Environmental Management Overview

Index
Chapter 1. Introduction

2. Pollution

3. Legislation Overview

4. Environmental Standards

5. Environmental System Implementation

6. Glossary
 Chapter 1

Introduction

Chapter 1

Introduction
 1. Environmental Management

2. Commitment

Environmental Management

Precisely what is “environmental management ‘? In its most basic form it is how an

organisation controls its impact upon the environment. The activities, processes and products
of every organisation have an interaction of some sort with the environment be they adverse
or beneficial. While most organisations practice some form of environmental management,
the common one being the efficiency with which they use energy, there are potentially huge
benefits to be gained by mere aggressive environmental management.

In general no organisation can be totally ‘environmentally friendly’, its activities have some
form of environmental impact. One of the fundamentals of an environmental management
system is the improvement of environmental performance, and here it defers dramatically
from a quality system. A quality system that ensures the customer always receives what they
require would probably be considered perfect, and there would be no reason to improve upon
the performance of the organisation.

The motivators behind environmental management are moral, ethical, and national and
international legislation. There are obvious marketing benefits which can be gained by
promoting a caring environmental image, but there are a series of guidelines which must be
adhered to even here in matters of advertising and product labelling.

All organisations must comply with regulations and legislation. Unfortunately, compliance is
made difficult by the volume, complexity, and ever changing status of current legislation.
The divisions in accountability between the various regulatory bodies responsible for
ensuring compliance does not help either.

Environmental law is only partly prescriptive because it mainly requires organisations to

demonstrate specific management behaviour. This implies training of personnel and the
existence of procedures to follow. In this ISO 14001 is becoming the common model for the
control of environmental activity. With legislative requirements becoming increasingly
onerous, conformance to an environmental standard can pre-empt the impact of the
legislation. While undertaking environmental audits and environmental risk assessment can
identify potential areas of risk, which have growing implications in obtaining insurance and
securing investment funding.

Environmental management is not a stand alone activity, it encompasses all the things an
organisation does. We have quality management systems to control the quality of our service
or product, we also have health & safety requirements to address. It would be sensible then,
to combine these and operate a single management system. Realistically while this is an
excellent final objective, it is considered a while down the road by many organisations.

Current legislation has introduced a ‘duty of care’ requirement, where individual directors
and employees are liable for failing to comply, this could mean imprisonment and or heavy
fines. The advantage of taking a pro-active rather than a reactive are obvious; this is where an
environmental management system comes in, ISO 14001 addresses a prevention approach. It
does not lay down any specific environmental performance criteria, but provides a
framework within which environmental policies and objectives can be set. Also a basis on
which organisations can assure themselves of compliance with their environmental policies
and objectives.

To summarise, environmental management should:

Allow the most effective environmental and commercial options to be identified

Have procedures in place to help ensure compliance with legislation

 Have a built in mechanism for continual performance improvement

Allow advantage to be taken of changing market demands.

Commitment

There is a schematic diagram of the stages in the implementation of an EMS model in ISO
14001, the first box is named Senior Management Commitment! A standard cry is ‘we need
top management commitment if we are to achieve this, strange, is it not, when it is top
management’s job to review the issues affecting their business, decide on policy and strategy,
and commit their staff.

There has to be commitment to setting targets, commitment to carry through the changes
required to achieving those targets and commitment to allocate the necessary resources.
Environmental performance is not just about adhering to legislative limits, this is only one
element in what must be integrated environmental management, effecting all the
organisation’s activities. At a very minimum, these activities will include marketing, product
or service design, purchasing, process, planning and operation, packing and distribution, even
finance.

Environmental issues are complex and need to be addressed in a style which is sympathetic
to the culture of the organisation. Some environmental initiatives will require significant
changes to working practices; others, while appropriate from the environmental standpoint,
will always be popular. Support for implementation of an environmental management system
is a crucial part of commitment.

There are also the moral and ethical issues, quite apart from national and international
legislation. How is the organisation’s environmental commitment seen in the market place?

Environmental policy and behaviour questions are appearing on supplier approval

questionnaires. To do business with many large companies, you must have some level of
environmental credibility.

A broad and integrated approach has to be taken to environmental management, the

organisation has to be in the position to establish an effective environmental management
system. Effective from the point of view that it minimises the organisation’s environmental
impact and places it in a position to take advantage of opportunities open to it.
 Chapter 2

Pollution

Chapter 2

Pollution
1. Air Pollution
Introduction
Monitoring and measuring
Abatement and reduction
 2. Water Pollution
Introduction
Pollution Types
Measurement
Treatment and disposal

3. Land Pollution
Introduuction

4. Waste Disposal

1 Air Pollution

Introduction

The atmosphere is made up of a collection of natural constituents many of which we call

pollutants. These gases, such as hydrocarbons, nitrous oxides and sulphur dioxide, only
become pollutants when they begin to have an effect on the environment or health. The rapid
growth of bothe population and industrialisation have overloaded the ecosystem and negated
its natural assimilative properties. This trend is now considered to be irreversible, but with
controls and management it should be possible to limit damage and attain some level of
restoration.
Air pollutants exist either in gaseous or particulate form. They are measured on a
mass/volume basis (ug/m3) or a volume/volume basis(ppm). Sulphur oxides, nitrogen oxides,
ozone, carbon monoxide, hydrocarbons and volatile organic compounds (VOCs), tend to be
the major gaseous pollutants with widespread or global effects. Particulate pollutants are
either organic or inorganic. Organic substances are those containing carbon, while inorganic
substances are those which do not contain carbon. Particulates include dust, smoke, soot,
metal oxides, etc., and vary from less than 0.01 um to greater than 100 um in diameter. The
smaller particulates grow rapidly in the atmosphere through the process of coagulation. The
larger particulates settle out under the action of normal gravitational forces. Those with a
diameter smaller than 2 um are from man-made ( anthropogenic) sources such as lead from
motor vehicles. Particulates larger than 2 um are generally of natural origin, such as salt from
the oceans.

Smoke, grit, dust, fume and aerosol are other air pollution terms. Smoke refers to the fine
carbonaceous particles and small droplets that are discharged as a result of the incomplete
combustion of fossil fuels, wood, and other carbonaceous materials. Smoke is also taken to
include soot, ash, grit and gritty particles in smoke. Grit is defined as particulates greater than
75 microns in diameter with an upper diameter of 500. Particles with a greater diameter than
500 microns are unlikely to become air-borne. Dust is defined as particulates in the range of
1 to 75 microns, and fumes refers to particles with a diameter of less than 1 micron. Aerosol
is a colloidal dispersion of solid or liquid particles in a gas, smoke, or fog.

Carbon Compounds

The main carbon compounds are carbon dioxide and carbon monoxide. While carbon dioxide
is inert and does not have any health effects, carbon monoxide is a poison and kill at
relatively low concentrations. Both are products of combustion of organic matter, but carbon
monoxide is not a major concern as it readily oxidises to carbon dioxide in air.

Carbon dioxide is a minor component of air and inert. However rapid industrialisation has
steadily increased the concentrations of carbon dioxide in the atmosphere. Carbon dioxide is
one of the main contributors to the ‘greenhouse effect’ resulting in global warming. Natural
decomposition of organic matter also produces vast amounts of carbon dioxide. This is easily
assimilated in the carbon cycle during which vegetation acts as a ‘sink’, using up carbon
dioxide.

The atmosphere acts as a greenhouse by allowing ultraviolet radiation from the sun to reach
the earth’s surface, which in turn warms the surface. The warm surface then radiates heat
away from the earth but as infrared radiation which would normally be lost to space. The
effect of the greenhouse gases is to absorb this infrared radiation trapping the heat and
returning it to the earth’s surface, increasing surface temperature.

Hydrocarbons and volatile organic compounds

Hydrocarbon is a general term which refers to organic compounds containing carbon and
hydrogen. Volatile organic compounds (VOCs) are hydrocarbons which are volatile under
normal atmospheric conditions. The major sources of hydrocarbons and VOC’s are from the
partial combustion of fuels and from the evaporation of solvents and fuels. The properties of
hydrocarbons vary depending on their structural make-up. For instance, most polyaromatic
hydrocarbons (PAH) are known carcinogens and/ or mutagens, such as benzene.
A VOC can be defined as ‘any organic compound that is capable of producing photochemical
oxidants as a result of reaction with nitrogen oxides in the presence of sunlight’. VOCs are
involved in the formation of low level ozone, the depletion of the ozone layer, and also
contribute to the greenhouse effect.

Nitrogen Oxides (NOx)

Nitrogen oxides are produced both naturally and through man’s activities. Nitric oxide (NO)
and Nitrogen dioxide (NO2) are of prime environmental concern. They are emitted during the
combustion of fossil fuels such as coal and oil which have inherent
nitrogen compounds. The main source of NOx is exhaust emissions from vehicles.

NOx is a major component in the formation of photochemical smog. The other main
components are hydrocarbons and energy from sunlight. Under the influence of sunlight
Nitrogen dioxide is dissociated into nitric oxide and oxygen atom. The oxygen atom is
reactive and combines with oxygen in air to form ozone. Being unstable the ozone oxidises
nitric oxide to form nitrogen dioxide. This is the original component in the reaction and, as
long as sunlight is present, the reaction becomes self -sustaining. The buildup of nitrogen
dioxide and ozone leads to more complex reactions which yield secondary pollutants such as
peroxyacetyl nitrate (PAN).

NOx also causes depletion of ozone which increase the amount of radiation to earth and
exacerbates the global warming effect caused by carbon dioxide.

Sulphuric Oxides

Sulphuric oxides are principally released into the environment through the combustion of
fossil fuels such as coal and oil. During combustion suphur dioxide is emitted into the
atmosphere. Once released into the atmosphere it is further oxidised by oxidants such as
hydrogen peroxide to suphur trioxides and finally absorbed in water vapours as sulphuric
acid mists, which then precipitate as acid rain.

Soil contains growth nutrients such as aluminium, calcium, manganese and magnesium. Acid
rain can cause leaching of these nutrients by hydrogen ions. The metals are transported by
ground waters into the rivers and lakes. Not only does the soil become acidic, the loss of
nutrients retards growth of vegetation which ultimately results in deforestation and
exfoliation. The receiving waters become acidic and rich in the leached metals, stressing the
aquatic environment as well.

Fluorides and chlorides

Fluoride emissions are associated with aluminium smelting, brick manufacturing, glass and
glass fibres manufacture, iron and steel manufacture, oil refineries, incinerators and coal fired
power stations. Fluorides can be discharged as either gases or as particulates and are
cumulatively poisonous to vegetation and grazing animals. Fluorine is a very reactive
oxidant, it is capable of reacting with and impairing enzymes and other chemicals.

Incineration of municipal waste and domestic waste is one cause of chlorine, primarily due to
the fact that a high percentage of packageing materials and products are manufactured from
polyvinyl chloride (PVC) which releases hydrogen chloride (hydrochloric acid) in a gaseous
form. Other sources are the manufacture of aluminium products and the combustion of coal.

Heavy Metals

The heavy metals normally associated with pollution and toxicity effects include cadmium,
chromium, copper, mercury, nickel, lead and zinc. The description ‘heavy metal’ is applied a
group of metals and metalloids with an atomic density greater than 6g/cm 3. Heavy metal
sources include agriculture (fungicide droplets), chemical industries(volatisation of
electrodes and catalysts), electronics (aerosols from manufacturing processes), fossil fuel
combustion (aerosol particles from combustion), mining ( fumes, ore dusts and fine tailings),
metallurgical industries (aerosol particles from furnaces), pigments and paints (droplets of
sprayed paint) and waste disposal (aerosols from the incineration of metal containing wastes).

