still meeting what is
required by law. ISO 14000 provides a high level of assurance that they are managing that obligation successfully. A
customer or regulator will have greater confidence in a company with ISO 14000 over one without.

There is also value in a systems approach. Addressing environmental problems on an issue basis may produce
unexpected outcomes. It is also more difficult for a business to incorporate single issues into a business strategy. A
response to a single issue is too likely to become a cost rather than an investment. When an organisation
systematically reviews all of its environmentalaspects and impacts and integrates this understanding into its business
planning process it is more likely to have an affect on what and how things are done. It has the chance of becoming
part of the culture not merely another irritant.

2.15 EMAS Eco-Management & Audit Scheme

The Eco-management and Audit Scheme (EMAS) is a voluntary initiative designed to improve organisations'
environmental performance. It was initially established by European Regulation 1836 / 93 (EC, 1993) although this
has been replaced by Council Regulation 761 / 01 (EU, 2001).

The scheme is open to any type of organisation from any economic sector. EMAS uses the same definition of
'organisation as ISO 14001. The scheme applies in the European Union (EU); but at the time of writing, the EC is
consid ering allowing organisations from anywhere in the world to participate. Participation in EMAS is voluntary.

The overall aim of EMAS is to recognise and reward those organisations that go beyond minimum legal compliance
and continually improve their environmental performance. In addition, it is a requirement of the scheme that
participating organisations regularly produce a public environmental statement that reports on their environ mental
performance. It is this voluntary publication of environmental information, whose accuracy and reliability has been
independently checked by an environmental verifier, that gives EMAS and participating organisations enhanced
credibility and recognition.

Participating organisations are required to implement an EMS that meets the require ments of ISO 14001. In addition,
they are required to ensure that:
 they comply with legal requirements as a minimum and demonstrate the ability to do so on an ongoing basis;
the organisation's environmental performance improves over time;
dialogue takes place with interested parties over their environmental performance, and they publish a
publicly available environmental statement; and
employees are involved in the process of continual improvement of environmental performance.

To ensure that the scheme's requirements have been met, organisations are required to have their EMS verified, by
an independently accredited environmental verifier. The verifier is required to validate the reliability, credibility and
correctness of the data and information in the environmental statement, and the environmental statement must
include the following:

A clear and unambiguous description of the organisation registering under EMAS and a summary of its
activities, products and services, and its relationship to any parent organisations as appropriate.
The environmental policy and a brief description of the EMS of the organisation.
A description of all the significant direct and indirect environmental aspects that result in significant
environmental impacts of the organisation and an explanation of the nature of the impacts as related to
these aspects
A description of the environmental objectives and targets in relation to the significant environmental aspects
and impacts.
A summary of the data available on the performance of the organisation against its environmental objectives
and targets with respect to its significant environmental impacts. The summary may include figures on
pollutant emissions, waste generation, consumption of raw material, energy and water, and noise as well as
other aspects indicated in Annex VI. The data should allow for year by year comparison to assess the
development of the environmental performance of the organisation.
Other factors regarding environmental performance including performance against legal provisions with
respect to their significant environmental impacts.
The name and accreditation number of the environmental verifier and the date of validation.

The organisation is then required to apply for registration. The application must be made to the organisation that
deals with EMAS registrations in their particular member state, known as the competent body. In the UK, the
competent body is the Institute ofEnvironmental Management and Assessment (IEMA, 2004).

The competent body will check that the application is complete and consult with the environmental regulators to
ensure that the organisation is complying with relevant laws and regulations. Provided that these checks are
satisfactory, the organisation will be added onto the register. The EU EMAS register can be found
at http://ec.europa.eu/environment/emas/index_en.htm

Registered organisations may use EMAS logos to promote their achievements and their participation in the scheme.
The two versions of the logo are shown in Figure below. Version 1 indicates that the organisation is registered
whereas version 2 indicates that the information associated with the logo has been independently validated.

