GUIDE

ENVIROWISE PUBLICATION:INFORMATION ON ENVIRONMENTAL MANAGEMENT SYSTEMS

ENVIROWISE - SUSTAINABLE PRACTICES, SUSTAINABLE PROFITS

Congratulations on requesting your tailored Resource Efficiency Guide from Envirowise.

Every day, UK businesses are literally throwing away profit due to the waste they produce. Many businesses are

unaware of how much this impacts on their bottom line, others just dont know where to go for practical, confidential

advice to help them make better use of their resources.

WHAT WE CAN DO FOR YOUR COMPANY

Envirowise is a Government-funded programme that has helped UK companies save over 1 billion by reducing the

amount of waste they produce. Offering a wealth of resources and industry-specific information for all businesses,

whatever size or sector, our services are available for you to access directly or can be tailored to suit individual needs.

Our informative website, confidential Advice Line, publications and workshops are all available to UK businesses free of

charge. Our Regional Managers work closely with the business support organisations in your area, signposting various

initiatives.

WHY SHOULD YOU BECOME MORE RESOURCE EFFICIENT?

■ Your costs will decrease. Did you know that wasting water, raw materials and utilities, costs on average, 4% of

turnover? With help from Envirowise, you could make significant cost savings and dramatically reduce the amount

of waste you send to landfill each year.

■ Your Corporate Social Responsibility (CSR) credentials will increase. Your customers and stakeholders now

actively seek suppliers with a strong environmental record. By demonstrating resource efficiency, especially with

an environmental policy or accreditation, you will be in a stronger position to retain or win new business.

■ Your company will comply with legislation. Environmental legislation has become much more prevalent and many

companies face penalties for non-compliance. Envirowise can help your business comply with the laws that affect

it, through reducing or designing out hazardous waste and helping you to eliminate bad practice.

Resource efficiency benefits all sectors, from construction, office-based professional practices, engineering to retail.

Most of the measures we propose are at no or low cost and all our advice is confidential and free of charge. If you decide

to invest in environmentally friendly equipment, payback times are typically short and Envirowise can tell you about the

tax benefits that are available.

This Guide was produced by EnvirowiseThis Guide was produced by EnvirowiseThis Guide was produced by EnvirowiseThis Guide was produced by Envirowisefor Liza Bradley of B Bowden & Co Limited

ENVIROWISE PUBLICATION:INFORMATION ONENVIRONMENTALMANAGEMENT SYSTEMS

CONTENTS

SECTION PAGE

1 INTRODUCTION TO EMS 1

2 COMMITMENT 6

3 ORGANISATION AND PERSONNEL 8

4 ENVIRONMENTAL POLICY 12

8 SIGNIFICANCE OF ENVIRONMENTAL ASPECTS 17

11 REGISTER OF LEGISLATION 24

13 OBJECTIVES AND TARGETS 26

16 MANAGEMENT PROGRAMME AND MANAGEMENT MANUAL 30

18 AUDITS AND REVIEWS 35

21 TRAINING AND AWARENESS RAISING 42

22 BS8555, ISO 14001 AND EMAS 44

25 ENGINEERING 50

27 CHEMICALS SUPPLEMENT 77

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INTRODUCTION TO EMS

WHAT IS AN ENVIRONMENTAL MANAGEMENT SYSTEM?

Increasingly companies are recognising that the environment is a management issue and not just a matter of compliance.

An EMS is a systematic approach to managing your company’s impacts on the environment. Having and following an

EMS is voluntary, but companies with an EMS have an explicit commitment to continual environmental improvement.

Setting up an EMS will provide your company with a framework through which its environmental performance can be

controlled and improved.

EMS:

■ a mechanism for defining environmental responsibilities for all staff, helping them to understand the environmental

impact of their activities and their individual actions

■ ensures that all operations have procedures that minimise their impacts

■ records environmental performance against set targets

■ can be audited

■ will also help you identify opportunities to reduce waste and thus reduce your operating costs

To implement an effective EMS, you need to know your business and understand its impacts on the environment. By

knowing how your business operates, you will be able to easily identify how to improve efficiency, reduce costs and

improve profits.

Although many companies have already made significant improvements in their environmental performance, an EMS will

ensure that improvements continue through ongoing maintenance and monitoring of the system. An EMS also ensures

that environmental performance and other related issues are raised regularly with senior management and that the

momentum for making improvements is maintained.

POTENTIAL BENEFITS OF IMPLEMENTING AN EMS

There are a number of potential benefits of implementing and EMS:

Financial

■ Identification of opportunities to reduce waste and thus reduce raw material, utility and waste disposal costs

■ Increased profits

■ Reduced risk of fines for non-compliance with environmental legislation

■ Lower insurance premiums as risks and liabilities are reduced

■ Retaining site asset value

■ More easily obtainable bank loans

■ Attracting shareholders and investors

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Productivity

■ Improved process control (fewer rejects, less re-work, higher yields)

■ Reduced use of raw materials and consumables

■ Less waste

Sales And Marketing

■ Improved products

■ Competitive advantage (preferred supplier status)

■ Increased sales achieved through promotion of greener credentials

Management

■ Structured approach to environmental issues and continual improvement

■ Keeping ahead of environmental legislation

■ Better relations with regulators

Public Relations

■ Improved relations with local community and environmental groups

■ Improved public image

Personnel And Training

■ Improved working environment

■ Reduced potential for environmental incidents

■ Increased employee motivation and environmental awareness

Peace Of Mind

■ Conforming to legal requirements

■ Avoiding penalties for pollution

■ Avoiding bad publicity from pollution incidents

WHAT DOES AN EMS INVOLVE?

An effective EMS includes:

■ an assessment of your company’s activities, products, processes and services might affect the environment

■ development of an environmental policy

■ an environmental improvement programme

■ defined roles and responsibilities for all employees

■ a training and awareness programme

■ written procedures to control activities with a significant environmental impact

■ a controlled system of records

■ periodic auditing of the system to ensure effective operation

■ a formal review of the EMS by senior management

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The various elements of an EMS are shown in the flow diagram.

Elements of a typical EMS

Remember the ‘three Cs’:

■ Commitment - gain support for the EMS at all levels within the company through good communications.

■ Continuity - ensure the system remains running once it has been established.

■ Continual improvement - continuously reduce the company’s significant environmental aspects.

TYPES OF EMS

There are three strategies available to companies wishing to implement a formal EMS, ie:

■ develop their own in-house EMS

■ follow the guidelines of the international standard ISO 14001, the EC’s Eco-Management and Audit Scheme (EMAS)

* or the British standard BS 8555 (designed specifically for small and medium sized businesses) but do not pursue

formal certification/verification to these standards

■ pursue formal certification/verification to these standards.

* Regulation (EC) No. 761/2001, as amended (No. 196/2006), replacing Regulation (EC) No. 1836/93

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All three strategies are voluntary, but differ in their scope and approach. The choice depends on what is right for your

company, but the Envirowise Advice Line (0800 585794) may be able to help you decide what is best for your

circumstances.

The Advantages Of A Formal Approach

A formal approach not only increases the commitment for environmental improvement across the company, but also

identifies opportunities for improvements and cost savings on an ongoing basis. Achieving EMAS or ISO 14001 may

increase the credibility of your EMS with customers and suppliers, as they are internationally recognised standards. BS

8555 is a relatively new British Standard (published in April 2003) but has particular merits for smaller companies.

Many companies seeking certification to a formal environmental standard have found that the cost savings significantly

outweigh expenditure. The disadvantages of adopting a formal standard often stem from the introduction of unnecessary

bureaucracy.

An EMS contains several features present in a quality management system (QMS) and there may be advantages to

integrating the two systems. There are differences between an EMS and a QMS, but they are both fundamentally

concerned with ensuring that specific management objectives are met.

There is a growing international consensus that these standards should align as closely as possible, thus helping

companies develop integrated management systems. However, it is not appropriate to simply combine EMS and QMS

elements. Instead, the emphasis should be on fundamentally integrating environmental issues into the existing

management structure of an organisation.

BS 8555

The phased EMS implementation approach used by BS 8555** and piloted through Project Acorn breaks down the

process of installing a formal EMS into five levels. A sixth level allows organisations to develop systems, with the

possibility of seeking recognition against ISO 14001 or EMAS.

BS8555 also incorporates BS EN ISO 14031:2000 that gives guidance on the design and use of environmental

performance evaluation

The introduction of BS 8555 has allowed businesses that do not posses the resources to gain European or international

certification or to implement a fully fledged EMS, but which have made progress in environmental management, to receive

acknowledgement of their efforts.

An independent inspection scheme has been developed by the Institution of Environmental Management and Assessment

(IEMA) which offers accredited recognition for organisations evaluating and improving their environmental performance

through the phased implementation process. Full details of the Acorn Inspection Scheme are given on IEMA’s website

(www.iema.net/acorn).

For simplicity this document refers only to ISO 14001 and EMAS. For more information about BS 8555 and free advice

about its potential benefits for your company, contact the Envirowise Advice Line on 0800 585794.

** full title: Guide to the phased implementation of an environmental management system including the use of environmental performance

evaluation

Phase 1     Commitment and establishing a baselinePhase 2      Identifying and ensuring compliance with legal and other requirementsPhase 3     Developing objectives, target and programmesPhase 4     Operation and implementation of the EMSPhase 5     Checking, auditing and management review

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EMS TERMINOLOGY

As well as the familiar term ‘environmental impact’, published guidance on formal environmental management systems

uses the terms ‘environmental aspect’ as defined below:

■ Environmental aspect. Any element of a company’s activities, products or services that can interact with the

environment. This can mean almost anything a company does from industrial processing to office admin.

■ Environmental impact. Any change to the environment wholly or partially resulting from a company’s activities,

products, processes or services either directly or indirectly. An impact can be adverse or beneficial. An

environmental aspect will have a corresponding environmental impact (or even several impacts).

Do not confuse an environmental audit with an environmental review:

■ Initial environmental review ‘kick starts’ the EMS

■ Internal environmental audits maintain its momentum

■ The management review allows senior management to consider how well the EMS is working

EMAS - A full list of definitions is provided in Article 2 of the Regulation

ISO 14001 - Terms and definitions are detailed in Clause 3 of the Standard

UKAS Accreditation

Different terms have been adopted to denote the function of the independent third parties that ensure conformity with the

respective requirements of ISO 14001 ‘certification’, and of EMAS ‘verification’. Those carrying out these functions

(‘certification bodies’ and ‘verifiers’) are accredited by the United Kingdom Accreditation Service (UKAS)*** using common

criteria and procedures. Accreditation by UKAS demonstrates the competence, impartiality and performance capability of

these evaluators. UKAS maintains a list of UK accredited environmental verifiers.

*** www.ukas.com

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COMMITMENT

OVERCOMING OBSTACLES

Many companies experience some expression of negativity about the intention to implement an EMS. This can come

from management, employees or other interested parties such as shareholders. Such concerns can jeopardise an EMS

even before implementation has begun. Some of the common misconceptions surrounding an EMS are tackled below.

Common Concerns

■ We don't know what an EMS is. It is important to explain the basic aims and benefits of an EMS to all interested

parties early on in the process - perhaps by giving a presentation to the management board or by dissemination

through the company notice-board, intranet or newsletter.

■ We don't have any environmental issues. Any company that buys raw materials, uses energy and water,

receives and makes deliveries, uses packaging or produces liquid/solid waste has an impact on the environment.

■ We don't have the time or the resources to implement an EMS. This is a common concern and one to which

there is no single, straightforward answer. However, an EMS will help your company to become more efficient by

reducing waste and the consumption of raw materials and utilities. The time and resources needed to implement

your EMS should be viewed as an investment that will produce high yields in terms of cost savings and thus make

the company more profitable. Increasing numbers of companies have already invested in an EMS and are reaping

the benefits.

■ Does an EMS have to be implemented across the whole company? An EMS does not have to be

implemented across the whole company. It can be piloted or implemented within one part of a company and rolled

out to other sites/facilities or operational areas as and when required.

■ No one in the company is trained to implement an EMS. One or two members of staff will need to have an in-

depth knowledge of the EMS. However, most employees just require an overall understanding of the environmental

issues relating to the job they do. By using Envirowise guidance or following the requirements of a recognised

standard such as ISO 14001, it is possible to implement an EMS without the need for additional 'expert' or third

party training. Whether carried out by external parties or undertaken in-house, training can be relatively inexpensive

and can be scheduled to avoid any operational disruptions. This is particularly true where a 'train the trainer'

approach is applied, ie a person or small group is trained to then carry out further training within the organisation.

■ Will it cost money? Almost invariably, the implementation of an EMS entails some costs. These vary considerably

and depend upon the size of the company, the number of sites involved, the number of employees and the level of

existing in-house expertise. If costs are a major concern, then carrying out a simple cost-benefit analysis will help

to estimate potential savings. A walk around your site will probably highlight a number of no-cost or low-cost

opportunities that will produce significant cost savings and thus offset the initial cost of implementing the EMS.

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THE IMPORTANCE OF TOP LEVEL COMMITMENT

Although an EMS needs to be adopted at all levels within the company, its effectiveness will depend on the level of

commitment from the managing director and other senior staff.

Therefore, before starting to design the system it is essential to obtain the full commitment of senior management to the

aims and objectives of your EMS.

The benefits that senior Management Commitment gives an EMS include:

■ Importance with the organisation

■ Consistent approach throughout the organisation

■ Gains the commitment of other key members of the organisation

■ Authorisation to use other available resource i.e. staff time and budget

One of the easiest ways of securing commitment is by estimating the potential cost savings from adopting an EMS. For

example, calculate the annual costs of water, gas, electricity and waste disposal for your company by looking at the bills

from the previous 12 months. As a general rule, it should be possible to cut the costs of these services by at least 10 -

15% without substantial capital expenditure.

The commitment of senior managers is important in obtaining sufficient time, resources and money to achieve continual

environmental improvement through an EMS.

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ORGANISATION AND PERSONNEL

RESPONSIBILITY FOR IMPLEMENTATION

Sharing responsibility for the implementation of an EMS across all levels will enable the company to get the most out of

the Environmental Management System.

Many companies have difficulty deciding who should be responsible for implementing their EMS. Some will be in a

position to appoint an environmental manager and some will not. If you fall into the latter category, you need to allocate

the time to someone with similar work responsibilities and skills.

person responsible for implementing an EMS is described in ISO 14001 as the Management Representative. This

document also uses this term.

The Management Representative

■ is responsible for:

■ undertaking the initial review

■ implementing and maintaining the EMS

■ gathering, organising and disseminating information

■ co-ordinating inputs from other people with complementary responsibilities

■ reporting environmental performance to senior management

■ delegating tasks and establishing deadlines

■ producing, maintaining and controlling the EMS Manual or Management Manual

■ key functions are those of:

■ communication

■ co-ordination

■ motivation

■ training/raising awareness of all employees

■ should possess the following qualities:

■ some experience of environmental, health and safety issues

■ reasonable knowledge of the processes carried out at your site(s)

SEEKING HELP FROM OTHER PEOPLE

Many companies have found that it has taken some time to implement their EMS because the person responsible has

other roles with an equal call on their time.

The Management Representative should seek help from:

■ Site/process engineer. Much of an EMS revolves around greater efficiency from process operations and

monitoring. It is therefore logical for the person with responsibility for monitoring and maintenance of process

equipment to be closely involved in the development and maintenance of your EMS.

■ Health and safety manager. Much of the information required under health and safety legislation is applicable to an

EMS. Given these close links, the health and safety manager should also be asked to help develop your EMS.

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■ Quality assurance manager. If your company has a quality assurance system, the documentation procedure is

likely to relate to EMS requirements. The department/individual responsible for quality assurance in your company

should therefore be able to help develop procedures and documentation.

■ Purchasing manager. In addition to providing information about your raw material and utility costs, the purchasing

manager will need to be involved if liaison with suppliers is required.

TIP:During the development of your EMS, it may be worth employing a student on work experience or a graduate

placement to provide temporary assistance in gathering data.

ENVIRONMENTAL MANAGEMENT TEAM

Setting up an Environmental Management Team will help you implement and operate your EMS effectively. Depending on

the size and nature of the company this team can be the entire workforce (companies of up to ten employees) or a core

group of people representing different departments or operational areas of the company, together with a member of

senior management (to provide top level commitment).

Everyone with primary responsibilities within the EMS should be a member of the team.

Although individual members and their level of involvement will depend on the company, team members can include:

■ managing director

■ environmental manager or Management Representative

■ works director

■ quality manager

■ maintenance engineer(s)

■ shift foremen

■ works engineer

■ personnel/training officer

The Environmental Management Team has a vital role in planning the implementation of the EMS and further embedding

the process into general work practice. The specific role of the team should be to:

■ attend regular team meetings that should follow an agenda and be minuted - these documents will provide records

for the management review process.

■ assist with the implementation of the EMS

■ encourage the involvement of other staff

■ draw up action plans to ensure that improvements are made and that progress is monitored

Each member of the team should have clearly defined responsibilities. It is also important that specific tasks are

assigned to individuals, eg workshop manager, section head and environmental manager.

TIP: You may find it helpful to set up smaller project teams or working groups, which should be asked to report back

to the Environmental Management Team.

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COMMUNICATION

Commitment to a project at the proposal stage can soon wane, or even be withdrawn if, things don't go to plan,

circumstances or individuals' change. It is important to keep management and staff informed. All too often new schemes

start off with good intentions, but enthusiasm flags if people are not kept up to date with what is happening. Effective

communication can ensure engagement and assist to embed principles into working practices.

Communication cannot be overemphasised. The more involved your employees are in the EMS, the more committed

they will be and the easier it will be to implement the system effectively. An edict from senior management on its own will

only achieve short-term success. To ensure continual improvement and long-term success, training and

communication are essential.

■ Before beginning your environmental review, let the workforce know what is happening and encourage them to

start thinking about the part they can play.

■ Communicate with employees, eg using an environmental notice-board, internal memos, meetings, intranet, team

briefings and letters to all employees.

■ Ask employees for their ideas. Those doing a job every day normally have ideas about how things can be done

more effectively. Ensure that these ideas are acknowledged and are not falling on deaf ears.

■ Be open, let employees know that some decisions are not set in stone.

■ Provide feedback both good and bad.

■ Make sure employees understand and believe in any procedures introduced as part of the EMS through suitable

training.

■ Set up short, but frequent, Environmental Management Team meetings and make sure line managers are brought

into the process.

REMEMBER: Everyone gains, professionally and personally, through effective communication. These skills should

be embedded within your company. It requires a commitment, but the return on the investment is well worth the time

and energy.

RESOURCES NEEDED

Before implementing your EMS, it is important to consider what will be needed in terms of time and other resources to

establish an effective EMS.

The time taken to implement an EMS is typically 12 - 18 months, though there is no standard timescale; it will depend on:

■ the company

■ site circumstances

■ the experience of the personnel involved

■ the type of EMS chosen

TIP: Delegation and team working can help to reduce the time taken significantly

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Tasks include:

■ administrating the system

■ monitoring goals and targets

■ helping to produce and revise work procedures

■ arranging for training for new employees

■ adapting the system to accommodate changes in regulatory controls and manufacturing processes

■ liaising with external consultants

Auditing the system and ensuring that any corrective actions are carried out will take 0.5 days/week. The internal auditor

(s) should be allowed 3 - 4 hours/week to carry out one or two audits.

While this may seem a lot of staff time, remember that 20% of the salary of a senior employee is often less than the

anticipated cost benefits, ie 10 - 15% of the combined cost of utility consumption and waste disposal. In addition, do not

assume you are starting from scratch - it may be possible to build on existing procedures.

Senior management should allocate sufficient time for regular management review meetings and allow time for

considering requests from the Management Representative for improvement measures involving capital expenditure. If

your company has a QMS, the management review can be linked to similar procedures.

Using An External Consultant

Asking an external consultant to help may reduce significantly the time spent on implementing your EMS. Although this

will cost money, it may save you time and allow you to benefit from the consultant's experience. However, it is essential

you provide the consultant with a clear brief as part of the written contractual agreement.

There may be cases where you need to get specialist advice and assistance, particularly in the areas of legal

compliance, environmental aspects and impacts, emergency planning and environmental auditing.

When seeking outside help, check that potential consultants have the necessary experience and qualifications. Choose

an environmental specialist who is familiar with the particular issues associated with your sector and who understands

staff needs. It is unlikely that an ISO 9000 quality consultant without significant EMS experience will have sufficient

expertise.

TIP: A consultant does not negate the need for an on-site Management Representative; the company must take

ownership of the EMS to ensure continuous improvement.

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ENVIRONMENTAL POLICY

INTRODUCTION

An environmental policy is a written statement outlining your company's mission in relation to managing the

environmental impacts of its operations. The policy is the driving force behind the objectives, targets and Management

Programme of your EMS. The policy:

■ states the company's aims and objectives and forms the basis for its EMS

■ endorsed and actively supported by senior management and accepted by all staff

■ allows management to communicate its aims and objectives to employees and other interested parties, including

shareholders, customers and suppliers.

■ should be part of the business strategy

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 holding company.

Writing an environmental policy is a voluntary undertaking in the UK, and the structure and content are not regulated

under UK legislation. For companies intending to obtain certification to a formal EMS including ISO14001 and EMAS, the

Environmental Policy is a mandatory document providing a cornerstone in the system's development and

implementation

The written policy needs to:

■ be specific to your company and its environmental impacts

■ only address issues relevant to your business activities

For companies intending to obtain certification to ISO 14001 or registration to EMAS, the environmental policy is the

cornerstone of the EMS's development and implementation. Both give guidance on the principles on which the

environmental policy should be based. ISO 14001 and EMAS specify that the environmental policy must include

commitments to legislative compliance and continual improvement.

The order followed by ISO 14001 places writing a policy before identifying significant aspects and legislation. However,

many companies complete these stages before finalising the environmental policy. This ensures that the policy is

reasonable and practical for a company's business activities.

COMMUNICATION AND REVIEW

The policy should be:

■ communicated to all staff, contractors and suppliers1

■ made available to customers, shareholders, other stakeholders and the public1

■ located in a prominent place on site, such as the reception area

■ reviewed regularly and, if necessary, revised to take account of developments in your EMS and significant changes

to your business activities or operations.

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TIP: Start by reviewing the policy after the first six months of operation of the EMS and then annually

GOOD PRACTICE: Even if your company is not intending to adopt a formal EMS, it is worthwhile designing your

policy carefully as you will wish to publicise it and your customers will want to see it.

1 Key requirement of both ISO 14001 and EMAS

CONTENT AND STYLE

There is no standard format for writing an environmental policy, but the style should reflect your organisation s culture.

TIP: If your business is closely linked to key customers through the supply chain, a good starting point is to obtain a

copy of their environmental policies and ensure that your policy reflects their requirements and needs.

Look at examples of policies written by other companies and select the format and style most appropriate to your

own.

Consider the following:

■ Be realistic and practical for your business - compare what you actually do with what the policy says you will do.

■ Keep the policy short - if it is longer than an A4 sheet, then it is probably too long.

■ The policy is meant for everyone to see, so make sure it is easy to read and understand.

■ The policy must be realistic, achievable and relevant to your company s activities and practices.

■ To demonstrate commitment to making the policy work, get the policy signed, dated and endorsed by the

managing director, chief executive or another senior manager.

■ State the review period.

The targets and timescales stated should be realistic and address overall environmental performance. The policy should

be influenced by the findings of the environmental review and should be finalised after this has taken place.

An environmental policy may encompass the following:

■ liaison with the local community and address any complaints received

■ compliance with the requirements of environmental legislation and approved codes of practice

■ assessment of environmental impact of past, current and future operations and set objectives/targets to reduce

these impacts

■ continually seeking to improve environmental performance

■ environmental considerations and criteria in capital investment decisions

■ fostering the commitment of all employees to improve the environmental performance of the business

■ use of sustainable principles for all raw materials, supplies and energy efficiency (where achievable)

■ aiming to reduce all types of waste and to increase the re-use, recovery and recycling of waste

■ reporting publicly on environmental objectives and targets

■ expecting similar environmental standards from all third parties, ie suppliers, vendors and contractors

An example of an environmental policy is given below.

You may also find the Policy Writing Checklist useful.

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Policy Writing ChecklistIssue Comments

Purpose ■ Why are you creating an environmental policy?  

Scope

■ Does it cover business unit/division/entire company?

■ Does it give a brief description of copany activities?

■ Does the policy reflect company values and principles?

 

Objectives

■ Have you identified about five key environmental objectives?

■ Are these directly relevant to your company?

■ How were these identified?

■ Are they achievable?

■ Do they reflect your significant environmental impacts?

 

Legal requirements■ Do you intend to meet/exceed legal and other

requirements?  

Responsibilities■ Who is responsible for overseeing and implementing

the policy?  

Communication

■ How will it be communicated to employees?

■ How will it be communicated to customers, suppliers, contractors and other interested parties?

 

Review

■ Is this document to be reviewed annually/peridoically?

■ ...By whom and under what circumstances?  

Authorisation

■ Who is responsible for authorising the policy?

■ Is evidence included?

■ Is it dated and subject to version control?

 

ISO 14001 Requirements

■ Have you included a commitment to prevent pollution?

■ Have you included a commitment to continual improvement?

 

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Company X

Environmental Policy

Company X is a young firm of environmental consultants, specialising in environmental business support solutions to ensure regulatory and legal compliance. We employ over 450 staff and operate from two sites, Company X provides cost-effective management support for environmental management.

Company X ensures that all activities carried out by the organisation comply will all relevant environmental legislation.

The organisation is committed to the prevention of pollution; we aim to continuously improve our environmental performance through the support and involvement of all employees and any other interested parties. In recognition of this we have implemented an environmental management system.

We aim to:

■ Actively minimise waste through our waste reduction policy, which describes our principle of reducing, reusing and recycling all our office waste

■ Maximising efficient use of natural resources through office best practice guidelines ■ Continue to operate a purchasing policy to ensure as much material as possible is sourced from recycled

material ■ Reduce the amount of energy consumed during office hours by efficiently using equipment and operating

our 'switch off when not in use' policy ■ Continue to encourage our clients, suppliers and stakeholders to adopt our environmental principles and

develop an environmental management system in their own organisations ■ Review our EMS including this policy and publish an environmental statement annually

Signed: Joe Bloggs

Company DirectorIssue 1

April 2008

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IMPLEMENTING THE ENVIRONMENTAL POLICY

Developing and writing the policy are just the first steps. The environmental policy must then be put into practice. The

environmental policy needs to be a living document that is implemented during day-to-day activities.

