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Guidance: Risk assessments for your environmental permit

Environment Agency

November 21
13:30 2023

Read this guide to find out:

  • when you do or do not need to do a risk assessment
  • when the Environment Agency can do your risk assessment for you
  • how to do a risk assessment
  • how to check for protected sites and species

Generic risk assessment for standard rules permits

You do not need to do your own risk assessment if you are applying for a standard rules permit and can meet all the requirements for that permit.

The Environment Agency has done generic risk assessments for all standard rules permits. These list the potential risks and how to manage them. You need to check the generic risk assessment for the standard permit you are applying for so you understand the potential risks and can manage them effectively.

Risk assessments for bespoke permits

You must do a risk assessment if you want to apply for or change (vary) a bespoke permit, unless the Environment Agency can do your risk assessment.

If you are applying for a bespoke permit but most of your activities are covered by standard rules, you only need to do a risk assessment for the activities or risks that are not covered by the generic risk assessment for those standard rules.

For example, if your site is likely to create noise or odour problems for nearby homes, but otherwise meets all the standard rules requirements, you should complete a risk assessment for noise or odour emissions (for the entire site).

If your site processes biowaste you must make sure that any people living or working near your site are not exposed to unacceptable levels of bioaerosols. The Environment Agency will not usually permit biowaste sites within 250 metres of places where people live or work, unless your risk assessment demonstrates that you are controlling emissions to an acceptable level.

Contact the Environment Agency if this situation applies to you.

Find out what activities are covered by standard rules permits. You will find the generic risk assessment on the same page as the standard rules permit for your activity.

When the Environment Agency can do your risk assessment

You can ask the Environment Agency to do a risk assessment for you in some cases if:

  • you are a farmer discharging certain substances to ground
  • your activities discharge domestic treated sewage to surface water or to the ground (depending on the discharge volume limits and your sites environmental sensitivity)

Contact the Environment Agency before you submit your permit application if after reading this guide you are unsure whether the Environment Agency will do your risk assessment for you.

You must still complete your whole permit application. The Environment Agency will use your completed permit application to decide if it will do your risk assessment for you.

Farmers

The Environment Agency can do your risk assessment if you are a farmer applying for a bespoke permit to discharge any of the following to ground:

  • waste sheep dip
  • waste pesticide
  • pesticide washings (liquid waste left over from washing or cleaning equipment used to apply pesticides)

You must provide all the information required on your application for the Environment Agency to do your risk assessment for you. If you do not, your application will be rejected as it cannot be processed.

Treated sewage effluent or trade discharges

The Environment Agency will generally do your risk assessment if you are applying for a permit to discharge:

  • less than 15 cubic metres of treated sewage to ground, for example from a septic tank or small sewage treatment plant, outside a groundwater source protection zone 1 (SPZ1)
  • treated sewage or trade effluent into a river
  • less than 2 cubic metres of treated sewage to ground in a groundwater SPZ1, for example from a septic tank or small sewage treatment plant

Trade discharge includes those that are a mix of trade effluent and domestic treated sewage which share a treatment facility and the same monitoring point.

You must do your own risk assessment if any of the following apply:

  • you are a water company or similar large operator
  • you are making a treated sewage or trade effluent discharge to surface water which contains specific substances or may have an impact on temperature
  • you are making a treated sewage or trade effluent discharge to a lake, estuary, coastal water or bathing water
  • you are making a trade effluent discharge to ground, including discharges which may have an impact on temperature
  • your discharge of treated sewage to ground is more than 15 cubic metres per day
  • your discharge to ground is more than 2 cubic metres per day and you are in a groundwater SPZ1

Human cemeteries

You must do your own risk assessment if you are applying for a bespoke groundwater activity permit for a human cemetery.

How to do a risk assessment

Follow these steps to do a risk assessment.

  1. Identify and consider risks for your site, and the sources of the risks.
  2. Identify the receptors (people, animals, property and anything else that could be affected by the hazard) at risk from your site.
  3. Identify the possible pathways from the sources of the risks to the receptors.
  4. Assess risks relevant to your specific activity and check they are acceptable and can be screened out.
  5. State what you will do to control risks if they are too high.
  6. Submit your risk assessment as part of your permit application.

You must also include a copy of your risk assessment in your management system.

Risks from your site

In your risk assessment you must identify whether any of the following risks could occur and what the environmental impact could be:

  • any discharge, for example sewage or trade effluent to surface or groundwater
  • accidents
  • odour (not for standalone water discharge and groundwater activities)
  • noise and vibration (not for standalone water discharge and groundwater activities)
  • uncontrolled or unintended (fugitive) emissions, for which risks include dust, litter, pests and pollutants that should not be in the discharge
  • visible emissions, for example smoke or visible plumes
  • release of bioaerosols, for example from shredding, screening and turning, or from stack or open point source release such as a biofilter

If you do not think any of them are significant risks, you will need to state why in your permit application.

You can screen out potential risks from emissions to air, discharges to water or deposition onto land by carrying out tests to check whether they are within acceptable limits or environmental standards. If they are, you do not need to do any further assessment of the pollutant because the risk to the environment is insignificant. The different risk assessments for specific activities explain screening out in more detail.

The Environment Agency can ask you to redo your risk assessment if it thinks you have not been accurate enough about your risks or problems.

For each risk that applies, identify each actual or possible hazard and state (for example in a table):

  • the hazard for example dust, bioaerosols, litter, type of visible emission
  • the process that causes the hazard, for example shredding and turning green waste
  • the receptors people, animals, property and anything else that could be affected by the hazard
  • the pathways how the hazard can get to a receptor
  • what measures you will take to reduce risks
  • probability of exposure, for example whether a risk is unlikely or highly likely
  • consequences what harm could be caused
  • what the overall risk is, based on what youve already stated in the table for example low if we apply the management techniques

Example risks

Hazard: emissions to air dust from screening plant 3

  • receptor: people living at Land End Cottage R1 400 metres east of the site
  • pathway: wind-blown
  • risk management techniques: visual dust monitoring in accordance with local operating procedure. Shift manager is responsible for checking wind strength and direction, and will stop operations if necessary
  • probability of exposure: dust could potentially reach the dwelling when a strong wind blows in that direction, approximately 50 days a year
  • consequence: nuisance dust on cars, clothing, and so on
  • overall risk: low if we use the management techniques

Hazard: pests f

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