2.16 Lifecycle Assessment

In order to assess the environmental impact of a product properly and to be able to compare alternative products with
one another, the lifecycle assessment (LCA) tool has been developed. An LCA is a systematic way of evaluating the
environmental effects of a product using a `cradle to grave` approach in which all the life stages of a product from raw
material usage to final disposal are taken into account.

There is a great need for objective information to be able to make choices from an environmental perspective
between products and materials and in product design.

Lifecycle assessment studies have often produced as many different results because of the different LCA
methodologies available. The need for harmonisation in this area has proved that it is a typical subject for
standardisation.

Subcommittees 5 of ISO/TC207 is working on a series of standards on the subject of Life Cycle Assessment. ISO
14040, Life Cycle Assessment: Principles and Framework, is a general document that provides the principles and
general framework for LCA. ISO 14040 addresses issues such as:

Terms and definitions in the field of LCA

The various phases of an LCA
The methodological framework for the various phases
Reporting and critical review of LCAs

Auditing helps determine whether the planned elements of the Environmental Management System are being
implemented as intended and whether the system is functioning as planned?

1.
A. ? True

B. ? False

3.0 Emergency Planning Introduction

Whilst emergency planning is a requirement of an EMS, it is also a necessity under certain legislation, such as
an Authorisationunder EPA 1990 or a Permit under the Pollution Prevention and Control Regulations 2000, where
certain conditions require preparations to be made in the case of emergency conditions arising.

These conditions may arise from a variety of different circumstances.

Natural Events

Natural events such as high winds, storms or excessive rainfall can cause emergency conditions to arise at a factory,
for example:

Winds may cause wind-blown dust.

Rain can cause flooding or prevent discharges flowing away easily.
Storm sewers may overflow.

Spillages and Containment Failure

Spillages can be caused by a variety of circumstances, for example:

Road traffic accidents.

Failure of pipes, hoses or other equipment.

Once again, an analysis of the risks should be carried out. A source-pathway-target analysis should identify the
pathways and targets. Appropriate emergency procedures and equipment should then be put in place to reduce the
risk to a condition which is as low as practicable, the amount (and cost) of risk reduction measures will depend on the
potential damage that could be done if the substances escaped, and the sensitivity of the receptor.

Emergency plans can vary from complex off- and on-site plans involving the local authority and emergency services,
evacuation procedures and closure of roads and railways, to a small number of local procedures and spillage kits, to
cover the spillage of a low risk chemical in a low risk situation.
The former scenario would be a requirement of the COMAH (Amendment) Regulations 2005. Such sites will have
an emergency officer, with a dedicated control room, meteorological information, drain plans, road plans, etc. and
usually a media communication officer. It is always prudent to practice emergency procedures, and most companies
will have invited the emergency services (particularly the Fire and Rescue services) to the site as part of the planning
process. Having an inventory of the chemicals in use on the site and information concerning services (electricity, gas,
water, etc.) is essential.

Disposal of Fire Water

Fire water can pose particular pollution problems. It has the potential to be contaminated with a mixture of
combustion products, chemicals and possibly fire fighting foams, all of which can do harm to surface waters or
sewage systems. Polluting a water course or the sewage system may be an offence, even if there was an emergency
situation prevailing. It is therefore preferable to consider the disposal of fire water prior to the emergency situation.

Possible solutions include sacrificial areas, retention tanks and containment bunds.

The Environment Agency issues a number of advisory leaflets called Pollution Prevention Guidelines, to explain best
practice in this and other related subjects (they can be found
at: http://www.netregs.gov.uk/netregs/links/63875.aspx). This subject will be explored later. Fire water is discussed
in Planning Policy Guidance 18: Enforcing Planning Control.

3.1 Emergency Planning

1. On-site Emergency Plan

Emergency Planning is necessary to cover a wide range of eventualities including those listed. However most
detailed planning tends to relate to 'major' accidents and incidents which affect neighbouring sites or the general
public.

An emergency plan will vary depending on the site and the nature of the business. However certain essential
features are common to any plan.