The majority of atmospheric heavy metal pollution is in the form of aerosols and particulates.
The size of particles, the wind speed and precipitation determine how long they remain in
suspension. While in suspension, there is a danger that they may be inhaled by humans and
animals and absorbed into the blood stream.

Particulates

Particulate matter can be generated by construction and demolition, combustion,

manufacturing, traffic etc. The size of particulates range from 0.005 um to 100 um. Those
smaller than 3 um are considered dangerous since they are easily inhaled and can quickly
settle in lung tissue. This is especially dangerous if the particulates are toxic and can cause
dust diseases or pneumoconioses such as black lung or silicosis.

Monitoring and Measuring

Once emissions are released into the atmosphere, their concentration is affected by the
prevailing meteorological and climatological conditions such as wind speed and direction,
turbulence and atmospheric stability. The higher the wind speed the lower the concentration
of pollutants; concentration is inversely proportional to wind speed. Wind direction will
determine the direction the emissions take, affecting those areas downwind from the
emission. Emissions such as high
velocity gases with high buoyancy will rise higher up into the atmosphere enhancing their
dilution. Stable atmospheric conditions cause emissions to concentrate at ground level while
unstable conditions enhance dilution through increase buoyancy.

Sampling of Gases

The methods used are wet chemical techniques or continuous analyser techniques. Wet
chemical methods are slowly being phased out. They have the disadvantage of being tedious,
time consuming and labour intensive. They are subject to atmospheric degradation if the
duration between sampling and analysis is long or if the sampling container is breached.

Continuous analyser techniques are gaining popularity due to the fact that the equipment
detects most of the gases based on their absorption of light. This reduces the time and
manpower resources as the equipment can be left on its own for long periods of time. Data is
either collected using data loggers or plotted on graph paper. One drawback can be the need
to validate the methodology and equipment prior to acceptance of the data obtained.

Particulate Sampling

Gravimetric Method

A sampling air pump is used to collect particulates on a filter paper. The particulate
concentration is determined by the weight of particulates collected for a given volume of air
expressed as g/m3. A disadvantage is that this method gives no information on particulate
size.

Impactor Technique

The impactor technique is used when an analysis of particulate size is required. Particles are
separated into ranges of sizes on the basis of their aerodynamic properities. An impactor
consists of several stages of stainless steel plates which are stacked one on top of each other.
Each plate consists of a large number of circular holes of successively smaller diameters. The
number of holes in each stage increases as the diameters decreases. The stages are staggered,
particles of a particular size range which pass on to the next stage impact onto the surface of
that stage and remain there. In this way the particles are seperated according to specific size
ranges.

Stack Sampling & Measurement

Ambient air monitoring is used to determine the air quality around stacks while measurement
in the stack will determine flue gas concentrations. An essential part of a stack monitoring is
a determination of emission characteristics to ensure that a representative sample is being
taken. Key characteristics are suitable locations for sampling, determining traverse points to
obtain representative velocity and temperature profiles and an accurate ioskinetic sampling
rate for particulates.

Abatement and reduction

Typical abatement techniques include;

Settling
Filtration
Inertial Separation
Electrostatic Precipitation
Scrubbing
Adsorption

Settling

The simplest way of capturing particles is settling. Particulates fall out of suspension due to
gravitational forces. A gravity settling chamber is used. It must be large enough to reduce
airflow velocity sufficiently to allow particulates to settle out. Only large particles will settle
out (typically < 50um) and this method is used primarily as a first stage cleaner for more
effective collectors.

Filtration

One of the most economical and efficient methods of particle removal is filtration. It is also
very reliable. Filter construction and material varies depending of the type of particulate
being removed.

Inertial Separation

Inertial separation relies on impaction to reduce the inertiaof the particulates sufficiently to
allow them to fall out of the air stream. A typical inertial separator is in the shape of a
cylindrical drum with a tapering conical outlet at the bottom. The inlet is tangential to the
surface of the cone creating a centrifugal force on the incoming air stream. Particulates are
thrown against the wall of the cyclone and gradually lose their inertia, moving in a
downward direction and forming a descending vortex. The cleaned air stream is exhausted at
the top and forms an ascending vortex. Particles are collected in a hopper at the bottom.

Inertial separators are very sensitive to flow patterns. High variations in loadings can also
affect their performance. Large diameter separators typically capture particles 40 - 50 um in
diameter, while small diameter separators capture particles 15 - 20 um in diameter.
Separators are sometimes used in series to increase the overall efficiency or in parallel to
cope with variations in loading.

Electrostatic Precipitation

Electrostatic precipitation uses the principle of electrostatic attraction to collect particulates.

The air flow passes through an electric field consisting of discharge electrodes at high
voltage ( 35 - 40 kV) and collection plates at ground potential. The particles pass the
discharge electrodes, become negatively charged and are attracted by the positively charged
collecting plates. Once on the collecting plates, the particles lose their charge and fall into a
collection receptacle. Precipitation can cope with particle sizes from 1 um to 100um and can
be up to 99% efficient.

Scrubbing

Scrubbing is the action of particulates colliding with liquid droplets in the air stream. When
wetted, the particles increase their mass and fall out. An air stream enters a cylindrical tower
from the bottom , the rising particles are wetted by fine sprays positioned at the top of the
cylinder and fall out. To prevent corrosion when the air stream has an acid base, an alkaline
scrubbing liquid is used instead of water.

Adsorption

Adsorption is a process in which a gaseous contaminant (adsorbate) is removed by contact

with a solid phase (adsorbent). Very porous material such as activated carbon or alumina can
be used to adsorb gases. The air stream is passed through towers packed with the adsorption
material. The adsorption can either be surface reaction of the material or a chemical reaction.
2 Water Pollution

Introduction

Water in the form of stream, river, lake or sea is easily contaminated although each has
different characteristics. The flow velocity of streams and rivers has a significant effect on
dissolved oxygen and pollutants. In the upper reaches of streams and rivers, the dissolved
oxygen contend tends to be high mainly due to turbulent water flow and low pollution levels.
A lack of organic pollutants results in a low oxygen demand. Flow velocity decreases in the
lower reaches, as does the amount of turbulence, and results in a much reduced oxygen
dissolution. This coupled with higher levels of pollution means that the residual oxygen
concentration is much lower.

Saline Stratification occurs in the estuary were the river meets the sea, fresh water being less
dense than salt water. Where there is a low level of mixing between the two, fresh water will
float on the surface of the salt water and river bourn pollutants will not readily disperse. This
may also be exacerbated by tidal effects. High tide can block the outward flow and cause a
back up of pollutants.
Sea water is stratified into layers due to differences in temperature although the depth of
these layers varies greatly. In the upper layers of seas and oceans, the water temperature is
relatively constant and there is a high degree of mixing. Below these layers is the
thermocline, a level at which the temperature drops sharply. This acts a barrier separating
well mixed upper layers from relatively static lower layers. Surface currents are influences
by

wind velocity, wind direction, and depth. Deep water circulation is influenced by
temperature, salinity and gravitational effects. Pollutants from the upper layers can therefore
move into this deep water and become isolated from the surface waters.

The water flow in lakes is virtually stationary in relation to streams and rivers. As a result,
the reduction of organic loads by biodegradation can be hampered by the lack of available
oxygen.

An important factor to consider is the balance of inflow to outflow. Inflow can consist of
incoming streams or rivers, run off from the catchment area, and rain. Outflow can be via
streams or rivers, seepage into surrounding land, and evaporation. Imbalances can occur
when there is low precipitation and high evaporation. The low outflow will result in an
accumulation of pollutants washed into the lake. Similarly, where there is high precipitation,
the high outflow will result in a low accumulation of pollutants.

Lakes stratify in three layers with the depth of each layer varying during each season. The
upper most layer is called the circulation layer, beneath this is the transition layer, and at the
bottom of the lake is the stagnation layer. There is little if any intermixing between the layers
and pollutants discharged into the lake will accumulate in one of these layers. Depending on
the extent of stratification, turbulence cause by the action of wind can help with the dilution
and dispersion of pollutants.

Self Purification

The self purification capacity of a body of water is its ability to dilute and disperse organic
pollutants. Micro organisms biodegrade organic pollutants by their action of drawing oxygen
from water to breath while digesting the pollutants. Organic pollutants are converted into
gases and inorganic pollutants settle out on the bottom. Water can therefore recover from
pollution provided it is given sufficient time and the pollution loading is low. The ability to
recover is influenced by factors such as dissolved oxygen content, temperature, volume and
flow rates.

Pollution Types

Bioaccumulation is where low level organisms absorb and accumulate levels of toxins.
Higher level organisms feed on these lower level ones and ingest the toxins. As these
proceeds up the ladder, the higher level organisms have greater longevity and therefore
greater potential to accumulate high levels of toxins. In the long term, the toxicity will reach
a high enough level to have detrimental effects or cause death.

Two types of effects can occur when pollutants react together. These are synergism, where an
additive effect occurs, producing an adverse effect greater than the sum of the effects
produced by the individual pollutants, and an antagonistic effect where the adverse effect of
one or more of the pollutants is reduced by the presence of one or more of the other
pollutants.

Organic Suspended Solids

Organic suspended solids exert an oxygen demand on the water which reduces the amount of
dissolved oxygen in the water. As mentioned above, micro organisms use up oxygen while
digesting the organic pollutants. The lowered oxygen concentration has an adverse impact on
aquatic life.

Artificial Fertilisers

Artificial fertilisers are rich in phosphorus and nitrogen. Over application and subsequent run
off and leaching from agricultural land can lead to serve environmental damage and
eutrophication. Detergents are another source of non-biodegradable phosphorus.

Eutrophication

Eutrophication is the uncontrolled growth of algae cause by excessive nutrients in the water.
Eutrophication is usually restricted to either lakes or very slow moving bodies of water.
Phosphorous is the key nutrient for growth and by controlling the inflow of phosphorous will
control eutrophication.

The rapid growth of the algae places such a high demand upon the dissolved oxygen
concentration of the water, that species requiring a high dissolved oxygen concentration are
unable to survive. Blue-green algae also produces high enough concentrations of toxins to
cause severe poisoning of aquatic mammal life.

Pollution Measurement

Water pollution measurements usually involve testing for the following:

Organics - BOD, COD, TOC, grease, oil and detergents

Inorganics - chlorides, dissolved oxygen, nitrates, phosphates, sulphates
Acidity and alkalinity
Metals
Physical properties - colour, solids content, temperature, turbidity

Biochemical Oxygen Demand (BOD)

BOD is the quantity of oxygen required by micro organisms to biodegrade organic wastes
into simpler substances such as carbon dioxide, nitrogen, and water. It is the principle test to
used to determine the pollution status of water.

Chemical Oxygen Demand (COD)

COD determines the quantity of oxygen required for chemical oxidation of organic and
inorganic components of wastes. While determination of biologically assimilative
contaminants is not possible using COD, its advantage is that readings can be quickly
determined, typically in 3 hours or less.

Total Organic Carbon (TOC)

TOC is a measure of the total organic matter in a waste sample. A sample is subjected to high
temperatures, oxidising the organic carbon to carbon dioxide which is then measured using
an infrared analyser or most of the newer instrumental models utilize a flame ionization
detector (FID)

Treatment and Disposal

The choice of treatment will depend on the required quality of the effluent and the discharge
path. Conventional treatment consists of preliminary, primary, secondary and tertiary
processes, which can be either physical, chemical or biological.

