Risk assessments for your environmental permit
When you need to do an environmental risk assessment, when the Environment Agency will do it for you, and how to do a risk assessment.
Read this guide to find out:
- when you do or don’t need to do a risk assessment
- when the Environment Agency can do your risk assessment for you
- how to complete a risk assessment
Generic risk assessment for standard rules permits
You don’t need to do your own risk assessment if you’re 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’re 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’re 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 aren’t covered by the generic risk assessment for those standard rules.
For example, if your site creates noise or odour problems for nearby homes, but otherwise meets all the standard rules requirements.
Contact the Environment Agency if this situation applies to you.
Find out what activities are covered by standard rules permits. You’ll 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’re 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 site’s environmental sensitivity)
Contact the Environment Agency before you submit your permit application, if after reading this guide you’re 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.
The Environment Agency can do your risk assessment if you’re 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 don’t, your application will be rejected as it can’t be processed.
Treated sewage effluent or trade discharges
The Environment Agency will generally do your risk assessment if you’re applying for a permit to discharge treated domestic sewage:
- 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 discharge 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 for discharges of treated sewage if any of the following apply:
- you’re a water company or similar large operator
- you’re making a trade or mixed trade and sewage discharge
- your discharge to ground or water is more than 15 cubic metres per day
- your discharge to ground is more than 2 cubic metres per day and you’re in a groundwater SPZ1
How to do a risk assessment
Follow these steps to do a risk assessment.
- Identify and consider risks for your site, and the sources of the risks.
- Identify the receptors (people, animals, property and anything else that could be affected by the hazard) at risk from your site.
- Identify the possible pathways from the sources of the risks to the receptors.
- Assess risks relevant to your specific activity and check they’re acceptable and can be screened out.
- State what you’ll do to control risks if they’re too high.
- 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
- 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 shouldn’t be in the discharge
- visible emissions, for example smoke or visible plumes
If you don’t think any of them are significant risks, you’ll 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’re within acceptable limits or environmental standards. If they are, you don’t 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 haven’t been accurate enough about your risks or problems.
If noise from your site could cause a problem for your neighbours, the Environment Agency will ask you to carry out a more detailed assessment of the noise risks and produce a noise impact assessment report. You will need to employ a noise consultant to do this. This requirement is most likely to affect large waste operations or installations.
For each risk that applies, identify each actual or possible hazard and state (for example in a table):
- the hazard - for example dust, litter, type of visible emission
- 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’ll 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 you’ve already stated in the table - for example ‘low if we apply the management techniques’
|Hazard||Receptor||Pathway||Risk management techniques||Probability of exposure||Consequence||Overall risk|
|Emissions to air: Dust from screening plant 3||People living at Land End Cottage R1 – 400 metres east of the site||Wind-blown||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||Dust could potentially reach the dwelling when a strong wind blows in that direction, approximately 50 days a year||Nuisance - dust on cars, clothing, and so on||Low if we use the management techniques|
|Pests: flies on farmyard manure could move offsite and affect nearby residents||Local residents or school beyond the boundary of the activity||Airborne||Isolation and securing or removing waste that attracts scavengers. Regular inspections by nominated personnel||Waste left unattended could result in problems offsite||Potential for spread of disease and adverse health impacts on vulnerable people||Low if we use the management techniques|
Examples of possible accidents include:
- transferring substances, for example loading or unloading vessels
- overfilling vessels
- plant or equipment failure, for example over pressurised vessels and pipework, blocked drains, fire and contaminated water used to fight the fire escaping into the local watercourse or ground
- releasing an effluent before checking its composition
- inadequate bunding around tanks
There could also be a risk of accidents related to your specific industry.
Assume that operator error will occur at least once every 100 times you carry out an operation, for example you may:
- drop or damage a drum from a forklift
- have a spillage from a tanker
- releases to air, for example from storage of raw materials or wastes, or evaporating volatile organic compounds, dust
- releases to water and land, such as potential leaks or spills from storing or handling liquids or chemicals that could harm the environment
- uncollected run-off from operational and storage areas
- mud that could get off the site
- pests that could get off site, such as flies
- pollutants that are in your release at levels which don`t need emissions limits but where you do need to use other measures to make sure they don’t cause pollution
Read the guide to controlling and monitoring emissions.
You must identify all the receptors that are potentially at risk from your site.
