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2. General management appropriate measures

Environment Agency

October 19
12:35 2023

1. You must have and follow an up to date, written management system. It must incorporate the following features.

You must 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

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

You must implement 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
  • the management of change (including legislative changes and ELV or components classification changes)
  • emergency preparedness and response
  • making sure you comply with environmental legislation

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

  • 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.

You must review the development of cleaner technologies and their applicability to site operations.

When installing new or upgraded equipment, you must assess the environmental impacts from its operating life and eventual decommissioning.

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

You must compare your sites performance against relevant sector guidance and standards on a regular basis.

You must have and maintain the following documentation:

If required, you have and maintain the following documentation:

2.2. Staff competence

1. Your site must be operated at all times by an adequate number of staff with appropriate qualifications and competence.

2. The design, installation and maintenance of infrastructure, site and equipment must be carried out by competent people.

3. You must have appropriately qualified managers for your ELV activity who are either:

4. Non-supervisory staff must be reliable and technically skilled. Their skills may be based on experience and relevant training.

2.3. Accident management plan

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

2. The accident management plan must identify and assess the risks the facility poses to human health and the environment.

3. Areas to consider include:

  • ELV types and the risks that they pose
  • robust ELV acceptance procedures to avoid receiving unwanted items, such as gas cylinders
  • abatement systems failure for example, interceptors
  • equipment failure (for example, over-pressure of vessels and pipework, blocked drains)
  • containment failure (for example, bund failure, or drainage sumps overfilling)
  • damaged lithium-ion (Li-ion) batteries and any part of the electrical circuit in electric end of life vehicles (EELVs)
  • failing to contain firefighting water
  • making the wrong connections in drains or other systems
  • making sure that interceptors are functioning correctly
  • vandalism and arson
  • extreme weather conditions for example, flooding or very high winds

Assessing the risks

4. You must assess the risk of accidents and their possible consequences by carrying out a risk assessment.

Risk is the combination of the likelihood that a hazard will occur and the severity of the impact resulting from that hazard. Having identified the hazards, you can assess the risks by addressing 6 questions:

  • how likely is it that the accident will happen?
  • what may be emitted and how much?
  • where will the emission go what are the pathways and receptors?
  • what are the consequences?
  • what is the overall significance of the risk?
  • what can you do to prevent or reduce the risk?

5. You must identify any fire risks that may be caused, for example by:

  • arson or vandalism
  • self-combustion, for example within oily rags and overalls
  • equipment failure and electrical faults
  • naked lights and discarded smoking materials
  • use of improper tools
  • hot works (for example welding or cutting), industrial heaters and hot exhausts
  • reactions between incompatible materials
  • neighbouring site activities
  • sparks from forklift trucks and machinery
  • hot loads deposited at the site for example, vehicles involved in collisions resulting in thermal runaway of batteries
  • damaged Li-ion batteries
  • batteries left connected in ELVs causing an electrical short circuit
  • batteries (storage, processing, and handling)

This list is not exhaustive and you must have a fire prevention plan that identifies the risks at your site and meets the requirements of our fire prevention plan guidance.

6. The depth and type of accident risk assessment you carry out will depend on the characteristics of the site and its location. The main factors to consider are the:

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