Once the policy has been completed it must then be communicated to others

Internal communication: Make sure that all employees know about your environmental policy. Check that employees

have received and understood this information. Below are some examples of what you can do to actively promote your

environmental policy to all employees:

■ Present the policy at a meeting for all employees

■ Post the policy on the wall in offices, reception area, canteens etc.

■ Give every employee a personal letter from managing director accompanied with copy of the environmental policy

with their pay slip

■ Publish the document in an internal newsletter

■ Include the environmental policy in induction training or hold formal environmental training for all staff to introduce

the new policy

External communication:Decide whether you want to actively promote your policy or to provide it to external parties only

upon request. If you want to promote the policy, this can be done by:

■ Upload a copy of the policy on your company website

■ Publish your new environmental intentions in an external brochure / booklet

■ Write environmental commitment in your organisation annual report

■ Take advantage of advertising opportunities

CLOSE THE LOOP

The policy must be reviewed on a regular basis: To check that your organisation's current activities comply with the

Environmental Policy, a review needs to be undertaken regularly - usually on an annual basis. If your organisation's

business activities or operations change significantly, the policy may need to be amended.

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SIGNIFICANCE OF ENVIRONMENTAL ASPECTS

IDENTIFYING YOUR ENVIRONMENTAL ASPECTS AND IMPACTS

Identifying and understanding your company's environmental aspects and impacts will help you to reduce adverse

impacts on the environment. Preparing a list of aspects and impacts will also help you identify opportunities to minimise

waste and thus achieve significant savings through reduced raw material purchase and waste disposal costs.

The most important issue is to recognise and record your company's environmental aspects and impacts, and decide

which ones are significant for your business.

The information gained during the initial review will help you to prepare a list of environmental aspects for your company.

Aspects deemed significant for your company are the ones your EMS will seek to control.

Once you have started to identify your company's environmental aspects, you can begin to compile a register of them.

The Register of Environmental Aspects should contain:

■ a list of all potential environmental aspects

■ an assessment of their significance

■ the action you propose to take to reduce the impacts associated with those aspects identified as significant

If applicable, develop a process flow diagram showing the main inputs and outputs to the different stages of your

process. Aspects can be:

■ direct, eg packaging waste and water use

■ indirect, eg the performance of suppliers, contractors, product design and distribution.

Use Worksheet: Identifying significant environmental aspects to help you compile your register - adapting it as

necessary to suit your company's circumstances.

Compiling your Register of Environmental Aspects may be the stage where you need most help and could benefit from

some free advice from Envirowise. Call the Envirowise Advice Line on 0800 585794 to find out more.

IDENTIFYING SIGNIFICANT ENVIRONMENTAL IMPACTS

Having established which aspects have or can have an impact on the environment, the next task is to assess which are

significant for your company. This will help you to decide the key issues for your EMS to address and prioritise your

actions for improvement.

Assessing significance will allow you to make effective use of your resources. It will enable you to concentrate on taking

action to reduce major impacts and avoid having to try to deal with all impacts (including those that are not deemed

significant).

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Environmental aspects that exhibit significant environmental impacts must be considered when setting the objectives

of your company's EMS.

To complete your Register of Environmental Aspects:

■ evaluate each of the environmental aspects listed for its significance for your company

■ record whether or not you think the environmental aspect is significant and the actions to be taken to address it.

A formal EMS requires all the environmental aspects of a company to be considered including those that may not be

significant, eg use of company vehicles, use of paper, production of domestic sewerage and canteen wastes.

EMAS requires a Register of Environmental Aspects to be maintained. If seeking certification to ISO 14001, documentary

evidence is required to show that environmental aspects have been considered.

Methods For Evaluating Significance

There is no set approach for evaluating significance. You should choose the approach that is most appropriate for your

company, starting initially with an evaluation of significance under normal operating conditions.

Flow Diagram

One simple method is to judge the significance of the aspects against a number of criteria.

Flow diagram for assessing significance

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Numerical Rating/Weighting

Alternatively, you can develop your own point scoring system by awarding a numerical score to each environmental

aspect. Aspects which score more than an agreed amount could be considered 'significant'. In the following example,

each environmental aspect is first awarded a score to reflect the relative importance under normal operating conditions

of:

■ legislation (both current and forthcoming)

■ the severity of environmental damage, eg toxicity, acidity, greenhouse gas emissions and ozone-depleting

substances

■ interested parties, eg the reaction of the local residents and environmental interest groups

■ quantity, eg the volume of the waste stream or the frequency of occurrence at the site.

The scores are then multiplied by a weighting factor, which reflects the overall importance of the criterion at a particular

site or company. You should adjust these as necessary to reflect your company's concerns. Adding the four together

produces a total score for this environmental aspect under normal operating conditions. It is then up to you to decide

where to set the threshold score for environmental significance.

Repeat the exercise for all identified aspects.

Matrix to an environmental aspect under normal operating conditions

TIP: You may consider some factors so important that rather than applying a weighting, the aspect under

consideration should immediately be deemed significant if one particular factor has a high score.

GOOD PRACTICE: When a company is seeking certification/verification to a formal EMS standard such ISO 14001

or EMAS, the certification/verification body requires evidence that the company has assessed its environmental

impacts formally and logically. A system that rates and scores the relative significance of each aspect typically fulfils

this requirement.

Different operating conditions can have a tremendous effect on the significance of an environmental impact. For

example, the use of returnable plastic packaging may not be considered to have a significant environmental impact under

normal circumstances. However, when exposed to fire, noxious fumes may be released resulting in harm to human

health or the environment, and potential litigation from employees, members of the public or regulators.

It is therefore important to also consider your identified environmental aspects under other operating conditions. Other

operating conditions cover:

■ abnormal operations, eg factory start-up after a holiday shutdown period

■ accident/emergency, eg fire or accidental damage

■ past activities, eg activities of former site occupant or burial of waste on-site

■ planned activities, eg new product or production line, modified equipment or site development.

Adding the scores together will produce a total score under other operating conditions. This total score is used to rank

Environmental aspect:

Score Weighting

  3 2 1 0 factor

Legislation Existing Impending None x 2 = a

Environmentalimpact

Knowndetriment

Possibledetriment

Limiteddetriment

Nodetriment

x 3 = b

Interestedparties

Considerableinterest

Moderateinterest

Littleinterest

Nointerest

x 2 = c

Quantity High Medium Low Nil x 3 = d

Normal operating  conditions total score = (a + b + c + d)

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the environmental aspects under other operating conditions.

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Matrix to score environmental impacts under other operating conditions

Under this system, a significant environmental aspect is one which scores more than a certain number of points under

either normal or other operating conditions. Some aspects may be significant in only one category, others in both. Using

this methodology, the maximum possible score under either normal or other operating conditions is 30.

It is up to you to decide where to set the threshold score for environmental significance.

Whichever method you decide to use to evaluate significance, it is important to record the reasons for your

decision. If you need further advice on assessing the significance of your environmental aspects, contact the

Envirowise Advice Line on 0800 585794.

REVIEW OF REGISTER OF ENVIRONMENTAL ASPECTS

Because the relative significance of your environmental aspects may change over time, you should aim to review the list

and significance assessment regularly. New legislation, targets being met or the introduction of new processes or

facilities may affect the significance of your aspects, create new ones or eliminate others. For example, the replacement

of cardboard transit packaging with returnable plastic crates may eliminate cardboard from the packaging waste stream.

GOOD PRACTICE: Review environmental aspects and impacts at least once a year, and revise or complete from

new when:

■ projects or alterations are introduced, resulting in new or significantly modified activities, products or services

■ new information is received, eg impending relevant environmental legislation, complaints, enforcement notices,

new ISO 14000 series standards and technological progress

■ substances (that can have an adverse effect on the environment) are introduced into the business activities

Environmental aspect:

Score:

12 6 3 0

Abnormaloperations

Increasedenvironmentalimpact

Nochange

Reducedenvironmentalimpact

= a

Accident/emergency

Increasedenvironmentalimpact

Nochange

Reducedenvironmentalimpact

= b

Pastactivities

Evident/requiresaction

Possibledamage/difficultto evaluate

No damage = c

Plannedactivities

Increasedenvironmentalimpact

Nochange

Reducedenvironmentalimpact

= d

Other operating conditions total score = (a + b + c + d)

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Worksheet: Identifying significant environmental aspects

This worksheet is in two parts:

■ Worksheet A contains a checklist of business areas giving rise to environmental aspects. ■ Worksheet B: use the first four columns to list all the company's environmental aspects and impacts under

different operating conditions. Then assess the significance of each aspect and record your conclusions in the fifth column. Use the last column to document the proposed action to reduce significance.

Worksheet B forms your Register of Environmental Aspects.

Worksheet A: Environmental aspects: checklist of business areas

Use this list to ensure that each business area giving rise to environmental aspects is covered.

Business functions Tick if covered Office-based activities Tick if covered

Process design/operation Energy use

Waste disposal Waste disposal

Solid waste management Paper use

Emiisions/discharges Water use

Water use/discharges

Raw materials

Storage on site

Transport and distribution

Energy sources

Product design

Packaging

22

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REGISTER OF LEGISLATION

LISTING RELEVANT LEGISLATION AND OTHER REQUIREMENTS

The pace of quantity, complexity and range of regulations is growing all the time in the environmental field. Increasingly

stringent and far-reaching environmental legislation has come from both Europe and the UK. Additionally the enforcing

authorities have shown that they will not hesitate to prosecute when necessary.

Therefore, regardless of whether or not you have an EMS, it is important for your company to:

■ ensure it complies with UK environmental legislation

■ be able to demonstrate compliance to the appropriate regulatory authorities

Maintaining a Register of Legislation can help your company to comply with existing legislation and make you aware of

impending legislation. This knowledge will also help you identify the processes with a significant impact on the

environment.

Knowledge of relevant legislation is an essential requirement of any EMS and is a useful method of summarising your

obligations for compliance.

EMAS requires a list - 'Register of Legislation' - of all relevant statutes and approved codes of practice (eg process

guidance notes) relating to your activities, products or services.

You do not need to hold full copies of all these documents, but the relevant people in your company must understand

their requirements.

However, you will find it useful to hold copies of important legislation and documents specifying numerical limits and

essential techniques.

Use Worksheet: Register of Legislation to help compile your record of key documents affecting how your business

operates.

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OBJECTIVES AND TARGETS

SETTING OBJECTIVES AND TARGETS

The aim of an EMS is to manage environmental issues so as to achieve continual improvement. An EMS does not

guarantee improved environmental performance - accidents and incidents can still happen. However, it does allow quick

detection, mitigation and, if necessary, remediation of any pollution incident.

To bring about continual improvement, you need to set specific objectives broken down into realistic targets. These

should be based on the information collected during your initial review and should aim to address your significant

environmental aspects.

■ Objectives are the goals that the company sets itself for achieving improved environmental performance. They

indicate the company's aim regarding particular significant issues. For example, a company objective could be to

reduce waste going to landfill.

■ Targets provide interim points on the way to achieving objectives. One objective can have several targets. An

example target supporting the objective above could be to reduce waste to landfill by ...% by ...year.

Objectives and targets can be used both to motivate employees and to measure cost savings.

Where regulations, permits and consents contain specific compliance requirements, these should be incorporated into

your objectives and your mechanism for setting targets.

The setting of objectives and targets is based on the information obtained during the initial review and the identification of

significant environmental aspects. When you set objectives and targets, it is important to:

■ Identify the individual or department responsible for ensuring that they are met.

■ Identify someone to oversee the implementation of changes to ensure that targets are met.

■ ensure that the measures taken do not indirectly create another significant environmental aspect.

Identifying the opportunities to improve performance requires communication with the Environmental Management Team.

The team members are the ones who know the processes and they will probably have ideas for improvement.

TIP: If it will be expensive or difficult to achieve a particular objective and legislative compliance is not an issue, you

may find it more worthwhile to give priority to some easier targets. Quick paybacks will help to maintain interest in the

EMS and obtain commitment from all levels of the business.

When setting targets, be SMART. All targets should meet these criteria:

■ Specific - each target should address one issue only.

■ Measurable - your targets should be expressed quantitatively, eg 10% reduction/unit.

■ Achievable - your targets must be something you can achieve. For example, a zero waste target is probably not

achievable for most companies.

■ Realistic - your targets should be challenging but not overly ambitious. Remember they can always be revised

once they have been met.

■ Time-bound - your target must be assigned an end date for delivery.

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It is important that agreed objectives and targets are communicated to all staff. Staff awareness and acceptance of these

objectives and targets are essential to their success.

Use Worksheet: Objectives and targets for an improvement programme to help you record your objectives and

targets based on your environmental policy, your significant environmental aspects and your Register of Legislation. This

will provide a framework for the development of your continual environmental improvement programme. Also decide and

record the timescale and responsibility for achieving these targets.

Targets should be measurable in absolute terms and be clearly documented, along with any assumptions necessary.

For example, setting an energy reduction target of say 10% is vague and requires qualification. One obvious variable that

affects energy consumption is the level of production.

An emission reduction target should also be quantified in both absolute terms and specific terms. Waste-related targets

could be classified into two parts - one concerned with reducing the amount of waste generated in relation to a measure

of production and the other with increasing the proportion of residual waste that is recycled.

Assessment-based objectives such as supplier evaluation, site drain surveys and raw material substitution should be

broken down into individual tasks with expected deliverables and dates.

Continual Improvement Under ISO 14001 And EMAS

To achieve certification/verification, it is necessary to show that objectives and targets have been set and to demonstrate

your performance towards achieving them. You must have a monitoring programme and keep records of your monitoring

regimes.

Although there is a requirement for continual improvement, there is no set standard or guidance concerning the rate at

which you improve. A company is free to decide its continual improvement programme, taking into account the

expectations of stakeholders and other interested parties. For example, a company aiming to reduce its energy

consumption by 1% per year would not be penalised by a certifier or verifier compared with a company planning to

reduce its energy consumption by 25% per year. The requirement is merely to specify reduction levels that are

measurable and achievable.

27

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MANAGEMENT PROGRAMME AND MANAGEMENT MANUAL

DEVELOPING AN ACTION PLAN

Once you have agreed your objectives and targets, the next stage is to develop a continual environmental improvement

programme designed to give priority to key areas for action and to deliver the targets you have set.

When developing an environmental improvement programme, it is important to:

■ prioritise the areas in which improvement is needed

■ set a realistic timescale and budget for each objective

■ ensure that you have the necessary resources, eg manpower and finance

■ assign responsibility for each objective

■ obtain the support of management/employees for the improvements

■ hold short and regular meetings to report progress

■ establish new deadlines if deadlines prove difficult to meet

■ review and update the environmental improvement programme regularly.

TIP: Software packages are available which can provide a powerful and effective tool for managing your

environmental, quality and production information. These can be helpful when implementing and maintaining a formal

or an informal EMS. However, they are only as effective as the person using them and should not be used to provide a

quick fix solution for someone with little experience of environmental matters.

Although there is a requirement for continual improvement, there is no set standard or guidance concerning the rate at

which you improve. A company aiming to reduce its energy consumption by 1% per year would not be penalised by a

certification/verification body compared with a company planning to reduce its energy consumption by 25% per year. The

requirement is merely to specify reduction levels that are measurable and achievable.

EMS MANUAL

Documentation is necessary to describe and support the EMS. The EMS Manual or Management Manual forms the

basis of your company s EMS and should, therefore, be relevant to the operations and processes employed.

The Manual:

■ provides a central point of reference to the implementation and maintenance of the overall system

■ acts as a signpost to other documents within the system. It is usually produced, maintained and controlled by the

Management Representative.

possibility is to use a consultant to help you design and compile a manual. If you decide to undertake this task yourself,

try to keep the system as simple as possible. Remember, the more procedures you produce, the more you will have to

control, maintain and audit.

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Tip: Keep the manual short and use flow diagrams where possible to reduce text.

GOOD PRACTICE: A simple way of creating an environmental manual is to follow the headings set out in a

recognised standard such as ISO 14001. Under each heading, briefly describe your approach to tackling that element

and signpost the location of supporting documentation.

Your EMS Manual, which can be either paper-based or in an electronic format, describes how your EMS operates. It

should contain or include references to the location of:

■ the company's environmental policy

■ a chart showing the company's organisational structure

■ a statement of the company's objectives and targets, and its environmental improvement programme

■ the responsibilities and authority of employees involved in the EMS, including the Management Representative

■ documented procedures for all processes and activities that have a significant potential environmental impact.

OPERATIONAL CONTROL AND RECORD KEEPING

As part of your EMS, you need to demonstrate that the company is controlling its significant environmental aspects on a

daily basis. Operational controls includes one or more of the following; procedures, work instructions, physical controls

and use of trained personnel.

Procedures need to be developed to monitor and control these aspects, making sure that these documents:

■ are available for easy reference at all times, eg as part of an existing quality systems

■ easy to understand

■ updated as necessary. Procedures can be changed at any time to improve the integrity or ease of operation of the

system. Any changes must be properly documented and controlled (ie obsolete documents should be removed

and only the current version made available).

■ indicate who has responsibility for investigating and rectifying problems that occur either suddenly or over a period

of time.

It is also important to provide relevant employees with detailed instructions on how to operate processes and to carry out

activities that could have a significant environmental aspect.

Keeping records will allow you to determine performance compared with objectives and targets.

REMEMBER: Your record-keeping system should be designed to comply with the requirements of any standard that the

company may seek to achieve.

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PROCEDURES

To monitor and control the impacts that certain processes or materials may have on the environment, procedures should

be defined and made available for easy reference at all times.

These documented procedures:

■ should be easy to understand

■ updated as necessary

■ should be written with a view to increasing efficiency and minimising waste

■ will ensure the smooth functioning of the EMS

Procedures are usually split into:

■ system procedures - those relating to the operation of the EMS itself, eg auditing procedures

■ operational procedures - those relating to the control of identified significant aspects, eg waste management

procedures.

Examples of those areas for which companies could require procedures are given in the table on the next page.

Use Worksheet: Procedure as a template to help you prepare and record your procedures.

Examples of procedures

Area Example procedures

System procedures

Policy ■ Environmental policy review

■ Training ■ Documentation

control

Legislation ■ Register of Legislation

■ Evaluating legislative compliance

Environmental aspects ■ Register of Environmental Aspects

Environmental management ■ Environmental audits

■ Management system review

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Area Example procedures

Operational procedures

Emissions to atmosphere ■ Emissions inventory ■ Emissions monitoring ■ Emissions inspections ■ Refrigerant control ■ Heating and other

combustion equipment

Discharges to controlled waters ■ Discharge to controlled waters inventory

■ Discharge monitoring

Energy ■ Energy inventory ■ Energy monitoring ■ Energy auditing

Materials ■ Raw material inventory ■ Packaging

assessment

Products ■ Written description of products

Wastes (solid and liquid) ■ Waste classification ■ Waste handling and

storage ■ Effluent monitoring

Transportation ■ Transportation inventory

■ Purchasing policy/driver training

Land ■ Land and premises assessment

■ On-site use of herbicides, etc.

■ Land investigation

Change ■ Control of change ■ Environmental

assessment of proposed changes/developments

Incidents ■ Recording and reporting of environmental incidents

■ Environmental audits

Emergency ■ Environmental emergency plan

Safe systems at work ■ Safe systems of work ■ Unloading hazardous

materials

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Worksheet: Example procedureCompany:

Procedure: RefNo:

Subject: Issue:

Issued By: Signed: Date:

Approved By: Signed: Date:

Purpose:

Related procedures:

Title Ref Location

     

     

     

Circulation list:

Relevant legislation:

Title Ref Location

     

     

     

Procedure:

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AUDITS AND REVIEWS

AIMS AND SCOPE OF AN INTERNAL AUDIT

The aim of an internal audit is to regularly assess whether:

■ your site is operating according to the agreed policies, control systems and procedures

■ your site is conforming to planned arrangements and legal requirements

■ your site is conforming to the clauses of an EMS standard (if a certified EMS such as ISO14001/EMAS has been

chosen)

■ defined objectives and targets are being met.

The ISO series of standards ISO 14010, 14011 and 14012 provide guidance on auditing. For EMAS, the ISO

standards are referenced within the Regulation and the verifier will check audit procedures for compliance against

these requirements.

Internal audits involve a systematic inspection and comparison of actual operating methods with the procedures

specified in the EMS Manual. It should identify and highlight where things are working well and also identify where things

need to be improved.

An audit may be performed against either a procedure or an area of operation.

The key to a successful EMS is commitment from all employees. If employees are not committed, the system will be

difficult to implement or maintain. Audits provide a valuable tool for gauging commitment within different parts of the

company.

The key areas to assess during the environmental audit include:

■ compliance with procedures

■ compliance with policy

■ compliance with objectives and targets

■ adequacy of controls

■ adequacy of emergency procedures

■ areas of lack of control or unacceptable risk

■ employee skills and training

■ contractors

■ suppliers

■ adequacy of communications

■ whether the general layout of the site poses a risk to third parties, suppliers, contractors or site visitors

■ whether there are any new potential environmental risks

It is essential that sufficient resources to carry out the audit are made available. The findings and recommendations of

any audit must be reviewed and assessed. Any actions should be implemented according to a specified programme. In

some cases, action will need to be taken immediately, eg where a lapse in procedures has led to possible non-

compliance with legislative requirements.

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SELECTING AUDITORS

The people selected to carry out internal audits should:

■ have experience of carrying out audits and have received appropriate training

■ not have direct management responsibility for the procedure or area being audited (ie be impartial)

Specifically, auditors need:

■ appropriate knowledge of environmental legislation and issues

■ knowledge of the relevant EMS standard(s)

■ understanding of the best environmental practices in the industry

■ experience in auditing management systems

■ appropriate training to undertake the task

More than one internal auditor may be required, but this also allows cover for holidays and sickness. Colleagues in the

industry may be able to provide valuable contacts and the certification body/verifier may also be able to advise.

THE AUDIT PROCESS

Good quality internal auditing will save time, effort and money as the certified accreditor/verifier should be able to use the

results with confidence as the basis for their own assessments.

A systematic approach should be taken that includes:

■ planning the audit

■ preparing checklists, including the checks and verifications to be performed

■ obtaining any necessary background documentation, eg relevant procedures, emission data and site plans

■ reviewing the EMS documentation

■ conducting and documenting the audit

■ identifying and summarising all non-compliances

■ requesting corrective action (completion of Corrective Action Request or CAR forms)

■ completing administrative tasks, eg having the audit report signed off by the relevant manager

■ stating the date for the next audit and highlighting if it is different to the audit plan.

Undertaking an audit is straightforward. Determine which procedure or area you are going to audit according to the audit

plan. It is common practice to inform the manager responsible for the area or procedure to be audited in advance of the

audit. This ensures that staff and documentation will be available during the audit, and that there is no conflict with

operational duties or requirements.

When undertaking the audit, keep it simple by asking key questions about the significant areas being audited. You must

satisfy yourself that work is carried out in accordance with the applicable procedure and that the supporting evidence is

genuine.

Read the procedure(s) applicable to that area and then use Worksheet: Internal audits to prepare an internal audit form

by inserting appropriate questions relating to each section of the procedure(s) into the first column. In the second

column, use a simple yes or no answer to record against each question whether or not the area under

investigation conforms with that part of the procedure. Where a no is recorded, state the reason for this decision in

the third column and whether corrective action is required.

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Remember, the audit process is designed to provide objective evidence as to the effectiveness of the EMS

and not to apportion blame.

■ Try to audit people carrying out the process or working in the areas being audited.

■ Ask questions and observe. Record the replies and your observations on the audit sheet accurately and at the time

that you are performing the audit.

■ Check that you have filled in and answered all sections before signing and dating the audit form.

NON-COMPLIANCE AND CORRECTIVE ACTION

Non-conformances are failures within the system. Usually these relate to differences between how duties are being

carried out and those set out in procedures.

When a non-conformance (ie a no on the audit form) is recorded, it is the auditor s responsibility to suggest a way

of correcting the fault and preventing it from happening again. The auditor should prepare a non-conformance report or

corrective action request (CAR) form that describes:

■ what has gone wrong

■ how the fault will be rectified

■ who will do the remedial work

■ when it will be done, ie the timescale for improvement

■ actions that can be taken to prevent the fault from happening again

This logical and straightforward process is crucial to the success of your continual improvement programme.

TIP: A non-conformance is sometimes due to a problem with the wording of a procedure rather than incorrect

performance. In this case, the written procedure should be modified to improve the description of the operating

method.

Observations recorded by the auditor may relate to areas in which there are no specific non-conformances, but where

the auditor feels that the system could be improved in some way.

Use Worksheet: CAR form to draw up your own corrective action request form.

Any corrective action should be agreed with the person responsible for that area or procedure.

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AUDIT FREQUENCY

The frequency of audits will depend on the significance of your environmental aspects, but all procedures should be

audited at least once a year. The number of internal audits carried out per month will depend on your company s

circumstances.

To comply with the requirements of EMAS, all parts of the EMS must be audited between successive Environmental

Statements, ie at least once every three years.

The Management Representative should use the Register of Environmental Aspects to identify:

■ areas of high risk (ie the most significant environmental aspects)

■ areas where the company has failed to meet legal requirements in the past.

The frequency and sequence of audits should be compiled into an audit timetable which shows the area to be audited,

the date/time and the auditor(s) involved.

The audit timetable is normally prepared and co-ordinated by the Management Representative. The Management

Representative is also responsible for communicating the results of the audit to senior management.

A well-designed audit with suitable checklists should take 20 - 40 minutes (average 30 minutes). However, the process

may take 2 - 3 hours the first time each audit is carried out.

COMMUNICATING AND REPORTING

An audit report is essential to ensure that the results of the audit are communicated effectively.

The audit report normally consists of:

■ a brief description of the audit s objectives

■ a brief description of the areas that have been audited and who was involved in auditing them

■ a review of the audited areas, highlighting

■ non-compliances, ie lapses in either the content or implementation of procedures and records

■ corrective actions agreed

■ any other areas of potential risk

■ an outline of the opportunities for improvement, eg waste minimisation and cleaner technology

■ a summary list of non-compliances.

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AIMS AND SCOPE OF A MANAGEMENT REVIEW

The Management Review allows senior management to consider the effectiveness of the EMS and any changes

necessary. It is a formal evaluation of the status and adequacy of the organisation s environmental policy, systems and

procedures in relation to environmental issues, regulations, changing circumstances and continual improvement.

