December 2009

Examiners’ Report
NEBOSH National
Diploma in
Environmental
Management
Examiners’ Report
NEBOSH Diploma in
Environmental Management
DECEMBER 2009

CONTENTS

Introduction 2

General comments 3

Comments on individual questions 4

© 2010 NEBOSH, Dominus Way, Meridian Business Park, Leicester LE19 1QW
tel: 0116 263 4700 fax: 0116 282 4000 email: info@nebosh.org.uk website: www.nebosh.org.uk

The National Examination Board in Occupational Safety and Health is a registered charity, number 1010444

T(s):exrpts/E/ED-0912 EXTERNAL SS/DW/REW

 Introduction
Introduction

NEBOSH (The National Examination Board in Occupational Safety and Health) was formed in 1979 as
an independent examining board and awarding body with charitable status. We offer a
comprehensive range of globally-recognised, vocationally-related qualifications designed to meet the
health, safety, environmental and risk management needs of all places of work in both the private and
public sectors.
Courses leading to NEBOSH qualifications attract over 25,000 candidates annually and are offered by
over 400 course providers in 65 countries around the world. Our qualifications are recognised by the
relevant professional membership bodies including the Institution of Occupational Safety and Health
(IOSH) and the International Institute of Risk and Safety Management (IIRSM).

NEBOSH is an awarding body recognised and regulated by the UK regulatory authorities:

• The Office of the Qualifications and Examinations Regulator (Ofqual) in England

• The Department for Children, Education, Lifelong Learning and Skills (DCELLS) in Wales
• The Council for the Curriculum, Examinations and Assessment (CCEA) in Northern Ireland
• The Scottish Qualifications Authority (SQA) in Scotland

NEBOSH follows the “GCSE, GCE, VCE, GNVQ and AEA Code of Practice 2007/8” published by the
regulatory authorities in relation to examination setting and marking (available at the Ofqual website
www.ofqual.gov.uk). While not obliged to adhere to this code, NEBOSH regards it as best practice to
do so.

Candidates’ scripts are marked by a team of Examiners appointed by NEBOSH on the basis of their
qualifications and experience. The standard of the qualification is determined by NEBOSH, which is
overseen by the NEBOSH Council comprising nominees from, amongst others, the Health and Safety
Executive (HSE), the Confederation of British Industry (CBI), the Trades Union Congress (TUC) and
the Institution of Occupational Safety and Health (IOSH). Representatives of course providers, from
both the public and private sectors, are elected to the NEBOSH Council.

This report on the Examination provides information on the performance of candidates which it is
hoped will be useful to candidates and tutors in preparation for future examinations. It is intended to
be constructive and informative and to promote better understanding of the syllabus content and the
application of assessment criteria.

© NEBOSH 2010

Any enquiries about this report publication should be addressed to:

NEBOSH
Dominus Way
Meridian Business Park
Leicester
LE10 1QW

Tel: 0116 263 4700

Fax: 0116 282 4000
Email: info@nebosh.org.uk

2 EXTERNAL
 General comments

Many candidates are well prepared for this unit assessment and provide comprehensive and relevant
answers in response to the demands of the question paper. This includes the ability to demonstrate
understanding of knowledge by applying it to workplace situations.

There are always some candidates, however, who appear to be unprepared for the unit assessment
and who show both a lack of knowledge of the syllabus content and a lack of understanding of how
key concepts should be applied to workplace situations.

In order to meet the pass standard for this assessment, acquisition of knowledge and understanding
across the syllabus are prerequisites. However, candidates need to demonstrate their knowledge and
understanding in answering the questions set. Referral of candidates in this unit is invariably because
they are unable to write a full, well-informed answer to one or more of the questions asked.

Some candidates find it difficult to relate their learning to the questions and as a result offer responses
reliant on recalled knowledge and conjecture and fail to demonstrate a sufficient degree of
understanding. Candidates should prepare themselves for this vocational examination by ensuring
their understanding, not rote-learning pre-prepared answers.

Common pitfalls

It is recognised that many candidates are well prepared for their assessments. However, recurrent
issues, as outlined below, continue to prevent some candidates reaching their full potential in the
assessment.

− Many candidates fail to apply the basic principles of examination technique and for some
candidates this means the difference between a pass and a referral.

− In some instances, candidates are failing because they do not attempt all the required
questions or are failing to provide complete answers. Candidates are advised to always
attempt an answer to a compulsory question, even when the mind goes blank. Applying basic
health and safety management principles can generate credit worthy points.

− Some candidates fail to answer the question set and instead provide information that may be
relevant to the topic but is irrelevant to the question and cannot therefore be awarded marks.

− Many candidates fail to apply the command words (also known as action verbs, eg describe,
outline, etc). Command words are the instructions that guide the candidate on the depth of
answer required. If, for instance, a question asks the candidate to ‘describe’ something, then
few marks will be awarded to an answer that is an outline.

