2. General management appropriate measures
The appropriate measures for the general management of a regulated facility with an environmental permit for the treatment or transfer of WEEE.
1. You must have and follow an up-to-date written management system. It must incorporate the following features.
You have:
- management commitment, including from senior managers
- an environmental policy that is approved by senior managers and includes the continuous improvement of the facility’s environmental performance
You plan and establish the resources, procedures, objectives and targets needed for environmental performance alongside your financial planning and investment.
You implement your 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 and records
- effective process control
- maintenance programmes
- the management of change (including legislative changes and waste classification changes)
- emergency preparedness and response
- making sure you comply with environmental legislation
You check environmental performance and take corrective action paying particular attention to:
- monitoring and measurement
- 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 and operations to confirm it has been properly implemented and maintained
Senior managers review the management system at least annually to check it is still suitable, adequate and effective.
You review the development of cleaner and more efficient technologies and their applicability to site operations.
When designing new plant, you make sure that you assess the environmental impacts from the plant’s operating life and eventual decommissioning.
You consider the risks a changing climate poses to your operations. You have appropriate plans in place to assess and manage future risks.
You compare your site’s performance against relevant sector guidance and standards on a regular basis, known as sectoral benchmarking.
You have and maintain the following documentation:
- inventory of emissions to air and water
- residues management plan
- accident management plan
- site infrastructure plan
- site condition report
- fire prevention plan
If required, you have and maintain the following documentation:
- odour management plan
- noise and vibration management plan
- dust management plan
- pest management plan
- climate change risk assessment
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, plant and equipment must be carried out by competent people.
3. You must have appropriately qualified managers for your waste activity who are either:
- qualified under a technical competence scheme
- operating under a Competence Management System approved under a technical competence scheme
4. Non-supervisory staff must be reliable and technically skilled in the activities they are responsible for and in emergency response procedures. Their skills may be based on experience and relevant training.
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 may include:
- waste types and the risks they pose
- robust waste acceptance procedures to avoid receiving unwanted items, such as gas cylinders
- failure of abatement systems
- failure of plant and equipment (for example over-pressure of vessels and pipework, blocked drains)
- failure of containment (for example, bund failure, or drainage sumps overfilling)
- damaged lithium-ion batteries
- failure to contain firefighting water
- making the wrong connections in drains or other systems
- checking the composition of an effluent before emission
- vandalism and arson
- extreme weather conditions, for example flooding or very high winds
- loss of power
4. You must assess the risk of accidents and their possible consequences. 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. In particular, you must identify any fire risks that may be caused, for example by:
- arson or vandalism
- self-combustion, for example the finer fractions of shredder residue
- plant or equipment failure and electrical faults
- naked lights and discarded smoking materials
- hot works (for example welding or cutting), industrial heaters and hot exhausts
- neighbouring site activities
- sparks from loading buckets
- hot loads deposited at the site
- damage to, or shorting of, batteries
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 plant and its location. The main factors to consider are the:
- scale and nature of the accident hazard presented by the plant and its activities
- risks to areas of population and the environment (the receptors)
- nature of the plant and complexity of the activities and how difficult it is to decide and justify adequate risk control techniques
7. Through your accident management plan, you must also identify the roles and responsibilities of the staff involved in managing accidents. You must provide them with clear guidance on how to manage each accident scenario, for example, whether to use containment or dispersion to extinguish fires, or let them burn.
8. You must appoint one facility employee as an emergency co-ordinator who will take lead responsibility for implementing the plan. You must train your employees so they can perform their duties effectively and safely and know how to respond to an emergency.
9. You must also:
- establish how you will communicate with relevant authorities, emergency services and neighbours (as appropriate) both before, during and after an accident
- have appropriate emergency procedures, including for safe plant shutdown and site evacuation
- have post-accident procedures that include assessing the harm that may have been caused by an accident and the remediation actions you will take
- test the plan by carrying out emergency drills and exercises
1. You must take the following measures, where appropriate, to prevent events that may lead to an accident.
Segregating waste
2. You must keep incompatible wastes apart.
Preventing accidental emissions
3. You must make sure you contain the following for off-site disposal or route to the sealed drainage system as appropriate:
- process waters
- site drainage waters
- emergency firefighting water
- oil or chemical contaminated waters
- spillages of oils and chemicals
4. You must be able to contain surges and storm water flows. You must provide enough buffer storage capacity to make sure you can achieve this. You can define this capacity using a risk-based approach, for example, by considering the:
- nature of the pollutants
- effects of downstream waste-water treatment
- sensitivity of the receiving environment
5. You can only discharge waste-water from this buffer storage after you have taken appropriate measures, for example, to control, treat or reuse the water. Discharges to ground, surface water or sewer must be lawful and must comply with any consents or permissions that are required.
6. You must have spill contingency procedures to minimise the risk of an accidental emission of raw materials, products and waste materials, and to prevent their entry into water.
7. Your emergency firefighting water collection system must take account of additional firefighting water flows or firefighting foams. You may need emergency storage lagoons to prevent contaminated firefighting water reaching a receiving water body. This should be considered as part of your fire prevention plan.
8. You must consider and, if appropriate, plan for the possibility that you need to contain or abate accidental emissions from:
- overflows
- vents
- safety relief valves
- bursting discs
If this is not advisable on safety grounds, you must focus on reducing the probability of the emission.