The Management Review should cover:

■ environmental performance and progress in achieving objectives and targets

■ compliance with legislation

■ results of internal audits and reports

■ status on actions required, in connection with non-conformances

■ new processes and any changes to known environmental issues

■ any changes in circumstances such as

■ operating requirements

■ any third party requirements such as customers, suppliers, stakeholders, regulators or in response to

complaints

■ changes in legislation

■ new technology

■ the effectiveness of training

■ the need for any revisions to your environmental policy, objectives and targets

■ follow up actions from previous management reviews

■ recommendations for improvement

Management review meetings should be attended by those with either executive responsibility or specialist responsibility.

This would normally include:

■ the site director or most senior manager

■ the Management Representative

■ line managers with defined responsibilities

REMEMBER: These reviews also provide an opportunity to implement waste minimisation and other programmes to

deliver significant cost savings as well as ensuring continual improvement in environmental performance.

39

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40

Worksheet: Example corrective action request (CAR) formProcedure No: CAR No:

Auditor: Date:

Auditee:Severity of non conformanceObservation / Minor / Major

1.   Non conformance

Signed: Signed:

Date: (Auditee) Date: (>(Auditor)

2.   Agreed Corrective Action

Signed: Proposed follow up date:

Date: (Auditee)

3.   Action Completed

Signed:

Date: (Auditee)

4.   Preventative Action

Signed: Date:

   

5.   Review of existing procedure Does an existing procedure need to be revised or a new on implemented?

Signed: Date:

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TRAINING AND AWARENESS RAISING

WHO NEEDS TO KNOW WHAT?

Some parts of the workforce will need more information about environmental issues than others. The amount of

information will depend on the level of responsibility assigned to them.

TIP: Start by looking at job descriptions and deciding the level of environmental information needed to carry out

particular tasks.

A good way of encouraging involvement in the EMS is to examine whether bonus and suggestion schemes will work for

your company. Could an existing scheme be adapted to include environmental issues? Such schemes can often be

used to motivate and encourage ownership of an EMS.

Certification/verification requires you to demonstrate that employees training requirements have been identified through

a training needs analysis. You will also need to prove that contractors have received appropriate training before being

allowed on site.

Basic Information

Most employees will benefit from a general awareness training session that:

■ highlights the company s commitment to environmental management

■ explains why environmental management is being adopted

■ describes what the company hopes to achieve from implementing an EMS

■ introduces the company s environmental policy

■ explains how it relates to individuals, eg taking measurements, recording waste arisings, segregating wastes,

sweeping up solid wastes and switching off hoses when not in use.

In addition, senior management should receive training to make them aware of their own responsibilities relating to

environmental protection.

Greater Understanding

Individuals who are expected to manage particular elements of an EMS and explain them to others need a greater level of

training. This could include:

■ more detailed information about specific elements of the EMS and the environmental concerns related to specific

environmental issues

■ an introduction to the environmental legislation governing the issues they are required to manage

■ an introduction to EMS documentation and procedures

Those people with direct responsibility for implementing and auditing the EMS should undertake a dedicated training

programme, eg a recognised external course. Their training should cover:

■ auditing

■ environmental management system standards

■ environmental and other relevant legislation

■ the external certification/verification process

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Training Records

Keep records of all training received, with an indication of the course content, dates and duration.

Contractor Awareness

Making contractors aware of environmental issues at the site can help to reduce the likelihood of a contractor being

responsible for pollution for which your company is held liable.

Contractors and suppliers form part of your EMS. Make them aware of their relationship to the EMS and, as a minimum,

present them with a copy of your environmental policy.

Depending on their duties on site, a higher degree of awareness may be necessary through specific contractor training.

Contractor training and awareness can include:

■ issuing them a copy of your environmental policy

■ a short introduction to company procedures and requirements by a company employee

■ a presentation highlighting environmental issues around the site

To prove that contractors have received the correct training, ask them to sign a form to acknowledge that they have

received the information (as they do after a health and safety briefing). This will help if you seek external

certification/verification.

You may find that environmental training and awareness programmes do not change the culture and thinking overnight.

At first, employees often perceive environmental issues in global terms rather than in terms of their working practices. It

is therefore a good idea to explain the implications for the company if procedures are not followed.

It is essential:

■ to communicate clearly and simply how the EMS affects departments and individuals

■ that senior management continues to show commitment

■ to provide a mechanism to ensure that employees are given the necessary training when they change jobs

Requirements Of ISO 14001 And EMAS

ISO 14001 and EMAS require training needs to be identified and for those whose work may lead to a significant impact

on the environment to receive appropriate training. Both require employees at all levels to be made aware of:

■ the importance of maintaining compliance with the environmental policy and objectives and the requirements of the

management system established under the EMS

■ the potential environmental aspects of their work activities

■ the environmental benefits of improved performance

■ the cost benefits of measures to improve environmental performance

■ how their roles and responsibilities help to achieve and to maintain compliance

■ the potential consequences of departure from the agreed operating procedures

Assessing The Effectiveness Of Training

A practical way of assessing the effectiveness of training is to conduct realistic dummy runs . Key areas to focus on

include chemical spillage, effluent plant failure and fire fighting. The effectiveness of training can be monitored directly

through normal working operations. In addition, production meetings can provide a forum for a regular review of

procedures and the identification of additional training needs. The EMS audit should include an assessment of the

effectiveness of training.

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BS8555, ISO 14001 AND EMAS

ADDITIONAL REQUIREMENTS OF BS8555, ISO 14001 AND E

If your company decides to seek certification to BS 8555, ISO 14001or EMAS, this will take more of the Management

Representative's time. There will also be the costs of achieving certification.

To implement a formal system, the Management Representative will require more support from the Environmental

Management Team. Experience suggests that, on average, each member of the team may spend 5 - 10% of their time

working on sections of the EMS.

However, the time spent by team members will depend on the number of areas and working groups in which they are

involved.

A formal EMS requires all the environmental aspects of a company to be considered in the review, including those that

may not be significant such as use of company vehicles, use of paper, production of domestic sewerage and canteen

wastes.

The phased EMS implementation approach used by BS 85551 and piloted through Project Acorn breaks down the

process of installing a formal EMS into five levels. A sixth level allows organisations to develop systems, with the

possibility of seeking recognition against ISO 14001 or EMAS.

BS8555 also incorporates BS EN ISO 14031:2000 that gives guidance on the design and use of environmental

performance evaluation

If seeking certification to ISO 14001, documentary evidence is required to show that environmental aspects have been

considered. EMAS requires that a Register of Environmental Aspects is maintained.

ISO 14001 is available from the British Standards Institution (BSI). Copies of the EMAS Regulation and guidance

documents can be found on the website of the Competent Body (www.emas.org.uk).

full title: Guide to the phased implementation of an environmental management system including the use of environmental performance

evaluation

ENVIRONMENTAL STATEMENT (EMAS ONLY)

One of the main differences between ISO 14001 and EMAS is that the latter requires the preparation of an

Environmental Statement. This statement defines the company's environmental performance and must be made

available to the public. The Environment Statement must be validated by an independent accredited verifier and updated

as required to accommodate changes to products, processes and services.

Phase 1     Commitment and establishing a baselinePhase 2      Identifying and ensuring compliance with legal and other requirements

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Under the EMAS Regulations, the Environmental Statement must contain the following information:

■ a description of activities, products and services carried out by the company and the location of the site

■ identification and assessment of all activities with a significant environmental effect (environmental aspects)

■ data on solid waste, emissions, discharges, raw material use, energy consumption, water use and any other

significant environmental impacts

■ an outline of the company's environmental policy and a description of the environmental management system

■ a summary of the company's objectives, targets and environmental improvement programme

■ other factors relevant to the company's environmental performance, including the introduction of new technologies

to reduce environmental impacts

■ significant changes since the last statement

■ the deadline for the next statement

■ the name of the accredited verifier, who has checked the information with the date it was done

ISO 14001 CERTIFICATION PROCESS

To be ready for certification to ISO 14001, the EMS should have been fully operational for at least three months and at

least one management review should have been conducted. This also gives time to ensure that the internal audit system

is fully operational and shown to be effective.

The certification process involves a desk-top study followed by a certification audit.

Desk-Top Study

The desk-top study will examine:

■ information on the site and its activities

■ the environmental policy and programme

■ the description of the site's EMS

■ any previous site environmental reviews or audit reports

■ any corrective action details prepared as a result of previous reviews or audits

As part of the desk-top study, the certifier is likely to ask for the following:

■ EMS documentation, including procedures and, preferably, a cross-referenced list linking the documentation to the

relevant sections of the standard

■ a description of the site's processes and an analysis of environmental aspects associated with the production

process, waste flows, products and by-products

■ the evaluation of environmental aspects (Register of environmental aspects and impacts)

■ the continual improvement programme (objectives and targets - management programme)

■ a list of relevant legislation (Register of legislation)

■ an overview of permits/licences, consents and any other agreements with regulatory authorities

■ records of emission data (to check compliance with permits/licences and consents)

■ details of any breaches of legislation and regulatory consents

■ records of correspondence with the regulatory authorities

■ internal audit reports

■ management review reports

■ records of any complaints received and actions taken in response to these complaints.

During this initial assessment, the certification body will advise of any omissions it has identified. These will need to be

corrected before the certification audit can be undertaken.45

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Certification Audit

This audit represents the final stage in the certification process. A site visit will be requested by the certification body, for

which desk space will be needed on-site for its personnel. The purpose of this visit will be to confirm that the written

procedures are actually used in practice and that the requirements of the standard are met. The time needed for the

certification team to carry out the site visit is about two days.

Any non-conformance with ISO 14001 found during the visit will be recorded and a date set by the certification body by

which any necessary corrective action must be carried out. A check will be made that this has occurred and, assuming

that the corrective action is satisfactory, certification will follow.

Retaining ISO 14001 Certification

Retaining certification to ISO 14001 involves demonstrating that the EMS is being properly maintained. This involves

routine surveillance visits by the certification body. The approach taken by the various certification bodies differs. In

general, there will be a visit every six months to review elements of the EMS. An additional fee is payable for renewal.

EMAS VERIFICATION AND REGISTRATION

To be ready for EMAS registration, it is prudent to have had the EMS fully operational for at least three months. This

should allow enough time to evaluate whether the internal audit system is adequate and effective. During this period, at

least one management review should be conducted. The accredited verifier will ask the company to complete a

questionnaire.

Note that in addition to requiring an Environmental Statement, EMAS refers to 'environmental review' rather than 'internal

review'.

TIP: structure the verification so that one third of the organisation s activities are verified each year, so that all

activities are verified over 36 month period (in accordance with Annex V, 5.6 of the Regulation). This will help give the

verifier confidence in the accuracy and reliability of the information detailed in the environmental statement.

The Verification Process

The verification process is very similar to the ISO 14001 certification process and also involves a desk-top study followed

by a main assessment.

Desk-Top Study

The desk-top study will examine:

■ information on the site and its activities

■ the environmental policy and programme

■ the description of the site's EMS

■ any previous site environmental reviews or audit reports

■ any corrective action details prepared as a result of previous reviews or audits.

As part of the desk-top study, the accredited verifier is likely to ask for the following:

■ EMS documentation, including procedures and, preferably, a cross-referenced list linking the documentation to the

relevant sections of the standard

■ a description of the site's processes and an analysis of environmental impacts associated with the production

process, waste flows, products and by-products 46

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■ the evaluation of environmental impacts

■ the continual improvement programme

■ a list of relevant legislation

■ an overview of permits/licences, consents and any other agreements with regulatory authorities

■ records of emission data (to check compliance with licences and consents)

■ details of any breaches of legislation and regulatory consents

■ records of correspondence with the regulatory authorities and history of environmental problems

■ internal audit reports

■ management review reports

■ records of any complaints received and actions taken in response to these complaints

■ involvement of workers

■ the Environmental Statement, and the reliability of the information held within it

The Registration Process

The Competent Body should be contacted with a request for an application form. The form asks for basic information on

company contacts, the site address, activities on-site, the EMS, the name of the verifier of the Environmental Statement,

and contact details for the appropriate regulatory authorities (EA, SEPA, EHS, local authorities). The Competent Body

contacts the regulators to ascertain whether they know of a reason why the organisation should not be registered.

An original copy of the Environmental Statement must be submitted with the completed form.

If the application is successful, an EMAS registration number will be allocated and the company will be entered into the

EMAS register. The company may then use the EMAS logo on letterheads and on its Environmental Statement.

In general, organisations need to renew their registration on an annual basis.

Losing EMAS Registration

De-registration from EMAS can occur in three ways.

■ If a company fails to submit a validated Environmental Statement for a site, along with the appropriate registration

fee, within three months of the deadline specified in the site's previous Statement.

■ If the Competent Body becomes aware that the site is no longer complying with the requirements of the EMAS

Regulation. This information can come via a number of routes, such as public complaints or from regulators.

■ If a regulatory body informs the Competent Body that the site is in breach of relevant environmental legislation, the

site may be refused registration or have its registration suspended. The EMAS Regulation does not define

breach , and so guidance has been drawn up, in agreement with the regulatory bodies, and is available from the

Competent Body. Registration is not likely to be refused or suspended for trivial breaches. If suspension or refusal

of registration is necessary, it will be reversed only when the Competent Body has been assured by the regulator

that the site has rectified the breach and has procedures in place to prevent recurrence.

47

Use of ISO 14001 As a Route to EMAS Registration

In a decision published in the Official Journal of the European Communities on 4 April 1997, the European Commission formally recognised ISO 14001 as an acceptable standard. Article 12 of the EMAS Regulation allows verifiers to accept certificates of compliance with a recognised standard as denoting compliance with most of the EMAS Regulation. This means that those with an ISO 14001 certificate are well down the path in meeting the EMS requirements of EMAS. The additional requirement for EMAS is the publication of a validated Environmental Statement.

Transferring from ISO 14001 to EMAS

ISO14001:2004 EMAS:2001

ClauseNumber

Clause TitleClauseNumber

Clause Title

4.1 General requirements I-A.1 General requirements

4.2 Environmental policy I-A.2 Environmental policy

4.3 Planning I-A.3 Planning

4.3.1 Environmental aspectsI-A.3.1 & Annex VI

Environmental aspects

4.3.2 Legal and other requirements I-A.3.2 & I-B.1 Legal and other requirements

4.3.3 Objectives, targets and programme(s) I-A.3.3 Objectives and targets

4.4 Implementation and operation I-A.4 Implementation and operation

4.4.1 Resources, roles and responsibilities I-A.4.1 Structure and responsibility

4.4.2 Competence, training and awareness I-A.4.2 Training, awareness and competence

4.4.3 CommunicationI-A.4.3 & I-B.3, I-B.4

Communication

4.4.4 Documentation I-A.4.4Environmental management system documentation

4.4.5 Control of documents I-A.4.5 Document Control

4.4.6 Operational control I-A.4.6 Operational control

4.4.7Emergency preparedness and response

I-A.4.7 Emergency preparedness and response

4.5 Checking I-A.5 Checking and corrective action

4.5.1 Monitoring and measurement I-A.5.1 Monitoring and measurement

4.5.2 Evaluation of compliance I-B.1 Legal compliance

4.5.3Non-conformity, corrective and preventative action

I-A.5.2Non-conformance, corrective and preventative action

4.5.4 Control of records I-A.5.3 Records

4.5.5 Internal audits I-A.5.4 Environmental management system audit

4.6 Management Review I-.A.6 Management review

Annex IIInternal Environmental Audit Requirements

Annex III Environmental Statement

Annex VI Environmental Review

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ISO 14001 AND EMAS

Companies operating environmental management systems fully compliant with ISO14001:2004, who wish to become

inspected to EMAS will have to ensure that changes are made in order to be fully compliant with the requirements of

EMAS. These include:

Certification Body

■ Check that the certification body is recognised by the Competent Body.

Scope Of The Certificate

■ Check that the scope of the certificate covers the same geographic area as the scope area for EMAS registration.

Environmental Performance

■ Ensure that the evaluation of overall environmental performance is included as a routine part of monitoring and

management review processes.

Environmental Review

■ Ensure that issues specified in Annex VI of the EMAS Regulation have been addressed in the scope of the review.

Environmental Audit

■ Ensure that the issues specified in Annex II of the EMAS Regulation have been addressed in the scope of the audit.

■ Verifiers will need to be satisfied that audits have been conducted in compliance with Annex II of the EMAS

Regulation. This will be achieved if the audit is carried out in accordance with the requirements of ISO 14010,

14011 and 14012.

■ The frequency of the audit programme will need to be based on the environmental significance of issues

highlighted in previous audits and be related to the rate of progress with which these are being addressed.

■ The audit frequency is likely to be greater than the minimum requirement stipulated within EMAS (at least every

three years, Annex V, 5.6).

Communication

■ Ensure that the way in which communications are handled meets the requirements of points Annex 1-A.4.3 and

Annex 1-B.3 of the EMAS Regulation.

Contractors

■ Ensure that it can be demonstrated that the system which requires contractors to work to equivalent environmental

standards meets the requirements Annex 1-A.4.6 of the EMAS Regulation.

Legal Compliance

■ Ensure that legal compliance can be demonstrated.

Preparation Of The Environmental Statement

■ Ensure that the Statement is a fair representation of performance and that it meets the requirements of Annex III of

the EMAS Regulation.

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ENGINEERING

INTRODUCTION

The table below has been compiled to assist engineering companies to establish an environmental management system

based on ISO 14001: 2004.

In order to comply with the standard, companies need to compile:

■ Register of Environmental Aspects and Impacts (to comply with Clause 4.3.1);

■ Register of Environmental Legislation (to comply with Clause 4.3.2).

The table will help engineering companies to compile these registers.

Engineering companies should check that they comply with each legal requirement (Clause 4.5.2).

It may be useful to generate a list of documents and records that could be inspected regularly to confirm compliance.

All Acts and Regulations since 1987 can be downloaded free from the government's Office of Public Sector Information

website (http://www.opsi.gov.uk/).

Additional interpretation and advice are available from the Environment Agency's NetRegs website

(http://www.netregs.gov.uk) and the Envirowise website (http://www.envirowise.gov.uk).

The table is not a complete list of environmental legislation but provides in general the relevant regulations specific to the

engineering industry.

A list of the environmental aspects of the major operations carried out in the engineering industry is also provided. Each

chemical or material released to any ecosystem should be considered in detail and the list will assist in identifying the

specific processes for individual plants to address.

50

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51

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ales

) R

egul

atio

ns 2

007

(EP

R).

The

re is

littl

e di

rect

impa

ct o

n ex

istin

g P

PC

per

mitt

ed s

ites.

The

exi

stin

g P

PC

req

uire

men

ts in

Sco

tland

and

Nor

ther

n Ir

elan

d cu

rren

tly r

emai

n un

chan

ged.

Act

iviti

es c

over

ed b

y th

e 'P

PC

reg

ime'

with

in th

e en

gine

erin

g in

dust

ry in

Eng

land

and

Wal

es m

ay b

e re

gula

ted

unde

r va

rious

se

ctio

ns o

f of P

art 2

of S

ched

ule

1 of

the

EP

R in

clud

ing:

■S

ectio

n 1.

1 C

ombu

stio

n A

ctiv

ities

; ■

Sec

tion

2.1

Fer

rous

Met

als;

■

Sec

tion

2.3

Sur

face

Tre

atin

g M

etal

s an

d P

last

ic M

ater

ials

; ■

Sec

tion

6.4

Coa

ting

Act

iviti

es, P

rintin

g an

d T

extil

e T

reat

men

ts;

■S

ectio

n 7

Sol

vent

Em

issi

ons

Dire

ctiv

e A

ctiv

ities

.

Air

Qua

lity

Sta

ndar

ds

Reg

ulat

ions

200

7 (S

I200

7/64

)T

hese

Reg

ulat

ions

app

ly to

the

who

le o

f the

UK

and

req

uire

that

the

Sec

reta

ry o

f Sta

te ta

kes

the

nece

ssar

y m

easu

res

to e

nsur

e th

at: ■

the

air

qual

ity s

tand

ards

pro

vide

d in

Sch

edul

e 1

of th

e R

egul

atio

ns a

re m

et fo

r G

roup

A p

ollu

tant

s -

benz

ene,

car

bon

mon

oxid

e, le

ad, n

itrog

en d

ioxi

de a

nd o

xide

s of

nitr

ogen

, par

ticul

ate

mat

ter

(PM

10)

and

sulp

hur

diox

ide

■th

e ne

cess

ary

mea

sure

s no

t ent

ailin

g di

spro

port

iona

te c

osts

are

take

n fo

r G

roup

B p

ollu

tant

s -

the

cont

ent o

f ars

enic

, be

nzo(

a)py

rene

, cad

miu

m a

nd n

icke

l, an

d th

eir

com

poun

ds, w

ithin

the

PM

10 fr

actio

n ■

targ

et v

alue

s an

d lo

ng-t

erm

obj

ectiv

es a

re im

pose

d fo

r oz

one.

Cle

an A

ir A

ct 1

993

Thi

s A

ct, w

hich

app

lies

to E

ngla

nd, S

cotla

nd a

nd W

ales

, pro

vide

s th

e m

ain

regu

lato

ry fr

amew

ork

for

air

qual

ity o

utsi

de o

f the

IP

PC

reg

ime.

Cle

an A

ir A

ct p

rovi

sion

s do

not

app

ly to

site

s re

gula

ted

unde

r th

e P

PC

/EP

R r

egim

es; e

mis

sion

s to

air

from

thes

e si

tes

are

cont

rolle

d un

der

the

cond

ition

s of

a p

erm

it.

The

Act

con

tain

s pr

ovis

ions

rel

atin

g to

the

follo

win

g ai

r qu

ality

issu

es:

■pr

ohib

ition

of d

ark

smok

e fr

om c

him

neys

and

indu

stria

l or

trad

e pr

emis

es;

52

■in

stal

latio

n of

furn

aces

; ■

limits

on

the

rate

of g

rit a

nd d

ust e

mis

sion

from

the

chim

neys

of f

urna

ces;

■

arre

stm

ent p

lant

for

furn

aces

; ■

mea

sure

men

t of g

rit, d

ust a

nd fu

mes

; ■

chim

ney

heig

hts;

■

smok

e co

ntro

l are

as;

■ad

apta

tion

of fi

repl

aces

; ■

mot

or fu

el;

■su

lphu

r co

nten

t of o

il fu

el fo

r fu

rnac

es o

r en

gine

s;

■in

form

atio

n ab

out a

ir po

llutio

n.

Sm

oke

Con

trol

Are

as

(Aut

horis

ed F

uels

)(E

ngla

nd)

Reg

ulat

ions

200

1 (S

I 20

01/3

745)

as

amen

ded

Sm

oke

Con

trol

Are

as

(Aut

horis

ed F

uels

) (E

ngla

nd)

Reg

ulat

ions

200

8 (S

I 20

08/5

14)

The

200

1 R

egul

atio

ns a

utho

rise

the

use

of c

erta

in fu

el ty

pes

in s

mok

e co

ntro

l are

as in

acc

orda

nce

with

the

prov

isio

ns o

f Par

t III

of th

e C

lean

Air

Act

199

3.

The

200

8 R

egul

atio

ns c

onso

lidat

e fiv

e se

ts o

f reg

ulat

ions

, ie

S.I.

200

1/37

45, 2

002/

3046

, 200

5/28

95, 2

006/

1869

and

200

7/24

60.

Sul

phur

Con

tent

of L

iqui

d F

uels

Reg

ulat

ions

200

7 (S

CO

LF)

(SI 2

007/

79)

The

SC

OLF

Reg

ulat

ions

lim

it th

e su

lphu

r co

nten

t in

liqui

d fu

els

- in

par

ticul

ar, a

s fr

om 1

Jan

uary

200

8, g

as o

il m

ust h

ave

a su

lphu

r co

nten

t no

grea

ter

than

0.1

% b

y m

ass

(Reg

ulat

ion

5) a

nd h

eavy

fuel

oil

mus

t not

hav

e a

sulp

hur

cont

ent l

ess

than

1%

by

mas

s (R

egul

atio

n 4)

.

Fin

ance

Act

200

0, C

hapt

er

17: S

ched

ule

6. C

limat

e C

hang

e Le

vy (

CC

L)

The

Clim

ate

Cha

nge

Levy

(C

CL)

is a

tax

on th

e us

e of

ene

rgy

in in

dust

ry, c

omm

erce

and

the

publ

ic s

ecto

r, w

ith o

ffset

ting

cuts

in

empl

oyer

s' N

atio

nal I

nsur

ance

Con

trib

utio

ns (

NIC

s) a

nd a

dditi

onal

sup

port

for

ener

gy e

ffici

ency

sch

emes

and

ren

ewab

le

sour

ces

of e

nerg

y. T

he le

vy fo

rms

a ke

y pa

rt o

f the

Gov

ernm

ent's

ove

rall

Clim

ate

Cha

nge

Pro

gram

me.

The

CC

L is

app

lied

to e

lect

ricity

, gas

, coa

l and

liqu

efie

d pe

trol

eum

gas

(LP

G).

The

rat

e at

whi

ch a

bus

ines

s pa

ys d

epen

ds o

n th

e ty

pe o

f fue

l use

d. T

he le

vy is

add

ed to

bill

s be

fore

VA

T a

nd, a

lthou

gh th

ere

is n

o le

gal r

equi

rem

ent f

or it

to b

e sh

own,

is li

kely

to

appe

ar a

s a

sepa

rate

item

on

ener

gy b

ills.

It a

dds

appr

oxim

atel

y 15

% to

typi

cal e

nerg

y bi

lls o

f UK

bus

ines

ses.

The

re a

re c

erta

in e

xem

ptio

ns a

nd d

isco

unts

from

the

levy

, eg:

■th

e le

vy d

oes

not a

pply

to s

mal

ler

busi

ness

es w

hich

use

a d

omes

tic a

mou

nt o

f ene

rgy;

■

ener

gy fr

om n

atur

al g

as in

Nor

ther

n Ir

elan

d (u

ntil

2011

);

■th

e us

e of

fuel

s oi

ls (

as th

ey a

re a

lread

y su

bjec

t to

an e

xcis

e du

ty);

53

'goo

d qu

ality

' com

bine

d he

at a

nd p

ower

(C

HP

) sy

stem

s.

