National Diploma C 10

NEBOSH National Diploma | Unit C
C O N T E N T S
Element Title Page
C10 Environmental Pollution and Waste Management
INTRODUCTION ............................................................................................................................................. 10-2

ENVIRONMENTAL POLLUTION....................................................................................................................... 10-3

RELEASES ............................................................................................................................................................... 10-3
PRINCIPLE OF SOURCE, PATHWAY, TARGET AND IMPACT IN RELATION TO EFFECTS OF POLLUTION ................................................. 10-4
BEHAVIOUR AND DISPERSION OF GASES ......................................................................................................................... 10-5
RELEASE AND DISPERSION OF TOXIC SUBSTANCES............................................................................................................. 10-6
ENVIRONMENTAL IMPACTS ........................................................................................................................................ 10-11
POLLUTION CONTROL STRATEGIES .............................................................................................................................. 10-15
NEED FOR CONTINUOUS AND GRAB SAMPLING AND MEASUREMENT AGAINST SET STANDARDS ..................................................... 10-18
NEED TO KEEP THE REGULATORY AND LOCAL AUTHORITIES INFORMED OF ENVIRONMENTAL PERFORMANCE .................................... 10-21

DEFINITIONS ......................................................................................................................................................... 10-24
ROLE OF THE ENVIRONMENT AGENCY/SCOTTISH ENVIRONMENT PROTECTION AGENCY .............................................................. 10-26
REVISION QUESTIONS .............................................................................................................................................. 10-29
CLASSIFICATION OF WASTES ...................................................................................................................... 10-30
DEFINITIONS ......................................................................................................................................................... 10-30
WASTE ................................................................................................................................................................ 10-32
METHODS OF CATEGORISING WASTE AND DIFFERENT TECHNIQUES REQUIRED FOR EACH WASTE CATEGORY ................................... 10-40
REVISION QUESTIONS ............................................................................................................................................. 10-42
PRACTICAL WASTE MANAGEMENT .............................................................................................................. 10-43

MINIMISATION ....................................................................................................................................................... 10-43
STORAGE ............................................................................................................................................................. 10-43
LABELLING ............................................................................................................................................................ 10-43
CARRIAGE............................................................................................................................................................. 10-43
THE DUTY OF CARE ................................................................................................................................................. 10-43
WASTE DISPOSAL ........................................................................................................................................ 10-46

TYPES OF WASTE TREATMENT .................................................................................................................................... 10-46
LEGAL REGIMES APPLICABLE ...................................................................................................................... 10-52

CONCEPT OF DUTY OF CARE ...................................................................................................................................... 10-52
REVISION QUESTION ............................................................................................................................................... 10-54
EMERGENCY PROCEDURES .......................................................................................................................... 10-55

NEED FOR EMERGENCY RESPONSE MEASURES IN THE EVENT OF AN UNCONTROLLED RELEASE ..................................................... 10-55
ENVIRONMENTAL ASPECTS OF THE CONTROL OF MAJOR ACCIDENT HAZARDS REGULATIONS ........................................................ 10-56
REVISION QUESTION ............................................................................................................................................... 10-63
SUMMARY .................................................................................................................................................... 10-64

NEBOSH National Diploma - Unit C | Workplace and Work Equipment Safety
NEBOSH National Diploma | Unit C
Element C10 | Environmental Pollution and Waste

Management
Learning Outcomes
On completion of this element, you should be able to:
¾ Identify potential sources and impacts of environmental pollution and appropriate
monitoring strategies.
¾ Describe the various types of waste, their categorisation, treatment, disposal, and
documentation.
¾ Outline the need for emergency response measures.
Unit 10:
© RRC Training Element C10 | Environmental Pollution and Waste Management 10-1
INTRODUCTION
You should note that the Diploma syllabus contains references to recommended prior learning
(RPL). These are highlighted in blue and red in the NEBOSH Diploma guide. In most cases,
RPL will have been covered in a suitable lower level course such as the NEBOSH National
General Certificate (Unit NGC1 and Unit NGC2). It is important for you to remember that RPL
material is examinable, and has indeed featured in examinations, so you are expected to be
familiar with it. In accordance with NEBOSH guidelines, and to reduce wholesale and
unnecessary duplication, some RPL content may not be repeated in the RRC Diploma course
notes, although some aspects may be developed further. To facilitate revision of RPL material,
you are provided with an electronic copy of the RRC Unit NGC1 and Unit NGC2 course notes.
Please note that the recommended minimum hours of study for each element does not include
recommended prior learning.
RPL content relating to this Element may be found in Element 6 of Unit NGC2.
You should read your course materials in conjunction with RRC’s online Health and Safety Law
and Case Law Guide; log in to RRC’s support website at www.rrc.co.uk to access this learning
resource.
ENVIRONMENTAL POLLUTION
Many substances and processes used by differing industries can involve the release of
potentially harmful materials (see the COSHH Regulations 2002). When such substances
are released they could also potentially cause harm to the environment. Many well-known
health and safety disasters, e.g. Seveso, 1976, or Chernobyl, 1986, have had widespread
environmental implications, causing harm to people not involved in the workplace as well as to
the land and water in the environment, with consequent effects on agriculture and the food
chain. For example, in the case of Aznacollar Mine, Spain, in 2002 toxic material contaminated
feeding grounds for numerous wild bird species.
Similarly, many common industrial activities, for example: combustion, cleaning, de-watering,
degreasing, stripping insulation materials, all have environmental implications when we dispose
of the wastes, the fumes, the liquids or the gases from these operations.
Some industries have a greater effect than others on the environment (see table that follows).
Examples of How Different Industries Can Affect the Environment
Industry/Process Potential Environmental Impact

Agriculture Wastes, use of pesticides, herbicides, fertilisers
Construction Dust nuisance, noise nuisance, use of raw materials,
contaminated water run-off
Food production Effluent containing food solids and fats, cleaning chemicals,
solid food waste, combustion gases, packaging, transport,
etc.
Brick manufacture Quarrying (landscape changes, noise, dust, transport, water
run-off, visual effects, loss of natural resources, etc.),
manufacture (noise, dust, energy use, transport, gaseous
emissions)
Metal finishing Acids, alkalis, effluent containing toxic metals, energy use,
fumes, VOCs*, detergents, toxic metals, waste water, cakes
or sludges contaminated with toxic metals, combustion
gases from boilers, etc.
Timber Sustainability of raw materials, noise, dust, transport
Offices Use of energy including air-conditioning systems, hardwood
furniture, paper use
*VOCs = Volatile Organic Compounds

(For more information on VOCs, see later in this element.)
The types and quantities of waste, waste water, energy and raw materials vary greatly from
one industry to another but the principle remains the same: one ton of product can mean
many tons of waste in the form of solids, liquids, gases and energy.
Releases
The release of these substances can affect people outside the workplace and also affect the
environment.
Intended Releases
A chemical plant may have a waste water effluent treatment plant for removal of metals and
pH adjustment, and a similar one for treatment of substances emitted to air, e.g. sulphur
dioxide. Provided the treated effluent to water or air is within authorised limits of purity, the
treated effluent at the end may then be released directly to the environment. There are many
examples of processes of this type, for example: combustion of oil, coal, gas and waste
treatment plants.
Pollution of this type is governed by the process of Environmental Permitting under the PPC
(Pollution Prevention and Control) regime contained in the Environmental Permitting (England
and Wales) Regulations 2007. The companies wishing to operate such processes need to apply
to the appropriate environment agency for a permit to operate. The processes affected are
described in Schedule 1 to the regulations The schedule is divided into various industrial
sectors according to their potential to pollute the environment, for instance, Part A(1) A(2) or
Part B processes, e.g. coating processes and printing. The permits detail the conditions and
emission levels under which they are allowed to operate as well as the prescribed substances
which may be released. Instances include: to air, for example, oxides of carbon, particulate
matter; to water, for example, mercury and its compounds, PCBs; to land, for example,
organic solvents, pesticides, organometallic compounds. The permits themselves are reviewed
every four years and are also subject to change. The control mechanism used for this regime,
BAT, is described later. Further legislation relating to authorisation of substances includes the
Radioactive Substances Act 1993 and the Solvent Emission Directive 1999/13/EEC -
requirements implemented through the PPC regime above.
Abnormal Conditions Giving Rise to Occasional Releases

Abnormal conditions might lead to unintended releases to the environment or releases which
are greater than normal. These might be situations where abatement controls temporarily fail
or are unable to cope (say at an effluent treatment plant that receives a sudden large surge of
effluent). Similar situations might occur on plant shut down, start up, decommissioning or due
to some human error, as happened at Camelford, Cornwall, in 1988 where aluminium sulphate
was deposited into the wrong tank.
Major Releases Following Plant Failure

These are, of course, abnormal and infrequent occurrences arising as a result of some accident
or dangerous occurrence – due to plant design or management failure. So, for example, an
out of control reaction at a chemical plant may cause an explosion or venting of large
quantities of vapour or gas into the atmosphere. Such incidents may give rise to fires,
explosions leading to spillages of chemicals, radiation, etc. The COMAH Regulations require
the effects of potential Major Accidents To The Environment (MATTEs) to be assessed.
Quenching a large fire may allow large quantities of contaminated fire water run-off to escape
to local waterways or sensitive environments, etc. There are a number of incidents of this type
which have caused not only environmental problems, but also had serious health and safety
implications, e.g. Bhopal, India (leak of methyl isocyanate); Chernobyl, Ukraine (radioactive
release); Seveso, Italy (release of TCCD, a dioxin).
Principle of Source, Pathway, Target and Impact in

Relation to Effects of Pollution
Toxic substances can be released and dispersed by way of three environmental media:
• Land releases can be by way of a number of different substances ranging from non-polar
organic solvents to organometallic compounds.
• Releases to the atmosphere as air pollutants can be in the form of oxides of sulphur and
nitrogen. Other toxic and polluting compounds may include carbon monoxide,
hydrocarbons and lead.
• Pollutants released to water are manifold and can be highly toxic in small quantities.
Oils, solvents and pesticides are common examples.
The behaviour and dispersion of pollutants to water, gases to the atmosphere and toxic
substances to ground all have features in common. In each case there is a man-made source
of pollutant, a pathway and an environmental target upon which there is a measurable
impact.
Pathways may be atmospheric by means of gaseous pollutants. They may be through water
supplies by means of liquid effluent or through the medium of ground water. The targets in
each case (see the figure later in this section – Source, Pathway and Target Model of
Related Substances) are people in the local population, fish in the waterways as potential
effluent and ground water targets. Finally, ground water pollution may have a significant
effect on drinking water supplies.
Behaviour and Dispersion of Gases

