June 2011

Examiners’ Report
NEBOSH Diploma in
Environmental
Management
Examiners’ Report
NEBOSH NATIONAL DIPLOMA IN
ENVIRONMENTAL MANAGEMENT
JUNE 2011

CONTENTS

Introduction 2

General comments 3

Comments on individual questions 4

 2011 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-1106 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 Education and Skills (DfES) in Wales
 The Council for the Curriculum, Examinations and Assessment (CCEA) in Northern Ireland
 The Scottish Qualifications Authority (SQA) in Scotland

Where appropriate, NEBOSH follows the latest version of the “GCSE, GCE, Principal Learning and
Project Code of Practice” 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 2011

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. Similarly the command word
‘identify’ requires more information than a ‘list’.

 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.

 Candidates should note that it is not necessary to start a new page in their answer booklet for
each section of a question.

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

Question 1 As the Environmental Adviser to a large organisation, you have decided

to develop an in-house auditing programme to assess the effectiveness
of the organisation’s environmental arrangements.

Describe the organisational and planning issues to be addressed in the

development of the audit programme.
You do not need to consider the specific factors to be audited. (20)

This popular question gave candidates an opportunity to show that they understood
the issues that arise when organising and planning an in-house auditing programme.
Although the question specifically states that specific factors to be audited are not
required, some candidates gave detailed descriptions of organisation and technical
arrangements which could be examined when undertaking an audit, such as
effectiveness of energy use, emission controls, emergency procedures etc. No credit
could be given for such matters. Candidates could have made reference to the
following:

The need to gain support and commitment from senior managers and other key
parties. Better answers made reference to briefing managers and employers on the
audit process and expected outcomes.

Consideration of logistics and resources that maybe required to support an audit

programme, including equipment required, time taken and staff resources.

Developing an audit programme that reflects the degree of risk posed and establishing
the most appropriate scale and frequency of auditing.

Defining the standards to be audited against which may have included legal
compliance, good practice or published management system standards. Better
answers included a description of the definition of a clear structure for audits, covering
the options to examine either vertical and horizontal slices or comprehensive audits.
Consideration could also have been given to the option to break audits down into
specific elements of management system standard requirements.

Establishing defined methodologies covering the key elements of an audit process:

initial planning; gathering evidence through interviews, documentation reviews and
verification checks; feedback on audit findings; reporting; corrective action definition
and follow-up.

Some candidates described the range of auditing guides that may be considered, such
as: development of specific audit protocols/questionnaires/checklists of the use of
proprietary software systems and questions. Credit was given for these issues. Better
answers also made reference to the role of scoring systems to help evaluate
performance and identify best practice and to the value of undertaking pilot audits to
test methodologies.

Developing an in-house audit team with defined roles would also be important.
Defining competence for each role and provision of training would also be worthy of
credit. Some candidates considered the need to maintain independence from areas
being audited and the value of local knowledge.

4 EXTERNAL
Question 2 (a) Outline the types of environmental impact that are likely to arise
from a major fire at a warehouse and distribution facility
containing hazardous substances. (8)

(b) Describe typical emergency response arrangements that should

be in place to minimise environmental harm arising from a fire at
the warehouse facility. (12)

Over recent years, regulators have shown particular interest in environmental risk and
control measures relevant to major fire emergencies. This question allowed candidates
the opportunity to demonstrate their awareness of environmental impacts that may arise
as a result of fire and typical response arrangements to minimise environmental harm.
This question was a popular one with many candidates.

In part (a), candidates were asked to outline the types of environmental impact that are
likely to arise from a fire at a distribution facility containing hazardous substances.

Most candidates included outlines of the potential impacts of air pollution, which would
have included reference to:

• release of harmful substances to the atmosphere and their potential human health
effects;
• release of ecotoxic substances to the atmosphere and their potential impact upon plant
and animal communities;
• release of global warming gases, ozone depleting substances, acid gases;
• release of substances which can create nuisance effects, including smoke and odour;
• fallout of polluting substances onto land, water, crops or buildings.