Ene

rgy

inte

nsiv

e in

dust

ries

can

get a

n 80

% d

isco

unt o

n th

e C

CL

if th

ey a

gree

to e

nerg

y us

e re

duct

ion

targ

ets

as p

art o

f Clim

ate

Cha

nge

Agr

eem

ents

(C

CA

s) n

egot

iate

d by

Def

ra w

ith th

e re

leva

nt tr

ade

asso

ciat

ions

on

beha

lf of

the

com

pani

es in

the

sect

ors

conc

erne

d (a

n 'U

mbr

ella

Agr

eem

ent')

. For

exa

mpl

e, th

e C

onfe

dera

tion

of P

aper

Indu

strie

s ha

s an

Um

brel

la A

gree

men

t with

D

efra

. For

exa

mpl

e, T

he S

ocie

ty o

f Brit

ish

Aer

ospa

ce C

ompa

nies

Ltd

, the

Met

al P

acka

ging

Man

ufac

ture

rs A

ssoc

iatio

n an

d th

e S

urfa

ce E

ngin

eerin

g A

ssoc

iatio

n ha

ve U

mbr

ella

Agr

eem

ents

with

Def

ra.

Gre

enho

use

Gas

Em

issi

ons

Tra

ding

Sch

eme

Reg

ulat

ions

20

05 (

SI 2

005/

925)

Was

te a

nd E

mis

sion

s T

radi

ng

(WE

T)

Act

200

3

(Em

issi

ons

Tra

ding

Sch

eme)

The

se R

egul

atio

ns c

onso

lidat

e th

e G

reen

hous

e G

as E

mis

sion

s T

radi

ng S

chem

e R

egul

atio

ns 2

003

(SI 2

003/

3311

) an

d th

e G

reen

hous

e G

as E

mis

sion

s T

radi

ng S

chem

e (A

men

dmen

t) R

egul

atio

ns 2

004

(SI 2

004/

3390

) as

am

ende

d.

The

Reg

ulat

ions

con

trol

em

issi

ons

of c

arbo

n di

oxid

e fr

om a

ny o

f the

act

iviti

es li

sted

in S

ched

ule

1 to

the

Reg

ulat

ions

The

EU

Em

issi

ons

Tra

ding

Sch

eme

(ET

S)

is o

ne o

f man

y po

licie

s im

plem

ente

d th

roug

hout

the

EU

in o

rder

for

mem

ber

stat

es to

m

eet t

heir

carb

on d

ioxi

de r

educ

tion

targ

ets

agre

ed u

nder

the

Kyo

to P

roto

col.

All

inst

alla

tions

with

com

bust

ion

plan

t (eg

boi

lers

) in

ex

cess

of 2

0 M

W th

erm

al in

put o

r ca

rryi

ng o

ut o

ther

act

iviti

es li

sted

in S

ched

ule

1 of

the

Reg

ulat

ions

mus

t app

ly to

the

'env

ironm

ent a

genc

ies'

for

a gr

eenh

ouse

gas

em

issi

ons

perm

it. T

he c

ondi

tions

of t

he p

erm

it w

ill r

equi

re in

stal

latio

ns to

mon

itor

and

repo

rt e

mis

sion

s in

acc

orda

nce

with

Eur

opea

n C

omm

issi

on's

gui

delin

es. E

ach

oper

ator

is a

lloca

ted

a fr

ee a

nd fi

xed

allo

wan

ce (

one

allo

wan

ce r

epre

sent

s on

e to

nne

of c

arbo

n di

oxid

e eq

uiva

lent

). A

t the

end

of e

ach

year

, ope

rato

rs h

ave

to

dem

onst

rate

that

they

hav

e en

ough

allo

wan

ces

to c

over

thei

r in

stal

latio

n's

emis

sion

s. T

hey

can

eith

er b

uy a

dditi

onal

allo

wan

ces

(on

top

of th

eir

free

allo

catio

n) o

r se

ll an

y su

rplu

s al

low

ance

s ge

nera

ted

from

red

ucin

g th

eir

emis

sion

s.

Par

t 2 o

f the

WE

T A

ct is

con

cern

ed w

ith th

e tr

adin

g of

em

issi

ons

quot

as in

par

ticul

ar e

mis

sion

s of

CO

2. The

Act

am

ends

the

'PP

C

regi

me'

to a

llow

for

the

enfo

rcea

bilit

y of

pen

altie

s, in

clud

ing

fixed

fina

ncia

l pen

altie

s.

Flu

orin

ated

Gre

enho

use

Gas

es R

egul

atio

ns 2

008

(F

Gas

Reg

ulat

ions

) (S

I 20

08/4

1)

The

se R

egul

atio

ns e

nact

EC

Reg

ulat

ion

No.

842

/200

6 in

to U

K la

w. T

he 'F

Gas

Reg

ulat

ions

' set

out

pro

visi

ons,

offe

nces

and

pe

nalti

es in

rel

atio

n to

the

use

of c

erta

in fl

uorin

ated

gas

es le

akag

es.

Flu

orin

ated

gas

es (

ofte

n re

ferr

ed to

as

F g

ases

) ar

e m

an-m

ade

gase

s th

at a

re u

sed

in a

num

ber

of d

iffer

ent s

ecto

rs. T

he m

ost

com

mon

ly u

sed

belo

ng to

a c

lass

of c

hem

ical

s kn

own

as h

ydro

fluor

ocar

bons

(H

FC

s). '

F g

ases

' als

o in

clud

e' p

erflu

oroc

arbo

ns

(PF

Cs)

and

sul

phur

hex

aflu

orid

e (S

F6)

as

liste

d in

Ann

ex I

and

prep

arat

ions

con

tain

ing

thos

e su

bsta

nces

, but

exc

lude

s su

bsta

nces

con

trol

led

unde

r R

egul

atio

n (E

C)

No.

203

7/20

00 o

n su

bsta

nces

that

dep

lete

the

ozon

e la

yer.

The

mai

n pr

ovis

ions

in th

e R

egul

atio

ns s

eek

to e

nsur

e:

■co

ntai

nmen

t thr

ough

res

pons

ible

han

dlin

g du

ring

use,

rec

yclin

g an

d en

d-o

f-lif

e re

cove

ry

54

■re

port

ing

on q

uant

ities

pro

duce

d, s

uppl

ied,

use

d an

d em

itted

■

cert

ain

appl

icat

ion

spec

ific

bans

on

use

and

plac

ing

on th

e m

arke

t.

The

Reg

ulat

ions

set

out

offe

nces

for

each

of t

he k

ey o

blig

atio

ns li

sted

abo

ve. A

fixe

d pe

nalty

pay

able

in p

ursu

ance

of a

fixe

d pe

nalty

not

ice

is '1

00.

The

Reg

ulat

ions

focu

s on

the

cont

ainm

ent a

nd r

ecov

ery

of fl

uorin

ated

gre

enho

use

gase

s. T

hey

also

set

out

:

■th

e qu

alifi

catio

ns r

equi

red

for

cert

ain

stat

iona

ry e

quip

men

t and

fire

pro

tect

ion

equi

pmen

t

' the

enf

orce

men

t pow

ers

avai

labl

e to

enf

orce

men

t bod

ies

(the

'env

ironm

ent a

genc

ies'

).

 

Not

ifica

tion

of C

oolin

g T

ower

s an

d E

vapo

rativ

e C

onde

nser

s R

egul

atio

ns

1992

(S

I 199

2/22

25)

Com

pani

es th

at o

pera

te o

pen

spra

y ty

pe c

oolin

g to

wer

s or

con

dens

ers

are

requ

ired

to r

egis

ter

with

thei

r lo

cal a

utho

rity

due

to

the

risk

of L

egio

nella

. Com

pani

es s

houl

d en

sure

that

:

■co

olin

g to

wer

s an

d ho

t and

col

d w

ater

sys

tem

s ar

e m

anag

ed a

nd m

aint

aine

d in

acc

orda

nce

with

the

App

rove

d C

ode

of

Pra

ctic

es

■th

e ne

cess

ary

risk

asse

ssm

ents

are

und

erta

ken.

Vol

atile

Org

anic

Com

poun

ds

in P

aint

s, V

arni

shes

and

V

ehic

le R

efin

ishi

ng P

rodu

cts

Reg

ulat

ions

200

5 (S

I 20

05/2

773)

The

Reg

ulat

ions

tran

spos

e th

e E

U P

aint

s D

irect

ive

2004

/42/

EC

with

the

aim

of r

educ

ing

chem

ical

fum

es in

cer

tain

pai

nts,

va

rnis

hes

and

vehi

cle

refin

ishi

ng p

rodu

cts.

The

Reg

ulat

ions

hav

e pr

escr

ibed

lim

its fo

r th

e am

ount

of v

olat

ile o

rgan

ic c

ompo

unds

(V

OC

s) th

at c

an b

e in

clud

ed in

pai

nts

sinc

e 20

07, w

ith m

ore

strin

gent

lim

its b

eing

bro

ught

in fr

om 1

Jan

uary

201

0.

Veh

icle

fini

sher

s us

ing

less

than

1 to

nne

of s

olve

nts

per

year

will

be

rem

oved

from

the

scop

e of

the

Sol

vent

Em

issi

ons

Dire

ctiv

e 19

99/1

3/E

C a

nd th

eref

ore

the

'PP

C r

egim

e'.

Env

ironm

enta

l Pro

tect

ion

(Con

trol

s on

Ozo

ne-D

eple

ting

Sub

stan

ces)

Reg

ulat

ions

20

02 (

SI 2

002/

528)

Ozo

ne D

eple

ting

Sub

stan

ces

The

se R

egul

atio

ns p

lace

res

tric

tions

on

the

supp

ly a

nd u

se o

f ozo

ne-d

eple

ting

subs

tanc

es in

clud

ing

chlo

roflu

oroc

arbo

ns

(CF

Cs)

, hyd

roch

loro

fluor

ocar

bons

(H

CF

Cs)

, hal

ons

and

met

hyl b

rom

ide.

Ope

rato

rs w

ho im

port

or

expo

rt o

zone

-dep

letin

g su

bsta

nces

are

req

uire

d to

hav

e a

licen

ce is

sued

by

the

Eur

opea

n C

omm

issi

on.

All

HC

FC

s w

ill b

e ba

nned

from

1 J

anua

ry 2

015.

55

(Qua

lific

atio

ns)

Reg

ulat

ions

20

06 (

SI 2

006/

1510

)T

he 2

006

Reg

ulat

ions

pre

scrib

e m

inim

um q

ualif

icat

ion

stan

dard

s (a

cur

rent

val

id c

ertif

icat

e of

com

pete

nce

from

an

accr

edite

d as

sess

men

t aut

horit

y) fo

r in

divi

dual

s w

ho s

ervi

ce a

nd m

aint

ain

refr

iger

atio

n or

air

cond

ition

ing

equi

pmen

t tha

t con

tain

ozo

ne-

depl

etin

g su

bsta

nces

.

Asp

ects

, im

pac

ts a

nd

ob

ject

ives

/op

erat

ion

al c

on

tro

ls

EN

VIR

ON

ME

NTA

L A

SP

EC

TS

Dire

ct d

isch

arge

s to

air

from

eng

inee

ring

indu

stry

act

iviti

es in

clud

e:

■pa

rtic

ulat

e m

atte

r (P

M)

- fr

om d

ust e

xtra

ctio

n sy

stem

s, s

pray

boo

ths,

siz

e re

duct

ion

(eg

cutti

ng, g

rindi

ng a

nd m

illin

g), m

achi

ning

ope

ratio

ns, s

hot b

last

ing

(eg

peen

ing)

, sto

rage

of i

nher

ently

dus

ty r

aw m

ater

ials

and

com

bust

ion

of fo

ssil

and/

or w

aste

der

ived

fuel

s;

■V

OC

s -

from

sur

face

coa

ting,

spr

ay b

ooth

s, in

com

plet

e co

mbu

stio

n pr

edom

inan

tly o

f hea

vy a

nd w

ater

fuel

oils

, sol

vent

cle

anin

g an

d de

grea

sing

ac

tiviti

es;

■ox

ides

of n

itrog

en (

NO

x) -

from

mel

ting,

cur

ing,

ann

ealin

g an

d te

mpe

ring

durin

g ho

t for

min

g pr

oces

ses

and

heat

trea

tmen

t of m

ater

ials

and

hig

h te

mpe

ratu

re d

egra

datio

n of

nitr

ogen

in r

aw m

ater

ials

and

hig

h-te

mpe

ratu

re o

xida

tion

of a

tmos

pher

ic n

itrog

en a

s co

mbu

stio

n by

-pro

duct

s;

■ox

ides

of s

ulph

ur (

SO

x) -

from

con

tam

inan

ts in

raw

mat

eria

ls r

elea

sed

durin

g ho

t for

min

g pr

oces

ses

and

heat

trea

tmen

ts;

■ox

ides

of c

arbo

n -

rele

ased

dur

ing

heat

trea

tmen

t pro

cess

es a

nd a

s a

com

bust

ion

by-p

rodu

ct;

■am

mon

ia -

from

wet

scr

ubbi

ng a

bate

men

t sys

tem

s an

d w

aste

wat

er tr

eatm

ent;

■

ozon

e-de

plet

ing

subs

tanc

es -

from

ref

riger

atio

n an

d co

olin

g sy

stem

s;

■Le

gion

ella

- fr

om in

adeq

uate

ly m

aint

aine

d co

olin

g eq

uipm

ent;

■

odou

rs -

from

was

tew

ater

trea

tmen

t and

cur

ing

subs

eque

nt to

hea

t for

min

g pr

oces

ses.

EN

VIR

ON

ME

NTA

L IM

PA

CTS

Par

ticul

ate

mat

ter/

dust

can

lead

to s

tatu

tory

nui

sanc

e. In

add

ition

PM

can

cau

se h

uman

hea

lth e

ffect

s an

d ha

ve a

neg

ativ

e im

pact

on

ecol

ogic

al r

ecep

tors

due

to

smot

herin

g. T

here

is a

Nat

iona

l Air

Qua

lity

Str

ateg

y ob

ject

ive

for

PM

10 o

f 50μ

g/m

3 ave

rage

d ov

er a

24-

hour

per

iod.

NO

x an

d su

lphu

r di

oxid

e co

ntrib

ute

to a

cid

rain

. The

y ca

n ha

ve h

uman

hea

lth e

ffect

s as

wel

l as

havi

ng a

del

eter

ious

effe

ct o

n ec

osys

tem

s du

e to

nut

rient

and

ac

id d

epos

ition

. Bot

h N

Ox

and

sulp

hur

diox

ide

are

two

of th

e su

bsta

nces

for

whi

ch th

e U

K g

over

nmen

t has

est

ablis

hed

an a

ir qu

ality

sta

ndar

d as

par

t of i

ts

Nat

iona

l Air

Qua

lity

Str

ateg

y (N

AQ

S).

The

NA

QS

impl

emen

ts a

n ad

ditio

nal s

tand

ard

for

sulp

hur

diox

ide

of 2

66 μ

g/m

3 ave

rage

d ov

er a

15-

min

ute

perio

d w

hich

is

not t

o be

exc

eede

d m

ore

than

15

times

per

yea

r.

NO

x ar

e al

so g

reen

hous

e ga

ses.

VO

Cs

in th

e at

mos

pher

e ar

e a

prec

urso

r of

gro

und

leve

l ozo

ne th

at c

an b

e re

spon

sibl

e fo

r re

spira

tory

pro

blem

s, c

ause

sm

og, a

nd d

amag

e bu

ildin

gs a

nd c

rops

. S

ome

VO

Cs

can

also

be

toxi

c an

d ev

en c

arci

noge

nic.

56

Inco

rrec

t ins

talla

tion,

ope

ratio

n an

d m

aint

enan

ce o

f hot

wat

er a

nd c

oolin

g sy

stem

s m

ay r

elea

se L

egio

nnai

re's

bac

teria

into

the

atm

osph

ere

with

con

sequ

entia

l ris

k of

ser

ious

illn

ess

in e

xpos

ed p

erso

nnel

.

OB

JEC

TIV

ES

/OP

ER

ATI

ON

AL

CO

NTR

OLS

PM

em

issi

ons

shou

ld b

e m

inim

ised

by

ensu

ring

raw

mat

eria

ls a

re s

tore

d/tr

ansp

orte

d in

enc

lose

d si

los

and

tran

spor

tatio

n sy

stem

s (e

g co

nvey

ors,

enc

lose

d sc

rew

feed

ers,

and

feed

poc

ket e

nclo

sure

s).

Any

loca

l exh

aust

ven

tilat

ion

(LE

V)

- pa

rtic

ular

ly fo

r dr

y m

ater

ials

load

ing

and

unlo

adin

g po

ints

, and

whe

re p

rodu

cts

are

shot

bla

sted

, gro

und

or m

illed

- s

houl

d be

ade

quat

ely

abat

ed, e

g cy

clon

es fo

llow

ed b

y fa

bric

filte

rs. W

here

LE

V e

xist

s fo

r th

e pu

rpos

e of

min

imis

ing

occu

patio

nal h

ealth

ris

ks fr

om s

olve

nts

(eg

spra

y bo

oths

), a

dequ

ate

abat

emen

t sho

uld

be c

onsi

dere

d to

ens

ure

was

tes

gase

s do

not

cau

se a

n en

viro

nmen

tal i

mpa

ct, e

g ac

tivat

ed c

harc

oal f

ilter

s or

ther

mal

tr

eatm

ent.

Oth

er fu

gitiv

e du

st m

itiga

tion

mea

sure

s in

clud

e:

■se

greg

atio

n of

sto

rage

are

as fr

om o

ther

ope

ratio

nal a

reas

; ■

use

of w

ind

prot

ectio

n (e

g ei

ther

art

ifici

al b

arrie

rs o

r ve

rtic

al g

reen

ery

such

as

dens

ely

grow

ing

tree

s an

d sh

rubs

if r

aw m

ater

ial i

s st

ored

in o

pen

pile

s);

■re

duce

d ai

r le

akag

e an

d sp

illag

e po

ints

thro

ugh

mai

nten

ance

act

iviti

es;

■m

aint

aini

ng n

egat

ive

pres

sure

in c

lose

d sy

stem

s us

ed fo

r m

ater

ial h

andl

ing.

Pol

luta

nts

emitt

ed v

ia a

sta

ck r

equi

re s

uffic

ient

dis

pers

ion

and

dilu

tion

in th

e at

mos

pher

e to

ens

ure

they

gro

und

at c

once

ntra

tions

that

are

har

mle

ss. T

his

can

be

achi

eved

by

ensu

ring

stac

k he

ight

s ar

e su

ffici

ent.

Em

issi

ons

of N

Ox

from

furn

aces

and

com

bust

ion

plan

t sho

uld

be m

inim

ised

whe

re n

eces

sary

to m

eet e

mis

sion

lim

it va

lues

and

sta

tuto

ry le

vels

by

optim

isin

g pe

ak fl

ame

tem

pera

ture

s an

d ut

ilisi

ng lo

w N

Ox

burn

ers.

End

-of p

ipe

tech

niqu

es th

at s

houl

d be

con

side

red

for

min

imis

ing

NO

x em

issi

ons

incl

ude:

■ca

taly

tic r

educ

tion

(3R

pro

cess

);

■se

lect

ive

cata

lytic

red

uctio

n;

■re

-bur

n;

■w

ater

/ste

am in

ject

ion.

Sul

phur

dio

xide

em

issi

ons

shou

ld b

e m

inim

ised

by:

57

■se

lect

ing

fuel

s w

ith a

low

sul

phur

con

tent

suc

h as

nat

ural

gas

or

LPG

; ■

usin

g lo

w-s

ulph

ur r

aw m

ater

ial a

nd lo

w-s

ulph

ur b

ody

addi

tives

to r

educ

e su

lphu

r le

vels

in p

roce

ssed

mat

eria

ls;

■op

timis

ing

the

heat

ing

proc

ess

and

firin

g te

mpe

ratu

re;

■us

ing

dry

scru

bber

s -

if dr

y so

rptio

n ca

nnot

pro

duce

a s

uffic

ient

cle

an-g

as c

once

ntra

tion

impl

emen

t the

use

of w

et s

crub

bers

(eg

rea

ctiv

e sc

rubb

ers

or q

uenc

h re

acto

rs).

(T

he e

ffica

cy o

f wet

scr

ubbe

rs c

an b

e im

prov

ed b

y ad

ding

bas

ic r

eact

ive

chem

ical

s (e

g ca

lciu

m-

and

sodi

um-b

ased

che

mic

als)

di

ssol

ved

into

was

h w

ater

).

Reg

ular

ly m

ake

and

reco

rd v

isu

al in

spec

tio

ns

of e

mis

sion

s to

air

for

dark

sm

oke

and

odou

r (o

lfact

ory

test

s).

End

-of-

pipe

tech

niqu

es (

eg a

ctiv

ated

car

bon

filte

rs)

shou

ld b

e co

nsid

ered

to m

inim

ise

the

emis

sion

s of

VO

Cs.

Em

issi

ons

in e

xces

s of

100

mg/

m3 s

houl

d be

tr

eate

d by

app

lyin

g th

erm

al a

fterb

urni

ng in

a o

ne o

r th

ree

cham

ber

ther

mor

eact

or.

In o

rder

to e

limin

ate

stea

m p

lum

es, r

elea

ses

from

wet

scr

ubbe

r ve

nts

shou

ld b

e ho

t eno

ugh

to a

void

vis

ible

plu

me

form

atio

n in

the

vici

nity

of t

he v

ent.

The

follo

win

g ar

e ad

ditio

nal e

xam

ples

of g

ood

envi

ronm

enta

l pra

ctic

e:

■C

ondu

ct m

onito

ring

of s

tack

em

issi

ons

to d

eter

min

e co

mpl

ianc

e w

ith p

erm

it co

nditi

ons.

■

Tra

in o

pera

tors

in th

e us

e of

env

ironm

enta

lly s

ensi

tive

plan

t. ■

Ens

ure

that

del

iver

ies

are

carr

ied

out i

n su

ch a

way

so

as to

min

imis

e no

ise,

spi

llage

and

dus

ty e

mis

sion

s.

■In

spec

t and

mai

ntai

n fr

eque

ntly

as

part

of a

pla

nned

pre

vent

ativ

e m

aint

enan

ce a

nd in

spec

tion

prog

ram

me

all p

lant

whi

ch m

ay le

ad to

an

impa

ct o

n th

e en

viro

nmen

t.

Equ

ipm

ent c

onta

inin

g oz

one-

depl

etin

g su

bsta

nces

(O

DS

) -

incl

udin

g re

frig

erat

ion

equi

pmen

t, ai

r co

nditi

onin

g eq

uipm

ent a

nd c

hille

rs -

sho

uld

be s

ervi

ced

regu

larly

to p

reve

nt le

aks.

OD

S s

houl

d ne

ver

be v

ente

d to

the

atm

osph

ere

and

mus

t be

reco

vere

d du

ring

serv

icin

g an

d m

aint

enan

ce.

58

WA

TER

Leg

isla

tio

n/C

od

e o

f P

ract

ice

Su

mm

ary

of

leg

isla

tive

req

uir

emen

ts

Wat

er R

esou

rces

Act

199

1 (W

RA

)

Eng

land

and

Wal

es

In E

ngla

nd a

nd W

ales

, it i

s an

offe

nce

unde

r S

ectio

n 85

of t

he W

RA

(C

hapt

er 5

7: P

art I

I) to

cau

se o

r kn

owin

gly

perm

it po

llutin

g m

atte

r (in

clud

ing

solid

was

te, t

rade

effl

uent

and

sew

age

but n

ot r

ainw

ater

) to

ent

er c

ontr

olle

d w

ater

or

surf

ace

wat

er d

rain

s.

Con

trol

led

wat

ers

incl

ude

surf

ace

wat

ers

(riv

ers,

lake

s, s

trea

ms,

ditc

hes,

etc

) an

d gr

ound

wat

ers.

An

offe

nce

is n

ot c

omm

itted

if

the

disc

harg

e is

mad

e in

acc

orda

nce

with

a d

isch

arge

con

sent

(w

here

a s

ite is

reg

ulat

ed in

acc

orda

nce

with

a P

PC

/EP

R

perm

it, a

con

sent

to d

isch

arge

is in

clud

ed w

ithin

the

enve

lope

of t

he p

erm

it).

Wat

er E

nviro

nmen

t and

Wat

er

Ser

vice

s (S

cotla

nd)

Act

200

3 (W

EW

S)

The

Wat

er F

ram

ewor

k D

irect

ive

(WF

D)

has

been

impl

emen

ted

in S

cotla

nd v

ia th

e W

EW

S A

ct. P

rovi

sion

s fo

r di

scha

rges

to th

e w

ater

env

ironm

ent a

re in

clud

ed w

ithin

the

Wat

er E

nviro

nmen

t (C

ontr

olle

d A

ctiv

ities

) (S

cotla

nd)

Reg

ulat

ions

200

5 (C

AR

). In

S

cotla

nd, '

cont

rolle

d w

ater

s' a

re r

efer

red

to a

s 'w

ater

env

ironm

ent'.

Wat

er (

Nor

ther

n Ir

elan

d)

Ord

er 1

999

Sim

ilar

prov

isio

ns a

s th

e W

RA

with

reg

ard

to o

ffenc

es a

nd d

isch

arge

con

sent

s ar

e in

clud

ed in

the

Wat

er (

Nor

ther

n Ir

elan

d)

Ord

er 1

999.

In N

orth

ern

Irel

and,

a d

isch

arge

con

sent

is r

equi

red

for

all d

isch

arge

s to

'wat

erw

ays

and

wat

er c

onta

ined

in

unde

rgro

und

stra

ta'.

Wat

er In

dust

ry A

ct 1

991

(WIA

)T

he W

IA c

ontr

ols

disc

harg

es o

f tra

de e

fflue

nt to

sew

er in

Eng

land

and

Wal

es. T

rade

effl

uent

is a

ny li

quid

was

te, i

n an

y qu

antit

y,

that

is p

rodu

ced

from

an

orga

nisa

tion'

s op

erat

ions

. Tra

de e

fflue

nt c

an in

clud

e:

■liq

uid

proc

ess

was

tes;

■

wa

sh w

ate

r;

■co

olin

g w

ater

; ■

cond

ensa

te w

ater

from

com

pres

sed

air

inst

alla

tions

; ■

was

te c

hem

ical

s.

No

disc

harg

e of

trad

e ef

fluen

t can

be

mad

e to

the

sew

er w

ithou

t aut

horis

atio

n fr

om th

e se

wag

e un

dert

aker

(T

rade

Effl

uent

C

onse

nt -

TE

C).