The way that toxic and/or flammable gases behave following a leak or spillage determines the
degree to which they are dispersed into the atmosphere. This dispersion depends on a
number of factors including:
• The density and temperature of the gas or vapour.
• Atmospheric conditions such as:
− Wind speed.
− Wind direction.
− Turbulence.
− Humidity.
− Air temperature.
• The quantity of material released.
• The rate of release of gas or vapour.
• The nature of the area surrounding the release, such as buildings or hills.
The quantity, rate of release and weather conditions will have a significant effect on the rate of
dispersion. This will determine whether toxic substances are quickly and safely diluted or
remain for some time at levels in excess of the relevant exposure limits. Similarly, there are
specific explosive limits for flammable substances and the conditions present at the time of the
release will determine whether the flammable gas cloud is able to reach or maintain explosive
concentrations. High wind speeds will accelerate dispersion; calm, light winds will delay
dispersion; temperature inversion conditions can trap the gas or vapour release and maintain
significant concentrations for a considerable time. Density and temperature also influence the
behaviour of the gas or vapour cloud with denser-than-air gases tending to remain at ground
level and light/hot gases dispersing upwards.
Release and Dispersion of Toxic Substances

To Ground
Companies operate various processes under the Environmental Permitting (England and Wales)
Regulations 2007. They have to comply with the conditions of their permits under the
regulations, which detail the conditions and emission levels under which they may operate.
These permits are ‘live’ documents, i.e. are subject to regular review and potential change.
This takes place approximately every four years, in line with the adoption of BAT (see later)
and the principles of higher standards for processes and less pollution in the EU environmental
policy and action plans.
In addition to prescribing processes, the Regulations also prescribe substances for release to
the environment. This includes substances released to land, for example: organic solvents,
azides, halogens and their covalent compounds, metal carbonyls, organometallic compounds,
oxidising agents, etc.
To Water
Certain pollutants are particularly harmful, for example, just 250 grams of pesticide could be
enough to exceed the permitted limits in the whole of London’s water supply. Oil is another
substance of particular harm, because a gallon of oil can pollute an area of water the size of
two football pitches. Solvents are also very polluting substances when allowed to reach a
watercourse or underground water; one litre of the common degreasant trichloroethylene
could contaminate 100,000,000 litres of drinking water (the equivalent of 50 Olympic sized
swimming pools).
In 2002, there were some 14,510 pollution incidents reported in England and Wales, of which
82 had a major, and 784 a significant impact. The dispersion of pollutants to water is often
caused by oils and fuel or sewage. The passage of water along a waterway both spreads and
dilutes a pollution event. The extent of dilution will therefore depend on the flow rate of the
watercourse and on any tidal effects.
Sources of Water Pollution
Water pollution is often caused by some, or all, of the following:
Point sources such as:
• Outfalls from sewage systems.
− Storm water overflows from sewage systems or combined sewers.
− Silage clamps or slurry stores on farms.
− Factory wastes, e.g. contamination deposited on drained surfaces, such as: oil,
rubber, chemicals, pesticides, and mud and silt from construction.
− Wrong connections of foul or surface water drains, either by ignorance or accident; all
companies should check their drain connections to ensure they are correct.
− Public ignorance of drainage systems and where they flow.
− Spillages or deliberate disposal, of oil in particular, flushed into surface water drainage
systems.
− Surface water pollution caused by sudden flooding of contaminated
drains/soakaways.
− Groundwater pollution from contaminated land, landfill sites or accidental spillage.

− Excess storm or fire water run-off.
• Diffuse sources, e.g.:
− Agricultural use of fertilisers and pesticides.
− Acid precipitation.
− Landfill sites and contaminated sites.
• Accidental releases, e.g.: road traffic accidents, spillage from industrial sources, ground-
water pollution from mining or metal working.
• Flow reduction due to over-abstraction.
To Air
Major Air Pollutants
In March 1997, the UK Government published its National Air Quality Strategy (revised in 2000
and 2007). This sets air quality standards and objectives for eight priority pollutants which
affect health, namely benzene, 1,3-butadiene, carbon monoxide, nitrogen dioxide, sulphur
dioxide, VOCs (including formaldehyde and PAHs), hydrocarbons and lead. The following table
details where common pollutants are found and what hazards they engender. Major pollutants
have been assigned control limits under Part IV of the Environment Act 1995.
Common Air Pollutants

Pollutant Occurrence Health Hazard/Effects
Benzene Naturally in crude oil and forms during the Persistent exposure or exposure to
upgrading of fuel oil. It is present in petrol, high levels, as found in some
not in diesel. occupational environments, may cause
anaemia. It is a carcinogen,
particularly linked to leukaemia.
1,3- Formed from olefins during the combustion Damages the genetic structure of cells
Butadiene of petrol and diesel fuel. Also used in the and can cause cancer.
manufacture of synthetic rubber tyres.
Carbon Produced by the incomplete combustion of This gas prevents the normal transport
monoxide carbon-containing materials like wood, coal of oxygen by the blood. It can
and oil and is a major air pollutant. The progressively lead to oxygen
main sources which affect human health starvation. The escalating symptoms
are smoking, car exhausts and unflued of carbon monoxide poisoning are
heating or cooking appliances. headaches and vomiting and in severe
cases, collapse and death, although
the effects of brief exposure are
reversible. Harmful exposure to
carbon monoxide is most common
indoors due to faulty heating
equipment, blocked flues or
inadequate ventilation. This can lead
to a significant reduction in the supply
of oxygen to the heart, particularly in
people suffering from heart disease.
Carbon When anything organic is burned, CO2 is CO2 levels in the atmosphere are
dioxide (CO2) produced. It is one of the greenhouse rising, causing concern about possible
gases that absorbs heat in the atmosphere, global warming.
keeping the earth warm. Road vehicles
produce 20% of the UK's CO2 emissions.
Nitrogen Main source is the combustion of fossil Nitrogen dioxide is highly toxic at
dioxide fuels (along with nitrogen oxide) - road elevated concentrations and can cause
(NO2) vehicles, power generation, heating plants, throat and eye irritation. However, it
and industrial processes. Indoor sources is not normally present in sufficient
are unvented gas cookers and other amounts to have serious effects. As
unflued gas appliances, paraffin stoves and an outdoor pollutant it is involved in
cigarette smoke. photochemical smog formation.
Sulphur A colourless gas with a choking taste which Asthmatics and others suffering from
dioxide (SO2) is a harmful air contaminant and a respiratory disorders may be exposed,
constituent of winter smog. As it is acidic it particularly if exercising out of doors, to
corrodes stonework and other materials. It levels of SO2 which might produce a
is produced by the burning of sulphur feeling of tightness in the chest and
compounds which are a natural constituent some coughing.
of coal and oil.
Volatile Present in exhaust fumes, cigarette smoke, Air pollution.
Organic synthetic materials and household
Compounds chemicals. VOCs are involved in the
(VOCs) formation of ground level ozone.

Formaldehyde A colourless gas emitted from foam Formaldehyde may cause eye, skin and
insulation, chipboard, plywood, some throat irritation, nausea and allergic
fabrics, motor exhausts, bonfires and reactions. High concentrations increase
cigarettes. the risk of lung disease, although such
levels of exposure are uncommon.
PAHs Emitted from coke production, coal burning Some PAHs are carcinogenic, but
and motor vehicles. With the introduction adverse effects are only likely in an
of smoke control areas and the decline in occupational situation.
use of coal in domestic heating,
atmospheric concentrations have fallen.
Hydrocarbons Compounds made of hydrogen and carbon; Can cause throat and eye irritation and
(HCs) they are present in petrol, diesel, gas and damage plants. Ozone also contributes
some solvents. Road traffic is responsible to acid rain and the greenhouse effect.
for 35% of HC emissions in the UK. Of
this, about ⅔ comes from vehicle exhausts
as unburnt fuel and the rest from
evaporation through the vehicle's fuel
system, or from the distribution and sale of
petrol. HCs react with NOx in sunlight to
produce harmful compounds called
photochemical oxidants which include
peroxyacetyl nitrate (PAN) and ozone.
Nitrogen Given off wherever fuel is burned. Road As well as reacting with HCs to produce
oxides (NOx) traffic is responsible for 46% of total UK photochemical pollution, NOx emissions
emissions. are further oxidised in the atmosphere,
contributing to acid rain. This has been
responsible for increasing the acidity of
soil and water in many parts of Europe,
and is implicated in effects on trees and
plants.
Lead For many years lead was added to petrol to Known to be a poison which builds up
improve engine performance. When petrol in the body; may affect the
is burned, lead is emitted from the exhaust, development of children.
and concern has focused on health effects.
Lead emissions from road vehicles are
falling as a result of use of unleaded petrol.
Particulate Consists of partly burned fuel. Road Fine particles can be carried deep into
matter vehicles, especially diesel-engined vehicles, the lungs where they can cause
(PM10) are now the largest source of smoke in the inflammation and a worsening of the
UK. Diesel exhaust is not only smelly, it condition of people with heart and
also produces dirt, soiling city buildings. lung diseases. Particulate air pollution
26% of PM10 in the atmosphere comes can contribute to an increased
from road vehicles. likelihood of myocardial infarction
(heart attacks), although the overall
burden of this on Western society is
less than that of tobacco smoking.
Particle pollution can soil buildings and
materials and harm health. It also
contributes to poor visibility.