− Some candidates fail to separate their answers into the different sub-sections of the
questions. These candidates could gain marks for the different sections if they clearly
indicated which part of the question they were answering (by using the numbering from the
question in their answer, for example). Structuring their answers to address the different parts
of the question can also help in logically drawing out the points to be made in response.

− Candidates need to plan their time effectively. Some candidates fail to make good use of their
time and give excessive detail in some answers leaving insufficient time to address all of the
questions.

− Candidates should also be aware that Examiners cannot award marks if handwriting is
illegible.

3 EXTERNAL
 Examination paper – five from eight questions to be attempted

Question 1 (a) Identify how manufacturing activities may contribute to causing

the phenomenon known as the ‘Greenhouse Effect’. (14)

(b) Explain how the technique of life cycle analysis may be used to
understand the extent to which a manufactured product
contributes to the Greenhouse Effect. (6)

This question was designed to explore candidates awareness of the ways in which
manufacturing activities may contribute to the “Greenhouse Effect” and how Life Cycle
Analysis could be used to better understand the extent of any impact.

Some candidates did reasonably well on the first part of the question. However many
candidates limited the scope of their answers to a few of the relevant effects and
hence limited the marks that were available. Examples of the types of activities
identified included:

Direct effects

− Release of greenhouse gases (GGs) to the atmosphere; including carbon dioxide,

nitrous oxide, methane, water vapour, F gases, and many others;

− Emission of GGs from on-site energy generation from fossil fuels;

− Emission of GGs from transportation systems, including both haulage and

employee work related transport;

− Process emissions of GGs;

− Services emissions of GGs including leakages from refrigeration/cooling systems;

− Changes to GG sinks.

Indirect effects

− Use of electrical energy generated from fossil fuels at powers stations;

− Methane emissions from degradation of biodegradable wastes;

− Emissions caused by others in making products used in manufacturing;

− Emissions from cement manufacture for buildings etc;

− Removal of environmental sinks; forests, peat, soil.

Many candidates faired less well on the second part to the question. Most restricted
their answers, and hence marks available, to a simple description of the main stages
of a Life Cycle Analysis (LCA) but without giving an explanation of how this technique
could be used to understand the extent to which a manufactured product contributes to
the Greenhouse Effect. LCA is a powerful technique that traces burdens of emissions
arising from a product from cradle to grave. The preparation of an inventory analysis
includes quantifying releases of GGs at each stage in this life cycle.

4 EXTERNAL
 By interpreting the inventory, the magnitude of total contributions of releases at any
stage of the product life cycle can be understood. Exceptional answers made
reference to the relevance of this to the preparation of detailed carbon footprints or
their equivalent.

Question 2 Outline reasons why many waste producers are seeking to minimise the
use of landfill as a disposal route for their industrial and commercial
waste streams. (20)

Landfill is declining in importance as a disposal route for many household, commercial

and industrial wastes. This question allowed candidates to demonstrate their awareness
of the main reasons for this decline.

Some candidates identified that there are concerns over the effect that landfilling may
have on the environment, which may include:

• impact on global warming due to the emission of methane and CO2;

• local and global air pollution effects of landfill gases, CFCs etc;
• health and safety concerns, particularly migration of methane gases;
• potential for nuisance, including odour, litter, vermin and scavengers;
• water pollution, particularly groundwater contamination from leachates.

There are also natural resource concerns, such as:

• burying materials that could be recovered or recycled;

• land required for landfilling and restrictions on what completed sites can be used for;
• restricting development of land due to concerns about health, safety and
environmental issues for buildings near to landfill sites;
• environmental and local protest groups.

For many waste producers cost factors are of growing importance. Landfill tax is
progressively making landfill less competitive to its alternatives and high operational costs
due to tighter regulation of landfills have increased prices for landfilling waste. The pattern
of consolidation into fewer, larger sites means greater transport distances to reach
sites. For some wastes, there are restrictions on disposal (liquids, hazardous wastes etc).
The development of new sites is limited due to the difficulties in obtaining planning
permissions. On the other hand recycling/reuse can yield income or significantly reduced
costs compared to landfill.

Many producers of waste have concerns over the longer term liability issues where waste
is incorrectly disposed of. For organisations holding ISO14001, there is pressure to seek
low waste systems, greater recovery of waste, recycling and other disposal options (such
as anaerobic digestion), energy recovery, etc. Many organisations are affected by
producer responsibility schemes that favour recovery of waste rather than disposal.

Finally some candidates made reference to the effect of the Landfill Directive in restricting
biodegradable waste disposal and requiring that waste to landfill must be subject to pre-
treatment in many cases. Exceptional answers outlined the requirements that for
construction and demolition waste, this must now be dealt with by recycling/recovery
where possible under the Site Waste Management Plan provisions.