In E

ngla

nd a

nd W

ales

, if t

he e

fflue

nt is

con

side

red

to b

e sp

ecia

l cat

egor

y tr

ade

efflu

ent,

the

wat

er c

ompa

ny c

ould

ref

use

to

acce

pt it

. If i

t doe

s co

nsid

er a

ccep

tanc

e, th

e w

ater

com

pany

mus

t ref

er to

the

Env

ironm

ent A

genc

y w

ithin

two

mon

ths

to

disc

uss

if an

d ho

w, i

n te

rms

of a

ny r

estr

ictio

ns, t

he d

isch

arge

mig

ht b

e ac

cept

ed.

Spe

cial

cat

egor

y ef

fluen

ts c

onta

in p

resc

ribed

sub

stan

ces

abov

e ba

ckgr

ound

con

cent

ratio

ns. T

he p

resc

ribed

sub

stan

ces

incl

ude:

■m

ercu

ry a

nd it

s co

mpo

unds

;

59

■ca

dmiu

m a

nd it

s co

mpo

unds

; ■

1,2-

dich

loro

etha

ne;

■tr

ibut

yltin

com

poun

ds;

■tr

iphe

nylti

n co

mpo

unds

; ■

tric

hlor

oeth

ylen

e;

■pe

rchl

oroe

thyl

ene.

In E

ngla

nd a

nd W

ales

, the

sew

age

com

pani

es a

re r

equi

red

to c

onsu

lt w

ith th

e E

nviro

nmen

t Age

ncy

to d

iscu

ss a

ny r

estr

ictio

ns

whi

ch m

ay b

e re

quire

d on

the

disc

harg

e.

In S

cotla

nd, S

cotti

sh W

ater

wou

ld d

iscu

ss p

oten

tial r

ecei

pt o

f suc

h ef

fluen

ts w

ith th

e S

cotti

sh E

nviro

nmen

t Pro

tect

ion

Age

ncy

(SE

PA

) pr

ior

to a

gree

ing

acce

ptan

ce, b

ut th

ere

is n

o le

gal r

equi

rem

ent.

In N

orth

ern

Irel

and,

it w

ould

be

nece

ssar

y to

dis

cuss

the

disc

harg

e w

ith th

e N

orth

ern

Irel

and

Env

ironm

ent A

genc

y.

Sew

erag

e (S

cotla

nd)

Act

(1

968)

Thi

s A

ct c

ontr

ols

trad

e ef

fluen

t dis

char

ges

to s

ewer

s in

Sco

tland

. Its

req

uire

men

ts a

re v

ery

sim

ilar

to W

IA.

Wat

er a

nd S

ewer

age

Ser

vice

s (N

orth

ern

Irel

and

Ord

er)

1973

Sim

ilar

prov

isio

ns e

xist

in N

orth

ern

Irel

and

whe

re th

ey a

re e

nact

ed b

y th

e W

ater

and

Sew

erag

e S

ervi

ces

(Nor

ther

n Ir

elan

d)

Ord

er 1

973.

Its

requ

irem

ents

are

ver

y si

mila

r to

WIA

.

Wat

er S

uppl

y (W

ater

Fitt

ings

) R

egul

atio

ns 1

999

(SI

1999

/114

8)

The

pur

pose

of t

he R

egul

atio

ns is

to p

reve

nt w

ater

mis

use,

und

ue c

onsu

mpt

ion

and

cont

amin

atio

n of

drin

king

wat

er s

uppl

ies.

The

Reg

ulat

ions

req

uire

any

per

son

who

pro

pose

s to

inst

all a

wat

er fi

tting

(or

ext

end

or a

lter

a w

ater

sys

tem

) on

any

pre

mis

es

to:

■gi

ve n

otic

e to

the

wat

er u

nder

take

r th

at th

ey p

ropo

se to

do

the

wor

k;

■no

t beg

in th

at w

ork

with

out t

he c

onse

nt o

f tha

t und

erta

ker;

■

com

ply

with

any

con

ditio

ns to

whi

ch th

e un

dert

aker

's c

onse

nt is

sub

ject

.

Gro

undw

ater

Reg

ulat

ions

19

98 (

SI 1

998/

2746

)T

he E

U G

roun

dwat

er D

irect

ive

80/6

8/E

EC

has

bee

n im

plem

ente

d in

UK

law

by

the

Gro

undw

ater

Reg

ulat

ions

. The

reg

ulat

ions

pr

ohib

it th

e di

scha

rge

of L

ist I

and

Lis

t II s

ubst

ance

to g

roun

dwat

er w

ithou

t an

auth

oris

atio

n. T

he a

utho

risat

ion

may

be

gran

ted

unde

r th

e re

gula

tions

them

selv

es o

r al

tern

ativ

ely

via

the

WR

A (

Eng

land

and

Wal

es),

WE

WS

(S

cotla

nd),

the

Wat

er (

Nor

ther

n Ir

elan

d) O

rder

or

via

the

IPP

C r

egim

es.'

Con

trol

of P

ollu

tion

(Oil

Sto

rage

) (E

ngla

nd)

The

Reg

ulat

ions

app

ly to

any

one

stor

ing

oil i

n co

ntai

ners

of m

ore

than

200

litr

es, a

bove

gro

und

at a

n in

dust

rial,

com

mer

cial

or

inst

itutio

nal s

ite, o

r m

ore

than

350

0 lit

res

at a

dom

estic

site

. The

Reg

ulat

ions

set

s ou

t pro

visi

ons

for

the

desi

gn o

f ext

ern

al,

60

Reg

ulat

ions

200

1 (S

I 20

01/2

954)

abo

ve g

rou

nd

oil

stor

es a

nd r

equi

re th

at s

econ

dary

con

tain

men

t (eg

bun

ding

) is

in p

lace

. The

Reg

ulat

ions

do

not a

pply

to

was

te o

il.

Wat

er E

nviro

nmen

t (O

il S

tora

ge)

(Sco

tland

) R

egul

atio

ns 2

006

(SS

I 20

06/1

33)

Sim

ilar

prov

isio

ns a

re in

clud

ed in

the

Wat

er E

nviro

nmen

t (O

il S

tora

ge)

(Sco

tland

) R

egul

atio

ns. H

owev

er th

e R

egul

atio

ns a

pply

to

dom

estic

pro

pert

ies

whi

ch s

tore

ove

r 2,

500

litre

s of

oil

and

to w

aste

oils

.

Oil

stor

age

in N

orth

ern

Irel

and

and

Wal

esT

here

are

cur

rent

ly n

o co

mpa

rabl

e re

gula

tions

in N

orth

ern

Irel

and

and

Wal

es. H

owev

er, t

he 'e

nviro

nmen

t age

ncie

s' r

ecom

men

d th

at o

pera

tors

in th

ese

regi

ons

shou

ld c

ompl

y w

ith th

e E

ngla

nd a

nd S

cotla

nd R

egul

atio

ns to

min

imis

e th

e ris

k of

pol

lutio

n an

d po

tent

ial e

nfor

cem

ent.

Asp

ects

, im

pac

ts a

nd

ob

ject

ives

/op

erat

ion

al c

on

tro

ls

EN

VIR

ON

ME

NTA

L A

SP

EC

TS

Pro

cess

wat

er in

the

engi

neer

ing

indu

stry

can

typi

cally

bec

ome

cont

amin

ated

with

:

■m

etal

s -

from

mill

ing

and

mac

hini

ng p

rodu

cts,

dus

t ext

ract

ion

and

leac

hing

from

raw

mat

eria

ls (

eg p

igm

ents

and

was

tes)

; ■

acid

s -

from

wet

scr

ubbi

ng, p

roce

ss w

ater

trea

tmen

t, et

chin

g pr

ior

to s

urfa

ce tr

eatm

ent a

nd w

aste

wat

er tr

eatm

ent;

■

alka

lis -

from

wet

scr

ubbi

ng, p

roce

ss w

ater

trea

tmen

t, w

aste

wat

er tr

eatm

ent a

nd d

egre

asin

g/cl

eani

ng;

■or

gani

c so

lven

ts -

from

spr

ay b

ooth

s, c

oatin

g op

erat

ions

, thi

nnin

g of

coa

tings

and

deg

reas

ing;

■

susp

ende

d so

lids

- fr

om s

tora

ge o

f dus

ty r

aw m

ater

ials

, sho

t bla

stin

g, s

ize

redu

ctio

n an

d m

achi

ning

.

EN

VIR

ON

ME

NTA

L IM

PA

CTS

Inef

ficie

nt u

se o

f wat

er c

an le

ad to

dep

letio

n of

the

wat

er s

uppl

y.

Con

tam

inat

ion

of w

aste

wat

er w

ith h

eavy

met

als,

org

anic

sol

vent

s an

d su

spen

ded

solid

s ca

n le

ad to

deg

rada

tion

of th

e w

ater

qua

lity.

Thi

s ha

s de

lete

rious

ef

fect

s on

hum

an h

ealth

, the

nat

ural

env

ironm

ent a

nd e

cosy

stem

s. C

erta

in d

egre

asan

ts u

sed

in th

e en

gine

erin

g se

ctor

(eg

tric

hlor

oeth

ylen

e -

know

n as

'trik

e')

can

have

ser

ious

impa

cts

on th

e aq

uatic

env

ironm

ent e

ven

in v

ery

smal

l am

ount

s.

Oils

use

d fo

r fir

ing

furn

aces

and

com

bust

ion

plan

t and

for

lubr

icat

ion

that

ent

er th

e gr

ound

can

pol

lute

the

grou

ndw

ater

con

tain

ed w

ithin

aqu

ifers

. Thi

s ha

s a

nega

tive

impa

ct o

n th

e qu

ality

and

ava

ilabi

lity

of d

rinki

ng w

ater

sup

ply

(35%

of t

he p

ublic

sup

ply

in E

ngla

nd is

from

gro

undw

ater

sou

rces

).

Oil

cont

amin

atio

n of

riv

ers

and

the

sew

erag

e ne

twor

k ca

n ca

use

serio

us d

amag

e to

the

aqua

tic e

cosy

stem

s du

e to

an

incr

ease

in b

ioch

emic

al o

xyge

n de

man

d (B

OD

).

61

The

add

ition

of a

cids

and

alk

alis

has

the

effe

ct o

f red

ucin

g or

incr

easi

ng th

e pH

of t

he w

ater

env

ironm

ent r

espe

ctiv

ely.

Aci

dic

surf

ace

wat

er c

an a

dver

sely

af

fect

bird

s, fi

sh a

nd o

ther

aqu

atic

org

anis

ms.

Hum

ans

can

also

be

affe

cted

by

dire

ct in

gest

ion

of c

onta

min

ated

sur

face

wat

er o

r di

rect

con

tact

thro

ugh

outd

oor

activ

ities

suc

h as

sw

imm

ing.

OB

JEC

TIV

ES

/OP

ER

ATI

ON

AL

CO

NTR

OLS

Ope

rato

rs s

houl

d en

sure

that

em

issi

on li

mit

valu

es s

et in

per

mits

and

con

sent

s ar

e ad

here

d to

by

empl

oyin

g en

d-o

f-pi

pe e

fflue

nt tr

eatm

ent t

echn

ique

s as

re

quire

d. E

xam

ples

incl

ude:

■ho

mog

enis

atio

n;

■ae

ratio

n;

■se

dim

enta

tion;

■

filtr

atio

n;

■ac

tivat

ed c

arbo

n ab

sorp

tion;

■

chem

ical

pre

cipi

tatio

n;

■co

agul

atio

n fo

llow

ed b

y flo

ccul

atio

n;

■io

n ex

chan

ge;

■re

vers

e os

mos

is.

Pro

visi

on s

houl

d al

so b

e m

ade

to e

nsur

e th

at n

o ac

cide

ntal

spi

llage

can

ent

er s

urfa

ce d

rain

s th

at m

ay a

ffect

dow

nstr

eam

sew

age

plan

ts o

r w

ater

cour

ses,

eg

the

inst

alla

tion

of 'e

nviro

valv

es',

sum

ps, i

nter

cept

ors

or b

alan

cing

tank

s. In

terc

epto

rs a

nd s

umps

sho

uld

be In

terc

epto

rs s

houl

d be

impe

rmea

ble,

sub

ject

to v

isua

l in

spec

tion

(and

any

con

tam

inat

ion

rem

oved

) an

d ha

ve a

n an

nual

mai

nten

ance

insp

ectio

n.

Tra

in r

elev

ant s

taff

in p

reve

ntat

ive

actio

ns/c

lean

-up

tech

niqu

es. R

epor

t ser

ious

spi

llage

with

off-

site

run

-off

to th

e ap

prop

riate

aut

horit

ies

imm

edia

tely

.

For

oils

sto

red

outs

ide

(or

may

esc

ape

outs

ide)

, con

tain

ers

mus

t be

with

in s

econ

dary

con

tain

men

t (eg

a b

und

or s

pill

cont

ainm

ent p

alle

t) w

hich

mus

t pro

vide

st

orag

e of

at l

east

110

% o

f the

tank

's m

axim

um c

apac

ity, o

r if

mor

e th

an o

ne c

onta

iner

is s

tore

d, 1

10%

of t

he la

rges

t con

tain

er o

r 25

% o

f the

tota

l cap

acity

. The

sa

me

arra

ngem

ents

mus

t be

appl

ied

to a

ll liq

uid

chem

ical

s us

ed w

ithin

the

prem

ises

. The

sam

e ar

rang

emen

ts s

houl

d be

app

lied

to a

ll su

bsta

nces

that

cou

ld

caus

e po

llutio

n (B

AT

).

62

WA

STE

AN

D C

ON

TAM

INA

TED

LA

ND

Leg

isla

tio

n/C

od

e o

f P

ract

ice

Su

mm

ary

of

leg

isla

tive

req

uir

emen

ts

Haz

ardo

us W

aste

(E

ngla

nd a

nd W

ales

) R

egul

atio

ns 2

005

(HW

R)

(SI 2

005/

894)

The

HW

R e

nact

the

EU

Haz

ardo

us W

aste

Dire

ctiv

e 91

/689

/EE

C (

HW

D)

in E

ngla

nd a

nd W

ales

.

Haz

ardo

us w

aste

s w

ere

prev

ious

ly r

egul

ated

und

er th

e S

peci

al W

aste

Reg

ulat

ions

199

6 (S

WR

). U

ntil

July

200

5, th

e te

rm 's

peci

al w

aste

' was

use

d to

den

ote

'haz

ardo

us w

aste

'. C

hang

es in

clud

e:

■st

ream

linin

g th

e co

nsig

nmen

t not

e sy

stem

; ■

rem

ovin

g th

e re

quire

men

t for

pro

duce

rs o

f haz

ardo

us w

aste

to p

re-n

otify

the

Env

ironm

ent A

genc

y (7

2 ho

urs)

pr

ior

to m

ovin

g th

e w

aste

.

Haz

ardo

us w

aste

pro

duce

rs a

re r

equi

red

to:

■re

gist

er th

eir

site

with

the

Env

ironm

ent A

genc

y (t

erm

ed 'n

otifi

catio

n of

pre

mis

es');

■

keep

a r

ecor

d of

the

quan

tity,

nat

ure,

orig

in a

nd, w

here

rel

evan

t, th

e de

stin

atio

n, fr

eque

ncy

of c

olle

ctio

n,

mod

e of

tran

spor

t and

trea

tmen

t met

hod

of th

e w

aste

thro

ugh

the

use

of C

onsi

gnm

ent N

otes

.

Rec

ords

of C

onsi

gnm

ent N

otes

mus

t be

reta

ined

for

a m

inim

um o

f thr

ee y

ears

.

The

reg

ulat

ions

pro

hibi

t the

co-

disp

osal

of h

azar

dous

with

non

-haz

ardo

us w

aste

at l

andf

ill s

ites.

As

a re

sult,

ther

e ar

e no

w o

nly

a fe

w la

ndfil

l site

s in

the

UK

that

can

acc

ept h

azar

dous

was

te a

nd w

aste

pro

duce

rs m

ust f

ind

alte

rnat

ive

disp

osal

met

hods

or

reco

very

opt

ions

.

All

haza

rdou

s w

aste

des

tined

for

land

fill m

ust n

ow b

e th

e pr

e-tr

eate

d to

ren

der

it le

ss h

azar

dous

.

Was

te is

dee

med

to b

e ha

zard

ous

if it

is:

■lis

ted

as a

haz

ardo

us w

aste

in th

e Li

st o

f Was

tes

Reg

ulat

ions

200

5 (L

oWR

) (E

urop

ean

Was

te C

atal

ogue

-

EW

C);

■lis

ted

in r

egul

atio

ns m

ade

unde

r S

ectio

n 62

A(1

) of

the

Env

ironm

enta

l Pro

tect

ion

Act

199

0;

■a

spec

ific

batc

h of

was

te w

hich

is d

eter

min

ed b

y th

e S

ecre

tary

of S

tate

to b

e ha

zard

ous.

The

HW

R p

rohi

bit t

he m

ixin

g of

was

tes

(eg

haza

rdou

s an

d no

n-ha

zard

ous

or h

azar

dous

and

haz

ardo

us).

The

ex

cept

ion

to th

is is

whe

re th

e m

ixin

g is

con

duct

ed a

s pa

rt o

f a li

cens

ed w

aste

dis

posa

l/rec

over

y op

erat

ion.

All

mix

ing

63

pits

for

mix

ing

and

trea

ting

haza

rdou

s w

aste

s m

ust c

ease

ope

ratin

g fr

om 1

0 N

ovem

ber

2008

.

For

mor

e in

form

atio

n on

haz

ardo

us w

aste

see

■E

nviro

wis

e gu

idan

ce o

n ha

zard

ous

was

te h

ttp:

//w

ww

.env

irow

ise.

gov.

uk/h

azar

dous

■

Env

ironm

ent A

genc

y -

regi

ster

ing

as a

haz

ardo

us w

aste

pro

duce

r (E

ngla

nd a

nd W

ales

) ht

tp:/

/ww

w.e

nvir

onm

ent-

agen

cy.g

ov.u

k/su

bjec

ts/w

aste

/101

9330

/121

7981

/177

2529

/

Land

fill (

Eng

land

and

Wal

es)

Reg

ulat

ions

200

2 (a

s am

ende

d) (

SI

2002

/155

9)

Land

fill (

Sco

tland

) R

egul

atio

ns 2

003

(SS

I 200

3/23

5) a

s am

ende

d

Land

fill (

Nor

ther

n Ir

elan

d) R

egul

atio

ns

2003

(S

R 2

003/

496)

The

se r

egul

atio

ns e

nact

the

Land

fill D

irect

ive

(LF

D)

into

UK

law

.

The

reg

ulat

ions

req

uire

that

, in

addi

tion

to th

e pr

e-tr

eatm

ent o

f haz

ardo

us w

aste

, non

-haz

ardo

us w

aste

mus

t be

pre-

trea

ted

befo

re it

can

be

land

fille

d. W

aste

Acc

epta

nce

Crit

eria

(W

AC

) ap

ply

to a

ll la

ndfil

ls.

■th

ree-

poin

t tes

t has

bee

n es

tabl

ishe

d in

ord

er to

ens

ure

that

ope

rato

rs m

eet t

he d

efin

ition

of w

aste

trea

tmen

t. W

aste

trea

tmen

t mus

t: ■

be a

phy

sica

l (in

clud

ing

sort

ing)

, che

mic

al, b

iolo

gica

l or

ther

mal

pro

cess

; ■

chan

ge th

e ch

arac

teris

tics

of th

e w

aste

, eg

solu

bilit

y, c

ombu

stib

ility

or

phys

ical

nat

ure;

■

redu

ce w

aste

vol

ume,

eg

via

inci

nera

tion

but n

ot c

ompa

ctio

n;

■re

duce

haz

ardo

us n

atur

e, e

g so

lidifi

catio

n w

ill r

educ

e th

e lik

elih

ood

of in

gest

ing

haza

rdou

s w

aste

; ■

faci

litat

e its

han

dlin

g du

ring

the

depo

sit o

f was

te in

land

fill o

r en

hanc

e its

rec

over

y.

Spe

cial

Was

te (

Sco

tland

) R

egul

atio

ns

1997

(S

SI 1

997/

257)

as

amen

ded

by

the

Spe

cial

Was

te A

men

dmen

t (S

cotla

nd)

Reg

ulat

ions

200

4 (S

SI

2004

/112

)

The

Spe

cial

Was

te A

men

dmen

t (S

cotla

nd)

Reg

ulat

ions

200

4 ca

me

into

forc

e on

1 J

uly

2004

. The

am

endm

ent a

llow

ed

Sco

tland

to e

nact

the

HW

D a

nd in

clud

es s

imila

r pr

ovis

ions

to th

e H

WR

.

Sco

tland

con

tinue

s to

use

a r

egim

e si

mila

r to

the

SW

R b

ut h

as in

corp

orat

ed th

e ch

ange

s in

the

Eur

opea

n W

aste

C

atal

ogue

. The

term

'spe

cial

was

te' c

ontin

ues

to b

e us

ed.

Haz

ardo

us W

aste

(N

orth

ern

Irel

and)

R

egul

atio

ns 2

005

(SR

200

5/30

0)N

orth

ern

Irel

and

has

adop

ted

a si

mila

r sy

stem

to th

at u

sed

in S

cotla

nd. N

orth

ern

Irel

and

how

ever

mak

es u

se o

f the

te

rm 'h

azar

dous

was

te' i

nste

ad o

f 'sp

ecia

l was

te'.

Env

ironm

enta

l Pro

tect

ion

Act

199

0 (E

PA

90

)P

art 2

of E

PA

90

enac

ted

the

conc

ept o

f sta

tuto

ry d

uty

of c

are

(DO

C)

into

UK

law

. The

Env

ironm

enta

l Pro

tect

ion

(Dut

y of

Car

e) R

egul

atio

ns 1

991

(as

amen

ded

by th

e La

ndfil

l Reg

ulat

ions

200

2) in

trod

uced

a s

tatu

tory

doc

umen

ted

syst

em to

pr

ovid

e a

'cra

dle

to g

rave

' aud

it tr

ail o

f was

te fr

om p

rodu

ctio

n to

fina

l dis

posa

l.

Env

ironm

enta

l Pro

tect

ion

(Dut

y of

Car

e)

Reg

ulat

ions

199

1 (S

I 199

1/28

39),

as

amen

ded

by th

e La

ndfil

l (E

ngla

nd a

nd

The

Reg

ulat

ions

req

uire

that

was

te is

tran

sfer

red

to a

lice

nsed

con

trac

tor.

The

y in

clud

e pr

ovis

ions

to r

ecor

d th

e tr

ansf

er o

n a

Was

te T

rans

fer

Not

e in

clud

ing:

64

Wal

es)

Reg

ulat

ions

200

2 (S

I 20

02/1

559)

■a

desc

riptio

n of

the

was

te;

■de

tails

of t

he p

rodu

cer

and

carr

ier;

■

EW

C c

ode.

The

Tra

nsfe

r N

ote

shou

ld b

e ke

pt fo

r tw

o ye

ars

for

cont

rolle

d w

aste

. (T

he is

sue

and

rete

ntio

n of

Con

sign

men

t Not

es

for

the

disp

osal

of h

azar

dous

was

te is

cov

ered

in th

e H

WR

.)

Con

trol

led

Was

te (

Reg

istr

atio

n of

C

arrie

rs a

nd S

eizu

re o

f Veh

icle

s)

Reg

ulat

ions

199

1 (S

I 199

1/16

24)

as

amen

ded

Car

riers

of a

noth

er p

erso

ns w

aste

, or

cons

truc

tion

and

dem

oliti

on w

aste

, sha

ll ho

ld a

Was

te C

arrie

rs L

icen

se is

sued

by

the

'env

ironm

ent a

genc

ies'

.

Pro

duce

r R

espo

nsib

ility

Obl

igat

ions

(P

acka

ging

Was

te)

Reg

ulat

ions

200

7 (S

I 200

7/87

1)

as a

men

ded

by T

he P

rodu

cer

Res

pons

ibili

ty (

Pac

kagi

ng W

aste

) (A

men

dmen

t) R

egul

atio

ns 2

008

(SI

2008

/413

)

and

The

Pro

duce

r R

espo

nsib

ility

(P

acka

ging

Was

te)

(Am

endm

ent)

R

egul

atio

ns (

Nor

ther

n Ir

elan

d) 2

008

(SR

20

08/7

7).

The

Pac

kagi

ng W

aste

Reg

ulat

ions

req

uire

that

'pro

duce

rs' o

f pac

kagi

ng w

aste

with

an

annu

al tu

rnov

er in

exc

ess

of '2

m

illio

n an

d ha

ndlin

g m

ore

than

50

tonn

es o

f pac

kagi

ng in

the

prev

ious

yea

r re

cove

r at

leas

t 60%

of p

acka

ging

was

te

and

recy

cle

betw

een

55%

and

80%

of p

acka

ging

was

te b

y 20

08.

'Pro

duce

rs' i

nclu

des:

■m

anuf

actu

rers

of p

acka

ging

raw

, con

vert

ors,

eg

thos

e w

ho m

ake

card

boar

d bo

xes

or a

lum

iniu

m c

ans;

■

pack

ers/

fille

rs;

■re

taile

rs w

ho s

ell t

he p

acka

ged

prod

uct t

o th

e co

nsum

er;

■im

port

ers

of p

acka

ging

and

pac

kagi

ng m

ater

ials

; ■

seco

ndar

y pr

ovid

ers;

■

serv

ice

prov

ider

s, e

g bu

sine

sses

whi

ch le

ase

or h

ire o

ut p

acka

ging

suc

h as

pal

lets

pic

k up

an

oblig

atio

n on

fir

st tr

ip le

ased

pac

kagi

ng.

Rec

over

y ca

n in

clud

e:

■m

ater

ials

rec

yclin

g;

■la

nd s

prea

ding

; ■

ener

gy r

ecov

ery;

■

com

post

ing.

Und

er th

e R

egul

atio

ns, p

rodu

cers

hav

e a

lega

l obl

igat

ion

to:

■re

gist

er w

ith th

e 'e

nviro

nmen

t age

ncy'

; ■

arra

nge

for

the

reco

very

and

rec

yclin

g of

pac

kagi

ng w

aste

;

65

■su

pply

a c

ertif

icat

e of

com

plia

nce

to th

e ag

ency

to d

emon

stra

te th

at th

e w

aste

has

bee

n re

proc

esse

d.