Radon A radioactive gas, a decay product of Inhalation of radon gives a risk of lung
radium and uranium metals, which occur cancer which is in proportion to its
naturally in various rocks, notably granite. concentration and time exposure.
Areas such as Cornwall which are on Particularly likely in smokers.
granite have unusually high radon levels
but it presents no risk in open air because
it disperses. DEFRA has issued guidance to
householders on whether precautions are
necessary as it may percolate through
wooden floors and concrete screeded
floors, and accumulate in living areas. Will
disperse where good ventilation exists.
Dispersion of Air Pollutants

The same principles apply to air dispersion as to other forms of pollutant spread, as illustrated
by the diagrams below.
Source, Pathway and Target Model of Released Substances, after HMSO

Released Substances 1996
Emissions to air are illustrated in the following diagram which also shows the principal types of
air emission, i.e. continuous, discrete and fugitive sources.
Buoyant rise
Continuous
Discrete
Fugitive
Pathway Target
Sources
Emissions to Air
In order to define a discharge to the environment, the following should be taken into account
and included in any emission inventory:
• The mass discharge rate of the pollutant gas.
• Volume flow of the gas based on stack diameter and efflux velocity.
• Temperature at release.
• Whether the release is continuous or intermittent.
• Height of the release.
• Location of the release relative to the environment, i.e. proximity to hills, buildings, other
pollution sources and potential targets.
• Presence of any fugitive emissions (e.g. from pipework or flanges).
Environmental Impacts
The term environmental impact is to be found in environmental management systems and in
other legal requirements such as the Town and Country Planning (Environmental Impact
Assessment) Regulations 1999.
BS EN ISO 14001: 2004 – “Environmental Management Systems” defines an environmental
impact as:
“…any change to the environment, whether adverse or beneficial, wholly or partially
resulting from an organisation’s environmental aspects.”
An environmental aspect is defined as:
“… an element of an organisation’s activities or products or services that can interact with
the environment.”
Examples of environmental impacts may be pollution of land, air pollution and consequent
health issues or traffic nuisance. These impacts may be local, regional or even global.
Examples of Environmental Hazards

The following are very different types of environmental hazards, e.g.:
• Release of environmentally harmful gases, such as chlorofluorocarbons (CFCs).
• Fires and explosions.
• Spills of chemicals.
• Dry weather leading to lower river flows.
• Planting a crop of genetically modified organisms.
• Depositing a harmful substance on the land.
• Past uses of a site.
• Lack of control systems or training.
Hazards which impinge directly on the environment, for example, emissions to air, discharges
to water, and waste disposal may additionally cause harm to the health and safety of people
outside the workplace, e.g. Minimata Bay, Japan in 1952 - dumping mercury catalysts into the
bay. The strong correlation between health and safety and environment continues when
considering environmental hazards. There is such a strong correlation between health and
safety and environment that some areas of physical, chemical or biological hazards and risks
are jointly administered in a single Competent Authority. There is a joint arrangement
between the Health and Safety Executive (HSE) and the Environment Agency, as in the
Control of Major Accident Hazards Regulations 1999 (COMAH).
The environmental media are air, water and land and they are interconnected within and by
the Earth’s natural cycles, of which humans are a part. It is often difficult to separate
environmental effects according to the different media which are affected by a particular
pollutant release, a fact acknowledged by the modern concept of Integrated Pollution
Prevention and Control (discussed later in this element).
The following are examples where releases of hazardous substances could cause harm directly
to the health and safety of people outside the workplace:
• Releases of pollutants to watercourses could affect recreational users or prevent its use as
drinking water.
• Releases from Local Exhaust Ventilation systems could affect neighbours and
neighbouring property.
• Chimney emissions could affect a wide swathe of the locality.
• Uncontrolled waste disposal could cause land or water pollution or pollute the
groundwater.
• Discharge of pollutants to land could pollute groundwater which is used for drinking or
cause harm to people using the land by virtue of its chemical or physical properties.
These effects can be short or long term; they could affect wide areas and whole populations, a
fact that can be demonstrated by using as examples key environmental disasters caused by
uncontrolled releases from industrial plants (see earlier in this element).
Components that Affect the Atmosphere

The deterioration of the environment has been the result of a variety of human developments
such as industrialisation, urbanisation, and population growth. The public perceives industry
as a major polluter. Pollution effects are not just limited to industrial activities, however. In
Northern Europe, for example, one of the most damaging pollutants affecting air quality results
from the use of private cars. The principal components that have a significant effect on the
environment are:
• Sulphur Dioxide
The major source is the combustion of fossil fuels containing sulphur, mainly coal and fuel
oil. Natural gas and petrol have much lower sulphur contents.
• Particulate Matter
Particulate air pollutants are very diverse in character. They can be organic or inorganic,
soluble or insoluble with diameters ranging from 0.01 to 100μm. The majority of
particulate matter (by weight) exists in the range 0.1-10μm (PM10) but the main causes
for concern are particulates below this upper range because of their ability to enter the
lungs.
In the UK, the main sources of particulate matter are internal combustion engines,
processing plants and fuel combustion.
• Oxides of Nitrogen
The major source of NOx is the high temperature reaction of atmospheric nitrogen and
oxygen in combustion processes. Power stations and road transport are the main sectors
for this type of pollution. Nitric oxide and nitrogen dioxide are significant in the formation
of ozone in lower parts of the atmosphere. Here ozone is harmful to health, as opposed
to stratospheric ozone, which protects us from the sun’s ultraviolet radiation.
• Oxides of Carbon
Carbon monoxide is associated with petrol engines. Most other combustion processes are
more efficient and cause little CO emission.
• Volatile Organic Compounds (VOCs)
‘Volatile Organic Compound’ is a general term, covering any organic compound that is gas
at normal temperature and pressure. It covers hydrocarbons and compounds also
containing other elements such as oxygen, nitrogen, and chlorine.
Water and Land Pollution

Water Pollution
Water pollution is the reduction in quality of rivers, lakes, streams, and oceans by the
introduction of chemical, physical, or biological pollutants. These can include:
• Waste
This includes: industrial effluents, domestic and agricultural sewage, radioactive
discharge, and thermal pollution.
• Urban Run-Off
The discharge of storm water drains directly to watercourses.
• Agricultural Run-Off
Fertilisers, pesticides and weedkillers.
• Oil Spills
These can be locally from a company’s operation into a stream or through accidental or
deliberate discharge into the sea.
• Acid Precipitation
Rainfall polluted by contaminants in the atmosphere and subsequently deposited in lakes
may cause acidification of the body of water and is an example of the movement of
pollution from one medium to another.
Land Pollution
Land, like water and air, is vulnerable to pollution from a range of sources:
• Atmospheric Deposition
Deposition of radionuclides (as happened in the Chernobyl disaster) can lead to extensive
soil contamination and the precipitation of acidic pollutants can result in acidification of
soils.
• Waste and Spills
Hazardous waste buried in landfill, fly-tipped or buried on company premises, as well as
spills and leaks associated with company activities, are frequent causes of land
contamination.
• Agricultural Practices
Soil contamination is an accepted but undesirable consequence of the application of
pesticides.
Global Impacts
Examples of global impacts include:
• Emissions of carbon dioxide (and other greenhouse gases), contributing to the
greenhouse effect, global warming, and climatic changes.
• Man-made halocarbons (CFCs, tetrachloromethane, 1.1.1-trichloroethane,
hydrofluorocarbons (HCFCs), halons and methyl bromide), contributing to stratospheric
ozone depletion.
• Use of hazardous substances that have persistent toxicity (mercury, DDT, polychlorinated
biphenyls (PCBs), dioxins and furans), contributing to their accumulation in living
organisms and toxicity to both man and ecosystems.
• Consumption of non-renewable resources (e.g. metals and fossil fuels), contributing to
resource depletion, and the economic and social issues associated with this.
Regional Impacts
Damage to Forests and Other Vegetation
This is caused by:
• Emissions of sulphur dioxide, oxides of nitrogen and ammonia, which attack leaves and
acidify the soil.
• Emissions of organic compounds that lead to the formation of ozone and other reactive
compounds.
Damage to Lakes and Coastal Waters

This can result from excessive deposition of water-borne or airborne substances containing
nitrogen and phosphorus. Many Scandinavian lakes have been acidified as a consequence of
airborne pollution.
Persistent Toxicity
Examples include:
• Agricultural pesticides have found their way into drinking water from pollution of
groundwater.
• Industrial chemicals or their degradation products with a variety of actions such as
oestrogen-like effects, increase frequencies of allergy and the risk of cancer and decrease
reproductive capacity.
Local Impacts
Examples of local impacts include:
• Physical impacts such as soil erosion, loss of arable land, flooding due to reduced drainage
capacity of rivers and watercourses, loss of aesthetic qualities and cultural assets.
• Consumption of renewable resources at a higher rate than production (for instance,
depletion of fish populations, regeneration of forests lacking the same biodiversity, and
impoverishment of the soil with intense agricultural practices).
Managing the Impact

Whether pollution results from routine processes or indeed accidents, it is inevitable that other
impacts may also be caused, such as human health effects and financial costs.
All these impacts can be managed by understanding the environmental risks associated with
our activities and implementing control mechanisms to eliminate or minimise those risks. In
the following sections we will look at various systems and procedures to identify, evaluate and
control environmental impacts from operations.
Pollution Control Strategies

The importance of an environmental control strategy is to identify, prioritise and reduce the
liabilities arising from the environmental issues. In order to do this, the issues must be
understood and their importance to the business recognised.
Prevent
Waste prevention employs various strategies which revolve around the basic principle of not
making waste in the first place, i.e. preventing waste being produced by eliminating certain
material from the waste stream.
Minimise
When designing waste minimisation programmes for industry, all types and forms of waste are
considered. Whichever wastes are considered - solid, liquid or gases - certain principles apply.
The wastes collected are then disposed of either by landfill, incineration or other disposal
routes.
There has to be an emphasis on reducing the total amount of waste in all waste streams, at
plants, within companies, nationally and internationally. The basic principles of waste
management may be summarised below. These principles are occasionally referred to as the
4R rule, which stands for Reduce, Re-use, Recycle and Responsibly dispose.
The generation of waste is counter-productive and is often the result of inadequate planning,
processes control or operational management. One of the objectives of quality control and
loss control is to manage the manufacturing process to make the most effective use of raw
materials and energy and reduce the number of wasted or rejected finished products. In
many cases, waste reduction has achieved results with very little capital expenditure.
Waste minimisation has been recognised as an important financial management concept in
industry for several years. The need to improve environmental performance to achieve legal
compliance and the inability of end-of-pipe technology to achieve the reduction in emission
levels necessary to meet tightening standards has re-focused attention on this issue. In 1992,
the Centre for Exploitation of Science and Technology (CEST) designed a waste minimisation
project based on the catchment areas of the Aire and Calder Rivers in West Yorkshire. The
project was called the “Aire and Calder Project” and it was sponsored by BOC Foundation for
the Environment, the former HMIP (Her Majesty’s Inspectorate of Pollution), the former NRA
(National Rivers Authority) and Yorkshire Water. CEST summarised the achievements of the
project as follows:
“Reduction in pollution and improvements in profitability are not mutually exclusive. In
the first 18 months of a project established to demonstrate the benefits of waste
minimisation and cleaner technology, eleven participating companies made savings of
over £2 million a year. Further savings of a similar magnitude are possible in subsequent
years. Reductions in the use of inputs such as water, energy and raw materials exceeded
savings in effluent production by a significant margin, thereby confirming that companies
can profit from cleaner production through improved process efficiency.”
Just over 10% of the measures to reduce waste were cost neutral and a further 60% had a
payback of less than one year. Indeed, only 10% had a payback of over two years. The
financial benefit from this approach is so substantial that all companies should have no
difficulty in implementing programmes on their own initiative. However, there are additional
benefits in club type projects and companies may consider it worthwhile joining, either locally
or in supply chain relationships.
Waste minimisation projects require a detailed analysis of the process and the waste products,
but the results will almost certainly repay the effort expended, for example, the recovery and
recycling of packaging waste is governed by the Producer Responsibility Obligations
(Packaging Waste) Regulations 2007.
Most organisations keep their water use under constant review under their waste minimisation
programmes and many good examples can be found. Water use will also be part of the PPC
Permit.
Air Emissions Energy (heat, noise)
Raw Materials
Product
Ancillaries
and Consumables
Water Transport
PROCESS
Energy Packaging
Packaging An Improvement in any

of these indicates waste
minimisation
Wastes
Solids Effluent
Liquids
Matt
ers
Which Should Be Investigated As Part of a
Waste Minimisation Project
The Environmental Technology Best Practice Programme (ETBPP) also has many examples of
water minimisation taken from different industries.
Render Harmless
A number of options are available for rendering harmless certain substances for particular
industries, skilled trades and the general public. These include: recycling, neutralisation,
controlled discharge, incineration and water purification.
Pollution Control Methods