Despite this choice of issues, many candidates limited the marks available to them by
outlining only a small number of reasons why producers are minimising waste to landfill.

5 EXTERNAL
Question 3 A manufacturing organisation uses large quantities of organic solvents
for degreasing metal products.

Outline the range of measures that could be adopted to minimise

emission of organic solvents to the atmosphere. (20)

This question sought to examine candidates’ knowledge of the range of control measures
that are appropriate for minimising emissions of solvents. Many candidates realised the
obvious value of the hierarchy of control measures and used this as a structure for their
answers. The significance of elimination and substitution as appropriate measures was
identified in many answers. Better answers also considered technical measures that may
be used in design of process to ensure minimisation through: process temperature control;
physical containment to limit evaporative losses; minimising air flows; and process
temperature control.

The use of emission control devices would also be important for residual solvent releases.
A few candidates gave brief mention to examples of types of devices that are appropriate
to control of solvents, which can include: adsorption; absorption; thermal
treatment/incineration; biological treatment and condensation.

An outline of behavioural measures such as appropriate training/education would also

have gained marks. Further marks would have been gained by reference to relevant
procedural measures, including the importance of maintenance and systems for handling
solvents.

Question 4 Describe the measures an organisation could take to minimise adverse

impacts on plant and animal communities (biodiversity). (20)

This question was reasonably popular and many candidates gave answers which
included both ways of minimising adverse impacts but also highlighted positive
measures for encouraging wildlife and enhancing habitats to offset any adverse
impacts that may occur. Better answers covered the following areas:

• Purchasing timber from sustainably managed sources - FSC certification was

commonly mentioned;
• Purchasing supplies and raw materials from accredited sources;
• Minimising disruption of habitats and species during development of land and
premises;
• Habitat creation in landscaping schemes and use of native species of value to
wildlife;
• Control of water abstraction activities to ensure that water resources are
maintained;
• Adoption of sustainable urban drainage system practices to provide new aquatic
and marginal habitats;
• Provision of facilities to encourage wildlife (eg bird boxes, bat roosts);
• Control of releases to the environment (air, water or land) that could impact upon
wildlife;
• Control of noise, light etc that may disturb wildlife;
• Avoiding release of non-native species (particularly invasive species);
• Appropriate use of pesticides, fertilisers etc;
• Containment of waste to prevent escape;
• Funding/participation in environmental projects;

6 EXTERNAL
 • Education/information to increase awareness of wildlife;
• Provision of emergency response resources to minimise harm to wildlife from
incidents.

Better answers also made brief reference to the benefits to be gained by adoption of
policies to promote biodiversity and the application of Biodiversity Action Plans.
Exceptional answers would have referred to the importance of monitoring the health of
wildlife populations, possibly using bio indicators.

Question 5 (a) Explain what is meant by the terms:

(i) ‘water quality standard’; (4)

(ii) ‘water quality objective’. (4)

(b) Using a suitable example, explain how a company can use

biological indicators to determine whether an effluent discharge
into a river could have a deleterious effect on the ecological
balance within the receiving water. (12)

Regulation and protection of water quality in the UK is based on the requirements of

various EU Directives which require control over ‘dangerous’ substances in the water
environment and also ensure that water is fit for specified purposes.

Water quality standards (WQS) derive from the EC Directive on pollution caused by
certain dangerous substances. These are commonly referred to as Black List and Grey
List, or List I and List II substances. They set down limits in concentration of specified
dangerous substances allowed in discharges to controlled waters. A company wishing to
discharge effluent containing such substances will face considerable hurdles in gaining
consent and tight limits on the amounts that can be released to ensure that the WQS limits
are not exceeded.

Water quality objectives (WQO) are a system for classifying waters according to their
actual or potential use, again deriving from a range of EU Directives. They set down limits
or relevant substances or quality criteria based on the use that water is to be put to. There
are EU Directives specifying what objectives should apply for specified uses such as
bathing water, shellfish, drinking water abstraction etc.

Biological indicators refers to a range of techniques that use living organisms with known
susceptibility to the effects caused by a polluting activity or condition. Exposure of
organisms to harmful concentrations results is changes in the indicator organism or
population of organisms which can be measured and used to assess the likely impact that
a discharge may have upon the aquatic environment in a receiving water. The principle is
used in direct toxicity testing of complex effluents to determine whether their overall toxicity
is such as to harm biological quality of receiving water. There are a number of different
test organisms that are commonly used, such as bacteria, oyster embryos, fish, algae etc.
It may also be used by making use of naturally occurring populations of organisms in a
river environment and tracking the numbers and distribution of species over time to detect
possible deleterious effects.

