WASTE RECYCLING
How an EMS can protect waste site
operators from the effects of COVID-19 By WESTBURY ENVIRONMENTAL LTD
NO, an Environmental Management System (EMS) cannot act as a vaccine, but a good EMS really could help waste site operators get through these difficult times.
COVID-19 has had a global impact, brought cities to a virtual standstill and changed our day-to-day lives. However, the Environment Agency (EA) will still regulate permit holders and act to protect the environment.
Social distancing requirements and the fact that many EA officers are working from home means that far fewer site visits are being undertaken by the EA. I’m sure waste site operators won’t see this as a problem! However, many operators are experiencing problems due to the impacts of COVID-19.
I want to highlight just two of these problems and suggest how implementing a robust EMS could help:
Build up of waste on site due to the inability to process / remove it
This could cause a breach of your permit conditions, an increased fire risk, cross contamination of waste, etc. The EA have responded by releasing a Regulatory Position Statement (RPS) that applies to the temporary exceedance of
20
waste storage limits due to COVID-19 restrictions. Basically, if you exceed your storage limit and comply with all the requirements of the RPS then the EA will not normally take enforcement action against you. Your EMS documentation will be essential in demonstrating to the EA that you have complied with the conditions of the RPS.
No ‘Technically Competent Management’ on the site
This may be due to the inability of managers to complete their Continued Competence tests; they may be furloughed, in self-isolation or otherwise not able to attend the site. As part of the EA guidance it is stated that in the absence of a TCM, “the operator should be able and capable of operating the plant or site through both their EMS and operations training”.
An EMS should reflect the complexity of the waste operation / site. Lower risk activities will have simpler EMS’s than higher risk activities. Gone are the days where an old Working Plan would suffice. All EMS’s should contain a number of documents including Environmental Risk Assessments, Emission Management Plans, drawings, process flow information etc. and procedures. Documented assessments and plans can be difficult, if
not impossible to implement. Therefore, the EMS should bring together all the requirements of these documents into procedures. These procedures should be brief and instructional and may be associated with records that are kept to evidence the implementation of the procedure.
Records are also required to evidence the training of staff on the procedures. I recently had a case where an operator was given a non-compliance score by the EA due to not having training records despite having a good EMS.
How we can help
We can provide you with guidance on the development of your EMS or simply take care of the whole process for you. There is no generic template involved; each EMS is as unique as the sites and operators are. We can provide training on the implementation of the EMS. Not face- to-face of course at the moment but as I type, we are creating online content on this very subject. Training which even furloughed staff can benefit from.
Please see our website for further details or contact us for a chat.
01952 879705
www.westburyenv.co.uk
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