Pollution refers to contamination or damage to the environment caused by human activity. We
can identify three broad classes of pollution:
• Atmospheric pollution – fumes, smoke and dust discharged into the air from incinerators,
traffic exhausts or other by-products of industrial processes.
• Water pollution – liquid waste (effluent) comprising toxic substances such as detergents
discharged into ground water, rivers or sea-water directly from sewers, factories or
surrounding land, such as fertilisers being washed away from farm land by the rain.
• Land pollution – solid waste from industrial processes deposited on land.
Control of Atmospheric Pollution
Control of atmospheric pollution is achieved by a system of permits or consents from
government agencies. This is backed up with regular atmospheric monitoring of the stack. To
be within permitted emission limits usually requires some form of abatement technology, such
as scrubbers. The available techniques need to be balanced against the cost involved. What is
appropriate is considered in the light of the nature of the industry and the desired level of
environmental protection.
Disposal of Waste and Effluent

The general approach to waste disposal should take account of a hierarchy of waste
management options:
• Waste reduction – the primary emphasis should be on not producing waste in the first
place, by process change and optimising process efficiency.
• Reuse – for example, returnable glass bottles.
• Recovery of waste – including recycling (such as glass, metal and paper), composting and
incineration with energy recovery.
• Disposal – generally to landfill.
The keeping, treatment or disposal of solid waste is regulated, and requires the waste operator
to be permitted to operate.
Control over water pollution is based on a system of water discharge permits or consents,
obtained from the relevant government agency. These apply in respect of any discharge of
trade effluent or sewerage effluent into controlled waters. Controlled waters cover, essentially,
all moving water, including inland and underground waters and estuaries, as well as the actual
river bed and, in certain circumstances, territorial and coastal waters. Again, regular
monitoring may be required to ensure that the discharge consent is not exceeded.
Need for Continuous and Grab Sampling and

Measurement Against Set Standards
There are a number of monitoring techniques available to monitor environmental quality (for
example, of air or water).
Technical Guidance Notes (Environmental Monitoring)

These provide information on subjects related to the Environmental Permitting (England and
Wales) Regulations 2007 and to the Radioactive Substances Act 1993. They are
applicable across a wide range of processes and activities, and are grouped and numbered
according to subject. They are available from the Stationery Office. Series designator letters
are:
• A − Abatement.
• D − Dispersion.
• M − Monitoring.
Monitoring and Control

Monitoring is not a control method. It is a means of demonstrating control and of enabling
failures to be recognised.
Many companies discharge a trade effluent to the sewer or to surface water. The regulatory
agencies may check these from time to time, but the checks cannot be considered to be a
control method by the company producing the effluent, since the results will only confirm
something that happened perhaps several days or even weeks before. Reliance on them for
confirmation of day-to-day controls is not a valid method of ensuring that there are no
compliance failures.
Monitoring Techniques
These include:
• Routine visual inspection.
• Instrumental monitoring.
Techniques available for instrumental monitoring include: continuous measurement, and grab
or spot testing.
The type of monitoring required will depend on the level of risk. A large incinerator, for
example, will have continuous monitoring (of which there is a permanent record), whereas a
chimney stack where there is a low risk may only require monitoring on an annual basis.
Similar factors apply to water discharges.
Some of these techniques are most appropriately used in environmental testing where the
exact method may be specified in consents or licences, often with reference to a standard
which specifies precisely how the tests are to be carried out, e.g. “Sampling for particulates
will be carried out isokinetically (i.e. at the same linear flow velocity) in accordance with the
principles of BS 3405: 1983 − Measurement of Particulate Emission including Grit and Dust
(simplified method).” There are standard methods for most parameters which are measured
on a regular basis. Most licences, authorisations and permits require, in addition, that the
results of the monitoring or testing are submitted to the regulatory authorities, who have
additional powers to require information, or to have works done or even, in extreme
circumstances, to do work themselves and recoup the costs from the company.
Sampling Techniques
The first task in monitoring is to collect the sample, e.g. air, water, gas, so that it may be
analysed. There are a number of considerations here, with the decision of the approach to be
used depending on the risk level of the contaminant being assessed.
• Location of the Sample
Samples may be taken in the general working atmosphere, or at a position close to the
contaminant generation.
• Method of Analysis
The procedure may involve sampling and analysis in the same instrument, or taking the
sample collected and analysing it using different equipment, perhaps in a laboratory away
from the point of collection.
• Duration of the Sampling
There are three approaches to this:
− A spot or grab sample, which is a single sample collected instantaneously at a
particular location or in a limited area, and is representative only of that location or
area at that point in time. Such samples may be analysed on the spot by the same
instrument or be taken away for subsequent laboratory analysis. To obtain time-
averaged levels, a series of spot samples may be taken over the period in question,
but this is not necessarily accurate.
− A better method of obtaining a time-weighted average is by collecting a sample over
a period and then analysing it.
− A continuous monitored sample – where a sample is collected continuously over a

period of time. In this case, the sample will be analysed during the monitoring,
either by the sampling instrument itself or by direct connection to another instrument
which carries out the analysis continuously.
• Frequency of the Sampling
The frequency with which spot samples are collected will depend on the type of
contaminant and/or the results of the last sample. So, for example, if an initial sample
was borderline, further samples may be taken very frequently until a satisfactory reading
is obtained. On the other hand, if the initial sample showed that the atmosphere was
safe, no further readings would be necessary for a considerable period.
To obtain time-averaged levels, either a series of spot samples may be taken over the
period in question or spot readings may be taken from a continuous sample.
Monitoring of Waste Management Sites for Leachate and Landfill Gas
A programme for monitoring of landfill sites must be established. Monitoring should be
continued until the concentration of landfill gas is less than 1% by volume or there is a 95%
confidence level that all the biodegradable matter has been used up.
Several methods are available and may be used at different times and in different
circumstances; e.g. surface monitoring, subsurface monitoring (gas probes), excavated pits,
gas monitoring boreholes or gas wells, and leachate wells.
Other monitoring should also take place including groundwater and the integrity of the liner
(where appropriate), and records kept. In general, this will be a condition of the landfill
licence.
Monitoring Equipment
All measurements should be made by trained operators.
• Catalytic Oxidation Detectors
These detect low concentrations of flammable gases as a percentage of the Lower
Explosive Limit (LEL) of the gas.
• Thermal Conductivity Detectors
These measure the total concentration of all flammable gases and carbon dioxide by
comparing the thermal conductivity of the sample against an internal electronic standard
representing normal atmospheric air. They may be combined in a single instrument.
• Infra-Red Analysers
These can also be used to measure specific gases in the mixture.
• Gas Chromatography
This is probably the most reliable method for analysing landfill gas, and is often installed
permanently. It is often used in field laboratories.
• Flame Ionisation Detectors
These can detect any flammable gas. They should not be used where flammable gas is in
excess of 1% by volume (20% of the LEL).
• Gas Indicator Tubes

These may be useful to indicate the components in a gas mixture. The gas is drawn
through a tube containing a reagent which reacts, giving a colour change, with the
amount of colour change depending on the concentration of the gas.
• Carbon Dioxide Monitors
Carbon dioxide may be monitored by a number of methods − infra-red analysers, thermal
conductivity meters and gas indicator tubes.
Similar techniques are used for waste water and stack emissions but measured against
different standard.
Monitoring Standards
General monitoring and reporting provisions for emissions to all environmental media are
provided, for example: monitoring methodologies, frequency of monitoring, compliance
assessment criteria and environmental monitoring. The Environment Agency is a useful source
of further information. (See: www.environment-agency.gov.uk)
A Monitoring Certification Scheme (MCERTS) to improve the quality of monitoring data, and to
ensure that the instrumentation and methodologies employed for monitoring are fit for
purpose has been introduced by the Environment Agency. The list of such MCERTS equipment
is available.
The analytical methods given should normally be used. However, if other substances need to
be monitored, standards should normally be used in an order of priority: e.g. Comité Européen
de Normalisation (CEN), International Standardisation Organisation (ISO), British Standards
Institution (BSI), etc.
Additional guidance on standards for monitoring gaseous releases relevant to PPC (see later) is
given in the ‘M’ series of Technical Guidance Notes; available from the Environment Agency. It
specifies manual methods of sampling and analysis, which will also be suitable for calibration
of continuous emission monitoring instruments.
Need to Keep the Regulatory and Local Authorities

Informed of Environmental Performance
Development and Scope of Public Registers
The necessity for the information to be provided to the public authorities and for the public
authorities to provide information is written into several statutes. The requirement was part of
the EPA 1990, IPC and LAAPC (Local Authority Air Pollution Control) requirements (Sections
20-22) and is now part of the Environmental Permitting (England and Wales) Regulations 2007.
The Regulations state that the following information shall be put on the register:
• Documentation relating to the applications.
• Copy of the advertisement relating to the applications.
• Permits and conditions.
• Documentation relating to any notices.
• Any appeals.
• Any convictions.
• Monitoring data.
• Landfill closure notices
• Reports from the regulator about the consequences of the process in the particular
locality.
• Directions from the Secretary of State.
Removing information from the Register covers:
• Withdrawal of an application.
• If process ceases to be prescribed due to a change in the regulations.
• Monitoring information after four years.
• Information relating to a process which has been superseded.
Applicants may request that certain information be excluded on the grounds of commercial
confidentiality, and the regulator has 28 days in which to determine the request. If he fails to
do so in that period, it is deemed not to be commercially confidential, but will not be entered
on the public register for 21 days following notification to the applicant, who has a right of
appeal during that period. Any requests for exclusion on the grounds of national security are
determined by the Secretary of State.
Other Public Registers