This question was less popular among candidates. Some provided good descriptions of
both WQSs and WQOs and then went on the explain biological indicators with a suitable
example. Other candidates appeared to be confused about the differences between
WQSs and WQOs and did not generally refer to their derivation from EU Directives.
Similarly, explaining the concept of biological indicators also caused some candidates
difficulties and the examples that were given appeared to have been based largely on
guess work.

7 EXTERNAL
Question 6 Describe appropriate performance indicators that may be used to
measure an organisation’s environmental management performance
illustrating your answer with suitable examples. (20)

Many organisations now have in place systems of performance indicators (often

referred to as Key Performance Indicators). Candidates could have chosen from a
wide variety of such indicators, including such measures as:

• Incident frequencies;
• Near miss frequencies;
• Emissions to atmosphere;
• Waste generation and recycling rates;
• Water use;
• Discharges to surface water or sewer;
• Energy use;
• Noise emissions;
• Transport/travel emissions;
• Carbon dioxide emissions;
• Raw material use;
• Complaints.

Better answers also made reference to enforcement actions and adherence to

compliance standards. A few candidates also identified the value of audit findings,
particularly where scoring systems are in place.

Question 7 Describe the different pathways through which contaminated land may
affect human and other environmental receptors. (20)

The presence of contamination on or in land may adversely affect people and the
environment through a number of different pathways. This question was designed to
allow candidates to demonstrate that they understood how contamination might
contribute a risk if a suitable pathway links a source to a receptor. Examples of
pathways that could have been described included the following:

• Leaching and washing into surface waters giving rise to pollution in rivers, streams
and other surface water bodies and possible subsequent abstraction for drinking
water or causing direct harm to fish and other aquatic organisms;
• Vertical migration into groundwater and subsequent recharge into surface waters
or exposure following abstraction;
• Migration of flammable, toxic and asphyxiant gases through soils and natural
fissures leading to inhalation or explosion risk;
• Migration through soils and into drinking water supply systems through plastics
pipes and mastics;
• Direct uptake of contaminants by crops and subsequent ingestion by animals and
people;
• Direct contact with contaminated soils and possible ingestion, particularly by
children and site workers;
• Dust blow from the surface containing hazardous substances leading to inhalation
or deposit on food or land;
• Migration through and into building materials leading to their degradation;
• Escape of gases and vapours from the land leading to odour nuisance;
• Land stability effects leading to subsidence and landslip;

8 EXTERNAL
 • Exposure to radiation;
• Combustion of flammable materials in the ground leading to a range of potentially
serious environmental and safety risks.

Answers to this very popular question were generally of a good standard. Most
candidates identified water pollution pathways and inhalation and ingestion of dust.
Better answers also identified some of the other possible routes.

Question 8 Residents claim that dust emanating from a nearby waste transfer station
is damaging their property.

Describe the main grounds for action under civil law that might be
available to the residents. (20)

This question was designed to test candidates’ understanding of the civil remedies
that are available for environmental nuisance and pollution. Many candidates who
attempted this question gave good answers which provided a description of the main
routes through which redress could be sought. These concern the civil torts of
negligence, nuisance, the rule in Rylands and Fletcher, trespass and breach of
statutory duty.

For claims under negligence to succeed, the plaintiffs (residents) would need to
establish proof of causation and proof of harm. They would then need to demonstrate
that they were owed a duty of care (as neighbours), that the duty had been breached
in that the factory owner had not done all that was reasonably practicable to prevent
foreseeable harm and that the breach led directly to harm.

Nuisance comprises both public and private nuisance. Good answers made reference
to the need to demonstrate that there had been unreasonable interference with the
use and enjoyment of land, taking into account issues such as sensitivity and the
general character of the neighbourhood.

A claim for damages under the tort of breach of statutory duty could be made, where it
must be shown that a statutory breach had led to damage and where the statute does
not specifically disallow such an action. In practice, in using this action many plaintiffs
would pursue a double-barrelled action of negligence and breach of statutory duty.

The common law doctrine developed in the case of ‘Rylands and Fletcher’ imposes
strict liability for the escape of things likely to cause foreseeable harm. The relevance
of the doctrine in this question was picked up in the better answers.

Trespass require deliberateness and directness. If it could be shown that the transfer
station had deliberately caused the dust to spread over neighbours' property, an action
may be justified, but this may prove difficult to establish.

A small number of candidates struggled to differentiate between the concepts of

nuisance and negligence. As in many situations where previous examination questions
have clearly required consideration of civil law, in responses to this question some
candidates strayed into the realms of statutory powers of local authorities to serve
notices in the case of a statutory nuisance. These powers are not civil remedies and
cannot be given credit by the Examiners.

9 EXTERNAL
The National Examination
Board in Occupational
Safety and Health

Dominus Way
Meridian Business Park
Leicester LE19 1QW

telephone +44 (0)116 2634700

fax +44 (0)116 2824000
email info@nebosh.org.uk
www.nebosh.org.uk