In part two of three articles, WAMITAB trainer and assessor Linda Waite follows on from her previous article regarding acquiring the correct environment permit for your vehicle recycling operation and discusses what further information needs to be included.
Your Accident Management Plan forms part of your Management System (MS). It must identify potential accidents, e.g., equipment breakdowns, enforced shutdowns, fires, vandalism, flooding, or any other incident which causes an unexpected change to normal operations, such as bad weather.
For each potential incident, it must also state the likelihood of the accident happening; the consequences of the accident happening; measures you’ll take to avoid the accident happening; and measures you’ll take to minimise the impact if the accident does happen. Your accident plan must also say how you will record, investigate and respond to accidents or breaches of your permit.
Your accident plan must include the date it was reviewed, when it will next be reviewed; a list of emergency contacts and how to reach them; a list of substances stored at your site, and your storage facilities; and the forms to record accidents on.
Consider taking the following actions if you think they are relevant to the operations you carry out at your site: Make emergency services aware of your activities; take out insurance to cover the cost of clean-up following an accident; check if you’re in a flood risk area and sign up for flood warnings; develop a system to allow access to important information away from your site.
Online security is important, you can take some simple steps to protect your business against online security threats. Good online security will help make sure your business does not cause pollution. Any pollution that does occur is your responsibility as the permit holder.
If you have a waste or installations permit you must display a notice board at or near the site entrance telling the public about the site. It must include the permit holder’s name (company name); an emergency contact name and telephone number; a statement that the site is permitted by the EA/NRW; the permit number; Environment Agency telephone number 03708 506506 and the incident hotline 0800 807060.
It is important to consider whether your operations could be affected by a changing climate and that you plan for this. Climate projections for the UK suggest that we can expect higher average temperatures – particularly in summer and winter; more heatwaves and hot days; rising sea levels; changes in rainfall patterns and intensity and more storms. Basing your contingency plans and accident prevention and management plans on the current climate may not help you manage future risks.
Your MS requires you to have a Complaints Procedure that records any complaints you receive in relation to activities covered by your permit e.g., from neighbours about noise, odour or dust; how you investigate those complaints and any actions taken as a result of complaints.
Your MS needs to show how you manage staff competence and training records. You need to have enough staff and resources to make sure the site is run effectively in order to comply with your permit. Your MS needs to explain who is responsible for what procedures and who is technically competent. For each of your managers, staff and contractors, make a list of any roles they carry out that relate to activities covered by your permit. You will also need a procedure to check your staff and contractors have taken the training or qualifications required for the work they do; record any training, refresher training or qualifications taken by them.
Your MS must show how you keep any records required by your permit. In some cases, the permit will tell you how long to keep a record for, otherwise, you must consider how long you’ll need to keep different records for and write this in your management system. You must keep records to show how your management system is being implemented in line with the requirements of your permit.
You need to keep permits issued to the site; other legal requirements; your risk assessment; all management system plans; any plans required by the application or permit depending on your type of activity, e.g., odour management plan; all operating procedures; staff competence and training; emissions and any other monitoring undertaken; compliance checks and complaints made, findings of investigation and actions taken; audits of the management system, findings (reports) and actions taken; management reviews and changes made to the management system. You also need to include copies of your plans with your management system if your permit requires you to implement an approved plan or you have been asked to do this because there’s a problem at your site.
Click on the following link to read Management Systems and Environmental Permits for ATFs – Part One
You can contact Linda on 07814 932225 or email her at firstname.lastname@example.org if you require further information.