There are also public registers of registered waste carriers and brokers, waste management
licences, public registers of notifications made under the Genetically Modified Organisms
(Contained Use) Regulations 2000, registers of consented discharges to watercourses and
trade effluent, registers of actions to be taken in the case of an accident at a COMAH site, and
registers of works in relation to contaminated land.
Development of the Pollution Inventory
A number of legislative provisions, in particular the European Pollutant Release and Transfer
Register Regulation, require reporting of emissions to the Environment agency pollution
inventory. All permits contain a condition requiring operators of processes to provide annual
reports to the Environment Agency of releases of 183 specified substances. The reporting
date is 31st January each year and covers the preceding year. The data thus collected forms
the basis of the Agency’s pollution database. This replaces the Chemical Release Inventory
which was established under the former HMIP. Data is also collected by the local authorities
on processes which they control.
As releases of substances included in the inventory must be reported to the Agency on an
annual basis, the latest data will refer to the last reported year. The Environment Agency site
has been enhanced with detailed information on all pollutants emitted to air, water and land.
Entries may be found on the “Pollution Inventory” pages of the EA website (www.environment-
agency.gov.uk). There are 183 potentially hazardous substances listed and each has an
associated fact sheet giving contextual information about the substances. Fact sheets have
been available since 1st April 2003.
Reporting to the Pollution Inventory
Companies can provide information to the Pollution Inventory electronically or by completion of
a set of forms. Very detailed information is required.
Environment and Safety Information Act 1988

This Act requires safety and environmental authorities (such as Fire Authorities, Environment
Agency, HSE, Local Authority) to set up public registers of the enforcement notices they serve
on factories, shops and other premises where public hazards or breaches of safety or
environmental laws have happened.
It requires authorities to:
• Maintain a register of relevant notices served.
• Convey the substance of the notice in each entry to which it relates.
• Ensure that the register is adequately indexed.
• Ensure that both the register and index are open to inspection by the public free of charge
at all reasonable hours.
• On request, and on payment of a reasonable fee, supply a copy to any person inspecting
the register.
Separate registers may be kept to cover different areas.
Environmental Information Regulations 2004
These Regulations implement Council Directive 2003/4/EC on public access to information
on the environment. They require a public authority who holds any information to which these
Regulations apply to make that information available to every person who requests it and to
give advice and assistance. Information must progressively be made available by electronic
means. There is provision for a reasonable charge to be made to cover the costs of providing
the information.
The Regulations apply where the information requested is not the subject of other statutory
disclosure obligations. Specific details:
• Regulations apply to:
− All Ministers of the Crown, government departments, local authorities and other
national, regional or local public administration bodies that have responsibilities in
relation to the environment.
− Anybody with public responsibilities for the environment not covered by the previous
paragraph but under the control of a person falling within that paragraph.
• Information includes anything contained in any records.
• Records include registers, reports and returns, as well as computer records and any other
records.
• Statutory provision means any provision made by or under any enactment.
There are a number of significant exemptions including: security and defence, commercial
confidentiality, intellectual property.
Freedom of Information Act 2000 (Scotland 2002)
Full implementation of this Act took place on 1st January 2005. It extends the right to official
information at Central and Local Government levels and covers many areas besides
environment.
Appeals are heard by an Information Commissioner, although decisions about whether it is in
the public interest are taken by Government Ministers.
Schedule 1 to the Regulations lists the bodies to which the Act applies, including the House of
Lords, House of Commons, National Assembly of Wales, Scottish public authorities,
conservation and regulatory bodies, etc. Bodies to which the Act applies have to set out a
“Publications Scheme”, setting out what they will make publicly available.
Definitions
Integrated Pollution Prevention and Control (IPPC)
Background to IPPC
The European Council adopted directive 96/61 on Integrated Pollution Prevention and Control
(“the IPPC Directive”) in September 1996. The Directive is derived in a large measure from
Integrated Pollution Control (IPC) established under Part I of the Environment Protection
Act 1990, although there are some important differences. In the UK, the directive was
implemented through regulations known as the Pollution Prevention and Control
Regulations 2000. These regulations have now, however, been replaced in England and
Wales by the Environmental Permitting (England and Wales) Regulations 2007.
These new regulations do not alter the regime or impose any new standards they purely serve
to consolidate many permitting requirements under one set of regulations. In Scotland the
Pollution Prevention and Control Regulations continue to apply. The regime, however,
continues to be referred to as the ‘PPC regime’.
The PPC regime:
• Applies PPC concepts such as “Best Available Techniques” (information on BAT follows) to
all installations covered by the regime.
The Environmental Permitting (England and Wales) Regulations 2007 and
Pollution Prevention and Control (Scotland) Regulations 2000 (The PPC
Regime)
The PPC Regime requires industry to prevent or, where that is not possible, to reduce
pollution from a range of industrial and other installations, by means of an integrated
permitting process based on the application of “best available techniques”. The new
permit process takes a wide range of environmental impacts into account:
• Emissions of pollutants to air, water and land.
• Energy efficiency; waste management.
• Consumption of raw materials.
• Noise and vibration.
• Site restoration and decommissioning.
In order to satisfy this condition, a Site Condition Report has to be prepared, giving the
condition of the site at the time the Permit was issued. Site must be returned to this condition
after the plant has closed.
Permits must take into account local environmental conditions at the site concerned, its
technical characteristics and its geographical location. Conditions must be included to address
any transboundary pollution from an installation.
New Installations
The original Directive’s requirements applied to new installations immediately, and to parts of
existing installations which undergo a “substantial change”. Existing installations, insofar as
they were not substantially changed, enjoyed a grace period of up to seven years following
transposition, during which they must be upgraded to meet the new requirements. All
installations are however now permitted and, in England and Wales, are undergoing transition
from being permitted under the Pollution Prevention and Control Regulations to the
Environmental Permitting Regulations. Once issued, a permit will be reviewed
periodically, and will be upgraded if there are significant technological or other developments.
The timetable for each process application is published in Schedule 3 to the regulations.
PPC is More Than Pollution Control
PPC seeks to regulate almost all of the environmental impact of the operation of an
installation, for example:
• Contaminated land.
• Energy efficiency.
• Noise, vibration and raw materials consumption.
• Accident prevention (COMAH and PPC data can be used to satisfy both requirements).
• Environmental Impact Assessment (a number of the installations require an environmental
impact assessment before consent for development is given. It is suggested that under
certain circumstances there may be benefit in running the two procedures together).
• Waste.
Best Practicable Environmental Option (BPEO)

Under the Environmental Protection Act 1990 (EPA), Part 1, Section 6, certain processes
required Authorisation in order that they could operate or continue to operate (in the case of
existing processes). The EPA introduced two parallel regulatory control regimes. Details of
the processes concerned were set out in the Environmental Protection (Prescribed
Processes and Substances) Regulations 1991, as amended. Processes were designated
Part A and Part B. Guidance (actually to the enforcing authorities) gave details of the
performance requirements expected of each process in terms of emissions and other factors.
Certain risk control strategies were incorporated within this legislation. These are respectively
BPEO (Best Practicable Environmental Option) and BATNEEC (Best Available Techniques Not
Entailing Excessive Cost). The more complex processes involved with potential releases to
more than one environmental medium (designated Part A) required both a BPEO assessment
and were required to work to BATNEEC, whereas all other processes were required to work to
BATNEEC only. Where there are releases to more than one environmental medium in the
process, the test of BPEO applied. Under the Pollution Prevention and Control Act 1999
and Regulations 2000, and the Environmental Permitting (England and Wales) Regulations
the concept of BATNEEC and BPEO has been extended to purely BAT (Best Available
Techniques).
Best Available Techniques (BAT)

Best means the most effective and advanced stage in the development of activities and their
methods of operation which indicates the practical suitability of particular techniques for
providing in principle the basis for emission limit values designed to prevent and, where this is
not practicable, generally to reduce emissions and the impact upon the environment as a
whole.
Available techniques means techniques which have been developed on a scale which allows
them to be used in the relevant industrial sector, under economically and technically viable
conditions, taking into account the costs and advantages, whether or not the techniques are
used or produced inside the member state in question, as long as they are reasonably
accessible to the operator.
Techniques include both the technology and the way the installation is designed, operated
and decommissioned.
Role of the Environment Agency/Scottish Environment

Protection Agency
The Environment Agency (EA) and Scottish Environment Protection Agency (SEPA) are the
principal enforcement agencies.
The Environment Act 1995 brought into being the Environment Agency and Scottish
Environment Protection Agency (SEPA) in April 1996.
The Environment Agency operates in England and Wales and brings together the former
National Rivers Authority (NRA), Her Majesty’s Inspectorate of Pollution (HMIP) and the Waste
Regulation Authorities (WRA). SEPA is the Scottish equivalent.
Environment Agency
The Environment Agency (EA) is charged with protecting and enhancing the environment
and contributing towards attaining the objective of achieving sustainable development. It
mainly aims to:
• Achieve major and continuous improvements in the quality of air, land and water.
• Encourage the conservation of natural resources, animals and plants.
• Make the most of pollution control and river-basin management.
• Provide effective defence and warning systems to protect people and property against
flooding from rivers and the sea.
• Reduce the amount of waste by encouraging people to reuse and recycle their waste.
• Improve standards of waste disposal.
• Manage water resources to achieve the proper balance between the country’s needs and
the environment.
• Work with other organisations to reclaim contaminated land.
• Improve and develop salmon and freshwater fisheries.
• Conserve and improve river navigation.
• Tell people about environmental issues by educating and informing.
• Set priorities and work out solutions that society can afford.
To achieve these aims, it must adopt an integrated approach and work with relevant bodies
and the public at large. Section 4 of the Environment Act 1995 details how this should be
done. It must also further the conservation and enhancement of natural beauty, flora and
fauna. According to its own literature:
“By combining the regulation of land, air and water, the Agency offers a comprehensive
approach to environmental protection and improvement (in England and Wales). This is
achieved with an emphasis on prevention and education and on vigorous enforcement
where necessary.”
More specifically the EA has pollution control responsibilities as follows:
• Authorising emissions, discharges and disposals to the various media by licensing,
monitoring compliance and taking enforcement action.
• Waste management licensing and regulation, including special and radioactive wastes and
also import/export of waste. It must assess waste disposal needs and offer technical
guidance on waste management.
• Regulating and reporting on contaminated land.
• Advising government in setting environmental quality objectives (EQOs).
• Advising industry and others on best environmental practice.
The Agency also has an administrative and consultative role. It must set up and consult:
• Regional Environment Protection Advisory Committees.
• Regional and Local Fisheries Advisory Committees.
• Regional Flood Defence Committees.
It must also set up registration and exemption schemes for producer responsibility (e.g.
packaging).
It must consult with the Joint Nature Conservation Committee about SSSIs (Sites of Special
Scientific Interest) and other relevant bodies in respect of issuing discharge consents and other
relevant decisions.
The Chief Executive and Directors are based in the head office in Bristol with supporting
offices in London. They manage the overall business and put new laws into practice to make
sure the environment benefits. They make decisions and manage the areas to make sure the
needs of the local community are met.
The Agency has seven regional offices, over 20 area offices and one in Cardiff representing
Environment Agency Wales. This allows a quick response to incidents and emergencies across
England and Wales and provides a local service.
The duties of the agencies may be summarised as:
• To enforce relevant legislation, i.e. to be responsible for authorisations, licences and
consents, and for monitoring compliance. An enforcing officer will be responsible only for
enforcing specific legislation, not all legislation.
• To monitor environmental conditions and publish statistics.
• To advise government in setting environmental quality standards and for proposals for
pollution prevention measures.
• To provide advice and guidance on best environmental practice.
• To respond to complaints from the public concerning environmental pollution and
nuisance.
Scottish Environment Protection Agency