Sm

alle

r co

mpa

nies

may

find

it b

enef

icia

l to

join

a 'C

ompl

ianc

e S

chem

e'. M

embe

rs o

f suc

h sc

hem

es w

ill b

e ex

empt

from

th

e in

divi

dual

obl

igat

ions

of t

he R

egul

atio

ns p

rovi

ded

the

Com

plia

nce

Sch

eme

man

ager

s su

cces

sful

ly d

isch

arge

its

mem

bers

' obl

igat

ions

. Com

plia

nce

Sch

eme

man

ager

s re

quire

rel

evan

t inf

orm

atio

n fr

om it

s m

embe

rs a

nd w

ill c

harg

e a

fee

to ta

ke r

espo

nsib

ility

for

the

indi

vidu

al's

obl

igat

ions

.

Det

ails

of C

ompl

ianc

e S

chem

es a

re a

vaila

ble

from

Def

ra a

nd th

e 'e

nviro

nmen

t age

ncie

s'.

Pac

kagi

ng (

Ess

entia

l Req

uire

men

ts)

Reg

ulat

ions

200

3 (S

I 200

3/19

41)

as

amen

ded

The

Reg

ulat

ions

set

out

the

requ

irem

ents

that

all

item

s of

pac

kagi

ng m

ust m

eet b

efor

e be

ing

plac

ed o

n th

e U

K m

arke

t. T

he E

ssen

tial R

equi

rem

ents

are

, in

sum

mar

y:

■pa

ckin

g vo

lum

e an

d w

eigh

t mus

t be

the

min

imum

am

ount

to m

aint

ain

nece

ssar

y le

vels

of s

afet

y, h

ygie

ne a

nd

acce

ptan

ce fo

r th

e pa

cked

pro

duct

and

for

the

cons

umer

; ■

noxi

ous

or h

azar

dous

sub

stan

ces

in p

acka

ging

mus

t be

min

imis

ed in

em

issi

ons,

ash

or

leac

hate

from

in

cine

ratio

n or

land

fill;

■pa

ckag

ing

mus

t be

man

ufac

ture

d so

as

to p

erm

it re

-use

or

reco

very

in a

ccor

danc

e w

ith s

peci

fic

requ

irem

ents

.

Land

fill T

ax R

egul

atio

ns 1

996

(SI

1996

/152

7)T

hese

Reg

ulat

ions

est

ablis

h a

tax

on w

aste

to la

ndfil

l. Im

pose

d in

199

8 at

'10/

tonn

e, th

e ta

x is

cur

rent

ly '3

2/to

nne

(200

8/09

) an

d w

ill r

ise

by '8

/tonn

e a

year

unt

il 20

11, i

e to

'48/

tonn

e.

Con

tam

inat

ed L

and

(Eng

land

) R

egul

atio

ns 2

006

(SI 2

006/

1380

)

Con

tam

inat

ed L

and

(Sco

tland

) R

egul

atio

ns 2

005

(SS

I 200

5/65

8)

Con

tam

inat

ed L

and

(Wal

es)

Reg

ulat

ions

20

01 (

SI 2

006/

2989

)

The

pur

pose

of t

he c

onta

min

ated

land

reg

ime

is to

iden

tify

land

that

, bec

ause

of t

he p

rese

nce

of c

onta

min

ants

, pr

esen

ts (

in it

s ex

istin

g us

e) a

sig

nific

ant t

hrea

t to

hum

an h

ealth

, pro

pert

y or

the

natu

ral e

nviro

nmen

t.

The

con

tam

inat

ed la

nd r

egim

es in

trod

uce

the

term

'App

ropr

iate

per

sons

' who

are

iden

tifie

d by

the

loca

l cou

ncil

or

'env

ironm

ent a

genc

ies'

and

are

res

pons

ible

for

all o

r pa

rt o

f the

rem

edia

tion

of th

e la

nd. T

here

are

two

clas

ses

of

appr

opria

te p

erso

ns: C

lass

A w

ho c

ause

or

allo

w th

e po

lluta

nt(s

) to

be

in, o

n or

und

er th

e la

nd; a

nd C

lass

B th

e ow

ner(

s) o

r oc

cupi

er(s

) of

the

land

.

If la

nd is

pot

entia

lly c

onta

min

ated

ope

rato

rs s

houl

d co

ntac

t the

ir lo

cal c

ounc

il.

If th

e co

unci

l ide

ntifi

es y

ou a

s be

ing

resp

onsi

ble

for

part

or

all o

f the

cle

an-u

p, th

ey w

ill s

end

you

a 'R

emed

iatio

n N

otic

e'

info

rmin

g yo

u th

at y

our

land

is c

onta

min

ated

. You

sho

uld

cons

ider

see

king

lega

l adv

icea

nd te

chni

cal s

uppo

rt. F

ailu

re to

co

mpl

y w

ith a

not

ice

is a

n of

fenc

e.

If yo

ur la

nd is

con

tam

inat

ed a

nd y

ou a

re r

espo

nsib

le, y

ou s

houl

d ag

ree

a 'R

emed

iatio

n S

chem

e' w

ith y

our

loca

l cou

ncil.

66

Thi

s m

ust b

e pu

blis

hed

as a

'Rem

edia

tion

Sta

tem

ent'

and

will

def

ine

the

mea

sure

s th

at y

ou w

ill ta

ke to

rem

edia

te th

e co

ntam

inat

ed la

nd.

Env

ironm

enta

l Pro

tect

ion

(Dis

posa

l of

Pol

ychl

orin

ated

Bip

heny

ls a

nd o

ther

D

ange

rous

Sub

stan

ces)

(E

ngla

nd a

nd

Wal

es)

Reg

ulat

ions

200

0 (S

I 20

00/1

043)

(PC

B R

egul

atio

ns)

The

se R

egul

atio

ns im

plem

ent E

C D

irect

ive

96/5

9/E

C a

nd a

re d

esig

ned

to e

nsur

e th

e el

imin

atio

n of

pol

ychl

orin

ated

(P

CB

s) in

Eng

land

and

Wal

es. S

imila

r pr

ovis

ion

has

been

mad

e fo

r S

cotla

nd a

nd N

orth

ern

Irel

and.

The

Reg

ulat

ions

im

pose

req

uire

men

ts r

elat

ing

to r

egis

trat

ion,

labe

lling

, dis

posa

l and

dec

onta

min

atio

n.

Equ

ipm

ent c

onta

min

ated

with

ove

r fiv

e lit

res

of P

CB

s w

as r

equi

red

to b

e di

spos

ed o

f by

2001

.

Site

s w

ith tr

ansf

orm

ers

with

flui

ds w

ith P

CB

con

cent

ratio

ns o

f 50'

500

part

s pe

r m

illio

n (p

pm)

mus

t be

regi

ster

ed w

ith

the

'env

ironm

ent a

genc

ies'

. The

tran

sfor

mer

s m

ay b

e he

ld u

ntil

the

end

of th

eir

usef

ul li

fe a

nd th

en m

ust b

e di

spos

ed o

f as

soo

n as

pos

sibl

e.

Env

ironm

enta

l Pro

tect

ion

(Dis

posa

l of

Pol

ychl

orin

ated

Bip

heny

ls a

nd o

ther

D

ange

rous

Sub

stan

ces)

(E

ngla

nd a

nd

Wal

es)

Reg

ulat

ions

200

0 (S

I 20

00/1

043)

(PC

B R

egul

atio

ns)

The

se R

egul

atio

ns im

plem

ent E

C D

irect

ive

96/5

9/E

C a

nd a

re d

esig

ned

to e

nsur

e th

e el

imin

atio

n of

pol

ychl

orin

ated

(P

CB

s) in

Eng

land

and

Wal

es. S

imila

r pr

ovis

ion

has

been

mad

e fo

r S

cotla

nd a

nd N

orth

ern

Irel

and.

The

re a

re fo

ur m

ain

legi

slat

ive

requ

irem

ents

to b

e ad

here

d to

:

■re

gist

ratio

n;

■la

belli

ng;

■di

spos

al;

■de

cont

amin

atio

n.

Equ

ipm

ent c

onta

min

ated

with

ove

r fiv

e lit

res

of P

CB

s w

as r

equi

red

to b

e di

spos

ed o

f by

2001

.

Site

s w

ith tr

ansf

orm

ers

with

flui

ds w

ith P

CB

con

cent

ratio

ns o

f 50'

500

part

s pe

r m

illio

n (p

pm)

mus

t be

regi

ster

ed w

ith

the

'env

ironm

ent a

genc

ies'

. The

tran

sfor

mer

s m

ay b

e he

ld u

ntil

the

end

of th

eir

usef

ul li

fe a

nd th

en m

ust b

e di

spos

ed o

f as

soo

n as

pos

sibl

e.

Was

te E

lect

rical

and

Ele

ctro

nic

Equ

ipm

ent R

egul

atio

ns 2

006

(SI

2006

/328

9)

(WE

EE

Reg

ulat

ions

)

Was

te E

lect

rical

and

Ele

ctro

nic

Equ

ipm

ent (

Was

te M

anag

emen

t

The

WE

EE

Reg

ulat

ions

impl

emen

t the

pro

duce

r re

spon

sibi

lity

aspe

cts

of th

e W

EE

E D

irect

ive

in th

e U

K. S

epar

ate

Reg

ulat

ions

dea

l with

the

site

lice

nsin

g an

d W

EE

E tr

eatm

ent r

equi

rem

ents

of t

he W

EE

E D

irect

ive

in E

ngla

nd a

nd W

ales

, S

cotla

nd a

nd N

orth

ern

Irel

and.

The

WE

EE

Reg

ulat

ions

aim

to:

■re

duce

was

te fr

om e

lect

roni

c an

d el

ectr

ical

equ

ipm

ent (

WE

EE

);

■en

cour

age

the

sepa

ratio

n co

llect

ion

of W

EE

E;

67

Lice

nsin

g) (

Eng

land

and

Wal

es)

Reg

ulat

ions

200

6 (S

I 200

6/33

15)

as a

men

ded

by T

he W

aste

Ele

ctric

al

and

Ele

ctro

nic

Equ

ipm

ent (

Am

endm

ent)

R

egul

atio

n 20

07 (

SI 2

007/

3454

)

Was

te M

anag

emen

t Lic

ensi

ng

Am

endm

ent (

Was

te E

lect

rical

and

E

lect

roni

c E

quip

men

t) (

Sco

tland

) R

egul

atio

ns 2

007

(SI 2

007/

172)

Was

te E

lect

rical

and

Ele

ctro

nic

Equ

ipm

ent (

Was

te M

anag

emen

t Li

cens

ing)

Reg

ulat

ions

(N

orth

ern

Irel

and)

200

6 (S

I 200

6/51

9)

■m

ake

prod

ucer

s of

ele

ctro

nic

and

elec

tric

al e

quip

men

t (E

EE

) re

spon

sibl

e fo

r th

e en

viro

nmen

tal i

mpa

cts

of th

eir

prod

ucts

.

The

WE

EE

Reg

ulat

ions

app

ly to

alm

ost a

ll bu

sine

sses

. Ope

rato

rs n

eed

to c

ompl

y w

ith th

e re

quire

men

ts o

f the

WE

EE

R

egul

atio

ns if

they

:

■m

anuf

actu

re, i

mpo

rt, r

e-br

and,

dis

trib

ute

and/

or s

ell E

EE

; ■

stor

e, u

se, r

epai

r, r

efur

bish

, tre

at, d

ism

antle

, rec

ycle

and

/or

disp

ose

of W

EE

E.

Pro

duce

rs o

f EE

E h

ave

to e

nsur

e th

at th

eir

prod

ucts

are

dis

pose

d of

in a

n 'e

nviro

nmen

tally

sou

nd' w

ay.

Pro

duce

rs a

re r

espo

nsib

le fo

r fin

anci

ng th

e co

llect

ion

and

trea

tmen

t of c

olle

cted

hou

seho

ld W

EE

E d

epen

ding

on

thei

r m

arke

t sha

re. I

n ad

ditio

n, p

rodu

cers

of E

EE

mus

t joi

n a

'pro

duce

r C

ompl

ianc

e S

chem

e' w

hich

will

reg

iste

r in

divi

dual

op

erat

ors

with

the

'env

ironm

ent a

genc

ies'

.

Use

rs o

f EE

E m

ust a

lso

com

ply

with

the

Reg

ulat

ions

. For

all

non-

hous

ehol

d E

EE

, eith

er th

e pr

oduc

er o

r en

d us

er is

re

spon

sibl

e fo

r th

e di

spos

al o

f the

pro

duct

.

WE

EE

rem

oved

from

site

mus

t be

give

n to

a r

egis

tere

d w

aste

car

rier

or a

noth

er a

ppro

ved

pers

on. T

he W

EE

E m

ust b

e:

■ac

com

pani

ed b

y a

Was

te T

rans

fer

Not

e or

haz

ardo

us w

aste

Con

sign

men

t Not

e (a

s ap

prop

riate

);

■ta

ken

to a

sui

tabl

e fa

cilit

y to

be

trea

ted

and

recy

cled

.

Pro

of th

at th

e W

EE

E w

as g

iven

to a

was

te m

anag

emen

t bus

ines

s an

d w

as s

ubse

quen

tly tr

eate

d an

d di

spos

ed o

f in

an e

nviro

nmen

tally

sou

nd w

ay m

ust b

e ob

tain

ed.

Res

tric

tion

of th

e U

se o

f Cer

tain

H

azar

dous

Sub

stan

ces

in E

lect

rical

and

E

lect

roni

c E

quip

men

t (R

oHS

) R

egul

atio

ns 2

006

(SI 2

006/

1463

)

(RoH

S R

egul

atio

ns)

The

RoH

S R

egul

atio

ns li

mit

the

amou

nts

of h

azar

dous

sub

stan

ces

that

can

be

incl

uded

in n

ew e

lect

rical

and

ele

ctro

nic

equi

pmen

t (E

EE

) pl

aced

on

the

mar

ket a

nyw

here

in th

e E

U.

Com

pani

es th

at p

lace

new

ele

ctric

al a

nd e

lect

roni

c go

ods

on th

e E

U m

arke

t mus

t ens

ure

that

they

do

not c

onta

in m

ore

than

the

perm

itted

leve

ls o

f cer

tain

haz

ardo

us s

ubst

ance

s in

clud

ing:

■le

ad;

■m

ercu

ry;

■ca

dmiu

m;

■he

xava

lent

chr

omiu

m;

68

■po

lybr

omin

ated

bip

heny

l (P

BB

);

■po

lybr

omin

ated

dip

heny

l eth

er (

PB

DE

).

Asp

ects

, im

pac

ts a

nd

ob

ject

ives

/op

erat

ion

al c

on

tro

ls

EN

VIR

ON

ME

NTA

L A

SP

EC

TS

Was

tes

gene

rate

d by

the

engi

neer

ing

indu

stry

can

be

as v

arie

d an

d as

vas

t as

the

sect

or it

self.

Com

mon

was

tes

gene

rate

d in

clud

e:

■w

aste

oils

and

oil

cont

amin

ated

mat

eria

ls -

from

mai

nten

ance

act

iviti

es, s

pilla

ges

and

as r

esid

ues

in w

aste

con

tain

ers;

■

spen

t bla

stin

g m

ater

ials

, scr

ap m

etal

and

rej

ecte

d co

mpo

nent

s -

from

red

unda

nt a

nd r

econ

ditio

ned

mac

hine

ry;

■sw

arf

- fr

om m

achi

ning

act

iviti

es;

■sp

ent f

ilter

s an

d co

llect

ed p

artic

ulat

e m

atte

r -

from

dus

t ext

ract

ion

syst

ems;

■

empt

y dr

ums

and

inte

rmed

iate

bul

k co

ntai

ners

(IB

Cs)

pre

viou

sly

cont

aini

ng r

aw m

ater

ials

, wat

er tr

eatm

ent c

hem

ical

s, e

tc;

■o

ff-s

peci

ficat

ion

prod

ucts

; ■

acid

ic w

aste

s -

from

pla

ting

and

etch

ing;

■

alka

line

solu

tions

- fr

om d

egre

asin

g an

d de

terg

ents

; ■

wat

er tr

eatm

ent c

hem

ical

s an

d re

sidu

es (

eg o

xyge

n-sc

aven

gers

suc

h as

sul

phat

es, c

hlor

ides

, etc

and

met

al h

ydro

xide

filte

r ca

ke);

■

gene

ral o

ffic

e w

aste

s.

EN

VIR

ON

ME

NTA

L IM

PA

CTS

Was

te r

epre

sent

s an

inef

ficie

nt u

se o

f res

ourc

es.

Inap

prop

riate

trea

tmen

t of w

aste

s ca

n le

ad to

the

loss

of r

ecov

erab

le r

esou

rces

.

Hig

h le

vels

of n

utrie

nts

and

sulp

hate

s in

was

te/w

aste

wat

er c

an:

■ad

vers

ely

affe

ct th

e qu

ality

of d

rinki

ng w

ater

; ■

lead

to a

lgal

and

wee

d gr

owth

if a

llow

ed to

ent

er th

e w

ater

env

ironm

ent.

Met

al h

ydro

xide

filte

r ca

kes

need

to b

e di

spos

ed o

f app

ropr

iate

ly to

avo

id a

cidi

c co

nditi

ons

and

thus

pre

vent

leac

hing

of t

oxic

met

als.

Hea

vy m

etal

s ar

e to

xic

to

aqua

tic li

fe a

nd c

an a

dver

sely

affe

ct th

e qu

ality

of d

rinki

ng w

ater

.

PC

Bs

have

long

bee

n re

cogn

ised

as

posi

ng a

thre

at to

the

envi

ronm

ent.

Due

to th

eir

stab

ility

they

are

not

eas

ily b

roke

n do

wn

in th

e en

viro

nmen

t and

tend

to

69

bioa

ccum

ulat

e in

the

fatty

tiss

ues

of a

nim

als

and

hum

ans.

Unc

ontr

olle

d st

orag

e, tr

ansp

ort a

nd tr

eatm

ent o

f was

tes

can

lead

to fl

y-tip

ping

and

the

subs

eque

nt p

ollu

tion

of la

nd, a

ir an

d w

ater

.

Dis

posa

l of w

aste

has

the

effe

ct o

f dep

letin

g la

ndfil

l voi

ds in

add

ition

to c

ross

-med

ia tr

ade-

offs

(eg

em

issi

ons

from

inci

nera

tors

, lea

chat

e an

d la

ndfil

l gas

ge

nera

tion)

and

whe

re, w

aste

is n

ot r

ecov

ered

or

recy

cled

, the

avo

idab

le d

eple

tion

of r

esou

rces

.

OB

JEC

TIV

ES

/OP

ER

ATI

ON

AL

CO

NTR

OLS

■sy

stem

sho

uld

be m

aint

aine

d to

rec

ord

the

quan

tity,

nat

ure,

orig

in a

nd, w

here

rel

evan

t, th

e de

stin

atio

n, fr

eque

ncy

of c

olle

ctio

n, m

ode

of tr

ansp

ort a

nd

trea

tmen

t met

hod

of a

ny w

aste

that

is d

ispo

sed

of o

r re

cove

red.

Was

tes

shou

ld b

e se

greg

ated

to e

nabl

e re

cove

ry a

nd fa

cilit

ate

recy

clin

g. O

ils a

nd r

eusa

ble

orga

nic

solv

ents

sho

uld

be b

ulke

d up

for

reco

very

.

Sto

rage

are

as s

houl

d be

und

er c

over

and

pro

tect

ed fr

om th

e el

emen

ts to

avo

id o

r m

inim

ise

envi

ronm

enta

l im

pact

- e

xcep

t whe

re s

tore

d m

ater

ials

are

in s

uita

ble

wea

ther

proo

f con

tain

ers.

Del

iver

y co

nnec

tions

to b

ulk

stor

age

tank

s sh

ould

be

loca

ted

with

in a

bun

ded/

cont

aine

d ar

ea, w

hich

is fi

xed

and

lock

ed w

hen

not i

n us

e to

pre

vent

pot

entia

l sp

ills

to la

nd o

r gr

ound

wat

er.

Ope

rato

rs s

houl

d co

nsid

er u

nder

taki

ng a

was

te m

inim

isat

ion

audi

t eve

ry fo

ur y

ears

and

a b

est p

ract

ical

env

ironm

enta

l opt

ion

(BP

EO

) re

view

of t

he c

hose

n w

aste

dis

posa

l opt

ion(

s) w

hen

chan

ges

are

mad

e to

the

disp

osal

rou

te.

70

HA

ZAR

DO

US

SU

BS

TAN

CE

S (H

EA

LTH

AN

D S

AFE

TY)

Leg

isla

tio

n/C

od

e o

f P

ract

ice

Su

mm

ary

of

leg

isla

tive

req

uir

emen

ts

Con

trol

of M

ajor

Acc

iden

t Haz

ard

(CO

MA

H)

Reg

ulat

ions

199

9 (S

I 19

99/7

43)

as a

men

ded

The

CO

MA

H R

egul

atio

ns im

plem

ent E

C D

irect

ive

96/8

2/E

C (

know

n as

the

Sev

eso

II D

irect

ive)

. The

obj

ectiv

e of

the

Reg

ulat

ions

is to

pre

vent

maj

or a

ccid

ents

at i

nsta

llatio

ns w

ho h

andl

e sp

ecifi

ed q

uant

ities

of h

azar

dous

sub

stan

ces.

CO

MA

H in

stal

latio

ns a

re d

ived

into

two

tiers

low

er ti

er (

low

er r

isk)

and

top

tier

(hig

her

risk)

. The

tier

s co

rres

pond

to a

sp

ecifi

ed q

uant

ity o

f nam

ed s

ubst

ance

s gi

ven

in S

ched

ule

1 of

the

Reg

ulat

ions

. Low

er ti

er s

ites

have

a g

ener

al d

uty

to

take

all

nece

ssar

y m

easu

res

to p

reve

nt a

ccid

ents

and

lim

it th

eir

cons

eque

nces

and

to p

rodu

ce a

doc

umen

ted

Maj

or

Acc

iden

t Pre

vent

ion

Pol

icy

(MA

PP

). In

add

ition

top

tier

site

s ar

e re

quire

d to

:

■ha

ve in

pla

ce a

Saf

ety

Rep

ort,

an O

n-si

te E

mer

genc

y P

lan,

an

Off-

site

Em

erge

ncy

Pla

n (p

rodu

ced

by th

e lo

cal

auth

ority

);

■pr

ovid

e re

leva

nt in

form

atio

n to

res

iden

ts li

ving

in th

e vi

cini

ty o

f the

site

(eg

det

ail o

f pro

cess

es c

arrie

d ou

t, m

ajor

ac

cide

nt h

azar

ds a

nd th

e su

bsta

nce

invo

lved

).

The

Com

pete

nt A

utho

rity

for

the

CO

MA

H R

egul

atio

ns is

com

pose

d of

the

Hea

lth a

nd S

afet

y E

xecu

tive

and

the

'env

ironm

ent a

genc

ies'

.

Con

trol

of S

ubst

ance

s H

azar

dous

to

Hea

lth R

egul

atio

ns 2

002

(CO

SH

H)

(SI

2002

/267

7) a

s am

ende

d

The

Reg

ulat

ions

req

uire

ope

rato

rs to

pre

vent

em

ploy

ees

bein

g ex

pose

d to

sub

stan

ces

haza

rdou

s to

hea

lth o

r, if

pr

even

tion

is n

ot r

easo

nabl

y pr

actic

able

, to

adeq

uate

ly c

ontr

ol th

e ex

posu

re.

Am

ong

the

prov

isio

ns in

the

Reg

ulat

ions

is a

req

uire

men

t for

ope

rato

rs to

:

■id

entif

y th

e ha

zard

ous

subs

tanc

es p

rese

nt a

t the

inst

alla

tion;

■

asse

ss th

e ris

ks p

osed

to h

uman

s he

alth

; ■

in s

peci

fic c

ircum

stan

ces

mea

sure

the

conc

entr

atio

n of

haz

ardo

us s

ubst

ance

s in

the

air

brea

thed

by

wor

kers

; ■

keep

rec

ords

of e

xpos

ure

mon

itorin

g fo

r at

leas

t fiv

e ye

ars;

■

prov

ide

empl

oyee

s w

ith s

uita

ble

and

suffi

cien

t inf

orm

atio

n, in

stru

ctio

n, tr

aini

ng a

nd s

uper

visi

on.

Con

trol

of A

sbes

tos

at W

ork

Reg

ulat

ions

200

6 (C

AW

R)

(SI

2006

/267

5)

The

se R

egul

atio

ns r

e-en

act,

with

mod

ifica

tions

, the

Con

trol

of A

sbes

tos

at W

ork

Reg

ulat

ions

198

7 (S

I 198

7/21

15)

as

amen

ded.

The

Reg

ulat

ions

req

uire

ope

rato

rs to

pro

tect

em

ploy

ees

and

othe

r pe

rson

s fr

om e

xpos

ure

to a

sbes

tos.

The

pro

visi

ons

of th

e R

egul

atio

ns r

equi

re e

mpl

oyer

s to

iden

tify

whe

ther

thei

r pr

emis

es c

onta

in a

sbes

tos

and,

if s

o, th

e co

nditi

on o

f the

as

best

os th

ereb

y as

sess

ing

the

risk.

Whe

re a

sbes

tos

is id

entif

ied,

em

ploy

ers

are

oblig

ed to

pro

duce

a p

lan

to m

anag

e

71

the

risk

of e

xpos

ure

to a

sbes

tos.

The

re a

re th

ree

type

s of

sur

veys

:

■T

ype

1 -

Pre

sum

ptiv

e su

rvey

to lo

cate

and

ass

ess

expo

sure

; ■

Typ

e 2

- S

ampl

ing

surv

ey to

loca

te, s

ampl

e an

d as

sess

the

expo

sure

; ■

Typ

e 3

- F

ull a

cces

s (I

ntru

sive

) su

rvey

prio

r to

dem

oliti

on o

r m

ajor

ref

urbi

shm

ent a

nd r

emov

al o

f asb

esto

s).

The

sur

veys

mus

t be

cond

ucte

d by

a c

ompe

tent

sur

veyo

r. C

ompa

nies

con

duct

ing

asbe

stos

sur

veys

are

req

uire

d to

be

UK

AS

acc

redi

ted

to IS

O 1

7020

(in

divi

dual

sur

veyo

rs w

ill b

e re

quire

d to

hol

d a

cert

ifica

tion

from

UK

AS

to E

N 4

5013

.