Preliminary Treatment

Preliminary treatment consists of the coarse screening of floating objects. The trapped solids
are either mechanically removed from the filters or in some cases shredded and returned to
the waste water for further treatment.

Primary Treatment

Primary treatment can either be physical, where settleable solids such as grit or sand are
removed, or chemical where coagulation is used to settle out colloidal particles. When the
sand or grit is contaminated with organic matter it will need to be washed prior to disposal.

Secondary Treatment

Secondary treatment is essentially biological in nature. It removes BOD, colloidal and

suspended solids, by organic decomposition. Biological treatment relies on biological
cultures to break down the organic wastes into carbon dioxide, energy, and water. The
treatment may either be aerobic, requiring the presence of free oxygen for metabolism and
synthesis or anaerobic where the micro organisms obtain their oxygen from compounds in
the waste water.

Tertiary Treatment

Tertiary treatment is used to remove dissolved solids which have passed through the previous
treatments. Typical treatments include :

Adsorption
Chemical oxidation
Chemical Precipitation
Coagulation
Ion exchange
 Neutralisation

Adsorption

Activated carbons are used to remove pollutants from waste water. Once used up, the
adsorption capacity of the carbon can be renewed by heating it to a high temperature to burn
or drive off adsorbed organics.

Chemical Oxidation

The addition of an oxidising agent can reduce or detoxify the waste to end products which
are less harmful or more readily biodegradable. Oxidation will destroy a wide range of
organic and inorganic molecules including chlorinated VOCs and cyanide. However, caution
must be used in determining the correct treatment as reactions between certain oxidising
agents and organics can result in an end product more toxic than the original waste.

Chemical Precipitaiton

Precipitation is used to remove heavy metals in the form of hydroxides by the addition of
lime or caustic. As the reaction requires a minimum of solubility, the pH has to be controlled.
The pH of the reaction will depend on the minimum solubility of the metal being
precipitated.

Coagulation

Coagulation is used for the removal of colloidal and suspended solids using coagulants such
as silica.

Ion Exchange

Ions are atoms or groups of atoms which carry positive or negative electrical charges as a
result of having lost or gained one or more electrons. Anions carry a negative charge and
cations carry a positive charge. Ion exchange resins are insoluble materials of high molecular
weight that contain groups which can be exchanged with ions in waste water when the waste
water is run over the resin. Ion exchange removes undesirable anions and cations from waste
water. Cations are exchanged for hydrogen or sodium and anions for hydroxyl ions.

Neutralisation

In general, discharges to sewer have to be between 6.5 - 8.5 pH. As a result many wastes
require neutralisation before they can be discharged to sewer. Sodium hydroxide caustic is
used to neutralise acidic discharges and hydrochloride or sulphuric acid is used to neutralise
alkaline discharges.
3 Land Pollution

Introduction

Contaminated land is defined as ‘land so damaged by industrial, or other development, that it

represents an actual or potential hazard to health., or the environment, and is incapable of
beneficial use without treatment’. The contaminants present will be very much dependent on
the historical activities of the site and will either be organic or inorganic compounds. Organic
compounds are man made, they do not occur naturally to any significant degree, they can be
volatile organic compounds (VOCs) or semi-volatile compounds. The main inorganic
compounds which give concern are heavy metals.

Typical land contaminants include:

Carcinogenic and toxic chemicals (benzene and cyanide)

Carcinogenic materials (asbestos)
Corrosive substances (acids, alkalies)
Flammable and toxic gases (methane and carbon monoxide)
Organic contaminants (oils and solvents)
Toxic metals (lead, chromium)
Radioactive substances

Remediation
The choice of remediation treatment will depend on the contaminants which have been
identified, type of soil, proposed use of the land and cost. Typical remediation treatment
includes:

Excavation and disposal

Bioremediation
Stabilization and solidification

Excavation and Disposal

Contaminated soil is excavated and replaced with clean soil. The contaminated soil can either
be treated or sent to landfill. Treatment could either be by incineration or washing.
Incineration involves destroying contaminants by subjecting the soil to temperatures higher
than 1000oC, while washing would be with aqueous extractive agents or solvents.

Bioremediation

Bioremediation involves treatment of the contaminants in situ using aerobic processes. Water
is withdrawn from the soil, enriched by injecting it with oxygen and nutrients, then reinjected
back into the soil. The enriched water stimulates growth of native micro organisms
eventually resulting in the degradation of the contaminants.

Bioremediation can also involve the placing of short-lived benign bacterial loads which then
break down the contaminants during their life-span.

Stabilization

Stabilization involves the melting and fusion of the soil at temperatures exceeding 1600oC by
the application of an electric current to the soil through series of electrodes. During this
process organic materials vaporise and then pyrolyse into simpler elements. Inorganic
materials decompose, and gases burn off. The conversion of the contaminants to gases results
in a overall reduction in soil volume.

4 Waste Disposal

The two primary methods of waste disposal are landfill and incineration

Landfill

Properly designed and operated landfilling can be environmentally safe. It is the most
common means of waste disposal and is sometimes combined with land reclamation. The
landfill is formed by excavating land to predetermined levels then filling it up with wastes up
to the designed levels. The excavated soil is used as cover material.

An impermeable liner is required to separate the wastes in the landfill from surrounding
ground water and must be able to withstand the hydraulic pressure exerted by the ground
water. The purpose of the liner is to prevent toxic liquids and gases from escaping from the
landfill and contaminating surrounding soil and ground water. Clay was traditionally used as
a liner but synthetic membranes are now popular and are sometimes combined with clay.

Waste is placed in layers approximately 60 cm thick and compacted. A cell is the volume of
material placed in a landfill during one operating period, usually a day, and a typical cell is
2.5 m to 4 m high and 3 m to 10 m long. All the exposed sides of the cell are covered with
soil to prevent scavenging by rodents. A completed layer of cells is called a lift and
perforated pipes, for gas recovery, are laid horizontal over each completed lift. Pipes for
leachate are also placed at this time. One of the landfill site has been filled to the required
level vertical wells, for gas and leachate extraction, are completed and the final cover is
planted with vegetation to prevent erosion.

Water slowly percolates through the landfill washing out the byproducts of aerobic and
anaerobic degradation processes that occur within the waste and toxic substances contained
in the waste. This liquid effluent accumulates at the bottom of the landfill and is known as
leachate. Because of its toxic nature it requires treatment before it can be discharged. As the
landfill ages the characteristics of the leachate change. Over time the biodegradable content
of the leachate will decrease while the non biodegradable content will increase. Leachate
discharge can continue for 30-50 years after capping of the landfill therefore collection and
treatment of the leachate are vital to prevent contamination of ground water.

The other significant by-product of the landfill is gas which is generated by the action of both
aerobic and anaerobic organisms within the landfill. The main components of the gas are
methane and carbon dioxide. Gas generation usually peaks after the second year but is likely
to continue for 20-30 years after capping. Methane can be explosive in high concentration
and being denser than air will migrate to low lying areas. During and after the life of the
landfill, methane is actively or passively vented to the atmosphere and is sometimes used as
an energy source.

Incineration of Waste

The waste is incinerated in a furnace at temperatures exceeding 10000 C. Maintenance of

furnace temperature and dwell time of the waste in the furnace are critical. Failure to
maintain either criteria could result in the incomplete combustion of toxic material and its
release to atmosphere via the flue gases. Waste gas from combustion is then passed over heat
exchangers to extract energy. The waste gases can include acid gases, dioxins, furans, carbon
monoxide, metals, nitrogen oxides, sulphur oxides, particulates and have to be treated prior
to release to the atmosphere. Combustion also produces solid waste in the form of bottom ash
and fly ash. Bottom ash will contain non combustible elements of the waste such as glass and
metals while fly ash is composed of the particulates removed from the flue gases prior to
release. The two main incineration systems are commingled solid waste (mass-fired) and
processed solid waste refuse derived fuel (RDF-fired). Minimal processing id given to the
collected municipal solid waste prior to incineration in the mass -fired system. Therefore the
energy derived is highly variable and depends on the calorific value and the moisture content
of the waste.

As most non-combustible materials have been removed in the RDF-fired system the overall
calorific value of the waste is higher. The incineration can be more easily controlled and
removal of noncombustible materials results in lower emissions of potentially polluting
gases.
Concern with incineration of waste centres around the release of toxic or hazardous materials
via flue gases. Plastic wastes such as polyvinyl chloride, polystyrene and polyethylene
produce hydrogen chloride and hydrogen fluoride gases when burned. Metallic dust
particulates in respirable range can be cancerous. Dioxins and furans are found in paper,
pesticides and wood preservatives, many isomers of dioxins and furans are known
carcinogens or mutagens.

Chapter 3

Legislation Overview
Chapter 3

1. European Community

2. United Kingdom

3. The Environment Act 1995

4. The environmental Protection Act

5. Emissions to the Atmosphere

6. Aqueous Effluent

7. Waste Management

8. Control, Storage and Handling of substances and Materials

9. Regulatory Agencies
1 European Community

The aim of EC environmental legislation is to encourage waste minimisation and recycling

by involving every one in environmental management and increasing public access to
ingormation. Pressure is put on organizations by tightening emission levels, increasing the
cost of waste disposal and adopting polluter pays principles. EC law is based on a series of
codes, of which European Court is the ultimate arbitrator.

Regulations

Regulations are directly applicable and legally binding in all member states. As such,
national legislation is not necessary to implement an EC regulation. EC regulations prevail in
cases of conflict between national and Community law.

Decisions

Directives are legally binding objectives to be achieved within a given time scale. The means
of achieving that objective, was however, is left to national governments. Directives require
national legislation to transpose their requirements into UK law. This is often done through
the development of new regulations, or the amendment of existing regulations.

Recommendations and opinions have no binding force, but simply state the European
Community’s view.

2 United Kingdom

The UK has a different legal frame work from the rest of the EU in that there is no written
constitution, but has instead a common law basis, with court decisions based on precedent.
The law making process consists of:

Bill
A bill is a proposal for law which has to pass through the Parliamentary decision making
process before being accepted by Parliament, once it accepted and has received
Royal Assent, it becomes an Act.

Act

An Act of Parliament is a Bill that has passed into statute law, Acts often deals with a
number of subjects and often do not provide for the regulation of every detail for each of the
subjects. An Act will, therefore, commonly confers powers for the making of detailed rules,
orders or regulations.

Regulations and Orders

Regulations and orders are the vehicles through which provisions of Acts are implemented,
usually in the form of Statutory Instruments (SIs), they are published by HMSO and are as
much part of the law as the parent Act of Parliament. EU Directives are commonly
implemented through regulations made under an Act.

Guidance

Guidance on the implementation of legislation is often issued in the form of notes, codes of
practice, or circulars. They form accompanying guidance providing advice for the regulatory
authorities for the implementation and interpretation of regulations. They may be given
statutory backing simply on the face of the legislation itself or they may be approved by the
Secretary of State by statutory instrument.

UK Legislation Overview

3 The Environmental Act 1995

The Environment Act 1995 is mixed bag of legislative measures dealing with the setting up
of the new environmental Agencies - Part 1, the making of provisions for contaminated land
and abandoned mines - part 1, the making of provisions for contaminated land and
abandoned mines - part 11, National parks - Part 111, and air quality - Part 1V. Part V deals
with miscellaneous items including provisions for national waste strategy, producer
responsibility initiatives, and changes to Scottish nuisance and water pollution law.