The main aim of SEPA is to improve the environment and contribute towards the achievement
of sustainable development. Other important aims include:
• Providing an excellent environmental service for Scotland.
• Improving sustainable use of natural resources.
• Maintaining and restoring good quality environments for: water, air and land.
• Promoting respect for the environment.
SEPA regulates:
• Activities that may pollute water and air.
• Waste issues.
• Disposal and retention of radioactive materials.
For further information on SEPA, see the website: www.sepa.org.uk.
? Revision Questions
1. Explain BAT.
2. Define ‘environmental impacts’.
3. What pollution control responsibilities do the environmental agencies have?
4. What types of pollution can be prevalent in drinking water?
5. Explain the difference between spot or grab and continuous sampling.
6. What standards are used in monitoring environmental performance?
7. What information is required to be put on public registers by the Environmental Permitting
(England and Wales) Regulations 2007.
(Suggested Answers are at the end of Unit C.)
CLASSIFICATION OF WASTES
Definitions
Solids, Liquids and Gases
There are many types of solid, liquid and gaseous waste, such as:
• Solids
Residues from incineration and from household waste.
• Liquids
Effluent from chemical processes activities and from water treatment works.
• Gases
Sulphur dioxide and nitrogen oxides.
Hazardous and Non-Hazardous

Wastes are defined as hazardous if, for example, they are highly flammable, harmful, toxic,
carcinogenic or corrosive. The definition includes many household products such as: fridges,
freezers and televisions, fluorescent light tubes and computer screens, and printer toner
cartridges. Hazardous wastes include those from:
• Industrial chemical processes.
• Oil refining.
• Metals processes.
• Nuclear industry.
They also include:
• Solvents.
• Waste oils.
• Some clinical waste.
• Asbestos.
Non-hazardous waste means waste that is not covered by the above, including: household
waste, paper, wood and other degradable waste.
Difficult Waste
Difficult waste is a term frequently encountered when discussing waste management options,
but it has no legal status. It is taken to mean waste which is difficult to handle, usually in the
context of a waste treatment or management facility. It includes: wet sludges, liquids or
dusty materials.
Flammable Waste
Annex 111 of the EC Directive 91/689 on Hazardous Waste describes flammable waste as:
liquid substances and preparations having a flash point equal to or greater than 21° C and less
than or equal to 55° C.
Clinical Waste
Clinical waste is defined in the Controlled Waste Regulations 1992, as amended, as:
“any waste which consists wholly or partially of human or animal tissue, blood or other
bodily fluids, excretions, drugs, pharmaceutical products, swabs, dressings, or syringes,
needles or other sharp instruments which, unless rendered safe, may prove hazardous to
any person coming into contact with it”
and
“any other waste arising from medical, nursing, dental, veterinary, pharmaceutical, or
similar practice, investigation, treatment, care, teaching or research, or the collection of
blood for transfusion, being waste which may cause infection to any person coming into
contact with it.”
There are specific joint HSC (“Health and Safety Commission”, merged with the HSE in
2008)/Environment Agency Guidelines published on the Safe Disposal of Clinical Waste, which
is a Code of Practice for all those managing and working with clinical waste. Requirements
include hygiene, training and waste segregation, including a colour coding for the different
categories of clinical waste, some of which demand incineration.
Clinical waste is subdivided into groups reflecting the means of disposal:
• Group A:
− Soiled surgical dressings, etc.
− Material other than linen from infectious disease cases.
− Human and animal tissues and carcasses and dressings, etc.
• Group B: sharps.
• Group C: laboratory and post-mortem waste.
• Group D: pharmaceutical and chemical waste.
• Group E: used disposable bedpan liners, incontinence sheets, etc.
Clinical waste should be segregated from general waste in order to reduce the amount as far
as possible. Separate bins, signage and training should be provided to encourage this.
• Group A waste should be put into heavy-duty yellow bags (⅔ full) and securely fastened.
• Sharps should go into properly designed sharps containers.
• Group C waste should be separately labelled, stored and transported with due respect for
the nature of the contents. Laboratory material where risk of pathogens is high should be
autoclaved before being included with other clinical waste.
All the above will need to be stored and should either be kept refrigerated or the storage time
kept to one-week maximum; ultimately to be incinerated in an approved facility.
• Group D waste will need to be handled separately because it must be incinerated under
conditions to ensure complete and rapid destruction in such a way that vapours are not
released.
• Group E is of large bulk and low hazard and may be sent to landfill.
Biodegradable Waste
Biodegradable waste is that which can undergo bacterial decomposition. Under the Landfill
Directive biodegradable waste is “waste from households or other similar waste which is
capable of undergoing anaerobic or aerobic decomposition”.
Radioactive Waste
A radioactive substance is defined as “any substance which contains one or more radionuclides
whose activity cannot be disregarded for the purposes of radiation protection".
Radioactive waste requires authorisation from the Environment Agency before such materials
are accumulated or disposed of.
Wastes can, of course, be covered by more than one definition; some definitions are
concerned with the point of arising or with physical properties.
Waste
According to the Environmental Permitting (England and Wales) Regulations 2007 waste is
called ‘Directive Waste’ (from the EU Waste Framework Directive) and is defined in terms
of any substance or object in the categories set out in the schedules thereto and also Schedule
22 of the Environment Act 1995.
The Waste Management Duty of Care Code of Practice describes it as being defined from the
point of view of the person discarding it. Waste is defined as any substance or object which
the producer or the person in possession of it discards, or intends or is required to discard
(Council Directive 75.442 EEC, as amended by Directives 91/156/EEC and
91/689/EEC). In this definition, the “producer" is anyone whose activities produce waste or
who carries out reprocessing, mixing or other operations resulting in a change in its nature or
composition. Anything discarded or dealt with as waste must be presumed to be waste unless
proved otherwise. A ‘yes’ answer to any of the following questions should clarify any doubts
about the matter:
• Would it normally be described as waste?
• Is it a scrap material?
• Is it an effluent or other unwanted substance?
• Is it broken, worn out, contaminated or spoiled?
• Is it being discarded as if it were waste?
Whilst waste may be a commonly understood term, its definition in law is far from
straightforward, and the waste management controls which have been evolving since the
Control of Pollution Act 1974 and the Environmental Protection Act 1990 have
profound implications for industry and commerce.
Controlled Waste
The Control of Pollution Act 1974 addresses all aspects of pollution including wastes and
introduces the concept of controlled waste, and later special waste (now hazardous
waste). Controlled waste was effectively any waste covered by the Control of Pollution Act
and meant all waste, including wastes from households, industry and commerce but not from
agriculture, mines and quarries, or explosives or radioactives (which have their own special
regulatory framework). It was incorporated into the Environmental Protection Act 1990,
Section 75, and the Controlled Waste Regulations 1992.
Most of the provisions of the EPA apply only to controlled waste: household, commercial and
industrial waste. Section 75 of the EPA further defines household waste as “waste from a
domestic dwelling, caravan, residential home, hospital or nursing home”; commercial waste is
waste from premises used for trade, business, sport, recreation or entertainment; and
industrial waste is waste from a factory or any premises used in connection with public
transport, public supply of gas, water, sewerage services and electricity, telecommunications
and postal services.
Although this definition is set out in the EPA, it is clarified by the Controlled Waste
Regulations 1992, and modified by Section 90 of the EPA, which states that the following
are not to be treated as household waste: “asbestos, mineral, synthetic oil or grease or clinical
waste”, so the definition and interpretation of the definition of waste becomes more complex.
Note that hazardous waste and clinical wastes are also controlled waste, but due to their
nature they require special provisions for handling.
Hazardous Waste
Directive 91/689/EEC on hazardous waste was initially implemented in the UK through the
Special Waste Regulations 1996 (1998 in N. Ireland). However the UK list of special
wastes varied from Europe and the Directive has now been fully implemented, to bring it in
line with Europe, by the Hazardous Waste (England and Wales) Regulations 2005, with
similar regulations for Scotland and N. Ireland. The Hazardous Waste Regulations 2005
repeal the Special Waste Regulations and wastes that are included in the definition are
now referred to as Hazardous Wastes rather than Special Wastes.
The European Waste Catalogue contains a list of hazardous and non-hazardous wastes
meeting the requirements of the Hazardous Waste Directive and the Framework Directive. The
European Waste Catalogue, 2002, has been implemented into the UK through the List of
Wastes Regulations 2005.
These Hazardous Waste Regulations came into force in two phases, on 16th April 2005 and 16th
July 2005. The regulations did not apply to Agricultural and Mines and Quarries Waste until 1st
September 2006.
The main provisions of the Hazardous Waste Regulations are:
• Definition of hazardous waste.
• Restriction of the mixing of wastes.
• Notification of premises producing hazardous waste.
• Consignment Note arrangements.
• Returns and records.
Definition of Hazardous Waste