Che

mic

als

(Haz

ard

Info

rmat

ion

and

Pac

kagi

ng fo

r S

uppl

y) R

egul

atio

ns

2002

(CH

IP3)

CH

IP is

the

law

that

app

lies

to s

uppl

iers

of d

ange

rous

che

mic

als.

The

Reg

ulat

ions

req

uire

the

supp

lier

of a

dan

gero

us

chem

ical

to:

■id

entif

y th

e ha

zard

s (d

ange

rs)

of th

e ch

emic

al (

this

is k

now

n as

'cla

ssifi

catio

n');

■

give

info

rmat

ion

abou

t the

haz

ards

to th

eir

cust

omer

; ■

pack

age

the

chem

ical

saf

ely.

Reg

ulat

ion

5 of

CH

IP3

requ

ires

a co

py o

f the

saf

ety

data

she

et (

SD

S)

to b

e se

nt to

the

reci

pien

t the

firs

t tim

e th

e ch

emic

al is

pro

vide

d. If

the

SD

S is

upd

ated

, a c

opy

mus

t be

sent

to th

ose

reci

pien

ts w

ho h

ave

rece

ived

the

chem

ical

w

ithin

the

last

12

mon

ths.

Asp

ects

, im

pac

ts a

nd

ob

ject

ives

/op

erat

ion

al c

on

tro

ls

EN

VIR

ON

ME

NTA

L A

SP

EC

TS

Rel

ease

of p

oten

tially

pol

lutin

g m

ater

ial t

o th

e en

viro

nmen

t due

to fi

re, e

xplo

sion

, acc

iden

t miti

gatio

n (e

g fir

e-fig

htin

g w

ater

).

EN

VIR

ON

ME

NTA

L IM

PA

CTS

Maj

or a

ccid

ents

can

hav

e ca

tast

roph

ic c

onse

quen

ces

for

hum

an h

ealth

and

saf

ety

and

the

envi

ronm

ent.

Acc

iden

ts c

ause

d by

cer

tain

mat

eria

ls s

tore

d an

d us

ed w

ithin

the

prem

ises

cou

ld p

oten

tially

res

ult i

n fir

es, e

xplo

sion

s, s

erio

us d

amag

e to

pla

nt, u

ncon

trol

led

rele

ase

of to

xic

or o

ther

dan

gero

us s

ubst

ance

s to

th

e en

viro

nmen

t.

Som

e of

the

raw

mat

eria

ls u

sed

in th

e en

gine

erin

g in

dust

ry c

an b

e de

trim

enta

l to

hum

an h

ealth

thro

ugh

cont

act w

ith th

e sk

in, i

nges

tion

and

part

icul

arly

thro

ugh

inha

latio

n du

e to

thei

r du

sty

natu

re.

72

All

type

s of

asb

esto

s ar

e cl

assi

fied

as C

ateg

ory

1 ca

rcin

ogen

s. A

mph

ibol

es, w

hich

incl

ude

croc

idol

ite (

blue

) an

d am

osite

(br

own)

, are

con

side

red

the

mos

t da

nger

ous

subs

tanc

es, w

ith th

e se

rpen

tine

chry

sotil

e (w

hite

) re

cogn

ised

as

bein

g sl

ight

ly le

ss d

ange

rous

.

OB

JEC

TIV

ES

/OP

ER

ATI

ON

AL

CO

NTR

OLS

For

the

prev

entio

n of

acc

iden

ts, t

he m

etho

ds e

mpl

oyed

and

the

equi

pmen

t use

d to

ens

ure

the

corr

ect h

andl

ing

and

stor

age

of fl

amm

able

mat

eria

ls n

eed

to b

e de

term

ined

by

trai

ned

pers

onne

l in

acco

rdan

ce w

ith th

e H

SE

gui

danc

e an

d th

e D

ange

rous

Sub

stan

ces

and

Exp

losi

ve A

tmos

pher

e R

egul

atio

ns 2

002

(SI

2002

/277

6).

Ope

rato

rs o

f eng

inee

ring

inst

alla

tions

sho

uld

adop

t an

acci

dent

man

agem

ent p

lan.

The

pla

n sh

ould

incl

ude

writ

ten

proc

edur

es fo

r in

vest

igat

ing

inci

dent

s (a

nd

near

mis

ses)

whi

ch m

ay a

ffect

the

envi

ronm

ent,

incl

udin

g id

entif

ying

sui

tabl

e co

rrec

tive

actio

ns a

nd fo

llow

ing

up.

Saf

ety

data

she

ets

shou

ld b

e av

aila

ble

for

all s

ubst

ance

s us

ed/p

rodu

ced

on s

ite w

hich

may

be

haza

rdou

s to

hea

lth. T

hese

dat

a sh

eets

sho

uld

incl

ude

emer

genc

y m

easu

res

(eg

fire-

fight

ing

mea

sure

s) a

nd a

ctio

ns in

the

even

t of c

onta

ct w

ith h

uman

s.

73

Mis

cell

aneo

us

leg

isla

tio

n a

nd

gu

idan

ce

PLA

NN

ING

Tow

n an

d C

ount

ry P

lann

ing

Act

199

0

Tow

n an

d C

ount

ry P

lann

ing

(Sco

tland

) A

ct 1

997

Pla

nnin

g (N

orth

ern

Irel

and)

O

rder

199

1

The

pla

nnin

g sy

stem

exe

rts

cont

rol o

ver

the

use

of la

nd a

nd th

e fo

rm o

f dev

elop

men

t upo

n it

thro

ugh

deve

lopm

ent c

ontr

ol

mea

sure

s, w

hich

are

gui

ded

by d

evel

opm

ent p

lans

. Dev

elop

men

t is

defin

ed a

s th

e ca

rryi

ng o

ut o

f bui

ldin

g, e

ngin

eerin

g, m

inin

g or

ot

her

oper

atio

n in

, on

or o

ver

land

, or

the

mak

ing

of a

ny m

ater

ial c

hang

e of

use

of a

ny b

uild

ings

or

land

.

The

pla

nnin

g sy

stem

is a

dmin

iste

red

by 'L

ocal

Pla

nnin

g A

utho

ritie

s (L

PA

s)' (

'Pla

nnin

g A

utho

ritie

s' in

Sco

tland

or

'Pla

nnin

g S

ervi

ce'

in N

orth

ern

Irel

and)

.

Bef

ore

deve

lopm

ent c

an b

e ca

rrie

d ou

t, th

e de

velo

per

mus

t gai

n pl

anni

ng p

erm

issi

on fr

om th

e LP

A. W

ritte

n ap

plic

atio

n m

ust b

e m

ade

for

plan

ning

per

mis

sion

. If a

dev

elop

men

t pro

posa

l is

subj

ect t

o en

viro

nmen

tal i

mpa

ct a

sses

smen

t (E

IA),

the

plan

ning

ap

plic

atio

n m

ust b

e ac

com

pani

ed b

y an

env

ironm

enta

l sta

tem

ent.

GU

IDA

NC

E

BS

414

2: 1

997

Met

hod

for

ratin

g in

dust

rial n

oise

af

fect

ing

mix

ed r

esid

entia

l an

d in

dust

rial a

reas

Noi

se e

mitt

ed fr

om p

rem

ises

can

be

a st

atut

ory

nuis

ance

, cau

sing

per

sona

l dis

com

fort

or

inte

rfer

ence

with

the

enjo

ymen

t of

one'

s pr

oper

ty (

see

EP

A P

art 3

abo

ve).

Bes

t Ava

ilabl

e T

echn

ique

s (B

AT

) sh

ould

be

used

to p

reve

nt o

r re

duce

noi

se fr

om s

ites

regu

late

d un

der

the

IPP

C r

egim

e. P

erm

its

may

incl

ude

spec

ific

cond

ition

s fo

r th

e re

duct

ion

of n

oise

or

in a

lim

ited

num

ber

of c

ases

qua

ntita

tive

nois

e em

issi

on li

mit

valu

es

(ELV

s).

BA

T is

to r

educ

e no

ise

by a

pply

ing

a co

mbi

natio

n of

the

follo

win

g te

chni

ques

:

■en

clos

ure

and

vibr

atio

n in

sula

tion

of p

rodu

ctio

n un

it;

■us

ing

sile

ncer

s an

d sl

ow r

otat

ing

fans

for

cool

ing

and

to in

duce

air

into

dus

t aba

tem

ent s

yste

m;

■si

tuat

ing

win

dow

s, g

ates

and

noi

sy u

nits

aw

ay fr

om n

eigh

bour

; ■

soun

d in

sula

tion

of w

indo

ws

and

wal

l; ■

carr

ying

out

noi

sy (

outd

oor)

act

iviti

es o

nly

durin

g th

e da

y an

d go

od m

aint

enan

ce o

f the

pla

nt.

Noi

se fr

om in

dust

rial s

ourc

es s

houl

d be

qua

ntifi

ed ta

king

into

acc

ount

pot

entia

l exp

osur

e to

loca

l sen

sitiv

e re

cept

ors

(res

iden

tial

area

s, s

choo

ls, h

ospi

tals

, eco

logi

cal r

ecep

tors

etc

). B

ritis

h S

tand

ard

(BS

) 41

42 is

the

acce

pted

met

hod

for

ratin

g in

dust

rial n

oise

.

Sec

tor

Gui

danc

e N

ote

IPP

C

S0.

01. I

nteg

rate

d P

ollu

tion

Pre

vent

ion

and

Con

trol

(IP

PC

). G

ener

al S

ecto

r

Thi

s IP

PC

Gui

danc

e N

ote

is a

pplic

able

for

site

s w

here

ther

e is

no

sect

or-s

peci

fic g

uida

nce

avai

labl

e. A

s st

ated

abo

ve, a

ctiv

ities

co

vere

d by

the

'PP

C r

egim

e' w

ithin

the

engi

neer

ing

indu

stry

may

be

regu

late

d un

der

vario

us s

ectio

ns o

f the

PC

C R

egul

atio

ns

incl

udin

g:

74

Gui

danc

e■

Sec

tion

1.1

(Com

bust

ion

Act

iviti

es;

■S

ectio

n 2.

1 (F

erro

us M

etal

s;

■S

ectio

n 2.

3 (S

urfa

ce T

reat

ing

Met

als

and

Pla

stic

Mat

eria

ls;

■S

ectio

n 6.

4 (C

oatin

g A

ctiv

ities

, Prin

ting

and

Tex

tile

Tre

atm

ents

; ■

Sec

tion

7 (S

ED

Act

iviti

es).

Var

ious

Sec

tor

Gui

danc

e N

otes

(S

GN

s) a

nd P

roce

ss

Gui

danc

e N

otes

(P

GN

s)

Var

ious

sec

tor-

spec

ific

guid

ance

not

es (

SG

Ns)

and

pro

cess

gui

danc

e no

tes

(PG

Ns)

issu

ed b

y D

efra

cov

er a

ctiv

ities

car

ried

out

in th

e en

gine

erin

g in

dust

ry, e

g:

■S

ecto

r G

uida

nce

Not

e IP

PC

SG

4. S

ecre

tary

of S

tate

's G

uida

nce

for

A(2

) A

ctiv

ities

in th

e N

on-f

erro

us M

etal

s S

ecto

r (J

anua

ry 2

006;

■

Pro

cess

Gui

danc

e N

ote

2/9

(04)

. Sec

reta

ry o

f Sta

te's

Gui

danc

e fo

r M

etal

Dec

onta

min

atio

n P

roce

sses

.

As

of A

pril

2008

, all

new

SG

Ns

and

PG

Ns

will

be

issu

ed u

nder

Reg

ulat

ion

64 o

f the

Env

ironm

enta

l Per

mitt

ing

Reg

ulat

ions

. In

acco

rdan

ce w

ith p

arag

raph

12.

4 of

the

gene

ral g

uida

nce

man

ual o

n po

licy

and

proc

edur

es fo

r A

2 an

d B

inst

alla

tions

, any

pr

evio

usly

pub

lishe

d S

G n

otes

are

take

n to

hav

e be

en is

sued

und

er R

egul

atio

n 64

.

The

SG

Ns

and

PG

Ns

form

sta

tuto

ry g

uida

nce

on w

hat c

onst

itute

the

best

ava

ilabl

e te

chni

ques

(B

AT

) fo

r LA

-IP

PC

inst

alla

tions

(a

lso

know

n as

A2

inst

alla

tions

) an

d LA

AP

C in

stal

latio

ns (

also

kno

wn

as B

2 in

stal

latio

ns).

Env

ironm

ent A

genc

y T

echn

ical

Gui

danc

e W

M2

Haz

ardo

us W

aste

: In

terp

reta

tion

of th

e D

efin

ition

and

Cla

ssifi

catio

n of

Haz

ardo

us W

aste

Thi

s T

echn

ical

Gui

danc

e do

cum

ent h

as b

een

deve

lope

d by

the

Env

ironm

ent A

genc

y to

pro

vide

gui

danc

e on

the

asse

ssm

ent a

nd

clas

sific

atio

n of

haz

ardo

us w

aste

bas

ed o

n th

e H

azar

dous

Was

te D

irect

ive

defin

ition

of h

azar

dous

was

te. I

t is

inte

nded

to

prov

ide

guid

ance

to a

ll in

volv

ed in

the

prod

uctio

n, m

anag

emen

t and

con

trol

of h

azar

dous

was

te a

nd to

be

a re

fere

nce

docu

men

t fo

r al

l leg

isla

tion

rela

ted

to h

azar

dous

was

te a

nd it

s m

anag

emen

t. In

clud

es th

e co

nsol

idat

ed E

urop

ean

Was

te C

atal

ogue

. A

vaila

ble

on th

e E

nviro

nmen

t Age

ncy

web

site

(ht

tp:/

/ww

w.e

nvir

onm

ent-

agen

cy.g

ov.u

k/su

bjec

ts/w

aste

/101

9330

/121

7981

/138

4307

/)

Pol

lutio

n P

reve

ntio

n G

uide

lines

The

Env

ironm

ent A

genc

y, S

cotti

sh E

nviro

nmen

t Pro

tect

ion

Age

ncy

and

Nor

ther

n Ir

elan

d E

nviro

nmen

t Age

ncy

have

pro

duce

d a

rang

e of

UK

-wid

e P

ollu

tion

Pre

vent

ion

Gui

delin

es (

PP

Gs)

. The

y ar

e av

aila

ble

from

the

agen

cies

' web

site

s or

from

the

Net

Reg

s w

eb

site

(ht

tp:/

/ww

w.n

etre

gs.g

ov.u

k/ne

treg

s/re

sour

ces/

2780

06/)

. Eac

h P

PG

is ta

rget

ed a

t a p

artic

ular

indu

stria

l sec

tor

or a

ctiv

ity

and

aim

s to

pro

vide

adv

ice

on s

tatu

tory

res

pons

ibili

ties

and

good

env

ironm

enta

l pra

ctic

e. E

xam

ples

incl

ude:

■P

PG

1 G

ener

al g

uide

to th

e pr

even

tion

of p

ollu

tion

■P

PG

2 A

bove

gro

und

oil s

tora

ge ta

nks

■P

PG

5 W

orks

and

mai

nten

ance

in o

r ne

ar w

ater

■

PP

G 7

Ref

uelli

ng fa

cilit

ies

■P

PG

8 S

afe

stor

age

and

disp

osal

of u

sed

oils

75

■P

PG

11

Indu

stria

l site

s ■

PP

G 1

3 V

ehic

le w

ashi

ng a

nd c

lean

ing

■P

PG

18

Man

agin

g fir

e w

ater

and

maj

or s

pilla

ges

■P

PG

21

Pol

lutio

n in

cide

nt r

espo

nse

plan

ning

■

PP

G 2

6 S

tora

ge a

nd h

andl

ing

of d

rum

s an

d in

term

edia

te b

ulk

cont

aine

rs

76

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CHEMICALS SUPPLEMENT

INTRODUCTION

Many chemical companies have committed to the global Responsible Care® programme (www.responsiblecare.org),

led in the UK by the Chemical Industries Association (CIA) (www.cia.org.uk). The CIA reports on environmental indicators

for the sector and helps share best practice. Companies report through a mandatory self assessment.

An EMS complements Responsible Care® and aids data collection and environmental improvement.

■ A responsible image can aid recruitment and staff retention.

■ There may be fewer objections to any planning applications made by the company.

■ Investment and insurance may be easier to obtain because of the reduced risks posed by the business.

This supplement contains information and guidance specific to the chemicals industry. It covers:

■ Initial Review - developing a process flow diagram

■ Register of Environmental Aspects

■ Register of Legislation

■ Resource efficiency

■ Green chemistry

■ Supply chain issues

■ Setting objectives and targets

■ Management Programme and Management Manual - integration of existing systems

■ Case studies from the chemical industry

■ Helpful free publications and tools.

The advantages of a formal approach

Most of the chemicals sector is covered by IPPC (see section on Register of Legislation).

Environment Agency IPPC Sector Guidance Notes S4.02 and S4.03 state:

‘The Regulators strongly support the operation of formal environmental management systems. The Regulators

recommend either certification to the ISO 14001 standard or registration under EMAS’.

77

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INITIAL REVIEW - DEVELOPING A PROCESS FLOW DIAGRAM

A process flow diagram is a way to organise information about company processes so that inputs and outputs can be

identified.

Considering the inputs and outputs will help you understand what the company’s environmental aspects are (eg use of

solvents, disposal of effluent and emissions to air).

The example process flow diagram included in this supplement is for the manufacture of an organic chemical in its pure,

solid form. Use this diagram as a guide to produce process flow diagrams for your company.

■ You may choose to produce a diagram for each process operated on-site.

■ One or more diagrams may be needed for supporting ‘processes’ such as maintenance or offices.

■ Where possible, group similar activities together to reduce the number of diagrams required.

You probably already use process flow diagrams within your company. If available, use these to help you produce your

process flow diagram. But be aware that diagrams produced for engineering or manufacturing purposes may not contain

all the inputs and outputs you are seeking to identify within your EMS.

If you have data on quantities, add these to the diagram. A ‘mass balance calculation’ is a way to account for 100% of

inputs and outputs to a process. Any existing mass balance calculations will provide useful information on quantities.

78

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EXAMPLE PROCESS FLOW DIAGRAM FOR THE MANUFACTURE OF AN ORGANIC CHEMICAL

79

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ENVIRONMENTAL ASPECTS

In order to establish an environmental management system that complies with on ISO 14001: 2004, chemical

companies need to compile:

■ Register of Environmental Aspects and Impacts (to comply with Clause 4.3.1).

The information below will help chemical companies to compile this register.

The table below gives examples of environmental aspects and impacts common to many chemical companies. These

are separated into:

■ inputs to the company;

■ outputs from the company;

■ downstream supply chain issues.

This information may help you identify impacts associated with your company’s aspects.

80

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COMMON ENVIRONMENTAL ASPECTS AND IMPACTS FOR CHEMICAL COMPANIES

Continued...

Aspect Impact(s) Notes on how environmental impacts can occurProcess inputsDelivery of materials Air pollution

 

Dust pollution

 

Water pollution

 

Pollution of land and groundwater

Materials may arrive by tanker, by pipeline, in drums or intermediate bulk containers (IBCs).

 

During transfer of materials, dust or vapour emissions may occur.

 

Solid or liquid spills can contaminate surface water, or seep into land reaching groundwater.

Storage of materials Air pollution

 

Odour

 

Dust pollution

 

Materials may either be stored in the containers they were delivered in or dedicated containers.

 

Solid materials may form dusts, particularly if not covered or in containers. Such dusts can cause air pollution, or pollute surface water or land.

 

  Water pollution

 

Pollution of land and groundwater

Liquids stored in tanks may leak, leading to contamination of surface water, land or groundwater.

 

Liquids or solids with a significant vapour pressure can give off fugitive air emissions. These may be minimised by containment, or vented to a treatment unit.

 

Also consider any additional inputs required to provide heating, cooling, a layer of inert gas or other special treatment during the storage of materials.

 

Hazardous materials can undergo unwanted reactions, on their own, or with materials stored close by. HSE publications HSG71 Chemical warehousing: the storage of packaged dangerous substances and HSG51 Storage of flammable liquids in containers provide detailed information on material storage (available from HSE Books, www.hsebooks.com).

 

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Aspect Impact(s) Notes on how environmental impacts can occurUse of raw materials Resource depletion

 

Air pollution

 

Water pollution

 

Pollution of land and groundwater

A vast range of raw materials are produced and used on chemicals sites, particularly in speciality chemicals manufacture. Inputs may be in gas, liquid, dissolved or solid form. They may include metals, inorganic compounds as solids or solutions, simple and complex organic compounds, acids, alkalis, and materials used as solvents.

 

The chemical properties exhibited by the raw materials are of interest not only in the process, but in the emissions and waste products. Some may be biodegradable and of little toxicity to receptors (plant, animal or human). Some may be bioaccumulative, persistent or toxic, posing issues both on- and off-site.

 

Resource efficient use of raw materials leads to lower costs and smaller amounts of waste and emissions. Catalysts are often used to speed up reactions and to increase the amount of desired product relative to by-products. With catalysts, lower temperature and pressure may achieve the same reaction. Catalysts are usually held in solid form within the process, or may be recovered from liquids for re-use. Microorganisms or extracted enzymes may be used to perform some processes.

 

The use of non-renewable feedstocks (based on inorganic materials or petrochemicals) depletes the amount of these resources available. The use of renewable feedstocks, or those derived from wastes from other industries, is likely to be increasingly important to the industry. Sourcing of feedstocks from biomass may be subject to sustainability issues (eg clearing of rainforests for biomass plantations or competition with grain food supplies). Extracting organic feedstocks from cellulosic materials such as wood or agricultural wastes is subject to fewer of these issues.

 

Higher purity raw materials are generally more costly. This must be balanced against the effect of impurities in the process. Impurities can increase the amount of by-product formed, require separation from the product, or increase the hazards of emissions or wastes. Many companies have quality assurance procedures for the procurement of material.

 

The containers used to deliver raw materials may be contaminated. They may be re-usable on-site or returnable to the supplier. Alternatively they may need to be decontaminated and/or disposed of as hazardous waste.

 

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Aspect Impact(s) Notes on how environmental impacts can occurUse of water Water resource depletion Water is, in principle, a renewable resource. However, it

is a resource that must be purified by the water company and paid for by users. Water abstraction, particularly in times of drought, has impacts on landscape and wildlife.

 

Water may be used on-site as a process solvent, as cooling water, for cleaning equipment and storage areas, and for domestic uses. The water may be from mains supply, from an on-site purification unit, or from a borehole. The costs of heating, pumping, treatment and disposal increase the cost of water used on-site.

 

Not all uses require water of a quality fit for drinking and water can be re-used on-site for lower grade purposes. Cooling water should in theory not come into contact with process chemicals, but leaks can lead to its contamination. Cooling water is recirculated in many, but not all installations. If cooling water is once-through, it leads to higher consumption and a greater volume of potentially contaminated water.

 Use of solvents Air pollution

 

Water, land and groundwater pollution

 

Solvents are used as a reaction medium and for cleaning. Solvents are selected for their chemical properties and include organic chemicals such as acetone, alcohols, ethers, organic acids, hydrocarbons and amines. Water can be a solvent in some situations.

 

Some solvents are easily vaporised and are so-called volatile organic compounds (VOCs). VOCs react at ground level to form ozone and photochemical smog, with effects on human and ecosystem health. VOC use is regulated by the Solvent Emissions Regulations 2004.(NB Separate regulations apply in England and Wales, Scotland and Northern Ireland).

 

Some solvents are hazardous (eg they may be assigned the risk phrase R45 ‘May cause cancer’) and their use is more strictly regulated by environmental and health and safety legislation.(NB The risk phase should be given on the packaging and material safety data sheet.)

 

Spills of solvents can contaminate water, land and groundwater. Some readily biodegrade; others persist longer in the environment (particularly highly halogenated and aromatic compounds).

   (Ozone depletion)

 

The Environmental Protection (Controls on Ozone Depleting Substances) Regulations 2002 banned the manufacture and use of highly ozone-depleting solvents such as 1,1,1 trichloroethane.

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Aspect Impact(s) Notes on how environmental impacts can occurUse of electricity Resource depletion

 

Air pollution

 

Climate change

Electricity will be used on-site for operating equipment and lighting, and sometimes for process heating. It will also be used for lighting and powering appliances in offices. Electricity can be a major cost for chemical companies.

 

Generation of electricity in the UK is mainly from fossil fuels, leading to depletion of these resources. Air emissions include nitrogen and sulphur oxides (leading to acid rain) and carbon dioxide which contributes to global climate change. It is possible to buy electricity from renewable sources. Combined heat and power (CHP) plants may be used to generate electricity and heat on-site. This is more efficient than generation at a power station where the heat is not used.

 

Large users of electricity include compressors, liquid and vacuum pumps, centrifuges and heating jackets. You may be able to identify them from a site walk around, data from sub-meters on-site, or if the rated power consumption is known to engineering staff. Timescales for replacement of equipment are long in the industry, but on replacement, more efficient equipment is likely to be available.

 

Regular maintenance, controls, timers and manual switch-off procedures are among low-cost ways to reduce electricity use.

 

The Climate Change Levy (CCL) is a tax on the use of non-renewable energy in industry, commerce and the public sector, with offsetting cuts in employers' National Insurance Contributions (NICs) and additional support for energy efficiency schemes and renewable sources of energy. The levy forms a key part of the Government's overall Climate Change Programme.

 

The CCL is applied to electricity, gas, coal and liquefied petroleum gas (LPG). The rate at which a business pays depends on the type of fuel used. The levy is added to bills before VAT and, although there is no legal requirement for it to be shown, it is likely to appear as a separate item on energy bills. It adds approximately 15% to typical energy bills of UK businesses. There are certain exemptions and discounts from the levy including the use of fuel oils (as they are already subject to an excise duty) and ‘good quality’ CHP systems.

Energy intensive industries can get an 80% discount on the CCL if they agree to energy use reduction targets as part of Climate Change Agreements (CCAs) negotiated by Defra (more recently DECC – Department of Energy and Climate Change) with the relevant trade associations on behalf of the companies in the sectors concerned (an ‘Umbrella Agreement’). The chemical sector has one CCA. This agreement is managed by CIABATA (www.ciabata.org.uk).

Other companies may be involved in the EU Emissions Trading Scheme. Energy efficiency requirements are also identified in Pollution Prevention and Control (PPC) permits.