Part 1: The Environment Agency and the Scottish Environment Protection Agency

In England and Wales, the functions of HMIP, NRA, the Waste Regulatory Authorities and
certain functions of the Secretary of State have been transferred to the Agency. In Scotland,
SEPA have taken over the functions of HMIP, the RPAs the local authorities with respect to
waste regulation and air pollution control, and certain functions of the Secretary of State.

Part 11: Contaminated Land and Abandoned Mines

Contaminated land

The provisions here are to be implemented through amendment of the Environmental

Protection Act 1990, inserting a new Part 11A. The act gives the first legal definition of
contaminated land. Local authorities are given a significant role and are the enforcing
authority ( except in the case of land designated as ‘special sites’). They are required to
inspect their area to identify contaminated land and closed landfill sites and to report findings
to the agency.

Abandoned Mines

Mine operators must now give the agency six months notice of any intention to abandon a
mine. After 31st December 1999 the exemption from prosecution for permitting water from
an abandoned mine to enter controlled waters will cease to exist, and it will be possible to
recover the costs of investigation and clean up from the operators.

Part 111: National Parks

This part amends and adds to existing legislation in relation to purposes and functions of
National Parks. National Parks authorities are to be established in England and Wales. These
will assume the responsibilities of the local planning and minerals planning authority.
Management plans must be prepared and be kept under review by the National Parks
authorities.

Part 1V: Air Quality

The government must prepare a national air quality strategy stating standards and objectives.
Local authorities must conduct reviews of Air quality within their area. If air quality
standards and objectives are not achieved then the Local Authority can designate air quality
management areas,. The LA must then prepare a time bound action plan in relation to these
designated areas.

Part V: Miscellaneous

The following are of particular interest:

National Waste strategy

Section 92 of The Environment Act 1995 allows for two new sections to be inserted into the
Environmental Protection Act 1990. Section 44A requires the Secretary of State to prepare
a strategy “in relation to the recovery and disposal of waste” for England and Wales (a draft
was issued for consultation in January 1995) under Section 44B SEPA is to prepare a similar
document as soon as possible. These strategies are required under the EC’s Framework
Directive on Waste 75/442/EEC.

Producer Responsibility Obligations (Packaging Waste) Regulations 1997

The regulations came into effect during March 1997 and implement the 1994 European
Directive on Packaging Waste. They require producers to meet the overall recovery target of
52% of packaging waste with a minimum of 16% recovery of each of the main materials,
glass, aluminium, steel, paper/board and plastics by 2001. To allow a steady increase in the
amount of packaging waste recovered and recycled each year targets for the years 1998-2001
have been graduated. The regulations effect any business with a turnover of more than £5
million which handles more than 50 tonnes of material in a year and is involved in one of the
following activities:

Manufacturing packaging raw materials (6%)

Converting raw materials into packaging (11%)
Packaging products or filling packaging (36%)
Selling goods in packaging to the final consumer (47%)

The percentage responsibility for recovery allocated to each activity is shown in brackets.

Importers must undertake the packaging recovery obligations for those stages of packaging
which have not been accounted for in the UK. In the case of packaged consumer items the
importer would be required to meet the packaging waste recovery obligations for the
manufacturing (6%), converting (11%), and filling (36%) stages of the items packaging. In
total 53% of the overall waste recovery obligation.

Businesses who produce or handle packaging are required to register with either the
Environment Agency in England and Wales or SEPA in Scotland, or subscribe to a scheme
which will undertake the responsibility of recovering the waste on their behalf. The anual fee
payable to the relevant Agency to cover registration, monitoring and enforcement costs is
£750. Where businesses register collectively in an exemption scheme, a partial rebate may be
offered depending on the size of the membership. The theory being that collective schemes
lower the administrative workload for the relevant Agency. Businesses affected by the
regulations must have registered by August 1997, either with the relevant Agency or with an
approved scheme. In order to register, the business must provide data on their ‘packaging
flows’ during 1996. From 1998, they must renew their registration and provide data by 1 st
April each year. They must also provide the relevant agency with a certificate to demonstrate
their compliance in any year to 1 April by 31January the following year. An entry will be
made in the register as to whether or not this obligation has been compiled with.

New Provisions for Scotland

Control of Water Pollution

Schedule 16 amends the water pollution offence and defence provisions of COPA 1974. It
inserts five new sections into the Act.

Statutory Nuisances

Statutory Nuisance in Scotland has until now been regulated under the Public Health
(Scotland) Act 1897, while in England and Wales the relevant legislation is now part 111 of
the Environmental Protection Act 1990. Schedule 17 of the Act amends Part 111 of the EPA
to extend these controls to Scotland.
Tripartite Sampling

Existing requirements for taking water samples for monitoring purposes are that these
samples are divided on a tripartite basis (one for the regulator, one for the discharger, and
one for analysis). This requirement is to be repealed. This will facilitate automated and self
monitoring. Monitoring results are assumed accurate, unless there is evidence to the contrary.

The majority of the provisions in the Act require further statutory instruments.
(Commencement Orders, Regulations etc.) to be issued before they come into force. Most of
part 111(national Parks) became law in September 1995.

4 The Environmental Protection Act

The Environmental Protection Act 1990, contains 8 parts

Part 1: Integrated Pollution Control and Local Authority Air Pollution Control

Part 1 introduced Integrated Pollution control (IPC) for prescribed processes, and Local
Authority Air Pollution Control (LAAPC). Operators of prescribed processes must apply for
authorisation to operate them from the relevant regulatory authority and must adopt the Best
Available Techniques Not Entailing Excessive Costs (BATNEEC) to control process
emissions. The programme for application for authorisation started in 1992 and ended in
1996, a defined time scale dictated when the various groups of processes had to be submitted
by.

IPC - Integrated Pollution Control

IPC is a first step towards placing controls on the environmental effects of processes, it
covers all three mediums and considers the effect on the environment as a whole, the most
serious pollutants for each environmental medium are prescribed according to their potential
for pollution. Process which produce significant quantities of scheduled substances are
subject to IPC. Where a process releases substances to more than one medium, BATNEEC
will be supplemented by the concept of Best Practicable Environmental Option (BPEO) to
minimise the pollution which may be released to the environment as a whole.

Schedule A Process

These comprise approximately 100 processes, either because of the materials they handle or
because of the scale of their operation. They must be registered with the EA or SEPA, use
BATNEEC, and if appropriate choose the BPEO.

Schedule B processes

These are considered to be less polluting processes, comprise approximately 60 processes,

and covers only emission to air. They must be registered with the EA or SEPA and use
BATNEEC.

Public Access to Information

The EA and SEPA will make environmental information collected as part of the IPC process
available to the public through a series of registers of information. Copies of the registers are
kept by Local Authorities.

Local Authority Air Pollution Control

Basically the same rules apply as IPC, but Borough and District councils in England and
Wales and SEPA in Scotland, are responsible for controlling releases to air.

Prescribed Processes

Prescribed processes are those with the potential to discharge significant quantities of
harmful wastes to any environmental medium.

Best Available Techniques Not Entailing Excessive Costs - BATNEEC

Best - the most effective means of preventing, minimising, or rendering harmless,

polluting emissions
Available - can be obtained generally
Techniques - design of processes, plant and buildings, construction of plant and
buildings, training of supervision and operators, etc.
Not Entailing Excessive Costs - Interpretation is very subjective, but implies that
every effort should be made to minimise serious pollutants.

It should be noted that BATNEEC is not a politically correct version of CATNIP ( Cheapest
Available Technology Not Involving Prosecution)!

Best practical Environmental Option - BPEO

The objective is to minimise the pollution which may be released to the environment as a
whole. This is achieved by an assessment of all emissions and discharges to determine if a
release to one medium would be less harmful than to another, and to ensure that the
pollutants are then treated to cause minimum environmental damage. Applications for
authorisation must contain a justification, by the company, of this assessment.

The Authorisation

The authorisation that is issued is a legally binding document. It is based upon agreed
parameters, including the scale of operation, emission and discharge levels. Significant
changes to the scale of operation require further authorisation, while records must be
maintained to demonstrate compliance the agreed emissions and discharges.

Part 2 - Waste on Land

Part 2 introduces a provision for the duty of care. The duty is applicable to every person who
has control of waste at any stage from production to disposal. The duty of care applies to
industrial and household waste, but does not apply to householders. It effects all
organisations, not just those operating prescribed processes.
Holders of the waste are responsible for it and any resultant consequences while it remains in
their care. A duty of care booklet is available from the DoE.

Waste regulation authorities had full responsibility to the licensing and enforcement of waste
disposal. They were required to draw up waste disposal plans which provide a strategic frame
work for waste likely to arise in their areas. They have now been absorbed within the EA.

Waste authorities were prohibited from operating their own disposal services. They had to
either transfer their disposal operations to Local Authority Waste Disposal Companies
(LAWDCs) or private contractors. The licensing system required waste regulation authorities
to charge for processing licence application and monitoring the waste facility.

Part 3 - Statutory Nuisances and Clean Air

Statutory nuisances are local nuisances capable of causing personal discomfort or prejudice
to health of individuals. For example, dust, steam, smells, emissions of smoke, fumes or gas
not dealt with under general pollution legislation, such as bonfire smoke. Noise, the keeping
of animals, accumulations and deposits are also covered.

LAs must take reasonably practical steps to investigate all complaints reported to them. They
have power to take anticipatory action to deal with short term nuisances, such as building
sites.

Part 4 - Litter Etc.

Part 4 places a duty on the Crown. LAs, educational institutions, certain statutory
undertakers (e.g. British Rail) and some owneres of other land, including public highways, to
keep their land free of litter and refuse.

Part 5 - Amendment of the Radioactive substances Act 1960

Part 5 makes a number of changes to the Radioactive Substances Act 1960 (RSA60). RSA60
controls th keeping and use of radioactive material, and the accumulation and disposal of
radioactive waste.

Part 6 - Genetically Modified Organisms

Part 6 provides for the prevention of damage to the environment by the escape or release of
genetically modified organisms. Organisations importing, acquiring keeping, marketing or
releasing genetically modified organisms must carry out a risk assessment and either notify
the Secretary of State or seek his consent for their proposed operation.

Part 7 - Nature conservation in Great Britain and Countryside Matters in Wales.

Part 7 reorganised the Nature Conservancy Council and the Countryside Commission into
three separate agencies the Nature conservancy Council of Scotland, the Nature Conservancy
Council for England, and the Countryside Council for Wales. The Scottish and England
agencies are responsible only for nature conversation functions, while the Welsh agency also
took over the relevant functions of the Countryside Commission.
Part 8 - Miscellaneous

Part 8 addresses a whole series of diverse topics, ranging from the control of harmful
substances, dumping at sea, oil pollution from ships, to control of dogs and burning of crop
residues.

5 Emissions to the Atmosphere

Controls introduced by the EPA 1990 will generally supersede those existing under previous
legislation. Where organisations do not fall under the EPA, regulation will continue to be
under the preceding legislation. Emissions to the atmosphere are controlled by the following
acts.

EPA 1990

Part I introduced IPC and LAPC. Operators of prescribed processes must apply for
authorisation to operate from the relevant regulatory authority and must adopt BATNEEC.
IPC and LAPC are regulated by the SEPA in Scotland and IPC process by the EA in England
and Wales. It refers to prescribed substances. These are substances which are considered to
be particularly harmful if released into the environment. They are generally controlled
through regulation of the processes which use or generate them.