Security measures
9. You must have security measures in place (including staff) to prevent:
- entry by vandals and intruders
- damage to plant and equipment
- theft
- fly-tipping
- arson
10. Facilities must use an appropriate combination of the following measures:
- security guards
- total enclosure (usually with fences)
- controlled entry points
- adequate lighting
- warning signs
- 24-hour surveillance, such as closed-circuit television (CCTV)
Fire prevention
11. There are 3 fire prevention objectives. You must:
- minimise the likelihood of a fire happening
- aim for a fire to be extinguished within 4 hours
- minimise the spread of fire within the site and to neighbouring sites
12. You must have a fire prevention plan that meets the requirements of our fire prevention plan guidance.
Other accident prevention measures
13. You must maintain plant control in an emergency using one or a combination of:
- alarms
- process trips and interlocks
- automatic systems
- manual interventions
14. You must:
- make sure all the measurement and control devices you would need in an emergency are easy to access and operate in an emergency situation
- maintain the plant so it is in a good state through a preventive maintenance programme and a control and testing programme
- use techniques such as suitable barriers to prevent moving vehicles damaging equipment
- have procedures in place to avoid incidents due to poor communication between operating staff during shift changes and following maintenance or other engineering work
- where relevant, use equipment and protective systems designed for use in potentially explosive atmospheres
Record keeping and procedures
15. You must:
- keep an up-to-date record of all accidents, incidents, near misses, changes to procedures, abnormal events, and the findings of maintenance inspections
- carry out investigations into accidents, incidents, near misses and abnormal events and record the steps taken to prevent their reoccurrence
- maintain an inventory of substances, which are present (or likely to be) and which could have environmental consequences if they escape – many apparently innocuous substances can damage the environment if they escape
- have procedures for checking raw materials and wastes to make sure they are compatible with other substances they may accidentally come into contact with
- make sure that any documents that may be needed in the event of an incident are accessible
1. You must have and implement a contingency plan and management procedures to make certain you comply with all your permit conditions and operating procedures during maintenance or shutdown at your site.
2. Your contingency plan must also contain provisions and procedures to make sure that you:
- do not exceed storage limits in your permit and you continue to apply appropriate measures for storing and handling waste
- stop accepting waste unless you have a clearly defined method of recovery or disposal and enough permitted storage capacity
- as far as possible, know in advance about any planned shutdowns at waste management facilities where you send waste
Your contingency plan must include plans and procedures for circumstances where you cannot send your wastes to other sites due to their planned or unplanned shutdown.
3. If you produce an end-of-waste material at your facility, your contingency planning must consider issues with storage capacity for end-of-waste products.
4. You must make your customers aware of your contingency plan, and of the circumstances in which you would stop accepting waste from them.
5. You must consider whether the sites or companies you rely on in your contingency plan:
- can take the waste at short notice
- are authorised to do so in the quantities and types likely to be needed – in addition to carrying out their existing activities
6. Where circumstances mean you could exceed your permitted storage limits or compromise your storage procedures, you must look for alternative disposal or recovery options. You must not discount alternative disposal or recovery options based on extra cost or geographical distance.
7. You must not include unauthorised capacity in your contingency plan. If your contingency plan includes using temporary storage for additional waste on your site, then you must make sure your site is authorised for this storage and you have the appropriate infrastructure in place.
8. Your management procedures and contingency plan must:
- identify known or predictable malfunctions associated with your technology and the procedures, spare parts, tools and expertise needed to deal with them
- include a record of spare parts held, especially critical spares – or state where you can get them from and how long it would take
- have a defined procedure to identify, review and prioritise items of plant which need a preventative regime
- include all equipment or plant whose failure could directly or indirectly lead to an impact on the environment or human health
- identify ‘non-productive’ or redundant items such as tanks, pipework, retaining walls, bunds, reusable waste containers (for example wheeled carts), ducts, filters and security systems
- make sure you have the spare parts, tools, and competent staff needed before you start maintenance
9. Your management system must include procedures for auditing your performance against all these contingency measures and for reporting the audit results to the site manager.
1. You must consider the decommissioning of the plant at the design stage and make suitable plans to minimise risks during later decommissioning.
2. For existing plant, identify potential decommissioning risks and take steps to address these. Make changes and design improvements as and when plant is upgraded, or when construction and development works are carried out at your site. Examples of design improvements could include avoiding using underground tanks and pipework. If it is not economically possible to replace them, you must protect them by secondary containment or a suitable monitoring programme.
3. You must have and maintain a decommissioning plan to demonstrate that:
- plant will be decommissioned without causing pollution
- the site will be returned to a satisfactory condition
4. Your decommissioning plan should include details on:
- whether you will remove or flush out pipelines and vessels (where appropriate) and how you will empty them of any potentially harmful contents
- site plans showing the location of all underground pipes and vessels
- how asbestos or other potentially harmful materials will be removed, unless we have agreed it is reasonable to leave such liabilities to future owners
- methods for dismantling buildings and other structures, and for protecting surface water and groundwater during construction or demolition at your site
- any soil testing needed to check for any pollution caused by the site activities, and information on any remediation needed to return the site to a satisfactory state when you cease activities, as defined by the initial site condition report
- the measures proposed, once activities have definitively stopped, to avoid any pollution risk and to return the site of operation to a satisfactory state (including, where appropriate, measures relating to the design and construction of the plant)
- the clearing of deposited residues, waste and any contamination resulting from the waste treatment activities
5. You should make sure that equipment taken out of use is decontaminated and removed from the site.