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Aspect Impact(s) Notes on how environmental impacts can occurUse of fossil fuel (natural gas, heating oil) for heat

Resource depletion

 

Air pollution

 

Climate change

Gas or heating oil may be used to heat processes and buildings. Process heat may be supplied directly from combustion, or by hot water or steam lines.

 

The use of fossil fuels depletes non-renewable and increasingly expensive resources. It creates nitrogen and sulphur oxides, which contribute to acid rain. Carbon dioxide emissions contribute to climate change. The Climate Change Levy is charged on natural gas but not fuel oils (see above) and carbon dioxide emissions can be traded (see above).

 

On-site CHP can provide lower carbon heat and electricity. Some manufacturing processes can be designed to capture and use waste heat from chemical reactions. These options are technically difficult for older sites, sites not currently being upgraded, and those using multi-purpose reactors.

 

Heat can be conserved by installing controls and timers. Regular maintenance of equipment and insulation on heated items will reduce losses.

 Use of cooling equipment Ozone depletion

 

Climate change

Building air conditioning and process cooling equipment uses electricity, with impacts as described above. The equipment may contain ozone-depleting substances such as chlorofluorocarbons (CFCs) and hydrofluorochlorocarbons (HCFCs) in the compressor. These were banned or phased out by the Environmental Protection (Controls on Ozone Depleting Substances) Regulations 2002. Only qualified personnel may work on existing equipment containing these substances.

 

Fluorine-containing gases have been used as replacements for ozone-depleting substances. These are potent greenhouse gases and are regulated by EC Regulation 2006/842/EC on Certain Fluorinated Greenhouse Gases.

 Process outputsOdour Impact on local population

quality of lifeSome chemicals used in the industry have noticeable or unpleasant odour. Hydrogen sulphide, ammonia, various organics, amines and chlorine are detectable at low concentrations. Therefore, controlled and fugitive emissions must be kept to low levels.

 

The colour of tanks affects the degree of solar heating and release of gas or vapour. Storage tanks can be vented to scrubber systems to remove odour.

 Noise Impact on local population

 

Impact on wildlife

Noise is created by processes, air handling, vehicle movement, alarms and many other sources. The impact of noise will be more noticeable in a quiet locality or at night.

 

Noise can create significant disturbance to nearby residential areas or wildlife.

 

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Aspect Impact(s) Notes on how environmental impacts can occurDust Impact on local population

and property

 

Water pollution

 

Land and groundwater contamination

Dust can arise from solid materials in uncovered storage areas and when materials are moved around the site by vehicle or conveyor. Dust may be created in milling, grinding and packing operations.

 

Once created, dust can be spread by wind and vehicle wheels. Rainwater may wash dust into drains or surface waters, or seep into the ground.

 

Dust is likely to cause annoyance to the local population. Depending on its chemical nature, it may also cause a hazard or damage to property.

 Emissions to air Climate change

 

Air pollution

 

Ozone depletion

Chemical manufacturing processes result in a wide variety of emissions made to air, including:

■ acid gases (hydrogen chloride, nitrogen oxides and sulphur oxides), which contribute to acid rain and photochemical smog formation;

■ VOCs, which contribute to ground level ozone and photochemical smog;

■ ammonia, leading to acidification and eutrophication of waters;

■ volatile inorganic compounds including carbon monoxide, cyanides, compounds of metals, fluorine, mercury or arsenic ;

■ particulates, which affect human health; ■ ozone-depleting substances such as HCFCs,

HFCs, CFCs, carbon tetrachloride, halons and methyl bromide.

Air emissions usually require a permit. Releases may be controlled by a stack and abatement system. Abatement uses energy, materials and water, and creates waste.

 

Fugitive (uncontrolled) emissions occur from:

■ joints; ■ vessel and joint opening; ■ vents in lines and vessels; ■ vaporisation from aqueous waste streams.

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Aspect Impact(s) Notes on how environmental impacts can occurDischarges to controlled waters

Water pollution Controlled waters are inland water bodies and some coastal waters. Discharges require a consent, which set limits for contaminants. Mains water discharged as consented effluent has been paid for twice over.

 

Effluent from chemical sites can arise from processes, separations, cleaning, cooling water and rainwater run-off.

 

Rainwater can be contaminated by spills and leaks, but can be routed to avoid such contact. In emergency situations, firewater may be discharged with a high load of contamination.

 

Some sites have effluent treatment plants. These require chemical and energy inputs, and produce wastes. Failure of effluent plants can lead to unauthorised discharges.

 

Contaminants that may be present in effluent include:

■ high nitrogen or phosphorus content, leading to eutrophication of waters;

■ acids or alkalis; ■ chelating agents such as EDTA, which can

remobilise metals in solution; ■ dissolved metals; ■ halogenated organic compounds; ■ suspended solids; ■ oils; ■ biocides and plant health products.

Chemical oxygen demand (COD) and biological oxygen demand (BOD) are aggregate measures. Oxygen demand results from high organic concentrations. High COD/BOD leads to oxygen depletion of waters and damage to wildlife. Persistent or bioaccumulative substances are of particular concern.

 

Unregulated discharges can come from direct run-off to watercourses or by contamination of surface water drains. Consider:

■ potential routes from storage areas; ■ procedures to deal with leaks and spills; ■ housekeeping; ■ segregation of incompatible substances.

Discharge to foul sewer Water pollution Any of the materials listed under discharge to controlled waters may be present in effluents discharged to foul sewer. A consent is required from the sewerage company and there will be a charge per m3 of effluent disposed.

 

Discharges must be monitored to ensure they comply with the consent.

 

Materials that will damage the sewers or the treatment plant are prohibited.

 

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Aspect Impact(s) Notes on how environmental impacts can occurEffluent treatment on-site Water pollution

 

Impacts from consumables, waste and energy

On-site effluent treatment is often used in the industry to treat large volumes of effluent. This allows a treated effluent to be discharged to sewer or surface water under the terms of a discharge consent from the regulator. Techniques include:

■ neutralisation of acidic or basic solutions; ■ sedimentation to remove solids; ■ wet air oxidation at high temperatures to remove

organics; ■ biological treatment to degrade organics.

 

On-site treatment requires consumables and energy to operate. It may produce wastes, which must either be disposed of, or if possible, returned to the process.

 

If on-site treatments plants fail, a pollution incident is likely to happen. Therefore, plants need to be carefully monitored.

 

Any material that will prevent the plant working should be segregated in separate tanks for disposal by another route.

 Disposal of liquid wastes in containers

Air pollution

Water pollution

Liquid wastes in containers or tanks may be sent to specialist facilities. This method is used for more concentrated or hazardous liquids that cannot be discharged to sewer or controlled waters.

 

Such waste may include sludges, tank and column bottoms, and off-spec product.

 

Liquids may not be disposed to landfill.

 

Hazardous wastes must not be mixed as this can increase hazards and prevent recycling. For example, waste solvent can be recycled or used as fuel, and waste chlorinated solvent is burned at higher temperatures to avoid dioxin formation.

 

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Aspect Impact(s) Notes on how environmental impacts can occurDisposal of hazardous solid wastes

Land contamination (at landfill)

 

Air pollution (from incineration)

 

Impacts of recycling processes

Chemical manufacturing processes produce significant amounts of hazardous waste. This includes:

■ process wastes; ■ filters and filter cakes; ■ off-spec products; ■ spent catalysts; ■ distillation residues; ■ ion exchange resins; ■ air pollution control residues

 

Waste electrical and electronic equipment (WEEE) and lighting lamps are also hazardous waste.

 

All hazardous waste treatments are expensive because of scarce capacity in the UK.

 

All wastes must be described by an EWC (European Waste Catalogue) code, which is used on hazardous waste consignment notes. The impacts of waste disposal vary widely for different materials and methods.

 

Waste may be reprocessed if components are valuable (eg precious metal catalysts).

 

Waste may be incinerated, possibly with recovery of the energy.

 

Waste destined for landfill must be pretreated to reduce the volume and hazard, or to enhance recovery.

 

Items contaminated with hazardous materials may be washed or chemically treated on-site to remove the hazard.

 

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Aspect Impact(s) Notes on how environmental impacts can occurDisposal of non-hazardous solid wastes

Land contamination (at landfill)

 

Impacts of recycling processes

Non-hazardous wastes may arise from any of the sources listed for hazardous wastes. If the material is non-hazardous or any hazardous component is below a threshold concentration, the waste is classified as non-hazardous. Other sources may include packaging, office wastes and waste from construction and maintenance.

 

The costs of waste disposal are increasing.

 

All wastes must be described by an EWC (European Waste Catalogue) code, which is used on waste transfer notes.

 

Waste may be landfilled, leading to ground contamination at the landfill site. Waste must be pretreated to reduce volume or enhance recovery.

 

Waste may be recycled; this is generally a better environmental option but still has various impacts.

 Packaging Resource depletion Packaging is required to contain and protect the product

on the way to the customer.

 

Some packaging may be unnecessary. It may be possible to supply bulk rather than container deliveries.

 

Some packaging may be re-usable, eg drums of solvent can be used to contain drums of product dissolved in the same solvent.

 

Agreements on returning packaging can be made with major customers or suppliers.

 Discharge to land and groundwater

Land contamination

 

Groundwater contamination

 

Storage and use of materials can lead to contamination of land and groundwater. This can occur through leaks or spills from processes or storage areas.

 

Disposal of waste by burial on-site requires an environmental permit (in England and Wales from April 2008) or a waste management licence.

 

Contamination of land can be very costly to remediate.

 

Contamination of groundwater is serious because this allows the contaminants to move through the ground. It also has the potential to affect water supplies.

 

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Aspect Impact(s) Notes on how environmental impacts can occurProduct impacts in use and disposal (downstream supply chain)Presence of persistent, bioaccumulative or toxic materials in products

Impact on human and ecosystem health

These chemicals have various effects on human health and ecosystems. Due to customer concerns, some retailers have banned or restricted chemicals that can legally be used in the EU at present. These chemicals are likely to be strictly controlled under the REACH Regulation.

 

 Recycling or disposal of product

Various impacts – specific to the material and use

Issues around recycling may arise when chemicals are incorporated into consumer products by downstream manufacturers. Packaging, electronics and automotive industries are highly regulated in this respect.

 

Chemical companies may need to communicate with downstream manufacturers to optimise recycling and to minimise impacts from disposal. These impacts are best addressed at the planning and design stage.

 

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LEGISLATIVE REQUIREMENTS

In order to establish an environmental management system that complies with on ISO 14001: 2004, chemical

companies need to compile:

■ Register of Environmental Legislation (to comply with Clause 4.3.2).

The information below will help chemical companies to compile this register.

Chemical companies should check that they comply with each legal requirement (Clause 4.5.2).

It may be useful to generate a list of documents and records that could be inspected regularly to confirm compliance.

All Acts and Regulations since 1987 can be downloaded free from the government’s Office of Public Sector Information

website (www.opsi.gov.uk).

The list of legislative requirements is not a complete list of environmental legislation but provides in general the relevant

regulations specific to the chemical sector. Additional interpretation and advice are available from:

■ NetRegs: www.netregs.gov.uk/netregs/businesses/chemicals/

■ Envirowise: www.envirowise.gov.uk

■ Environment Agency (England and Wales): www.environment-agency.gov.uk

■ Scottish Environment Protection Agency (SEPA): www.sepa.org.uk

■ Northern Ireland Environment Agency: www.ni-environment.gov.uk

Registration, Authorisation and Restriction of Chemicals (REACH)

The European Registration, Authorisation and Restriction of Chemicals (REACH) Regulation 2006 introduced a risk

assessment system for chemicals.

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hazards.

REACH timetable

The Regulation specifically requires communication along the supply chain. Information will be passed down the supply

chain in the form of material safety data sheets (MSDS.)

Substances of high concern (those that can cause cancer, mutations, birth defects or are persistent or bioaccumulative)

will be subject to authorisation and possibly phase-out dates. Use may be permitted only with specific techniques and

personal protective equipment.

REACH may drive innovation in safer use of chemicals and identification of substitutes, and in cheap, non-animal testing

methods. It is likely to drive reformulation of some products. Hazardous materials are likely to become more expensive.

Other substances may become unavailable because it is uneconomic to register them.

Your company’s REACH compliance activities are likely to include:

■ taking a product inventory;

■ developing work instructions;

■ communicating with suppliers and customers;

■ exploring material substitutions.

These tasks can be conveniently managed within the structure of an EMS.

More information about REACH is available on the HSE website (www.hse.gov.uk/reach). HSE is the competent

authority for REACH in the UK.

Integrated Pollution Prevention and Control (IPPC) Directive

Most chemical manufacturers are regulated under IPPC. The Pollution Prevention and Control (England and Wales)

Regulations 2000, and their equivalents in Scotland and Northern Ireland, list the operations that require a permit. They

require operators to:

■ have a permit from the regulator and to comply with its requirement for plant operating conditions, emission limits

for certain substances to air, land and water and annual reporting of pollutant releases;

■ conform to any improvement plan within the permit;

■ inform the regulator of any changes, requiring a change to the permit (multi-product protocols may be agreed for

frequently changed operations);

■ use Best Available Techniques (BAT) for processes to prevent pollution;

■ minimise waste and conserve energy;

■ limit accidents and their consequences;

■ restore the site after operations end.

The Environmental Permitting (England and Wales) Regulations 2007 came into force in April 2008. They combined

pollution prevention and control (PPC) permits and waste management licensing (WML) into a single, modern, simpler

system.

The following publications may be useful if you are regulated under IPPC or wish to identify BAT for your process:

■ Environment Agency Sector Guidance Note IPPC S4.01 - Guidance for the large volume organic chemicals sector

■ Environment Agency Sector Guidance Note IPPC S4.02 - Guidance for the speciality organic chemicals sector

■ Environment Agency Sector Guidance Note IPPC S4.03 - Guidance for the inorganic chemicals sector.

All three sector guidance notes can be downloaded from the Environment Agency’s website (www.environment-

Date Registration deadlineDecember 2010 For substances produced or imported to the EU in quantities over

1,000 tonnes and carcinogens, mutagens and chemicals toxic to reproduction

June 2013 For substances in quantities of over 100 tonnesJune 2018 For substances in quantities of over 1 tonne

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agency.gov.uk/business/sectors/39973.aspx).

The European Commission’s IPPC Bureau has published reference documents on Best Available Techniques. These

documents are known as BREFs.

The following may be of use for identifying BAT for your process or understanding your place in the supply chain:

■ cement, lime and magnesium oxide manufacturing industries;

■ chlor-alkali manufacturing industry;

■ common waste water and waste gas treatment/management systems in the chemical sector;

■ large volume inorganic chemicals - ammonia, acids and fertilisers;

■ large volume inorganic chemicals - solid and others;

■ large volume organic chemical industry;

■ manufacture of organic fine chemicals;

■ mineral oil and gas refineries;

■ production of polymers;

■ production of speciality inorganic chemicals.

BREFS can be downloaded from http://eippcb.jrc.es/reference/

RESOURCE EFFICIENCY

Resource efficiency is about increasing the proportion of inputs that make it into the final product. Materials and utilities

are used efficiently, and waste and emissions are minimised.

Significant cost savings can be made by improving resource efficiency and reducing waste. This is due to the increasing

cost of many raw materials and waste disposal. For chemical companies, hazardous waste disposal can be a

significant cost. Air and water emissions often require expensive monitoring and abatement. Reducing these at source

reduces the ‘end of pipe’ costs.

The case study at Peboc (see below) demonstrates the kind of savings that can be made by paying closer attention to

resource efficiency. An EMS can help your company systematically identify such opportunities and legislative

requirements, and embed new methods of working. The use of the statistical method, Six Sigma, helped Peboc

determine what changes should be made and what level of performance could be achieved. Shasun Pharma Solutions

(see below) used periodic process reviews to identify opportunities. This is a similar process to the EMS initial review

and the setting of objectives and targets, but applied to selected processes rather than the entire site.

Case study at Peboc: more effective management of waste

The multi-product batch plant at Peboc produces low volumes of high-value chemicals. The PPC permit held by the

facility includes a requirement to ‘carry out periodic waste minimisation and water use efficiency audits’.

Cleaning is carried out between product batches. It is important to clean effectively each time as repeating the process

uses more time, solvent, water and energy. An analysis of data on the cleaning process using the Six Sigma statistical

method suggested a number of improvements to cleaning equipment and techniques. Making these improvements

resulted in a 10% reduction in effluent generation, saving disposal costs of £4,000/year.

The company audited all solid waste streams on-site and evaluated the options for rework, recycling and final disposal

routes. Segregation of hazardous and non-hazardous wastes in particular offered significant savings as it was

discovered much material was being disposed to hazardous landfill when it was in fact non-hazardous and/or recyclable.

Mixed waste solvents were disposed of by incineration as cement kiln fuel. Management of the waste solvents’ water

 

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content was improved to below 10% so that more waste solvent could be disposed of by this route. Waste toluene was

segregated from other waste solvents and instead sold to a reprocessor. This resulted in significant savings (see table).

Use of recovered toluene in place of virgin solvent could lead to potential future savings of around £130,000/year.

For more details, see Envirowise Case Study CS791 Effective management and segregation reduce hazardous waste

disposal costs (www.envirowise.gov.uk/cs791)

Case study at Shasun Pharma Solutions: hazardous waste cut following process reviews

The Shasun Pharma Solutions Limited (SPSL) site in Northumberland manufactures advanced intermediates and active

pharmaceutical ingredients. Through working with its hazardous waste contractor, SPSL no longer sends any hazardous

waste to landfill.

Moving up the waste hierarchy, SPSL used Periodic Process Reviews (PPRs) to identify ways to eliminate waste at

source. This saved on disposal costs and met the improvement requirements of the site’s PPC permit.

A PPR was carried out for a reaction process in batch vessels and subsequent cleaning. A mass balance and waste

audit identified opportunities to reduce waste. Cleaning by filling vessels with solvent was replaced by cleaning with a

mobile spraying rig. This reduced the volume of methanol used for cleaning by 68%, saving £30,600/year for a process

campaign of ten batches. By moving from single use drums to larger and re-usable IBCs for methanol disposal, the

company saved a further £16,920/year. This approach could be extended to other process campaigns with potential

savings of £150,000/year.

A PPR was used to examine a process that used xylene as a carrier to keep the batch stirring at the end of product

distillation. It was found that a smaller volume could be used. This saved 783 kg (60%) per vessel charge, giving a cost

saving for 22 batches of £17,226/year.

Sodium hydroxide scrubbers are used to treat atmospheric emissions to meet the site’s PPC permit limits. It was found

that the scrubbers were used for every process, even when not needed. Sometimes they were left running when the

process was complete. Changes were made to manage the use of the scrubbers. The sodium hydroxide liquor was

monitored and replaced only when completely exhausted. This saved labour and energy, and 1,000m3/year of water.

Water cost the company 50p/m3 and 32p/m3 to treat in the onsite effluent plant. Thus, the company saved £820/year.

For more details, see Envirowise Case Study CS701 Process reviews reduce hazardous waste at a pharmaceutical

manufacturer (www.envirowise.gov.uk/cs701).

GREEN CHEMISTRY

Green chemistry has been defined by the International Union of Pure and Applied Chemistry (www.iupac.org)  as: ‘the

invention, design, and application of chemical products and processes to reduce or eliminate the use and generation of

hazardous substances’.

Green chemistry is part of sustainable development, linking economic activity with social progress and protection of

health and the environment.

In terms of an EMS, the principles of green chemistry apply to:

■ drawing up an environmental policy;

■ environmental aspects;

Toluene use 320 tonnes/yearCost for disposal as cement kiln fuel £35/tonne = £11,200/yearRevenue from sale to reprocessor £50/tonne = £16,000/yearCost saving £27,200/year

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■ setting objectives and targets.

For more information about green chemistry, see Envirowise guide GG679 Resource efficiency through green chemistry

(www.envirowise.gov.uk/gg679).

A self-assessment tool on green chemistry is available from the ‘Chemicals & Pharmaceuticals’ area of the Envirowise

website (www.envirowise.gov.uk/uk/Sectors/Chemicals-and-Pharmaceuticals.html).

SUPPLY CHAIN ISSUES

Speciality chemical companies generally sit in the middle of supply chains. They take raw materials from bulk chemical

processes, and supply products to downstream manufacturers more often than they supply direct to the public.

Bulk chemical companies sit higher in the supply chain.

Large volume organic chemical sites may be closely linked to oil refineries that supply their petrochemical feedstocks.

Suppliers may be making changes to their products as a result of environmental, health and safety concerns, or

regulatory pressure.

High oil and gas prices may change the availability of raw materials, or the economics of using them. This has stimulated

interest in feedstocks from biomass, while advances in technology could bring new materials into the marketplace

relatively quickly.

Customer companies increasingly ask questions about the origins and content of the materials they buy. This may be

because they are looking to reduce legal or reputation risk, or to source superior quality raw materials. It may be because

they are extending their environmental or quality management system into their supply chain. This can mean that they

award preferred supplier status to companies that also have an EMS.

Discussions with customers can result in better co-ordinated and safer deliveries, and take-back or reduction of

packaging.

There is an increasing trend to remove ‘toxic’ materials and to use eco-labels on retail consumer products. This requires

detailed information from the entire supply chain, which may be co-ordinated as part of an EMS. For example, Boots

developed a ‘priority substance list’ of chemicals of concern, some of which are to be phased out of the company’s

products. Marks & Spencer took similar action, introducing codes of practice for the dyes and pesticides used in

manufacturing its products.

Action taken to communicate and manage risks along the supply chain is known as ‘product stewardship.’

Whether a company is able to instigate environmental improvements in its supply chain, or is dictated to by the

requirements of its customers, depends often on the market, competition, and the relative size of the companies

involved.

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SETTING OBJECTIVES AND TARGETS

Chemical companies can make significant savings by setting objectives and targets based on the information obtained in

the initial review. These objectives and targets should take into account the aims of resource efficiency, the principals of

green chemistry and the need to accommodate supply chain issues.

Case study at a chemical formulator

A chemical formulator made significant savings when its action plan was put into place. An initial review identified

potential savings by addressing water use and effluent leaks, and minimising waste using cleaner technology. 

The potential was realised when plans were made to double the production capacity of the site. The new vessels

installed were superior to the existing, dated equipment in the following ways:

■ easy to clean with conical bottoms for easy draining;

■ integral high pressure washing heads;

■ computer control of additions and mixing, with interlocks to avoid mistakes.

Wash water is now saved in IBCs and returned to vessels for use in the next compatible batch reaction. This reduces

the loss of valuable raw materials in effluent. Future work may permit the closure of the on-site effluent treatment plant.

This would reduce the site’s operating costs still further.

Savings made included:

■ 80% reduction in water use;

■ 94% reduction in effluent volumes;

■ £168,000/year from reducing wastage of raw materials;

■ £21,000/year from reducing energy use.

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A key performance indicator was the amount of water entering the site which left in the product. This increased from 12%

to 73% as a result of the changes made.

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MANAGEMENT PROGRAMME AND MANUAL

Integration with existing systems

Chemical companies often have in-house or certified quality and health and safety management systems. The

standards, ISO 9001: 2000 (Quality management systems. Requirements), ISO 14001: 2004 (Environmental

management systems. Requirements with guidance for use) and OHSAS 18001 (Occupation health and safety

management systems. Requirements) have many similarities.

■ Controlling processes and reducing waste has close links to quality and environmental management.

■ Controlling hazardous substances and releases addresses health and safety and environmental risks.

Integrating management systems can simplify operations and improve communication. However, the essential features

of each (eg Register of Environmental Aspects) need to be retained.

Procedures for running the systems can be combined in the Management Manual. Joint procedures can be written, eg:

■ purchasing with environmental and quality requirements;

■ waste management with environmental and health and safety requirements.

ISO 14001 contains a table showing the correspondence of its clauses with ISO 9001.

Integrating systems may run counter to existing company structures and it is common for an EMS to be standalone from

the outset. In this case, it is better to use a similar layout to existing management systems in case of future integration.

For pharmaceutical companies, there may be conflicts between the requirements of Good Manufacturing Practice (GMP)

and resource efficiency. GMP requires traceable raw materials, which may prevent re-use and recycling. Changes to

processes have to be re-approved.

 

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FREE TOOLS AND PUBLICATIONS

Envirowise guides

■ GG681 Reducing hazardous waste in the chemical and pharmaceutical industries www.envirowise.gov.uk/gg681

■ GG679 Resource efficiency through green chemistry (www.envirowise.gov.uk/gg679)

■ GG395 Better solvent management in speciality chemicals manufacture (www.envirowise.gov.uk/gg395)

■ GG363 Managing water use in speciality chemicals’ manufacture: a signposting guide

(www.envirowise.gov.uk/gg363)

■ GG216R Increasing product output in batch chemical manufacture (www.envirowise.gov.uk/gg216r)

■ GG120R Cost-effective vessel washing (www.envirowise.gov.uk/gg120r)

■ GG101R Cost-effective management of vacuum systems (www.envirowise.gov.uk/gg101r)

Envirowise case studies

■ CS791 Effective management and segregation reduce hazardous waste disposal costs

(www.envirowise.gov.uk/cs791)

■ CS701 Process reviews reduce hazardous waste at a pharmaceutical manufacturer

(www.envirowise.gov.uk/cs701)

Envirowise tools

■ Interactive green chemistry toolkit - includes a tutorial and self assessment spreadsheet

(www.envirowise.gov.uk/uk/Sectors/Chemicals-and-Pharmaceuticals.html)

The Carbon Trust (energy)

■ CTV012 Chemicals sector overview (www.carbontrust.co.uk/Publications/publicationdetail.htm?

productid=CTV012)

■ GIL148 Chemicals fact sheet (www.carbontrust.co.uk/Publications/publicationdetail.htm?productid=GIL148)

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Envirowise offers a range of free services including:

· Free advice from Envirowise experts through the Advice Line.

· A variety of publications that provide up-to-date information onresource efficiency, cleaner design and waste minimisation issues,methods and successes.

· Best practice seminars and practical workshops that offer an idealway to examine resource efficiency, cleaner design and wasteminimisation issues and discuss opportunities and methodologies

Envirowise - Practical Environmental Advice for Business - is a Governmentprogramme that offers free, independent and practical advice to UKbusinesses to improve their resource efficiency and increase profits. It ismanaged by Momenta, an operating division of AEA Technology plc, andSerco TTI. Envirowise is funded across the UK by Defra, the ScottishGovernment, the Welsh Assembly Government and Invest Northern Ireland.

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