Focus on the main receptors that are at risk, for example for a sewage discharge to ground, the main receptor will be the groundwater beneath your site, but there may be other receptors nearby that you must also identify.
- ancient woods - use the Magic map application to check for these
- anywhere used to grow food or to farm animals or fish – check local maps or contact the Environment Agency
- drain and sewer systems – you can ask your local water company about these
- factories and other businesses
- fields and allotments used to grow food
- groundwater beneath your site – check if you’re in a groundwater protection zone
- homes, or groups of homes (such as villages or housing developments) – you can check local maps or ask your local council about these
- playing fields and playgrounds
- private drinking water supplies – you can ask your local council where these are located or ask your neighbours if they have a private supply
- regionally important geological sites – you can ask your local council about these
- schools, hospitals and other public buildings
- water, for example ponds, streams, rivers, lakes or the sea – you can check where these are on local maps or with the Environment Agency
- conservation and habitats protected areas and areas of scientific interest
In your risk assessment you need to include a plan that’s to scale, for example on an Ordnance Survey map. It must show:
- your site
- all the nearby receptors
Check for conservation and habitats protected areas and areas of scientific interest
- protected wetlands (Ramsar sites)
- sites of special scientific interest
- special protection areas
- special areas of conservation
The ‘designations’ tab of the MAGIC map allows you to search for land with a statutory designation.
Your local council, wildlife trust or records centre can also provide information on conservation sites or protected species.
Historic buildings, listed buildings and archaeological sites
You can check with any of these to find out if you have historic or listed buildings, or archaeological sites, near your site:
- your local planning authority
- the Institute of Historic Building Conservation (IHBC)
- the National Trust
- the county archaeologist at your county council
Risks from your specific activity
There are additional risk assessments you must do depending on:
- the activity your bespoke permit relates to
- where substances are released or discharged into the environment
When you’ve done one of those risk assessments it will show if you need to take further action regarding the substances you release.
Risk assessment for installations, waste and mining waste operations and landfill sites
If you’re an installation or a landfill site, or your activity involves storing, processing or treating waste or biodegradable waste, you must do one or more of the following, depending on the substances you discharge and where they’re discharged to:
- assess the risks of your air emissions
- calculate the global warming impact of your air emissions
- assess risks to groundwater
- assess risk to groundwater from landfill leachate
- assess risks to surface water from hazardous pollutants
- assess risks to surface water from sanitary and other pollutants
If you’re applying for a permit for inert waste landfill or deposit for recovery activities this template helps you consider all the risks from your activity.
Installations and waste operations must also decide how to treat, recycle or dispose of waste
Risk assessment for treated sewage or trade effluent discharges to surface water or groundwater
If your activity discharges treated sewage or trade effluent into surface water or groundwater, you’ll need to do one or both of the following:
- assess risks to surface water from hazardous pollutants
- assess risks to surface water from sanitary and other pollutants
- assess risks to groundwater
- assess risks to groundwater from infiltration systems
Risk assessment for intensive farming
You must assess risks for intensive farming if your activity involves intensive farming.
Help to assess risks for your specific activity
You can use the Environment Agency’s risk assessment tool to complete and submit any assessment of risks for your specific activity, except for assessing risks for intensive farming.
- includes instructions on how to develop risk assessments
- does calculations required for your risk assessment and screens out insignificant releases
- presents data so that the Environment Agency can assess it properly
This tool uses Microsoft Access. Contact the Environment Agency at firstname.lastname@example.org to get this tool.
The tool’s calculations are ‘worst case’ estimates that are often larger than if you do calculations using detailed modelling.
If you don’t want to use this tool you can:
- follow the steps in the risk assessment guides
- use other resources such as emission modelling software - you may be charged for this
You can use the J5 Infiltration Worksheet to help you with your assessment for groundwater risk assessments for treated sewage discharges to infiltration systems.
Bespoke permits: detailed modelling
The screening process will help you decide whether your releases to air, water or deposited from air to land are a risk to the environment and whether you need to do a more detailed assessment of them. Assessing the impact of emissions which aren’t screened out and are a risk to the environment is known as ‘detailed modelling’.
Detailed modelling requires specialist knowledge. You can find a consultant to do it for you. They’ll charge for their services. Contact the Environment Agency if you want to do your own detailed modelling.
Submit your risk assessment
Send your completed risk assessment as part of your permit application to the Environment Agency.
Contact the Environment Agency if you need help with your risk assessment.
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