Many candidates also made reference to the potential escape of contaminating

substances to land leading to land contamination. Better answers also made reference to
the potential to generate large amounts of contaminated waste that would require disposal
after the fire.

Most candidates also recognised the potential impact upon water resources through
escape of polluting substances to surface water or groundwater. Better answers included
mention of the potential for polluting substances to enter foul sewers and their impact on
sewage treatment systems. A well structured answer made distinction between escaped
substances and the overall cocktail of substances that are associated with fire fighting
water runoff.

Finally, candidates could have made reference to the potential impact upon adjoining
properties through damage caused by explosion or radiant heat.

In part (b) candidates were given the opportunity to demonstrate awareness of typical
emergency response arrangements. Many answers included reference to the need for
and maintenance of emergency response plans but few identified that these should be
based upon a fire and fire water risk assessment. A well rounded answer would therefore
have addressed:

• fire and firewater runoff risk assessment;

• development and maintenance of emergency response plans;
• arrangements for fire detection, response and fire fighting;
• command and control arrangements;
• provision of emergency response equipment, including fire fighting, drain covers,
booms, absorbents and allowance for firewater containment;
• access arrangements for emergency vehicles;
• off-site emergency plans;
• arrangements for notifying relevant organisations;

5 EXTERNAL
 • arrangements for practising emergency plans through desktop rehearsals or
simulated incidents;
• the need for regular training of staff and contractors in emergency response
procedures.

Generally, most candidates performed well on this question. Some candidates were
clearly familiar with emergency response through experience of working at sites regulated
under the Control of Major Accident Hazards regime and used this a model for the
answers to part (b).

Question 3 A manufacturing company has received a cautionary letter from its waste
disposal contractor advising that several partly empty cans of highly
flammable, solvent-based floor paint have been found in a non-
hazardous waste skip at the manufacturing site.

Prepare a brief for managers of the company in order to raise awareness

of the main regulatory controls applying to flammable solvent waste and
the implications of non-compliance. (20)

There have been a number of high profile prosecutions for companies who unwittingly
allow hazardous/special waste to be consigned for disposal as normal uncontaminated
waste. Accordingly, for the situation described in the question, Examiners expected
candidates to address the main issues arising from “waste management” and not just
those specifically connected with the storage of flammable liquids. The answer was to be
written in the form of a brief designed to raise awareness of the main regulatory controls
applying to management of flammable solvent waste. Credit was therefore given for the
production of a structured answer that dealt with both the technical and liability issues.

A well structured brief should initially have highlighted the hazards and risks associated
with this situation, which include environmental pollution, harm to health and the obvious
safety hazards arising from fire and explosion. Candidates should then have gone on to
review briefly the legislation which applied together with the potential penalties for non-
compliance. The legislation should have included the Environmental Protection (Duty of
Care) Regulations 1991, and the Hazardous Waste Regulations or their regional
equivalents. The former contain requirements to prevent the escape of waste, to use only
authorised carriers, to provide written descriptions and transfer notes, and to report
offences whilst the latter include definitions together with codes and categories of waste,
set out the consignment procedures and require the segregation of hazardous/special
from other waste. Better answers also made reference to the higher costs of disposing of
waste where hazardous waste is mixed with other waste.

Failure to comply with the requirements of these Regulations may expose the company to
the risk of prosecution and marks were available for referring to the detail of the
appropriate legislation and for listing the fines and/or custodial sentences which could be
imposed. Additionally, credit was given to those candidates who highlighted and
explained the risk of personal prosecution, the adverse publicity that could follow a
prosecution, the clean up costs and the loss of accreditation under environmental
management schemes.

Candidates generally addressed the main points mentioned above with the majority of
answers referring to the potential for a wider impact on business if there was to be a
further breach of the regulations.

6 EXTERNAL
Question 4 A chemical manufacturing organisation operates under a permit issued
by the Environment Agency for a Part A (1) process under Regulations
made under the Pollution Prevention and Control Act 1999.

