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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.

Recommended

tuition

time

not

less

than

hours

Relevant statutory provisions:

Control Of Major Accident Hazards Regulations 1999 and amendments thereto, 2005
HSG 191 Emergency planning for major accidents. Control of Major Accident
Hazards Regulations 1999
Civil Contingencies Act 2004

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 Best Practicable Environmental Option.
In 1988, the Royal Commission on Environmental Pollution produced the following definition
of Best Practicable Environmental Option (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 decisionmaking 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.
That option will, for a given set of objectives, provide 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 covers not only 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.

A central requirement of the EUs Integrated Pollution Prevention and Control Directive
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 preventative 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.

Question 1.
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.......
Multiple Choice (HP)
Answer 1: Best Available Techniques (BAT)
Response 1:
Jump 1: This page
Answer 2: Best Practicable Environmental Option (BPEO)
Response 2:
Jump 2: Next page
Answer 3: Best Available Techniques Not Entailing Excessive Costs (BATNEEC)
Response 3:
Jump 3: This page
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, for the
prevention 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, including levies and taxes are frequently used as a control strategy.
Examples of this 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
responsibly 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 saying 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 to those 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:

Question 2.
The correct hierarchical order of the waste strategy is...
Multiple Choice (HP)
Answer 1: Re-use, recycle, reduce, recover
Response 1:
Jump 1: This page
Answer 2: Recover, re-use, recycle, reduce
Response 2:
Jump 2: This page
Answer 3: Reduce, re-use, recycle, recovery
Response 3:
Jump 3: Next page
Question 3.
Companies environmental policy should be backed up by management systems, appropriate
control procedures and associated information and training.
True/False (HP)
Answer 1: True
Response 1:
Jump 1: Next page

Answer 2: False
Response 2:
Jump 2: This page
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 was developing the Ecomanagement
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 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 were 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 ensures 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 environmental aspects 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.
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 environmental aspects'.
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 incorporated 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 an 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 of pollution 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 declaration 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:

Question 4.
Which of the ISO standards was developed for Environmental Management systems?
Multiple Choice (HP)
Answer 1: ISO 900
Response 1:
Jump 1: This page
Answer 2: ISO 1300
Response 2:
Jump 2: This page
Answer 3: ISO 1400
Response 3:
Jump 3: Next page
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 is
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 which aspects 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 of

waste, 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 information 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 of waste 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 operating
conditions and periods of maintenance and shutdown, and to significant environmental
impacts that could occur during emergencies. Once impacts have been identified, their
significance should be evaluated.
Question 5.
The company environmental policy is

Multiple Choice (HP)

Answer 1: Communicated to all employees
Response 1:
Jump 1: This page
Answer 2: Unique to the orgnisation
Response 2:
Jump 2: This page
Answer 3: Made available to the public
Response 3:
Jump 3: This page
Answer 4: All of the above
Response 4:
Jump 4: Next page
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, neighbours, 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 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
per cent; 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 environmental 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 for which they have been
assigned responsibility.
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 reporting on 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 programme 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.
Question 6.
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..
True/False (HP)
Answer 1: True

Response 1:
Jump 1: Next page
Answer 2: False
Response 2:
Jump 2: This page
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 a pollution 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 EMS 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 assessments 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 - 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 suggesting 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 Programmes.
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 Programmes - Guiding Principles, Practices

and Certification Procedures of Multiple Criteria Programmes.
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.
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 peer 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 pollutionincident 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 unbiased 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 environmental aspects 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 EU is considering 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 environmental 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 requirements
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 of Environmental
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. This is referred to in greater detail in Element 2 of the course, Section 4.0 and
subsequent.
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.
Subcommittee 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.
Question 7.

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?
True/False (HP)
Answer 1: True
Response 1:
Jump 1: Next page
Answer 2: False
Response 2:
Jump 2: This page
Question 8.
Certification to ensure your Environmental Management System meets the requirement of
ISO 14001 is mandatory
True/False (HP)
Answer 1: True
Response 1:
Jump 1: This page
Answer 2: False
Response 2:
Jump 2: Next page
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 Authorisation under 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,

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 setup 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 of which the qualified operators were unaware.

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 crucial 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 as 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 short time, usually 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 break

down
in
a
major
emergency.
On Thursday, October 21st 1971 an escape of gas from a four-inch gas main into a large
unventilated void beneath shops in a shopping centre in Clarkston, Renfrewshire exploded.
Twenty-two 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
walkie-talkies 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 onsite, 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 called 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 decisionmaking.
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 systems.
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 welldesigned 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 welldesigned, 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. 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,
consider the need to take external advice as appropriate and decide 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.

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.
Question 9.

Emergency preparedness & response plans may include...

Multiple Choice (HP)
Answer 1: Internal and external communication plans
Response 1:
Jump 1: This page
Answer 2: On site emergency response teams and equipment
Response 2:
Jump 2: This page
Answer 3: Key personnel duties, responsibilities and contract details
Response 3:
Jump 3: This page
Answer 4: All of the above

Response 4:
Jump 4: Next page
Question 10.
All emergency preparedness and response plans should be practiced and tested periodically
True/False (HP)
Answer 1: True
Response 1:
Jump 1: Next page
Answer 2: False
Response 2:
Jump 2: This page
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 is 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.