Public Health (Scotland) Act 1987

The act is amended by the EPA 1990 to give LA’s powers to inspect and take action to deal
with a wide range of nuisances, including fumes and dust.

Clean Air Act 1993

The act repeals and consolidates the Clean Air Acts 1956 and 1968. It controls the release of
‘dark smoke’ from chimneys, industrial and trade premises, grit, dust and fumes from
furnaces (non domestic) and regulates chimney height.

European Communities Act 1972

Allows EC law to be recognised in the United Kingdom without any need of further
legislation.

6. Aqueous Effluent

Scotland

Commercial aqueous effluent is generally disposed off in the public sewerage system under
authorisation from the relevant water authority. The authorities act as effluent managers and
recover the cost of receiving, treating and disposing of commercial effluent by charging the
responsible organization. Organisations may discharge effluent directly into inland or coastal
waters with consent from relevant water authority, consents are charged on a cost recovery
basis. Aqueous effluent is controlled by the following acts:
EPA 1990

Processes with potential to release red list or Schedule 5 substances into the aquatic
environment fall under IPC control introduced by the EPA 1990. Authorisation in Scotland is
required from the SEPA and the EA in England and Wales. Operators of prescribed
processes are required to operate BATNEEC to control releases.

Control of Pollution Act (COPA) 1974

The control of Pollution Act places controls on poisonous, noxious or polluting discharges on
‘controlled waters’, and requires organisations either intending to discharge them, or
discharging trade effluent or sewage, into controlled waters to have authorisation from the
SEPA. The authorisations contain conditions on both the quality and the quantity of effluent
permitted. The term ‘controlled waters’ is used to define those waters, other than to sewer, to
which the legislation applies. It includes virtually all natural inland fresh water and saline
water up to the UK territorial limit.

Run off from industrial sites to controlled waters must also be authorised, under the COPA
1974. In Scotland, the Sewerage (Scotland) Act 1968 requires that run off to the sewerage
system has consent, otherwise it constitutes an unconsented discharge.

Water Act 1989

The Water Act amended the COPA 1974 by expanding the definition of, and setting
standards for, controlled waters. It granted new powers to the regulatory authorities for
achieving these standards.

While most of the water Act 1989 does not apply in Scotland, it did amend the Water
(Scotland) Act 1980 to allow specific bye-laws to be drafted to protect water quality.

Scotland

Water (Scotland) Act 1980

Schedule 22 to the Water Act 1989 extended the Water (Scotland) Act 1980 to empower the
Secretary of State to make regulations to protect water quality.

Sewerage (Scotland) Act 1968

Where trade effluent is discharged into a public sewer, the effluent producer requires
authorisation from the relevant water authority, who have the power to levy trade effluent
charges. The consent will contain conditions relating to both the volume and quantity of
effluent discharged.

Effluents from cleaning areas, washdowns, washbays, including those washed off by rain, are
considered trade effluents and their discharge to the public sewerage system require similar
authorisation.

Water Industry Act 1991

The discharge of trade effluent to public sewer requires the consent of the relevant Water
Service Company, these consents will contain conditions relating to both volumes and
quantity of the effluent. Discharges to sewer of substances, or from processes, prescribed by
Regulations made under the Act require authorisation from the EA as well as consent from
the Water Service Company. The Water Service Companies are empowered to levy trade
effluent charges.

Water Resources Act 1991

The Water Resources Act is the principal legislation regulating discharges to ‘controlled
waters’ in England and Wales from processes which are not prescribed under the EPA 1990.
It deals with the functions and duties of the EA as they relate to water and controls the
pollution of water resources and the consenting of discharges to controlled waters.

It also places controls on poisonous, noxious or polluting discharges entering ‘controlled

waters’. It requires persons intending to discharge such substances or those discharging trade
or sewerage effluent directly to ‘controlled waters’ to obtain consent. The consent from the
EA will contain conditions on both the quality and quantity of effluent.

The Act also enables the Secretary of State to prescribe a system for classifying the quality of
waters according to specified criteria and to establish water quality objectives for waters iln
particular areas.

Other than for specific substances with a high potential to cause environmental damage,
conditions relating to concentration limits, characteristics and volume of effluent discharge
are generally at the discretion of the EA. This will depend on the use to which the receiving
water is put and its environmental sensitivity.

7 Waste Management

EPA 1990

Some waste disposal processes are prescribed under part 1. Operators of these processes,
such as incineration, energy from waste and recovery processes, require authorisation from
the relevant authority. Part 2 introduced new waste arrangement and disposal controls that
affect all companies producing controlled waste.

Section 33 makes it an offence to treat, keep or dispose of controlled waste without a waste
management licence, or “in a manner likely to cause pollution of the environment or harm
human health”.

Sections 35 -44 detail how the licensing system operates. These waste management licences
replace the disposal licences issued under sections 3 and 4 of the Control of Pollution Act
(COPA) 1974

Section 34 of the Act introduces a Duty of Care for all those who own or deal with waste.
All waste producers must follow the duty of care, under which they should ensure that:
 Waste consigned to a waste disposal contractor or transporter is accompanied by a
detailed, written description containing necessary information for the safe handling,
treatment and disposal of the waste.

Waste is consigned only to authorised persons, i.e. registered waste carriers, licensed
waste contractors, local authority waste collection authorities or persons dealing with
waste in ways that are exempt from licensing.

Waste is securely contained to prevent it escaping to the environment both during

storage and transit.

Appropriate measures are taken to ensure that others involved in the handling and
disposal of the waste do so in accordance with the law.

The various Waste Management Licensing Regulations replace the Waste Disposal Licensing
elements of COPA 1974 in line with the amended EC directive on Waste (91/156/EEC). A
Waste Management Licence is required for the deposit, keeping, treatment or disposal of
“directive waste” in or on land.

The licensing system requires that the applicant be “fit and proper”, i.e. have no previous
convictions for relevant offences, be technically competent and have the necessary financial
resources to undertake the activity in question effectively. Importantly, a licence cannot be
surrendered until the regulators are satisfied that the condition of the land is unlikely to cause
pollution of the environment or harm to human health.

Waste Management Regulations 1996

Make a number of changes to waste management legislation, amending the Waste

Management Licensing Regulations 1994. The Regulations extend the transitional exemption
for certain activities involving biological or physico -chemical treatment, amend the
definition of mobile plant and modify the technical competence provisions.

Waste Management Licensing (Scotland) Regulations 1996

Allow those who have managed waste management sites in accordance with resolutions set
by a local authority to be considered to be technically competent to operate those facilities.

Environmental Protection (Duty of Care) Regulations 1991

Require all persons subject to the Duty of Care (anyone who produces, receives, holds,
carries, treats or disposes of controlled waste, or as a broker has control of such waste) to
prepare and retain certain written descriptions of waste and transfer notes and to furnish
copies on request. Transfer notes should contain both a description of the waste and identify
who the waste is transferred from and to. Waste should only be transferred to an authorised
person.
Special Waste Regulations 1996 as amended by Special Waste (Amendment)
Regulations 1996

Defines special waste in accordance with the EC Hazardous Waste List and the Directive on
Hazardous Waste (91/689/EEC). The definition is extended to also include other waste
considered to display particular hazardous properties.

The Regulations establish a consignment note system which allows the Environment Agency
in England and Wales and the Scottish Environmental Protection Agency in Scotland to
monitor the movement and location of special wastes. Special waste producers must notify,
the receiving agency between one month and three days before the waste is to be transported
to its destination and producers, carriers and disposers are required to keep a register of
consignment notes. Producers of special waste are required to pay a fee for most
consignments.

Mixing of different categories of special waste is prohibited, as is mixing of special waste

with non special waste, unless prior authorisation is gained. Special wastes are also
controlled wastes and therefore subject to the Duty of Care.

Controlled Waste Regulations 1992 as amended by Controlled Waste (Amendment)

Regulations 1993

The main purpose of these Regulations is to define ‘controlled waste’ for the purposes of part
2 of the EPA 1990, which introduced three categories of controlled wastes, household,
industrial and commercial. These regulations set out in greater detail descriptions which will
enable the categorisation of any waste, particularly those which might otherwise be confusing
and the provisions of part 2 of the Act which apply to each category. The Regulations also
set out a legal definition of ‘clinical waste’. Scrap metal was treated as a controlled waste
after October 1995 and has become subject to Duty of Care.

Control of Pollution (Amendment) Act 1974

Most of part 1 of the COPA has been replaced by the EPA 1990. The control of pollution
(special wastes) Regulations 1980 made under the COPA continue to regulate the
management of special wastes, landed ship’s waste, and control of some agricultural
processes . Special wastes are subject to the duty of care. The Control of Pollution
(Amendment) Act 1989, contains provisions for the registration of carriers of controlled
waste, and means of controlling illegal fly tipping.

Finance Act 1996

Contains most of primary law on land fill tax as well as setting out provisions for the
operational aspects of the tax and situations where a lower rate of tax will be levied, or an
exemption will occur.
8 Control, Storage and Handling of Hazardous Substances and
Materials

Planning (Hazardous Substances) Act 1990 as amended by the Planning and

Compensation Act 1991 and the Environmental Protection Act 1990.

Provisions under this Act provide that the presence at or above certain quantities of
hazardous substances on , over or under land requires consent from the hazardous substances
authority (District or London Borough Council. Special cases are detailed in Section 3 of the
Act). These provisions aim to give Local Authorities the opportunity to monitor and control
the presence of hazardous substances in their area. The consent system covers the use or
storage of hazardous substances irrespective of whether associated development requiring
Planning permission is involved. Regulations made under the Act introduce consent
procedures similar to those followed for planning permission for the storage or handling of
certain types and quantities of hazardous substances.

Town and country Planning (Scotland) Act 1972 as amended by the Housing and
Planning Act 1986, the Environmental Protection Act 1990 and the Planning and
Compensation Act 1991.

Provisions under the Act provide that the presence above certain quantities of hazardous
substances on, over or under land requires consent from planning authorities. These
provisions aim to give local authorities the opportunity to monitor and control the presence
of hazardous substances in their area. The consent system covers the use or storage of
hazardous substances irrespective of whether associated development requiring planning
permission is involved. Regulations made under the Act introduce consent procedures similar
to those followed for planning permission, for the storage or handling of certain types and
quantities of hazardous substances.

Health and Safety at Work Etc. Act 1974

The act provides a comprehensive and integrated legal system for securing the health, safety
and welfare of persons at work. It also created the Health and Safety Executive (HSE). The
HSE and local authorities are jointly responsible for enforcing legislation made under the
Act. Employers have a duty to ensure the safety of anyone who might be affected by the
storage, handling and conveyancing of hazardous substances is protected from risks arising
from such activities. COSHH Regulations were introduced to protect individuals in the work
place from exposure to hazardous substances.

COSHH - Control of Substances Hazardous to Health

These regulations apply to all potentially harmful substances including wastes. They require
employers to undertake a systematic assessment of the exposure of personnel to substances
considered hazardous to health. The organisation must use control methods such as training
and information to employees, routine exposure monitoring, and health surveillance to
protect employees. They set out requirements considered necessary to protect individuals in
the workplace from such exposure.

NIHHS - Notification of Installations Handling Hazardous Substances

The regulations list substances and the quantities above which their presence on a site (or in a
pipeline) have to be notified to the HSE. In general the regulations require that the HSE is
informed about the storage, manufacture, processing, transfer or use of a quantity above a
specified minimum of defined hazardous substances. The information is used to compile
lists of installations handling notified substances to help define priorities in planning
inspection and emergency programmes.