(a) In the case of non-compliance with the conditions of the permit

identify the enforcement options open to the Regulator AND
describe the implications of EACH enforcement option. (15)

(b) Explain the procedure to be followed by the organisation if they

want to surrender their permit. (5)

This was a popular question and many candidates gave reasonable answers to the
first part. Most candidates gave the importance of enforcement notices which are
issued in case of non-compliance with permit conditions. Such a notice states the
potential contravention, remedial steps to be taken and the period within which they
must be taken. Better answers noted that the process can be continued until remedial
steps are taken up to a time limit, beyond that the organisation commits an offence.

Also important is the role of suspension notices which are issued where there is
serious risk of or actual pollution. These notices state the potential contravention,
remedial steps to be taken and the period within which they must be taken. In this case
the permit ceases to authorise the stated activity until remedial steps are taken and the
notice is withdrawn. Unless a suspension notice is withdrawn continued operation of
the process is an offence.

In serious cases, the Regulator may serve a revocation notice which takes effect not
less than 28 days after the notice is issued. This may specify steps to be taken to
return the site to a satisfactory condition. Many candidates also outlined the options for
the Regulator to use powers to remedy pollution and recover costs from the operator.
As a last resort, the Regulators can bring a prosecution for operating without a permit
or in breach of conditions or failing to comply with a notice. Many candidates also
referred to the general scale of criminal penalties being up to £50,000 and/or 12
months imprisonment upon summary conviction or an unlimited fine and/or 5 years
imprisonment following conviction upon indictment.

Better answers also made reference to the potential for a regulator remedy pollution
and recover costs of any clean up.

Candidates who referred to improvement notices, as apply in health and safety, did not
gain credit.

The second part to the question was generally answered satisfactorily by many
candidates. The procedure for surrender involves application to the Regulator,
including payment of a surrender application fee. A site report must be submitted
which identifies any changes in condition of the site from those reported at the time of
application. The Regulator then has 3 months to consider the application and if
satisfied may issue a notice to allow surrender. If not satisfied they may serve a notice
stating steps to be taken to return the site to satisfactory condition prior to surrender.

Question 5 Describe how environmental modelling can be used to assess risk

arising from the release of a pollutant substance into the environment. (20)

This question asked candidates to describe how environmental modelling can be used to
assess risk in the context of release of a pollutant substance. Although this was not a
popular question, the candidates that responded to it mainly focussed on air pollution
modelling as a relevant example.

7 EXTERNAL
 Well structured answers used the source-pathway-receptor relationship. Starting at the
source, it would important to establish, through prediction or measurement, the rate of
release of the pollutant into the environment. Most answers included reference to the role
of efflux velocity and concentrations to gain mass emission rates. Once released into a
pathway, there are many relevant factors that influence how a pollutant behaves. Most
answers included the need for consideration of weather, wind speed, river flow,
turbulence, buildings/structures, surface roughness or other factors that affect dispersion.
A few answers described additional factors that may affect the concentration of the original
pollutant and its chemical or physical form, such as reference to chemical reactions,
sedimentation, adsorption and biodegradation. The role of models to predict how the
substance disperses through the environment using a dispersion model or similar also
gained credit.

The importance of establishing existing background levels of the pollutant in the

environment was also creditworthy. Linking this to the predicted dispersion then allows
the dose to vulnerable receptors to be predicted. Better answers included the need to
establish levels above which the receptors would be harmed through dose-response
relationships, such as the relevance of environmental assessment levels (EAL),
environmental quality standards and the concept of predicted no effect concentration
(PNEC). Using modelling results to estimate additional exposure due to release over
existing levels and compare against Environmental Assessment Levels/PNEC would then
allow the extent of risk to be estimated. A well rounded answer would also have included
mention of the potential for bioaccumulation and the importance of understanding potential
for persistence.

Question 6 (a) Identify the chemical, physical and biological characteristics of

water pollutants. (6)

(b) Describe the main effects caused by discharge of water

pollutants into surface waters. (14)

This question was designed to assess candidates awareness of the properties that
water pollutants may have and the main effects that they may cause. Some
candidates found it difficult to distinguish between the properties and their effects.

