How to develop a management system for carrying out flood risk activities under an environmental permit.
You need to create a written management system for your environmental permit. This is a set of procedures describing what you’ll do to manage the risks from the activities covered by your permit.
- standard rules permit, the risks are set out in the generic risk assessment
- bespoke permit, you’ll have identified the risks by carrying out your risk assessment
You can develop and maintain your own management system or use an environmental management system scheme or standard.
The information you need to include will depend on how complicated and risky your activities are. The level of risk will be identified by your risk assessment. For example, if you’re a householder applying to do small scale work in your house or garden with low risks you only need to include:
- a site infrastructure plan showing where the specific activities will be carried out
- your method of work
For larger sites, you’ll need to address all the issues below.
You’ll be in breach of your permit if you don’t put your management system into immediate effect when you start work.
Site infrastructure plan
You must include a scale plan of your site showing:
- where you’ll do your activities
- any activities that you have an exclusion or an exemption for
- areas on or near your site that are vulnerable to flooding
- areas where wildlife is vulnerable or protected
- buildings and other man-made constructions that may be affected by your work
- where you’ll store materials or waste while you’re doing your work
Method of work
This should set out your working methods and what you’ll do to avoid or minimise the risks you have identified in your risk assessment.
Describe in detail the individual operations you’ll be doing on the site. Include enough detail to show how, when, where and for how long you’ll be doing each part of the activity. You must include all temporary works, including ‘enabling works’ that support that main activity.
Individual operations might include:
- unloading and storing materials
- temporary works such as scaffolding
- the construction, engineering or installation methods you’ll use
- the sequence of steps or works
List the steps you’ll take to prevent or minimise risks to the environment from each of your operations. Include what you’ll do at each stage to:
- ensure there’s no increase to flood risk or impact on drainage
- minimise sediment being disturbed and moving downstream
- minimise the impact on biodiversity
- ensure careful storage and disposal of waste
- prevent pollution of watercourses, for example from construction debris or contaminated land
- prevent pollution from static plant, mobile machinery, refuelling and material storage
- prevent or minimise impacts on habitats and wildlife
- prevent the spread of invasive non-native species or plant or animal diseases
Site and equipment maintenance plan
You need to show how you’ll maintain your site’s infrastructure and any machinery.
You must maintain and use machinery according to the manufacturer’s or supplier’s recommendations. You need to record each time you do any maintenance.
You need a plan to show how you’ll minimise the environmental impact of:
- enforced shutdowns
- unexpected conditions, like contaminated sediment or unexpected bank instability
- changes in normal operations, for example due to flooding or extreme weather
Read flood planning guidance to help you follow your environmental permit.
You need to show how you’ll deal with any accidents or events that could result in flood risk or pollution. Your plan must identify potential incidents, such as:
- equipment breakdowns
- enforced shutdowns
- any other incident which causes an unexpected change to normal operations
For each potential incident, your plan must also show:
- the likelihood of the incident
- the likely consequences
- how you’ll try to prevent it
- how you’ll limit the impact
Your accident plan must say how you’ll record, investigate and respond to accidents or breaches of your permit.
It must include:
- the last review date
- the next review date
- a list of emergency contacts and how to reach them
- a list of substances stored at your site
- a list of your storage facilities
- accident report forms
You may need to:
- make emergency services aware of your activities
- take out insurance to cover the cost of cleaning up following an incident
- check whether you’re in a flood risk area and register for flood warnings
- develop a system to allow access to important information away from your site
You need to include a procedure that records:
- any complaints you receive related to the permitted activities
- how you investigated those complaints
- any actions taken as a result of complaints
Staff competence and training records
You need to show you have enough staff and resources to run the site effectively and comply with your permit, who is responsible for what, 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’ll also need a procedure to:
- check your staff and contractors have taken the training or qualifications required for their work
- record any training, refresher training or qualifications taken by your staff or contractors
You’ll need to keep records of:
- permits issued to the site and other legal requirements
- any plans required by the application or permit depending on your type of activity
- your risk assessment and your management system, including your method of work and any plans
- all operating procedures
- any monitoring undertaken, for example water or sediment samples
- staff competence and training records
- compliance checks, findings of investigation and actions taken
- complaints made, findings of investigation and actions taken
- audits of management system, findings (reports) and actions taken
- certification audit reports and any actions carried out, where applicable
- management reviews and changes made to the management system
If your permit doesn’t tell you how long you must keep records for, you can propose how long you’ll keep them. Show this in your management system.
Review your management system
You must have a procedure for checking that you comply with your permit, procedures and management system. Keep a full record of periodic checks.
You must review and update your management system when:
- you make changes to your site, operations or equipment that affect the activities covered by your permit
- you apply to change your permit
- any accident, complaint or breach of your permit occurs
- you encounter a new flood, drainage or environmental problem or issue, and have put new measures in place to control it
You must keep a record of changes to your management system, particularly major changes like:
- changing the method of work
- putting new control measures in place
The Environment Agency may review your management system and recommend improvements after accidents or breaches. It may also ask you to improve your management system if you haven’t identified or minimised risks of flooding or environmental harm.
Make your management system available
Your staff must have access to and understand any sections of your management system that relate to their work.
The Environment Agency may ask to see your management system at any time.
You must be able to explain to people in the surrounding area how you manage your activity and comply with your permits if they request this information.