It should provide simple and logical procedures for effective direction and Co-ordination of an emergency incident. It
must deal with an incident in a way which triggers' off-site responses, emergency services safeguards personnel
minimises damage to plant and equipment prevents escalation safeguards neighbours, restores the site to normal
operation as rapidly as possible, minimises on-site and off-site pollution.

An inherent part of planning is to ensure that personnel who may be involved in a site emergency incident fully
understand their own role, and appreciate the roles of others, in dealing with it.

Categorising the Incident

A primary consideration is the means by which people are warned that an emergency has occurred. This may involve
bells, sirens, horns etc. but, the alarm must be audible to everyone likely to be affected', everyone must know what it
means and what action to take.

On a small site an emergency will affect the complete site. Hence a common warning system is required to alert
everybody. However, an occupier of a very large site, with possibly several independent units, would not wish to close
the whole site as a result of an emergency that may possibly be contained in one part of a complex. A two tier
warning system is then required, a local warning and a warning to the whole complex.

Pre-planning should include a system for categorising the incident. This needs to be achieved quickly by someone in
authority who is always available on site. There are four typical categories, namely 'Minor Incident' or Categories 1 to
3.

Minor Incident

A 'Minor Incident' is an emergency which can be dealt with fairly effectively and quickly by personnel on the spot
using the emergency equipment on hand, e.g. fire extinguisher. The situation can be dealt with by the work force, and
possibly the Works Fire Brigade, fairly quickly. It is fairly localised so that no other units are affected.

Category 1 - Incident
This is an incident requiring additional resources, but which can still be dealt with successfully by the site operator
and internal fire brigade. However whilst tackling it some thought needs to be given to whether, and when, the public
emergency service should be notified.

A Category 1 incident could escalate and the personnel on site may need assistance quickly. If the total site forces
are at full capacity dealing with a protracted incident then back-up resources may be needed. Since there can be no
guarantee that a second incident will not occur it is prudent to guard against this even though the first incident is only
of Category 1.

Category 2 - Incident

This is one which is clearly recognisable from the outset as being beyond the capability of the forces to hand. A
message would therefore be sent to the Emergency Services informing them of a 'Category 2 incident' at the specific
location. By virtue of good pre-planning the resources sent in response will have be pre-determined, e.g. the number
of fire appliances, ambulances, police etc.

Category 3 - Incident

This is an emergency of major proportions. It may have escalated from a lower category incident or arise
instantaneously, e.g. due to a confined or unconfined vapour cloud explosion. Good pre-planning will again have pre-
determined the response from the Emergency Services. Extensive evacuation of the general public may have to be
initiated.

Following the Three Mile Island nuclear power plant accident in 1979 the Commission set-up to enquire into it were
concerned by the highly uneven quality of emergency plans and by the problems created by multiple jurisdictions in
an emergency.

Emergency plans generally rely upon prompt action at local level to inflate a needed evacuation or to take other
protective action, whereas there was an almost total lack of detailed plans in the local communities around Three
Mile Island (see below).

3.2 Three Mile Island

An explosion took place, which involved a pressurised water nuclear reactor. In this type of reactor, heat is removed
from the core by a pressurised water circuit via a heat exchanger. The boiling water in the secondary circuit is used to
drive a steam turbine. The radioactive parts are enclosed in a containment building.

A fault occurred in the secondary steam circuit, which resulted in the steam turbine tripping out. It had the effect of
preventing heat removal from the reactor core. The heat produced in the core was stopped automatically by the
lowering of absorption rods. This reduction was not instantaneous, so some heat was still generated by radioactive
decay and the primary water boiled. This is not a serious fault. A relief valve lifted and the make-up water pumps
operated automatically to replace water, which had evaporated. The relief valve stuck open, but the control room light
indicated that it was closed. The operators should have realised what was actually happening by comparison with
other readings. The actual situation was that the valve was open and the primary water was boiling, but the pumps
were replacing the water. If the operators had done nothing, the system would have cooled naturally and safely.