In part (a) a good answer would have included a range of chemical, physical and
biological characteristics. Chemical characteristics could have included for example :
salinity, pH, biochemical oxygen demand and chemical oxygen demand, nutrients,
odour and taste. Physical characteristics may include: turbidity due to suspended
solids, colour, surface characteristics (floating films, foam, etc), temperature or
radiation. Biological characterises include: presence of bacteria / viruses.

In part (b), a good description of the main effects of pollutants when discharged to
surface waters would have included reference to:

 oxygen depletion;
 toxicity and ecotoxicity to plants, aquatic organisms, animals/birds or man;
 eutrophication associated with nutrients;
 infection risks associated with pathogenic substances;
 sedimentation leading to changes in flow;
 reduce light penetration and harm to plants;
 nuisance effects and the impact on downstream users and;
 coating of feathers on birds from floating contaminants.

8 EXTERNAL
 Better answers included reference to the potential effects arising from persistent
pollutants, potential for bioaccumulation and possible interactions / reactions with other
pollutants.

Question 7 Outline factors that have influenced the development of environmental

law in the UK since the second half of the 20th century AND give
examples to support your answer. (20)

This question required candidates to give an outline of factors that have influenced the
development of UK environmental law. This was a relatively popular question and of
those candidates that did attempt it many managed to outline the most important
factors, which would have included:

• development of prescriptive legislation in response to specific local environmental

problems and driven largely by public concerns. This factor could have been
illustrated by reference to examples such as Alkali Acts, Clean Air Acts, Public
Health Acts, Deposit of Poisonous Waste Act or many other similar enactments.

• tendency towards greater use of framework Acts which develop general pollution
control/prevention principles. Examples that could have been quoted included,
amongst others, the Control of Pollution Act, the Environmental Protection Act, the
Water Resources Act, or the Wildlife and Countryside Act.

• greater importance given to global and transboundary issues driven by greater

scientific understanding of environmental pressures. The role of international
treaties, conventions and protocols, particularly where issues affect global
commons, would have deserved particular mention. Examples that could have
been used would include the Montreal Protocol, Berne Convention, Kyoto Protocol
or many other suitable alternatives.

• the European Union’s influence through its thematic strategies on waste, water,
soil, or wildlife and the associated Directives and Regulations is also an important
factor. Many possible examples were available to illustrate the role of the EU.

• the second half of the 20th century has seen huge advances in communication.
The role of increased public and political awareness through improved public
education, prominence of coverage in the media or through documentaries would
certainly be a relevant factor, as would the special role played by environmental
pressure and special interest groups.

Question 8 Describe the air pollution control hierarchy AND give suitable practical
examples for EACH stage. (20)

This question was unpopular with candidates, with few attempting it. Of those that did
some managed to confuse the hierarchy of air pollution control with the waste
hierarchy and so struggled to make this relevant to air pollution control.

Most candidates did mange to describe the importance of elimination by for example:
contracting out to specialists; stopping processes; changing processes; or changing
materials. Typical examples included eliminating solvent in paint, buying in power or
dip coating rather than spraying.

Substitution is also an important option in the hierarchy. Replacement of one

substance with another that is less damaging in its effects would be worthy of mention
as would using substances less prone to causing emissions. Processes could also be
changed for ones with less potential for pollution. Suitable examples would have

9 EXTERNAL
included: changing fuel; using less volatile solvent; or using pellets rather powdered
raw materials

Reduction of releases into the environment would be viable options, through for
example: reducing quantities used/emitted; reducing length of process times or
running process less frequently; or through better process management - e.g.
temperature, ventilation rate. Examples may have included: lowering process
temperature to reduce vapour emissions, reduce LEV extraction rates, or putting lids
of containers.

Finally, air emissions that can not be avoided or reduced to acceptable levels using
the above could be controlled through the use of emission control devices, or by
ensuring adequate dispersal in the environment by ensuring adequate stack gas
velocities, chimney height etc. Most candidates used several types of air pollution
control devices to illustrate this part of the hierarchy, such a bag filters, scrubbers, etc.

10 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