A waste is hazardous if it is listed as a hazardous waste in the List of Waste Regulations
2005. The Environment Agency Technical Guidance Note WM2 – Hazardous Waste gives
guidance on the methodology for assessing wastes based on the European Waste Catalogue
(EWC) 2002.
The EWC lists the following wastes:
• Non-hazardous waste those entries that are given in ‘black’ and have no *
• Absolute entries those entries that are given in ‘red’ and have an * - these are
always hazardous waste.
• Mirror Entries those entries that are given in ‘blue’ and have an * - these
are only hazardous waste if dangerous substances are
present above threshold concentrations, specified in Article 2
of the EWC. (In the UK - the List of Wastes Regulations
2005).
Note that the term 'dangerous substance' is as defined in the Chemicals (Hazard
Information and Packaging for Supply) Regulations (CHIP). From the above
definitions it is clear that 'Mirror Entry' wastes may or may not be hazardous, depending on
whether certain criteria are fulfilled. Waste holders are required to determine whether their
'Mirror Entry' waste is indeed hazardous and, if so, assign it to one or more of the Hazardous
Property Categories (H1 - H14, listed in the technical guidance note, WM2, referred to earlier).
These hazardous property categories, for the most part, follow the categories of danger used
in the CHIP Regulations, e.g. H1= Explosive; H2 = Oxidising; H6 = Toxic; H7=Carcinogenic,
etc. There are several ways to determine the assignment:
• If the chemical composition of the waste can be determined (e.g. from knowledge of
which raw materials went into it and how it was produced) then it should be assessed to
determine whether it contains components which are 'dangerous substances'. Many
common 'dangerous substances' are listed in the Approved Supply List (ASL), which
accompanies the CHIP Regulations. If a component is listed in the ASL, then the
hazard classification of that component will be given for you, along with its associated 'risk
phrases'.
If a component is not listed in the ASL, then you must determine whether that component
is 'dangerous' or not by recourse to either safety data sheets or by using the approved
classification methods described in the approved classification and labelling guide (which
also accompanies the CHIP Regulations). If any of these identified 'dangerous
substances' are present in the waste above prescribed threshold concentrations, then the
waste as a whole is hazardous. The threshold concentrations are listed in the technical
guidance note for each hazard category.
• If it is not possible to determine the composition or there is insufficient information
available, then either you must test the waste as a whole or assume that it is indeed
hazardous (but the assumption should normally be based on at least some crude tests,
such as pH determination, and information on the likely nature of the waste)."
Note:
• Where a waste is not listed in the European Waste Catalogue – it is not a hazardous
waste.
• To be a Hazardous Waste a waste must first meet the definition of Controlled Waste.
The determination of Mirror Entry Hazardous Wastes can be complex; reference should be
made to Technical Guidance WM2 and the Consolidated European Waste Catalogue, also
available through the Environment Agency website.
Restriction of the Mixing of Wastes
It is an offence to mix hazardous wastes unless it is permitted as part of a disposal or recovery
operation. Mixing of hazardous waste includes:
• Mixing different categories of hazardous waste.
• Mixing with a non-hazardous waste.

• Mixing with any other substance or material.
There is an additional requirement that where such mixing has occurred the holder of the
waste must separate the wastes where it is technically and economically feasible. The duty to
separate may not necessarily be on the person who initially mixed the waste but on who now
holds the waste.
Disposal Arrangements
Notification of Premises Producing Hazardous Waste
Where hazardous waste is produced at or removed from premises, the premises must notify
the Environment Agency. Once the Environment Agency has been duly notified the premises
become ‘notified premises’ for the period of twelve months.
Note: It is an offence to remove hazardous waste from premises which have not been
notified to the Environment Agency, unless they are exempt premises or the waste has been
flytipped. All premises at which hazardous waste is produced or removed must be notified by
the producer of the waste or the consignor (the person who arranges for the removal of the
waste). A fee is payable to the Environment Agency on notification of premises. (This
requirement replaces the pre-notification of movement requirements in the repealed Special
Waste Regulations.)
Certain types of premises are exempt from the requirement to notify if less than 200kg of
hazardous waste is produced in any twelve month period. Premises that may be exempt under
this regulation include:
• Offices.
• Shops.
• Agricultural premises.
• A residential home.
• Caravan.
• Premises forming part of a university, school or other education establishment, hospital or
nursing home.
• Premises at which waste electrical and electronic equipment is collected.
• Dental, veterinary or medical practice or a ship (no quantity limit applies in the case of a
ship).
Consignment Notes
The movement of hazardous waste requires consignment notes, to be completed whenever
hazardous waste is removed from premises (which includes removal from ships and removal by
pipeline). The various types of form are set out in Schedules 4 to 7.
Producers, holders, carriers, consignors and consignees are all required to complete various
parts of the forms. If the consignee rejects the waste, suitable alternative arrangements must
be made.
Where more than one carrier transports the consignment a schedule of carriers must also be
completed.
Where a single carrier collects more than one consignment of waste in the course of a journey
and each consignment is collected from different premises, if all consignments are being
transported to the same consignee promptly, ‘multiple collection’ provisions are available.
An example of a consignment note follows.
Example of a Consignment Note
Records and Returns

Producers, holders, carriers, consignors and consignees are required to keep records. These
must be kept for a minimum of 3 years except in the case of carriers where the period is 12
months. Consignees are required to provide the Environment Agency with a quarterly return
setting out the consignments they have received during that period. Consignees may be
required to pay a fee to the Environment Agency but are given a right to recover the payment
from consignors who sent the waste to them. They are also required to send a return to
producers or holders who sent waste to them.
Disposal of hazardous wastes is managed by specialist companies (e.g. Rechem) who have
acquired expertise and operate dedicated chemical plant. Recovery of waste oils, solvents, etc.
is usually followed by incineration of the residues, which must be carefully controlled to
minimise production of environmentally nasty substances such as dioxins and furans. The
latter involves careful control of incinerator temperatures and cleaning of effluent gases. The
problems caused by the inadequate combustion of difficult substances such as PCBs underline
the need for effective high-temperature incinerators for treating hazardous wastes.
There are two merchant hazardous waste incinerators in England and Wales which receive
waste from other waste producers: i.e. Cleanaway, Ellesmere Port and Shanks, Southampton.
Hazardous waste is also incinerated at a number of chemical plants, drum reconditioning
facilities and cement or lime kilns that incinerate hazardous waste with other fuels.
Such a plant is subject to IPPC so that contaminant levels of prescribed substances must meet
defined limits at all times. These would include stack emissions of nitrogen and sulphur oxides
(which can form acid rain) and particulates; chemical composition, temperature and turbidity
of outfall passed to water; and content of dioxins, furans and other halogenated compounds
passed to all three media - land, air and water.
From July 2004 hazardous waste has had to be treated prior to landfill disposal due to the ban
on co-disposal with non-hazardous waste. The treatment must:
• Be a physical/thermal/chemical or biological process including sorting.
• Change the characteristics of the waste in order to:
− Reduce its volume, or hazardous nature; or
− Facilitate its handling; or
− Enhance its recovery.
Methods of Categorising Waste and Different

Techniques Required for Each Waste Category
Waste definitions and categorisation are represented in the diagram that follows. These waste
categories are generally dealt with by following the waste hierarchy already mentioned.
Eliminating or reducing waste, or changing to a waste disposal arrangement higher up this
hierarchy should both improve the environmental outcome and make economic sense in each
case.
Controlled Waste
Controlled waste can be split into the following categories:
• Household
Applies broadly to households, places of worship, charity premises, private garages,
campsites, prisons, public meeting venues, royal palaces, residential homes, educational
establishments and hospitals.
• Industrial
Applies broadly to waste arising from factories, public transport premises, premises used
to supply services (water, gas, electricity, telecommunications, etc.), commercial garages,
laboratories, workshops and excavation works. Also applies to certain categories of
sewage and clinical waste.
• Commercial
Defined broadly as waste from premises used wholly or mainly for the purposes of trade,
business, sport or recreation. It includes waste from offices, showrooms, hotels, large
private garages, clubs, societies, etc., and waste classified as ‘industrial’ or ‘household’
from courts, government departments, local authorities, corporate bodies, markets, fairs
and tents not pitched on a campsite.
WASTE
Controlled Waste Non-controlled Waste
Household Commercial Industrial Agricultural Mines, quarries
Inert Non- Hazardous

hazardous Special
Non-special
Waste Categorisation
We have discussed hazardous waste in the previous section.
8. Define the following wastes:

− Biodegradable.
− Flammable.
9. Explain what is meant by clinical waste, and what groups are used for its disposal.
10. Define hazardous waste.
11. Define controlled waste and give examples.
PRACTICAL WASTE MANAGEMENT

Minimisation
The emphasis should be on not generating waste in the first place. So, although waste may
be unavoidable in many cases, minimisation can be achieved by process change and optimising
efficiency.
Storage
Waste must be properly stored and protected. If it is not, it may escape to the environment
and cause harm. Practically this means covering skips, storage in bunded areas (to protect
against leakage) and security.
Labelling
Waste should be labelled where appropriate and in accordance with the CHIP Regulations.
If the waste is hazardous for transportation, it should also be correctly labelled in accordance
with transportation regulations.
Carriage
Anyone who holds waste may transfer it to a waste carrier who must be registered with the
Environment Agency. However, it is part of the waste holder’s duty to ensure that carriers
are suitable to handle and dispose of the waste. The holder should remain alert to any sign
that the waste may not be legally dealt with by a carrier.
The duty holder therefore ultimately remains responsible for the fate of the waste so that if, for
example, it is taken by a carrier and fly-tipped, it will be the duty holder’s (perhaps difficult)
task to persuade a court of law that he acted in accordance with the Code of Practice, which
explicitly has legal standing. It is for the waste holder to ensure the bona fides of any waste
carrier, who must be a registered carrier of controlled waste.
The Duty of Care

An important provision of Part II of the Environmental Protection Act 1990 was the
introduction of a new duty for all persons involved in the generation, importation, handling,
transporting and disposal of ‘directive waste’. Any such person automatically becomes a waste
holder. The duty identifies the responsibility for waste management from the generation of the
waste to its final disposal as lying with the company or organisation which generates or
imports the waste. The duty does not, however, extend to householders or occupiers of
domestic properties. The concept is dealt with later under legal regimes.
The Duty of Care Code specifies prevention of:
• Corrosion or wear of containers.
• Accidental spills or leakages.
• Breach of containment by weather.
• Blowing away or falling from vehicles or storage.
• Scavenging by vandals, thieves, children, trespassers or animals.