However, they shut down the pumps because they had been warned of the danger of too much water in the primary
circuit. The water level fell and temperature damage occurred, resulting in the release of radioactive material when
the containment closure ruptured. A major factor was that the operators did not understand the relationship between
pressure and temperature in the primary circuit. The boiling point of water depends upon the pressure, a fact which
the qualified operators were unaware of.

Modern training takes place in a simulated control room. The operator is presented with readings and is expected to
diagnose faults and suggest remedial action. All foreseeable scenarios are learned. Inherently safe designs are now
proposed and in use.

3.3 Calling-in Vital Staff

Key personnel need to be called-in if they are not already on-site when an emergency develops. These include:

staff able to continue operation of the plant safely

management who can take top-level decisions
 staff able to deal with the aftermath of casualties
public relations staff to deal with the media
staff able to co-ordinate pollution control, clean-up

Hence pre-planning includes preparation of a 'call-in list' with the proviso that 90% of personnel will respond when
called.

A specific person on-site will have been designated to do the 'calling-in'. A large organisation will probably have an
on-going Communications Control Centre, with adequate communications equipment, from which a Communications
Co-ordinator can function. In a smaller factory someone in the Security Office may have this responsibility. In any
event a dedicated telephone, which is ex-Directory and which has a number known only to the few people required to
respond to a call-out, is essential since the main switchboard is likely to be overloaded by incoming calls.

Responsibilities/pre-planning

When the nucleus of personnel with a pre-planned function in the emergency operation arrive on site it is essential
that each person understands clearly, and is well practised in the function that they have to perform.

One person e.g. a Duty Manager, Shift Manager or Shift Superintendent will have responsibility for responding
immediately to an incident and for taking charge. The priorities will be:

rescue of personnel, where appropriate' assessment of whether there are casualties or whether people may
be missing and should be searched for
carrying-out appropriate process action so that the situation does not escalate further ensuring that the fire
brigade, or other personnel trained in initial first aid/fire fighting, are present',
initiating some form of 'head count'.
control of spoilages, run-off etc.

Accounting for people can be very difficult, especially if large numbers of contractors personnel are on-site', hence
the advantage of site logging-in procedures at all times.

Instructions should also be posted in each workplace stating:

where personnel should go, by which route/alternative routes in an emergency',

to whom they should report on arrival',
what to do if they are unable to go to the nominated assembly point.

Managing an emergency effectively relies heavily upon serious pre- planning. This will cover for example

Procedures for the rapid assessment of the likely consequences in the event of e.g. loss of containment of a
hazardous material (e.g. to identify the nature and quantity of material lost, to check wind direction, to
determine probable areas to be affected from a map, and the likely population density threatened and
environmental impact)
Provision of sets of process manuals, flowsheets, plot plans etc. ready for immediate use
Lists of mechanical equipment available e.g. diggers, cranes, lifting equipment, and of emergency supplies
e.g. sand, wood

3.4 Provision of Action Lists, Lists of Emergency Contacts

Responsibility may subsequently be transferred to a more senior Emergency Manager, or one with more appropriate
specialist knowledge.

Dealing with Emergency Services and Respondents

In a Category 2 or 3 incident provisions are necessary to deal with the arrival on-site of both the Emergency Services
and personnel responding from outside. The plan should hence allocate designated locations for ambulances, fire
appliances etc to park until required ans a location for Emergency Services personnel to report to.

One lesson from the Milford Haven tank farm fire in 1983 was the importance of planning for good access for the
large number of foam tankers and appliances required to fight such a large fire. Some difficulties were encountered
because of the congestion around three elevations of the tank and on roads not designed for such traffic.
Route markers may be necessary on a large site to direct traffic to the various locations, since facilities may not
always be available to escort them to the scene.

Numerous employees may live near a large site', they will certainly hear of any Category 2 or 3 incident and a
proportion will come in voluntarily. Since they have no specific functions in the plan, the preferred arrangement is to
have everyone report to a designated area where they can be held until needed or sent home again.

Following a major incident the roads leading to a plant may become clogged with vehicles as the public flock in to
watch. Therefore in pre-emergency planning the police will have arranged to erect road blocks on essential roads to
allow easy access for key personnel and the emergency services. The plan must therefore include agreement with
the police on a form of identification for essential personnel, e.g. a car windscreen sticker.