CIMAH - Control of Industrial Major Accidents Hazards

CIMAH Regulations 1984 as amended by the CIMAH (Amendment) Regulations 1988 and
1990 apply to industrial activities where significant quantities of specified dangerous
substances are used or stored. The Regulations require operators to demonstrate to the HSE
that they have not only implemented procedures for identifying and controlling accidents, but
that they have also taken steps to prevent accidents from occurring. Operators must evaluate
major hazards associated with their industrial activities and establish comprehensive on and
off site emergency plans.

CHIP - Chemical (Hazard Information and Packaging)

CHIP Regulations implement a series of EU Directives on the classification, packaging and

labelling of dangerous substances and preparations. They aim to protect people and the
environment from the ill-effects of chemicals by requiring companies to identify and provide
information on the hazards, or dangers, of the chemicals they supply and package them
safely.

9 Regulatory Agencies

The Environmental Agency

The Environment Agency (EA) for England and Wales was established under the
Environment Act 1995 and became operational on the first of April 1996. The agency is an
amalgamation of the National Rivers Authority (NRA), Her Majesty’s Inspectorate of
Pollution (HMIP) and the local Waste Regulation Authorities (WRAs). The formation of the
Agency means that environmental management has been brought together for the first time
under one agency. This will allow an integrated approach environmental protection. The EA
is not responsible for all environmental regulations. In England and Wales Local Authorities
(LAs) continue with air pollution from ‘Part B’ processes, statutory nuisance, and some
aspects of contaminated land. The health and safety executive will continue to regulate health
and safety matters.

The Scottish Environment Protection Agency

The Scottish Environment Protection Agency (SEPA) fulfils a similar function to the EA. It
comprises the seven River Purification Authorities, HMIP, the waste regulation (unlike that
in England and Wales), local air pollution functions of the Island and District councils. In
addition, SEPA has taken over many of the duties of the Hazardous Waste Inspectorate.
SEPA’s structure consists of the regional and local offices. Each region has a Regional Board
appointed by the SEPA.
 Chapter 4

Environmental Management Standards

Chapter 4

Environmental Management Standards

1. The ISO 14000 Series of Standards

 2. ISO 14001

3. EMAS

4. Eco Labelling

5. Life Cycle Assessment

1 The ISO 14000 Series of Standards

This ever expanding series of standards can be thought of as organization orientated and
product oriented.

Organization Oriented Standards

ISO 14001 Environmental Management Systems - Specification with Guidance for Use

This is the only ‘normative’ standard in the ISO 14000 series, which means this is the
standard used as the basis to audit an organization’s environmental management system. All
the other standards are ‘informative’ and used for guidance only.

ISO 14004 Environmental Management Systems - General Guidelines on Principles,

Systems and Supporting Techniques.

The prime purpose is to be used by organizations for internal guidance in tailoring an EMS to
their organization’s needs. It is not intended to be used for certification and as such is not an
auditable document. It describes EMS principles and defines key terms, explains fundamental
environmental management concepts, and provides detailed guidance in implementing an
EMS.

ISO 14010 - 14012 guidelines for Environmental Auditing

Gives guidance to organizations, auditors etc. on the general principles of planning and
conducting environmental audits and auditor qualifications.

ISO 14031 Evaluation of Environmental Performance

Intended to define environmental performance evaluation (EPE) of management and

operational systems of organizations. It will also provide guidance for adopting such a
process. It is intended to have a CD (Committee Draft) by late 1997. A pilot test phase has
been suggest, with a DIS (Draft International Standard) by 1998.

The ISO 14000 Series Inter-relationship

ISO 14004
EMS Guidance
 ISO 14031 ISO 10040 - 43
ISO 14001 Eval of Env Life Cycle
Performance Assessment

ISO 14010 -14 ISO 14020 -24

Auditing Environmental
Labelling

Other Tools

ISO 14060
Environmental
Aspects

Product Oriented Standards

ISO 14020 Environmental Labelling - General Principles

Provides general principles to guide the development of specific environmental claims.

ISO 14021 Terms and Definitions for Self-Declaration Environmental Claims

The aim is to contribute to a reduction in the environmental burdens and impacts of

associated with the consumption of goods and services and to harmonise the use of
environmental claims. It establishes general guidelines regarding environmental claims in
relation to the supply of goods and services.

ISO 14022 Environmental Labelling - Symbols

To ensure that symbols used to denote resectability, recycled content, etc., have the same
universal meaning.

ISO 14023 - 14024 Environmental labelling

Preliminary work started on this in 1996

ISO 14040 - 14043 Environmental Management - Life cycle Assessment

Aimed at encouraging private organisations, public policy makers, and the public to approach
environmental issues in a systematic manner. It is intended to take into account a much
broader spectrum of activities than has traditionally been considered.

ISO 14060 Guide for the Inclusion of Environmental Aspects in Product Standards

Details general considerations that should be taken into account when developing product
standards to reduce environmental effects and achieve the intended product performance. It is
intended for use by standards writing bodies such as ISO.

2 ISO 14001

ISO 14001 was published in September 1996. In the introduction it states;

‘ A system of this kind enables an organization to establish and assess the effectiveness of,
procedures to set an environmental policy and objectives, achieve conformance with them,
and demonstrate such conformance to others. The overall aim of the standard is to support
environmental protection in balance with socio-economic needs’.

But it is more than that. It contains a requirement for you to consider the environmental
performance of your suppliers, and it embodies the concept of continual improvement.

What ISO 14001 requires is that you:

Set an environmental policy and objectives

Achieve compliance with that policy and objectives

Demonstrate that compliance

Continually improve upon environmental system performance.

3 EMAS
EMAS or the Eco Management and Audit Scheme, is a regulation passed by the European
Parliament. Its aim is to allow the voluntary participation in a Community Eco Management
scheme. European member states must establish a voluntary Eco Management and Auditing
Scheme. It applies to any company engaged in industrial activities at a given production site,
organizations wishing to participate must commit themselves to;

Establish an internal environmental protection system

Evaluate objectively the environmental performance of the system

Inform the public on environmental performance

Have the public statement verified by an accredited independent environmental

auditor

EMAS Requirements

EMAS requires participating organizations to;

Carry out an environmental review of the site concerned, it is site specific, not
organization wide

On the basis of the findings, introduce an environmental protection system and audit
system

Following each audit, draw up an environmental statement intended for the public

Have an accredited environmental auditor examine and validate the audit and the
statement

4 Eco Labelling

The Eco labelling scheme is designed to provide consumers with information on the
environmental impact of products. It aims to promote consumer goods with a reduced
environmental impact. Only products which meet specific environmental criteria will be
awarded an Eco label. These criteria will be analysed through life cycle assessment, in which
the environmental impact of the product is determined.

The Eco labelling scheme is administered in each member state by a Competent Body, who
will also help set assessment criteria. These criteria will change as technological advances
are made within each product group. Consequently, companies who continue to develop the
environmental efficiency of their products are likely to set the standards by which others will
be judged.
Although the scheme is voluntary, it is likely to set minimum environmental performance
standards for participating product groups and may provide a significant marketing potential
in both national and European markets. In time the label is likely to become a basic
specification set by purchasers.

5 Life Cycle Assessment

Life cycle assessment is used to analyse the environmental impact of a product at every stage
of its life span, from its design, through its manufacture and use, to its final disposal. Lif
cycle assessment evaluates a product’s environmental performance from ‘cradle to grave’,
focusing on the five main stages that make up the product life cycle;

Pre-production

Production

Distribution

Use

Disposal and Recycling

The concept of the integrated ‘cradle to grave’ approach, will increasingly be adopted by
those assessing product and company environmental performance. It is therefore important
that companies fully assess the product or project’s potential environmental impact at the
design stage to ensure that high environmental standards are incorporated from the start.
 Chapter 5

Environmental Management System

Implementation

Chapter 5

Environmental Management System Implementation

1. Preparatory Review

2. Environmental Policy

3. Environmental Aspects
1 Preparatory Review

ISO 14001 has no requirement for an organization to do a preparatory review. The logic
behind this is that it is not an assessable part of an established system; and, in truth, it is hard
to fault the logic. However it is well nigh impossible for an organisation to establish an
environmental management system without having actioned some sort of initial review. To
this end ISO 14001 provides guidance.

This review is the basis for establishing the environmental management system., therefore
the thoroughness of the review is paramount. It should consider all aspects of the
organisation, establish its strengths, weaknesses, the risks it faces and the opportunities for
reducing costs or increasing its environmental performance or profile.

The review should be conducted for normal, abnormal and possible emergency situations,
and cover the following four key areas;

 Legislative and regulatory requirements

 What is the relevance of;

 National environmental regulations

 National health & safety regulations
 International directives and standards

 Environmental and registration of significant environmental aspects

What are the effects of -

Product
procurement of materials
packaging
use by end user
disposal

Processes
environmental interactions
health & safety interactions

Potential Emergencies
project possible emergencies and consequences.

 Examination of all existing environmental management practices and procedures

for;

Products
Processes
Sub-contractors.

Measurement of feedback from the investigation of previous incidents and non

compliance with legislation and regulations or existing policies and procedures

The review report should highlight the nature and extent of deficiencies and problems, and
what priority they should be tackled in. It should also detail an improvement programme,
identifying the resources required.

2 Environmental Policy

Introduction

There is a danger that the environmental policy is seen as window dressing. The Standard
requires that organisation develop a policy detailing their commitment to responsible
environmental performance. That the poicy must be publicly available tends to detract from
the fact that it should be used as a basis for developing more specific environmental
objectives and targets throughout the different levels of the organization. The policy must
therefore state the organisation’s commitment to environmental improvement; set a clear
goal for environmental achievement, and provide the frame work within which the specific
objectives can be set.

The policy also serves as a mission statement and proof of senior management commitment
to the implementation of an EMS. As such the policy is obviously a living thing. Its
application will doubtless result in changes to the organisation, from a day to day activity
level all the way to strategic planning. New perspectives are bound to develop as the whole
organisation begins to realise the interaction between business activities and the environment.
This in turn will lead to refinement of the policy.

Setting the policy is the responsibility of senior management at board level. If the
organisation is part of a larger corporation, then it must be compatible with the corporate
policy, and endorsed by the corporate body. The content and the nature of the policy will
depend on the type of organisation and its activities. While the Standard recognises this, there
are some basic requirements which must be met, the policy must:

Be relevant to the organisation and the scale of its activities

Be consistent with other organisational policies

Reflect the organisational goals

Commit the organisation to legal compliance

Commit the organisation to ongoing improvement

Preparing the Policy

After the preparatory review identify the policy areas which were highlighted. From these
areas draw up your draft policy. Rather than starting with a blank sheet of paper, consider the
following when developing your policy:

At a minimum it must ensure compliance with regulatory and legal requirements

Polluting releases such as emissions, waste and effluents are minimised or eliminated.
Aim for pollution free processes.

That releases are managed to ensure minimum environmental impact.

There should be ongoing improvement with regard to environmental impact. Try to

adopt a ‘sustainable development’ principle, not compromising the ability of future
generations to meet their own needs, while achieving your own

Gain the commitment of all employees to improve the environmental performance of

the company
 Raw materials, energy, and water as used as effectively as possible. Try to use
renewable or recycled materials

The use of environmentally responsible suppliers and sub contractors. Expect

standards similar to your own from them

Sourcing of raw materials from non-renewable sources is minimised

Handling of materials and waste minimises the risk of accidental environmental

impact

New product or service development examines and minimises environmental impact.

