MARCO MUIA: DIRECT AND TO THE POINT
www.oaktree-environmental.co.uk
Peeking over a rival’s shoulder for clues will help you successfully compile a document
THIS time three years ago I expressed surprise that regulators were fi nally reading operator’s environmental management systems (EMS). This was because the documents had become more intrinsically linked to newer permit conditions, particularly in England and Wales. The ‘new’ permit conditions have been around much longer than many realise, as standard-rule permits were introduced in 2008 and the general management condition has been adopted as standard in bespoke permits too. However, little has changed over the last 10 years. So it should be of no surprise site inspectors are using an operator’s documents to fi nd fault, where they would previously have done so by referring to permit conditions. Below are advice points to follow to avoid points on your inspection form, and if we look at one of the most common standard rules sets (2008 No.3: HCI transfer station with treatment) the fi rst condition reads as follows: ‘The operator shall manage and operate the activities: (a) In accordance with a written management system that identifi es and minimises risks of pollution, including those arising from operations, maintenance, accidents, incidents, non- conformances, closure and those drawn to the attention of the operator as a result of complaints. (b) Using suffi cient competent persons and resources. Records demonstrating compliance with rule 1.1.1 shall be maintained. 1.1.3 Any person having duties are – or may be aff ected by – the matters set out in these standard rules shall have convenient
access to a copy of them at (or near the place) where those duties are carried out. 1.1.4 The operator shall comply with the requirements of an approved competence scheme.’ Make the following your to-do list over the next month, and do not wait until the EA or NRW come knocking. Give the task to someone in your offi ce to review the EMS and associated risk assessments and keep them up to date, even if they have been prepared by a consultant. In particular, make changes as required when you have investigated any accidents, incidents or complaints, and use feedback to critically review your EMS. Make sure each change has a revision date and version number to avoid confusion. When you have an inspection, make sure your regulator is working to the same version as you. Check any new documents - such as management prevention plans - do not contradict procedures in the main EMS. Keep an on-site folder of all up-to-date management documents so that staff have access to them. Not all staff need an intimate knowledge of the EMS and permit but should at least be able to refer to them as necessary. Train your staff in the EMS requirements relevant to their job and keep a record of the training. Keep completed records required by the EMS, remove unnecessary records or procedures and check you are following your written procedures. Employ a technical manager with the correct level of competence and make sure they have the resources to check compliance on site, then rectify any breaches. Operators also have to review measures taken to comply with the waste hierarchy
MARCO MUIA
MARCO Muia BSc (Hons) MSc MCIWM is a Director of Oaktree Environmental Limited and a respected industry professional.
He specialises in all aspects of waste planning and regulation consultancy. Waste expert Marco also holds the level 4 COTCs for Hazardous Waste
30 SHWM October, 2018 Treatment and Transfer, and is available for consultation.
You can contact Marco on: 01606 558833. If you have any questions about this article or want advice, e-mail him via:
marco@oaktree-environmental.co.uk
www.skiphiremagazine.co.uk
every four years. This is simple to do and can be recorded on an internal memo. If your site activities give rise to pollution from noise, vibration, dust, or odour then you will have to prepare a management plan for the relevant pollutant. Having procedures in your EMS to monitor, record and manage these issues could help prevent the cost of having to prepare a very detailed plan.
Guidance is available to assist with preparation of an EMS on
gov.uk (for England) under the title: Develop a management system: environmental permits.
Remember the EMS is your document. It must be site specific, which will also help you deal with your regulatory officers, as it will educate them about your site and procedures. It is not their job to tell you how to write an EMS, but a poor document will result in offi cers pointing out the defi ciencies. The cost of maintaining your EMS is much lower in the long run than gaining unnecessary scores on your site inspection compliance assessment report (CAR), which pushes up fees and charges. The cost of a third-party review of your EMS may be worth undertaking to check it covers all issues suffi ciently and will be cheaper than having someone draft the whole document. Don’t copy other EMS documents wholesale as some sections will not be relevant to your site. It is still worth looking at other sites’ documents, where available, as they may provide ideas about the content for your own document.
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