3.5 External Liaison

The media tend to arrive in a surprisingly shod time e.g. with the first few fire engines. A way of dealing with the
press, enabling them to gather news and report on a major incident, should therefore be included in the plan.

3.6 Communications

A sound communications plan, operated by nominated staff, trained in advance to handle specialised equipment is
certain to modify the effects and assist materially in survival and eventual recovery. However common experience is
that communications tend to breakdown in a major emergency.

In 1971 an escape of gas from a four-inch gas main into a large unventilated void beneath shops in a Shopping
Centre in Renfrewshire exploded. Thirteen people were killed and at least one hundred were trapped or injured as
shops collapsed and lines of cars from the rooftop parking area crashed down onto shattered concrete and twisted
girders. The rescue and recovery operations were speedily and satisfactorily coordinated by the police. However they
complained that there were too many mobile phones in use, resulting in a near break-down in communications.

Since a Loud Hailer was ineffective, wireless operators had to search on foot for people on-site, resulting in loss of
time. Thus provisions for primary and emergency communications (internal and external telephone links and radios)
need careful assessment.

If hand-held radios are used for communication between personnel and a central point a dedicated wavelength is
desirable, otherwise those not actually involved in handling the emergency will be able to interject enquiries.

In plants where there is a flammable hazard on-site radios will be intrinsically safe/flameproof for the particular
environment. Hence it may be necessary for Emergency Service personnel to pick up appropriate radios on arrival.

3.7 Training/Exercises

Every part of an Emergency Plan has to be understood by all the parties likely to be involved, including all the
Emergency Services. Detailed instructions have to be issued to all those required to act to control, or minimise the
effects of, a major incident.

Everyone on-site needs to understand the Plan and the procedures in it, irrespective of whether or not they are likely
to be involved. They should be familiar with the different alarms (e.g. on large works the alarm system may be
selective) so as not to confuse them, or to mistake a process plant alarm (e.g. high level or high pressure) for a
fire/toxic gas release signal. They should all be familiar with the actions to take, escape routes, assembly areas etc.

Thorough training including realistic practical exercises, with participation by outside services are important. A full
scale rehearsal is recommended at least once a year, with the emergency services actually turned-out. Following
each rehearsal, modifications can be introduced to cater for errors and omissions that are reported.

3.8 Monitoring, Measurement & Review

It is an essential element within any EMS that provisions are made for emergencies.

Both physical and human controls are part of an emergency plan. The plan should be proportionate to the risks.

Emergency preparedness and response plans may include the following elements:

On-site emergency response teams and equipment.

 Key personnel duties, responsibilities and contact details.
Inter-relationship with and contact details for off-site emergency services.
Internal and external communication plans.
Training arrangements and practice drills.
Detailed response measures for each type of emergency incident including personnel response and
equipment needs.
Supportive data on inventories, locations, method of storage and potential effects on the environment of the
full range of chemicals held on the site.

All such plans should be practised and tested periodically.

3.9 Integration of Management Systems

The following is the Institute of Occupational Safety and Health (IOSH) policy statement on the Integration of
management systems for OSH, environmental performance and quality taken from the IOSH website
(www.IOSH.co.uk).

The preamble has been omitted.

The policy statement was written before the publication in draft by the British Standards Institute of the harmonised
Occupational Health and Safety Series (OHSAS) specification 18001. Thus Safety and Health Management Systems
are moving towards assessment and certification.

IOSH Policy Statement

Introduction

The Institution believes that all organisations should determine the need for, and practicality of, integrating their
management systems for occupational safety and health ( OSH ), environmental performance and quality, and where
appropriate other topics such as product safety and security.

An Integrated Management System (IMS) offers organisations the opportunity to improve, among other things,
business effectiveness as well as OSH and environmental performance.

However, the process of creating, maintaining and developing an IMS is not easy. There are many challenges that
must be addressed prior to making a decision to integrate, when planning integration, and when maintaining and
developing an IMS.