Adopt ‘cradle to grave’ type assessments

The environmental impact of transport and distribution is minimised and an

environmentally sound transport policy is adopted

Assist customers in the use and disposal of products in an environmentally sensitive

way

Include environmental considerations in investment strategies and decisions

Personnel are trained in the implementation of the EMS

Ongoing liaison with the local community

Regular monitoring of environmental performance and auditing of the EMS

Once you are happy with the draft have each senior manager review. Again we are looking
for ownership. It is important that those responsible for making the system work are involved
in its establishment. Review the feedback and make the necessary changes. The draft policy
should now meet the following requirements;

Relevant

Does it relate to your company’s activities, your product, the aspects that were
identified in the preliminary review?

Comprehensive

Does it include all environmental impacts, pollution risks, project and strategic plans?

Consistent

Is there conflict with your quality system or health and safety policy?

Effective

Is it achievable, can you turn it into actions and measures?

 Improvement

Does it contain a commitment to improvement that is realistic and acceptable by your

company?

Public

How does your company plan to make it available to the public?

The time has now come to present the draft to senior management for their final approval.
The best strategy is to have a meeting specifically for discussions of the content of the policy
and agreement to its final wording. Circulate the draft to the various members in advance of
the meeting, so that they have time to read it.

At the meeting, check that it has been read. Give an overview of the function of the policy,
the requirements it must achieve, and where it fits in the overall scheme. Explain the content
of the policy and how conformance will be measured. It is important to obtain a consensus at
this meeting. Listen to comments, document changes, but always keep in mind that the policy
must fit your company and be achievable. After the meeting, circulate the final version for
confirmation.

3 Environmental Aspects

Introduction

ISO 14001 defines an environmental aspect as:

‘Element of an oraganisation’s activities, products or services which can interact with

the environment.’

And an environmental aspect as

‘Any change to the environment, whether adverse or beneficial, wholly or partially

resulting from an organisation’s activities, products or services.’

Environmental aspects include:

Controlled and uncontrolled emissions to atmosphere

Controlled and uncontrolled discharges to water

Solid and other wastes

Contamination of land

Use of land, water, fuels and energy, and other natural resources
 Noise, odour, dust, vibration and visual impact

Aspects on specific parts of the environment including ecosystems

Identifying Environmental Aspects

Environmental aspects are either direct or indirect and can be further sub divided into:

Resource usage aspects

Pollution aspects

Direct Aspects

Aspects are considered to be direct when they are directly controllable by the company
implementing them

Indirect Aspects

Indirect aspects are those aspects which the company’s activities may indirectly influence.
Such as the surrounding countryside, trees, plant life, Wild life, and landscape.

Resource usage aspects result in something being extracted from the environment, while
pollution aspects result in something being put into the environment. Aspects should be listed
and then rated according to their risk significance.

Ideally, the whole life cycle should be evaluated; however, the scope is usually restricted to:

Inputs to the process

The process itself

Outputs from the process

Service activities or support functions

Quantifying Environmental Aspects

The first step towards quantifying environmental aspects is to generate a process flow
diagram. Onto this, the waste stream then can be superimposed and a mass balance
calculated.

Flow Diagram

The process flow diagram traces the complete process from the input of raw materials to the
eventual output of completed product. It should be detailed enough to identify the changes in
material flow from one operation to the next.
Ensure that there are no missing operations or activities, and that inputs or outputs do not
appear from nowhere. Finally, compare the diagram with the actual process to ensure that it
does accurately reflect what happens.

Waste Streams

The chemical industry produces toxic wastes as by-products when producing dyes, synthetic
fibres, paints and plastics. Pharmaceutical companies produce very dangerous wastes as by
products when chemicals are synthesised. Plating shops produce sludges containing heavy
metals.

Problems can arise with waste disposal. If landfill sites are poorly designed or managed, it
can lead to leakage into rivers and aquifers.

Identify all obvious waste streams by type, solid, liquid or gas, whether hazardous or not.
Identify them either as process or operator caused, then search out the less obvious streams,
such as:

Leaks, spillages
Discharge points
Storage areas
Mass Balance

Mass balance can be used to identify unknown quantities such as waste. It is at best, an
estimation, based on the principle that:

Mass in = Mass out

Record all known inputs and known outputs, but exclude energy. Convert to standard weight
measurement units to allow comparison. In theory, the sums of inputs should equal the sum
of outputs; if they do not match, either an input or output has been missed or the data used is
at fault.

Consequences of the Aspect

Assessing the consequences

We now have to consider the consequences on the:

Medium

Community

Aesthetics

Medium

Air
Consider the ozone layer depletion. The main offenders are the CFC (chlorofluorocarbons)
family of chemicals and halons. CFCs are used as cleaners and degreasers in electronic
circuit board manufacture, metal machining and processing, and garages. They are used as
foaming agents in synthetic foam for packaging, insulation and fast food cups and containers.
Accidental release occurs when refrigerators and air conditioners are scrapped. Halons are
used in fire extinguishers designed for electrical fire fighting.

With global warming, carbon dioxide (CO 2 ) is the main contributor to the concentrations of
greenhouse gas. It is produced by the burning of fossil fuels (coal, oil and gas). Deforestation
has also produced a significant increase. Other greenhouse gases are methane, produced from
agriculture, fossil fuel extraction, and decomposing landfill waste, and CFCs.

Poorly maintained processes, machinery, and vehicles can all lead to increased consumption
of fossil fuels. So can operating with inefficient processes, or those which do not use the
most effective means of energy saving. Poor planning can result in more deliveries resulting
in wasted fuel and needless carbon dioxide emission.

Water

Pollution of the aquifer and damage to aquatic life.

Acid rain involves hydrocarbons and acid substances such as sulphur and nitrogen oxides,
which are produced by burning coal and oil. The acid gases can travel long distances before
being washed out in rain, mist or snow. Where the soil is sufficiently alkaline, the acid rain
has been neutralized. But in areas where the soil is less alkaline, the acid has contaminated
the rivers and lakes, killing off aquatic life.

Land

Contamination and usage

Is wood such as mahogany or teak obtained from unmanaged tropical forests? Much
‘executive’ office furniture contains such wood. Deforestation is a very emotive issue.
Forests play a vital role in regulating the global climate by locking up large amounts of
carbon dioxide during photosynthesis.

Community

Residential and Industrial Neighbours

Many industrial processes affect the health or quality of life of the people who live in the
surrounding area. Their safety can be endangered, property devalued, and the natural
characteristics of their environment and countryside destroyed. While much of these aspects
may be intangible, consider transport of materials and the associated heavy traffic; dangerous
chemicals and toxic waste being transported without due care; unsightly industrial sites and
buildings, noise; dust, smells litter and general nuisance; destruction of the wild habitat;
removal of trees and hedgerows.
What is the effect on the surrounding industrial neighbours? Would they have to be
evacuated in an emergency? How would an explosion of fire affect their processes or
materials? Could it lead to a chain reaction?

Aesthetics

Visual considerations associated with the site, including dereliction, should be evaluated.

Rating the consequences

Any rating system has to be considered as subjective. It establishes criteria for a high,
medium and low rating by describing and comparing the aspect, on media, neighbours and
aesthetics.

Criteria to consider are:

High Rating

Pollution of Aquifer
Highly visible
Close to domestic dwellings

Medium Rating

Wind-borne pollution, grit, dust etc.

Pollution of streams/ rivers
Industrial neighbours downwind
Discoloration of surrounding vegetation

Low Rating

No neighbours
Contained site
Toxic waste to landfill
Inert solid waste
Not visible

Initially the high, medium and low ratings for both the likelihood and consequences of the
aspect will suffice. Later on it may be necessary to refine them into the following
classifications:

A certainty
Likely or frequent
Probable
Possible
Remote
Highly improbable or impossible
Assessing the Significance

If an aspect is covered by legislation it is obviously ‘significant’. However, seemingly

insignificant aspects, in global terms, may be of extreme concern to interested parties.
Complaints from neighbours may well indicate that there is a nuisance from noise, fumes,
odours, etc. These may not be covered by legislation but still represent a significant
environmental aspect. Customers may have comments on types of materials used or disposal
problems. There may also be concerns from trade associations or pressure groups over
materials and processes.

Environmental Risk Assessment

Once the evaluation of environmental aspects is completed, we can consider the

environmental hazards and assess the risks and consequences. From there, a risk reduction
plan can be formulated. Hazard and risk can be defined as:

Hazard - ‘The potential to cause harm, including ill health, and injury, damage to property,
plant, products or the environment, production losses or increased liabilities’. This could
include the toxicity of a substance, a method of work, or a hazardous incident.

Risk - The likelihood that a specified event will occur due to the realisation of a hazard by or
during working activities or by the products and services created by work activities, and the
severity of the harm’.

These definitions can be further refined to differentiate environmental hazard and risk from
health and safety risk.

Environmental Hazard - ‘Any situation which in particular circumstances could lead to the
degradation, directly or indirectly, of the quality of the environment in the short or longer
term’.

Environmental Risk - ‘A measure of potential threats to the environment which combines

the probability that event will cause or lead to degradation of the environment and the
severity of that degradation.

When evaluating environmental aspects on a risk basis, we need to consider what the
probability is of the event happening, then what would be the consequences should the event
occur.

The hazards should be kept in the same four categories of:

Physical

Chemical

Biological

Natural
Each hazard should be assessed against a range of risks.

For example:

Leakage of heating oil from a storage tank could result from:

- spillage while filling

- fracture of feed pipe

- collision by vehicle

- corrosion

- vandalism
 Environmental Risk Assessment

Hazard Risk Legislation Probability of Environmental Hazard

Occurrence consequence Rating
Y N H M L score H M L Score
1. 1. Spillage while filling x x 4 x 3 12
Leakage of heating oil
2. Rupture of tank x x 2 x 5 10

3. Breakage of feed pipe x x 2 x 4 8

4. Collision by vehicle x x 5 x 5 25

2. 1.

2.

3.

4.

Consequences Probability
Negligible 1 Significant 4 Improbable or impossible 1 Probable 4
Slight 2 Highly significant 5 Remote 2 Likely or frequent 5
Minor 3 Major 6 Possible 3 Certainty 6
We can assess the potential frequency of occurrence and the environmental consequence if
the event happened. Take into account factors which could either increase or reduce the risk.
To reduce the subjectiveness and make the assessment more quantitative, each condition can
be given a weighting factor for seriousness. The two assessments can then be multiplied
together and a rating obtained.

In this way, the hazards and the risk that they present are identified and a plan can be
formulated to reduce or eliminate them.

3 Objectives and Targets

We have determined our environmental aspects and rated their significance. Now we must
set objectives based on these, develop improvement plans and set targets. There is no point in
setting objectives which are unachievable. The problem is that while many objectives are
only achievable in theory, the practice of achieving them is quite another thing. There must
be commitment from individuals, especially middle managers. It can be said that objectives
are how we demonstrate the reality of the environmental policy, and how seriously we take
it. It has to be stressed to the point of pain that objectives must be both practical and
achievable. They should act as an incentive for action.

Obviously the aspects which were identified as significant, during the rating process, have to
be managed. It would be logical to assume that each aspect must therefore have a
corresponding objective and improvement plan. This need not necessarily be so. The
practicality of improving everything at the same time is questionable, and the existence of an
objective does not mean an automatic improvement with respect to an associated aspect.
Yes, we are trying to achieve a year on year improvement of our overall environmental
performance, but not necessarily in all areas at all times. What is sought here is strategic not
short term improvement.

