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2. General management appropriate measures

Environment Agency

December 8
11:03 2022

1. You must have an up-to-date written management system, and activities at your facility must follow it. Your management system must incorporate the following features.

You have:

  • management commitment, including from senior managers
  • an environmental policy that is approved by senior managers and includes the continuous improvement of the facilitys environmental performance, so you can identify pollution risks and minimise them through appropriate measures

You plan and establish the resources, procedures, objectives and targets needed for environmental performance alongside your financial planning and investment.

You implement your environmental performance procedures, paying particular attention to:

  • staff structure and relevant responsibilities
  • staff recruitment, training, awareness and competence
  • communication (for example of performance measures and targets)
  • employee involvement
  • documentation
  • effective process control
  • maintenance programmes
  • management of change
  • emergency preparedness and response
  • making sure you comply with environmental legislation

You check environmental performance and take corrective action, paying particular attention to:

  • monitoring and measurement
  • learning from incidents, near misses and mistakes, including those of other organisations
  • records maintenance
  • independent (where practicable) internal or external auditing of the management system to confirm it has been properly implemented and maintained

Senior managers must review the management system to check it is still suitable, adequate and effective at least annually. Improvements should be carried out within a reasonable time, based on the level of environmental risk.

You review the development of cleaner technologies and their applicability to site operations. We would expect cleaner technologies to be considered:

  • as a result of substantiated pollution incidents
  • when reviewing management systems
  • when planning investment decisions, for example new items of plant

When designing new plant, you must assess the environmental impacts from the plants operating life and eventual decommissioning. You must make sure that new plant is authorised by your environmental permit.

You must have a written procedure for proposing, considering and approving changes to procedures or infrastructure related to storing or treating waste or pollution control. This is so you can track and control the process of change.

You consider the risks that a changing climate poses to your operations. You have appropriate plans in place to assess and manage future risks.

You compare your facilitys performance against relevant sector guidance and standards on a regular basis, known as sectoral benchmarking.

You have and maintain the following documentation as part of your management system:

Your management system must include a schedule of inspection and maintenance for all pollution control infrastructure, including for example the:

  • impermeable surfacing and drainage system
  • ducts of abatement systems

You must have a document control procedure that clearly describes how and when you will periodically review documentation and maintain version control.

Your management system must clearly set out the actual physical capacity of your facility to store and handle waste, which may be less than the quantity limits allowed by your permit. You must specify limits for the maximum:

  • waste storage capacity at any one time
  • daily and annual throughputs
  • residence time for waste

When doing this, you must take into account the characteristics of your facility and the waste types and the pollution risks, for example fire and odour.

Your limits must also reflect the constraints of the available space and waste handling processes. You must include factors like seasonal changes in supplies of inputs, and markets for outputs. More information on understanding capacity is available in our RGN 2 guidance.

2.2 Staff competence

1. Your facility must be operated at all times by an adequate number of staff with appropriate training, qualifications and competence. You must keep records of training, qualifications and relevant experience.

2. If you operate a 24-hour process, you must have:

  • remote or telemetric systems to make sure an alarm would be raised in the event of an incident during unmanned hours
  • appropriate personnel on call to deal with these incidents

You must explain these procedures in your management system.

3. The design, installation and maintenance of infrastructure, plant and equipment must be carried out by competent people, including Construction Quality Assurance where appropriate.

4. You must have appropriately qualified managers for your waste activity who are members of a government approved technical competence scheme and who attend the facility as set out in our attendance guidance.

5. Staff carrying out waste acceptance checks, including sampling and analysis of waste, must be appropriately trained and competent to:

  • classify and characterise waste properly
  • identify whether it is suitable for your facility
  • manage any loads that do not conform to waste acceptance criteria
  • determine end of waste products

2.3 Accident management plan

1. As part of your written management system you must have a plan for dealing with any incidents or accidents that could result in pollution, including near misses.

2. The accident management plan must identify and assess the risks the facility poses to human health and the environment. Particular areas to consider may include:

  • waste types
  • transferring substances, for example filling (including overfilling) or emptying of vessels and containers
  • preventing incompatible substances coming into contact with each other
  • failure of plant and equipment, for example storage tanks and pipework, or blocked drains
  • failure of containment, for example bund failure or drainage sumps overfilling
  • making the wrong connections in drains or other systems
  • failure to contain firefighting water
  • failure of abatement systems
  • hazardous atmospheres in confined spaces
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