Organisations that do not consider these matters may make inappropriate decisions in relation to their needs and
required competencies, and at best fail to capitalise on the benefits of an IMS. Organisations with a positive culture
are most likely to introduce an IMS that promotes more streamlined procedures and more inclusive and more ejective
decision-making.

The Institution recommends that organisations should consider the following matters when deciding whether or not to
integrate, in whole or in part, their management system for OSH, environmental performance and quality systems.

Organisations may need to evaluate carefully the impact of many of the issues identified, perhaps using formal
techniques, e.g. cost benefit analysis and business risk appraisal.

The case for integration

The Institution believes that the principal factors that favour the case for integration are:

a well-planned IMS is likely to operate more cost-effectively than separate systems, and facilitate decision-
making that best reflects the overall needs of the organisation',
an IMS offers the prospect of more rewarding career opportunities for specialists in each discipline',
the objectives and processes of management systems are essentially the same.

The Institution believes that the principal factors that favour the retention of largely independent systems are:

That the existing systems may simply work well.

 The process of integration may threaten the coherence and consistency of current arrangements that have
the support of everyone involved', relevant specialists may continue to concentrate in the area of their core
expertise and further specialist training may not be needed',
The models on which each management system is based may appear compatible, but there are conceptual
differences that may be difficult to reconcile, for example, quality audits assess compliance with a system
standard, however deficient, whereas an OSH audit should evaluate effectiveness, as well as compliance.

Furthermore, uncertainties regarding the meaning of key terms - already a problem in OSH - would be exacerbated in
an IMS; an IMS could become over-centralised and over complex without the capacity to give sufficient consideration
of local needs and constraints. Already many employers and employees are sceptical of the excessive bureaucracy
of existing management systems'.

The time during which an organisation is planning and implementing an integrated system is a period of
organisational vulnerability. Existing procedures may lapse, or be found wanting, at the moment when key personnel
are focusing attention on the development of new systems'.

System requirements may vary across the topics covered, e.g. an organisation may require a simple quality system
but a more complex OSH or IMS could introduce unreasonable environmental performance system.

Bureaucracy into, in this case, quality management'.

There may be distortions in IMS coherence associated with: (i) BS EN ISO environmental performance and quality
standards. These are certifications but the BS Guide to occupational health and safety management is not. It is
important to understand that a well-designed IMS should be able to overcome many of the problems listed here.
Organisations should recognise that the case for retaining largely independent systems is partly that the process of
creating an effective IMS is difficult, and partly that an IMS however well designed, may be irrevocably flawed.

We have in mind, for example, an organisation that manufactures a simple product to a customer specification, but
involves the use of dangerous machinery and the creation of toxic waste. By way of contrast, a computer software
company would need a highly sophisticated quality management systems but simple (by comparison) OSH and
environmental performance systems. In the latter case, a decision to integrate would be bizarre.

OSH and environmental performance are underpinned by statute, but quality management system requirements are
largely determined by customer specification', professional/organisational rivalries may impair the collective operation
of the system. Typically, a senior quality manager might seek to impose quality audit objectives on a more junior OSH
team. In contrast, the quality management team might resent supervision by an environmental manager who lacks an
intimate knowledge of quality control statistical techniques', regulators and single-topic auditors may have difficulty
evaluating their part of the IMS when it is (quite properly) interwoven with other parts of no concern to the evaluator'.

The work of external consultations may be impaired because the needs of business confidentiality could prevent
them taking a rounded view of elements of the IMS;

. . a powerful integrated team may reduce the ownership of the topics by line management', and a negative culture in
one topic may unwittingly be carried over to the others.

The prerequisites for integration

The Institution recommends that organisations should not decide finally to establish an IMS until the following
prerequisites to integration have taken place. The organisation should have:

reviewed the overall business case for an IMS;

reviewed the adequacy of existing arrangements and future needs of each management system which will
form part of the IMS',
identified the key skills and training needs of each system that must be retained within the IMS (e.g current
arrangements for OSH induction training) and the appropriate level of detail applicable to each',
decided on the phasing and extent of integration.