If we consider the situation where an aspect is under control, it is perfectly acceptable to

leave it like that. Our objective could be to ensure that it remains under control at all times.
On the other hand it could be that we have identified an significant aspect, but do not have
the finance to take any action. Here the objective could be to review new techniques as they
become available, to try to identify a lower cost alternative.

By realising that not all objectives need be linked to improvement, we can therefore link all
significant aspects to objectives. What is vital is that there is evidence of a relationship
between each significant aspect and at least one objective.

Categorising Objectives

Objectives can be considered in three categories:

Control objectives
Monitoring objectives
Improvement objectives

Control objectives
When an aspect is being successfully managed, the objective would be to stress the necessity
to ensure that all the controls relating to that aspect are applied. The aspect could be linked to
another objective. Where improved performance is not currently feasible, due to cost or
technology, then it could be linked to a monitoring objective.

Monitoring objectives

As we have mentioned improvement may be possible, but not currently practical, due to a
variety of reasons ranging from technology through resources and finance. In these cases, we
would set monitoring objectives, where the commitment would be to monitor or research the
areas likely to bring about a change in circumstances.

Improvement objectives

These will always be necessary to demonstrate ongoing improvement in environmental

performance. Improvement objectives must be linked to an improvement plan, and relate to
the aspects the company has decided to take action on.

Objectives need to be developed too. They form an integral part of the overall improvement
process of reducing significant aspects. They should be comprehensive, be integrated into the
business from senior management to shop floor level, and be motivated.

Setting Objectives

Objectives should be set to allow all company employees to have personal goals for
improving environmental performance. There is no best practice to set objectives, or to
determine where to concentrate environmental improvement. In setting objectives, the
following considerations should be taken into account:

Is the aspect subject to legislative or regulatory control as specified in the Aspects

Register?

Is there a compliance issue with other targets or objectives detailed in the Aspects
Register?

How does it impact on operational, business or financial requirements

Views of interested parties

The environmental policy

Do not fall into the trap of thinking that just because an aspect has been given a rating of
highly significant it can be improved. There is a need to do some level of evaluation based on
legislative requirements, effectiveness of existing controls, and the perceptions of interested
parties. The method shown is one recommended by The Institute of Environmental
Managers.
Legislation

(A) Is the issue subject to legislative or regulatory control?

If yes, give an automatic rating of 3. If it is likely to come under regulations in the

foreseeable future, or if indirect control is likely to be significant, rate between 1 and 3
depending on foreseeable impact.

(B) Are legislative or regulatory requirements being complied with?

If not, or there is substantial risk of requirements not being complied with, give a rating of 3.
If there is a minimal risk of failure to comply, or where future legislative developments
would cause a problem., but it would not be of great significance to the company, rate as 1 or
2.

Interested Parties

(A) Could the aspect be the cause of complaints?

Rate between 1 and 3 depending on the potential implications of the complaint. For example,
a high media profile would rate as 3.

(B) What is the potential of the aspect to cause complaints?

Rate between 1 and 3 depending on the nature of the complaint. If the issue has been the
cause of ongoing complaints, rate as 3, occasionally substantiated complaints - 2,
unsubstantiated complaints - 1.

Financial Implications

(A) Is the aspect associated with avoidable costs?

Rate between 1 and 3 depending on the significance of the cost. If the aspect is resulting in
very high environmental or resource costs, rate as 3. Significant costs, which are rising - 2,
significant costs - 1.

(B) What is the potential to reduce costs?

Rate between 1 and 3 depending on the extent to which costs are already being effectively
controlled.

Customers

(A) Is the aspect likely to be of interest to customers?

Rate between 1 and 3 depending on the extent of customer interest. If the aspect is an
important factor in customer decision making, rate as 3. Modest factor -2, could become a
factor - 1.

(B) To what extent are customer interests being met?

Rate between 1 and 3 depending on the extent to which customer interests are already being
catered for.

Improvement objectives are most likely when the sum of (A) gives a higher score than the
sum of (B), i.e. where there is divergence between the importance of the aspect and the
effectiveness of its management. Remember though, that where legislative or regulatory
considerations require action, an improvement object will not be optional.

Objectives are likely to change over time for a variety of reasons. As objectives are
implemented, aspects that were priorities will be minimised. Pressures from customers and
interested parties can change circumstances and result in the setting of new priorities. New
technologies may produce alternatives to solutions previously considered prohibitively
expensive.

A management activity will be the routine reassessing of the relevance of existing objectives.
Modifying them where necessary or even deleting them, and the development of new
objectives. The assessment must also ensure that these objectives still reflect the push for
continual improvement.

The motivational aspect of objectives can be difficult. Make objectives too aggressive and it
can be distinctly demoralising, even impacting on the credibility of the whole
implementation process. Make them too achievable and they fail to act as the drivers of
innovation and improvement. However, they must be readily understood by all company
employees, especially those to whom they apply.

Once the objectives have been identified, they will need senior management approval and
commitment. There then has to be ‘buy in’ throughout the organisation. While training will
play its part, consider incorporating objectives into job specifications, performance
appraisals, etc.

Targets

Targets should be specific measurable detailed performance requirements which arise from
the objectives and which are set to ensure that each objective is achieved within the specified
time frame. Remember ‘if you can’t measure it, you can’t manage it’, it is essential that some
sort of quantifiable measurement is in place. Avoid vagueness, terms like minimise or
maximise have no place here. We must be specific, ‘reduce the weight of paper waste by a
minimum of 50% over the next 12 months’.
 Chapter 11

Glossary

1 Acronyms
General

ABC Activity Based Costing

BOD Biological Oxygen Demand

ISO 9000 International Quality Management System

BS 7750 Specification for Environmental Management Systems

BS 7850 Total Quality Management Standard

BS 8800 Health & Safety Systems Standard

ISO 14000 Environmental Management Systems - General Guidelines

ISO 14001 Environmental Management System Specification

ISO 14010 series Guidelines for Environmental auditing

ISO 14020 series Environmental Labelling

ISO 14031 Environmental Performance

ISO 14040 Life Cycle Assessment

ISO 14060 Environmental Aspects in Product Standards

CATNIP Cheapest Available Technology Not Involving Prosecution

CFCs Chlorofluorocarbons

CHP Combined Heat & Power

EA Environmental Audit

EAC European Accreditation of Certification

EAPS European Aspects in Product Standards

EARA Environmental Auditors Registration Association

EIA Environmental Impact Assessment

EL Environmental Labelling

EMAR Eco Management Audit Regulation

EMAS Eco Management Audit Scheme

EMS Environmental Management System

EPE Environmental Performance Evaluation

EPI Environmental Performance Indicators

EVABAT Economically Viable Best Available Technology

ICC International Chamber of Commerce (Based in Paris)

LCA Life Cycle Analysis or Life Cycle Assessment

NIMBY Not in MY Back Yard

PCBs Polychlorinated Biphenyls

United Kingdom specific

BATNEEC Best Available Technique Not Entailing Excessive Cost

BPEO Best Practice Environmental Option

CHIP Chemical Hazards & Information Packaging

CIMAH Control of Industrial Major Accidents & Hazards

COSHH Control of Substances Hazardous to Health

DoE Department of Environment

EA Environmental Agency

EPA Environmental Protection Act 1990

HMIP Her Majesty’s Inspectorate of Pollution

HSC Health & Safety Commission

HSE Health & Safety Executive

IPC Integrated Pollution Control

LA Local Authority

LAWDC Local Authority Waste Disposal Company

NRA National Rivers Authority

NVQ National Vocational Qualification

SEPA Scottish Environmental Protection Agency

WCA Waste Collection Authority

WRA Waste Regulation Authority

U.S.A. Specific

CMA Chemical Manufacturers Association

EPA Environmental Protection Agency

GEMI Global Environmental Management Initiative

NIST National Institute of Standards and Technology

OSHA Occupational Safety and Health Administration

2 Glossary

Appropriate Technology

Used to describe technology that is suitable to the situation, such as third world or developing
countries where it is easy to use and repair.

BATNEEC

Best available techniques not involving excessive cost. Certain polluting processes are
required to use BATNEEC. The pollution inspectors decide on the term’s definition and can
change this definition when improved techniques or technology becomes available.

Biological Oxygen Demand (BOD)

A measure given to polluting organic industrial effluent when it is discharged into water
courses; the less polluting the effluent, the higher the BOD level. This type of effluent feeds
naturally occurring bacteria, consuming oxygen thus endangering aquatic life.

BPEO

Best practicable environmental option. Companies are encouraged to undertake systematic

decision processes with a view to seeking the BPEO that provides the least damage or most
benefit to the environment at an acceptable cost.

CFCs (Chlorofluorocarbons)
Previously used as solvents, aerosol propellents, refrigerants and in foam manufacture. The
signatories to the Montreal Protocol have agreed to eliminate CFCs by the year 2000.

Co-disposal

The mixing of liquid industrial waste with house hold waste; the household waste absorbs the
liquid and natural degradation helps neutralise the industrial waste. This practice has been
banned in the USA because of leakage into water courses.

Cradle to Grave

The life cycle of a product from conception to disposal.

Duty of care

An Environmental Protection Act requirement that all waste producers are liable for their
waste, even when it is in the hands of disposal contractors.

Eco-labelling

A consumer product scheme; the product must meet certain environmental criteria to obtain
the label.

Environmental Assessment

Now widely used to mean a study required by local authorities under the planning process for
certain types of development.

Environmental Impact Assessment (EIA)

A formal assessment of the total environmental effect of a product, process or project. It is a

legal requirement for some specific projects.

Environmental Targets

Detailed performance requirements, Quantified wherever practical, applicable to the

organisation, that arise from the environmental objectives and that need to be set and met in
order to achieve those objectives.

Eutrophication

Rich in nutrients, usually used to describe problems in euphotic waters. Can cause algal
blooms resulting in deoxygenation. Phosphates from sewage, detergents and fertilizers are
one of the common nutrients.

GEMI
Global Environmental Management Initiative is a Washington D. C. based organisation that
details with international business and environmental issues.

Hazardous Waste

A class of industrial waste that has to be disposed off in a controlled manner. Some toxic
organic wastes have to be incinerated at high temperatures.

Interested parties

Those with an interest in Environmental effects of an organisation’s activities, products and

services. They include those exercising statutory environmental control over the organisation,
local residents, the organisation’s work force, investors, and insurers, customers and
consumers, environmental interest groups and the general public.

IPC (Integrated Pollution Control)

Air, land and water are treated as a single medium. Industry is given a single release limit
that applies to all three.

Leachate

Liquid leakage from waste disposal sites.

PCBs (Polychlorinated Biphenyls)

Toxic and bioaccumlative synthetic chemicals used in older electrical equipment. Disposal by
incineration can produce dioxins and polychlorinated dibenzo-furans if the incineration
temperature is below 12000C.

Organisation

Any organised body or establishment, for example, a business, company or society. For
bodies or establishments with more than one site, a single site may be defined as an
organisation.

Polluter Pays

A requirement that a polluter is totally responsible for all cost, including environmental
impact.

Scrubber

A device used in chimneys to remove unwanted gases such as sulphur dioxide. Gas emissions
are reduced, but it produces solid or liquid wastes which must be disposed off.
Super fund

A super fund of $ 1,600 million was set up by the Comprehensive Environmental Response,
Compensation and Liability Act in 1980 to pay for the clean up of the most contaminated
sites and dumps in the USA.

Waste Minimisation

Cutting the amount of industrial waste produced.