It is possible, for example, that organisations will start to integrate at the policy and strategic planning levels, and also
within 'sharp end' operational procedures and systems.

However, they may wish to maintain separate procedures in the short term for specific tasks such as energy
conservation, quality control techniques, and statistical analysis of probative and reactive OSH data. Organisations
may decide to postpone, perhaps indefinitely, integration of the OSH, environmental performance and quality
repayments; consulted widely throughout the organisation. Many personnel will have extra work to do to achieve an
IMS and their full support is essential as is the enthusiastic support of top management for the IMS especially their
commitment that appropriate resources will be made available'.

The Institution will study the recommendations of any industry-specific IMS standards, and considered the need to
take external advice as appropriate; and decided on the measurable criteria that would be used to monitor and
review the effectiveness of the IMS.

The process of integration

The institution recommends that organisations should decide:

On the choice of an overall IMS model, e.g. selecting one of the two models given in BS8800. Caution should
be exercised if the BS EN ISO 9000 series approach is adopted because it is the least generic of the
standards, and does not include explicit considerations of risk assessment. Many organisations may have
developed quality systems that follow too slavishly the sequences of topics given in that standard;

How to retain the integrity and effective functioning of existing systems while the new system is developed
and put into place;

Whether piloting parts of the IMS is necessary prior to its planned introduction.

On a phased plan showing the milestones of an IMS, and the specific responsibilities of individual members
of staff;

On appropriate arrangements for training needs analysis and training covering both competence and
commitment; and

On the introduction of a continuing programme designed to retain the commitment of all affected personnel.

Maintaining and developing integration

The institution recommends that the organisation should make adequate arrangements to ensure:
That the impact of changes in standards/regulations/best practice in one element of the IMS has a positive,
or at least a neutral, knock-on effect on other elements of the system.

That it is in a position to respond, when necessary, to a potentially significant event (internal and external)
affecting one (or two) parts of the system; and

A streamlined updating procedure is developed as the combined system may be more difficult to change.

Useful Documents:

British Standards Institution, BS 8800: 1996, Guide to occupational health and safety management systems
British Standards Institution, BS EN ISO 9001: 1994, Quality systems: model for quality assurance in design,
development, production, installation and servicing
Chemical Industries Association (1995), CIA RC51, Responsible care management systems for health,
safety and environment
Health and Safety Executive (1997), HSG65, Successful health and safety management

Emergency preparedness & response plans may include...

1.
A. ? On site emergency response teams and equipment
B. ? All of the above
C. ? Key personnel duties, responsibilities and contract details

D. ? Internal and external communication plans

4.0 Summary

We have looked into the control strategies that are available to the environmental manager. Some may be dictated by
environmental law, others by company or other policies. A policy is only the first step in a whole strategy and the
policy, to be effective, should be backed up by a management system.

Although an environmental policy is not compulsory (unlike a health and safety policy), it is a requirement of many
customers, suppliers and other stakeholders. The responsibilities and arrangements of the health and safety policy
will be found in the body of the EMS, which has many clauses, each with the purpose of facilitating and
demonstrating management of a particular area of environmental management.

ISO 14001 is the principle standard which deals with environmental management systems. It is international,
certifiable, and widely used throughout the industrialised world. EMAS, on the other hand, is the European
registration system which covers the same area. It is very similar to ISO 14001, but differs in one main respect, which
is that it requires that organisations registered to EMAS issue an Environmental Statement

(Note: this is not the same statement which is required by the Environmental Impact Assessment Regulations).

All of these standards (or in the case of EMAS, a registration system) require self-auditing, although to achieve a
recognised certificate, the system must be externally certified by a body accredited to UKAS or similar organisations
in other EU countries.

The ultimate guiding statement is the environmental policy which makes specific commitments, including compliance
with environmental law, and often supplemented by other policies on specific subject areas such as transport or
energy.

Governments also have policy statements and the EU and UK policies enshrine international agreements,
whose overall aim is to protect the environment.