So leakage from waste into the ground may contaminate it, and the contamination may then
pollute ground-water. Waste holders’ duties are designed to prevent such abuses, which it was
anticipated would increase following the introduction in 1996 of the Landfill Tax at set amounts
per tonne for inactive waste (builders’ rubble) and for active (general) waste. The waste
holder must:
• Protect the waste while they have it (cover skips, store liquids in bunded enclosures, etc.).
• Ensure that it reaches the next holder intact (if the next stage is a waste transfer station,
it should be sorted and mixed so that excessive packaging is not needed).
• Segregate incompatible wastes (preventing cross-contamination of waste).
• Ensure security (secure against waste attractive to scavengers, e.g. building materials).
Waste left for collection should be adequately secured and left for a minimum of time.
12. The Environmental Protection Act 1990 introduced a duty of care for all persons
involved in the generation, importation, handling, transportation and disposal of ‘directive
waste’. What does that duty specify prevention of?
13. Which legislation should be considered when labelling hazardous waste?
WASTE DISPOSAL
Types of Waste Treatment
Physical and Chemical Treatment
Physical treatment of waste includes reducing its bulk, e.g. by the use of presses to remove
water from sludges. Physical treatment may also include heating to kill pathogens. Chemical
treatment may be necessary to reduce the hazardous nature of a chemical, e.g. neutralisation
of acids with bases, and treatment of sludges.
Newer technologies in this area are:
• Pyrolysis: in this treatment, organic waste is heated in the absence of air to produce a
mixture of gaseous and liquid fuels and a solid inert residue (mainly carbon).
• Fermentation: this particular treatment is confined mainly to agricultural wastes, but can
in theory also be extended to pre-treated municipal solid waste, to produce liquid fuel
(ethanol, and some methanol).
• Anaerobic digestion: this is the biological degradation of organics in the absence of
oxygen, producing methane gas and a residue suitable for use as a soil improver. It is
used to treat sewage sludges. The methane gas is used to meet on site power and
process heat requirements and the residue is cattle slurry.
• Gasification: where carbon based wastes are heated in the presence of air or steam to
produce fuel-rich gases. Northumbrian Water has proposed gasification for the treatment
of sewage sludge in its area.
• Feedstock recycling: it is possible to react mixed plastic waste in a polymer cracking
process which produces products similar to naphtha feedstock.
• Feedstock substitution: in this process mixed plastic waste is used as a feedstock in blast
furnaces producing pig iron. Mixed plastic waste can be used as a substitute source of
carbon.
• Substitute fuels: these include scrap tyres and solvent wastes which substitute coal and
petcoke (petroleum coke) in cement and lime kilns, and can also include packaging waste
paper, biofuels and plastics.
• Plasma arc: an alternative heat combustion system for mixed wastes, such as municipal
solid waste. It uses plasma arc heating (the energy released by an electrical discharge in
an inert atmosphere) to raise the temperature of the waste to anything between 3,000
and 10,000°C, converting organic material to a hydrogen rich gas and non-combustibles
to an inert glassy residue. The gas (which is relatively uncontaminated) is suitable for
generating electricity to support the process. The volume of gases discharged from these
processes is generally less than 10% of that generated by incinerators with the same
waste processing capacity.
• Biomechanical waste treatment (BWT): this commonly comprises a number of standard
waste separation operations to remove recycled materials such as glass, metals and
plastics, followed by composting of the remaining organic materials.
• Anaerobic digestion instead of composting: a variant of the BWT process that uses
biomechanical waste treatment. It is claimed that the potential of the residue for landfill
gas production and residual waste is reduced, but leads to an increase in levels of VOCs
(volatile organic compounds) to the atmosphere.
Landfill
Landfill Sites
Landfill sites are the most commonly used form of waste disposal. They have been used
extensively in the UK due to an abundance of disused mineral extraction sites. Every site is
different and use is subject to conditions set by the Environment Agency and the Local
Planning Authority. The conditions imposed on a landfill site will depend on the geology,
hydrogeology, topography and the general environment, i.e. proximity to houses, roads, etc.
The conditions on each landfill site will therefore be unique to that site. From a practical
viewpoint, waste producers must check (see Duty of Care as discussed later in this element)
that the particular site proposed for the waste is permitted by the Waste Management Licence.
There may be problems with heavy vehicle movements.
Landfill sites were originally small, informal or non-engineered sites used by local councils and
industry. Landfill was first defined in 1971 as “the deposit and compacting of waste in shallow
layers, and covering the exposed surfaces with inert materials to form a seal”.
Prior to the 1970s, there was little engineering control beyond that provided by local
topography and geology. Since then, the trend has been towards larger sites (5 × 106m3) sited
away from urban centres. Legislation to license landfills did not begin until the late 1970s,
with further tightening in 1994. Permitting will continue under the Environmental
Permitting (England and Wales) Regulations 2007.
A landfill site must be geologically suitable. Ideally it should be impervious, e.g. underlain by
clay, but if not a membrane can be laid to make it so. The design should minimise ingress of
ground-water which could arise due to changes in the local water table, flood conditions or the
existence of springs or streams. The site should be finished with an impervious clay dome to
shed rain-water. Modern landfill sites are highly engineered. Works commence with detailed
engineering surveys and studies of the geology, hydrogeology, soils, water, ground-water and
many other parameters. Today, sites are expected to avoid pollution, so sites are usually lined
with a plastic or asphaltic liner, followed by the development of a complex of leachate and gas
collection wells and pipes. Monitoring of all these systems is required and incorporated. The
waste inputs are carefully monitored and checked and tipping takes place in ‘cells’, each of
which will be virtually self-contained, giving a complex ‘honeycomb’ of cells in the completed
site, which is then capped with a carefully engineered series of different sealants (such as clay
and subsoil), before being finished with topsoil and planted.
Certain kinds of hazardous waste are not considered suitable for disposal by landfill, however
sophisticated the site; these include some clinical wastes, pesticides, industrial gases under
pressure in degradable containers, highly flammable concentrates, and certain heavy metals
such as lead and cadmium. The Landfill Directive introduced new regulations restricting
certain wastes which may be disposed of by landfill.
Potential Problems with Landfill Sites
The major potential problems concerned with landfill sites are:
• Landfill gas.
• Leachate.
• Nuisance.
Landraising
Landraising, or above ground landfills have increased in the last few years and may become
more widely used in order to combat the decreasing number of landfill sites. Planning Policy
Statement 10: Planning for Sustainable Waste Management (PPS10), is the principal source of
national planning advice on waste management and it distinguishes between landfill and
landraising. The disposal of wastes by landraising can provide more effective control over the
migration of landfill gas and leachate. These schemes are much less common than landfill
sites but have the same environmental disbenefits, e.g. incompatibility with the local
topography, visual intrusion, noise from vehicles on site and odour from landfill gas. Such
schemes require careful management and site choice throughout their life from conception and
planning to the final restoration stage.
Landraising might also be used for agricultural improvement, e.g. by improving drainage
and/or land productivity or for the restoration of degraded, contaminated or derelict land and
former mineral workings.
Landraising does however offer some benefits to the environment, for example:
• Greater distance from ground-water.
• Leakages may be easier to identify and control.
• Engineering aspects of design and construction are less complex.
Where landraising is proposed, operators will need to obtain a waste management licence from
the Environment Agency, as well as getting planning permission.
Incineration
Application
Incinerators are used for a variety of purposes. Applications include destruction of:
• Domestic waste, commercial waste and certain industrial wastes.
• Liquid industrial waste, e.g. oils, solvents.
• Sewage sludge.
• Clinical waste.
• Animal carcasses, etc.
Advantages
Incinerators are used in a number of applications and have many advantages over other
disposal methods, for example:
• Reduction in volume.
• Destruction of hazardous components.
• Creation of an easily disposed of ash.
• Small size of plant.
• Immediate and measurable effects.
• Can be used to raise energy by utilising calorific value of waste.
Disadvantages
These include:
• High capital cost and monitoring requirements.
• High fuel costs on start up.
• Need to carefully control inputs.
• Incinerators are not suitable for aqueous wastes, wastes containing heavy metals,
chlorinated materials (unless special controls are in place), and non-combustible solids.
The Waste Electrical and Electronic Equipment (WEEE) Regulations 2006
These Regulations have come into force since the introduction of the present syllabus and you
should have some knowledge of their impact. It is appropriate to include them here.
They finally came into full force in the UK on 1st July 2007.
Derived from the WEEE Directive, the Regulations aim to minimise the impact of electrical
and electronic goods on the environment, by increasing reuse and recycling to reduce the
amount of electrical and electronic equipment disposed of at landfill sites. They seek to
achieve this by making producers financially responsible for collection, treatment and recovery
of waste electrical equipment. The Regulations also oblige distributors to allow consumers to
return their waste equipment free of charge.
The WEEE Directive requires EU member states to collect and recycle the equivalent of 4kg
of "e-waste" for every person living in the country.
In the UK, DEFRA is responsible for ensuring the permitting of Authorised Treatment Facilities
for the WEEE Regulations. The enforcement agency responsible is the Environment Agency
in England and Wales, the SEPA in Scotland and the Environment and Heritage Service (EHS)
in Northern Ireland.
Manufacturers and importers in the UK have to join one of 37 authorised "producer compliance
schemes". The schemes, which are funded by manufacturers, are responsible for ensuring the
correct collection, recovery and disposal of e-waste. The schemes report to the appropriate
authority (e.g. the Environment Agency), which ensures enforcement of the measures.
Retailers must either offer a free in-store "take-back" service; take the customer's old
equipment when they buy a new one; or help fund improvements to local authority recycling
facilities.
Households are under no obligation to recycle their e-waste as far as the WEEE Regulations
are concerned, but they will be discouraged from throwing away items potentially containing
harmful substances.
They will be encouraged instead to use the recycling facilities being offered to them through
the authorised producer compliance schemes.
Products that have been on the market since August 2005 have been marked with a crossed-
out wheelie bin. The symbol is to help user identification of electrical and electronic
equipment (EEE).
The ten WEEE categories are listed below:
1. Large household appliances.
2. Small household appliances.
3. IT and telecommunications equipment.

4. Consumer equipment.
5. Lighting equipment.
6. Electrical and electronic tools.
7. Toys, leisure and sports equipment.
8. Medical devices.
9. Monitoring and control instruments.
10. Automatic dispensers.
The e-waste problem is the fastest growing category of waste in the European Union. In
the UK alone, an estimated 1.2 million tonnes of e-waste are produced each year. While the
WEEE Directive requires about 20% of the nation's electronic waste to be diverted away
from landfill, it is hoped that the new law will result in much more EEE being recycled.
When the WEEE Directive was first agreed in February 2003, it was criticised for being far
too complex and costly to implement. While a number of nations, such as Austria and the
Netherlands, were able to implement the measures on time, others struggled. The UK delayed
adoption of the legislation a number of times, but following the announcement of further
postponement in July 2006, the Opposition parties criticised the Government for taking "the
longest WEEE in history". Officials blamed the delays on "major difficulties".
Major figures in industry said the setbacks were due to the UK attempting to establish a
system that would be successful once it was up and running. A number of other nations
decided to adopt the Directive quickly and sort out resultant problems later.
According to the Department for Business, Enterprise and Regulatory Reform (formerly the
Department of Trade and Industry), full implementation of the WEEE Regulations in the UK
is estimated to cost between £111m and £133m, rising to £331m-£434m by 2017.
14. What environmental benefits are gained by using a landraising method of waste disposal?
15. Highlight the advantages and disadvantages of using incineration as a method of disposal.
16. Which hazardous wastes would not be considered suitable for disposal in landfill sites?
LEGAL REGIMES APPLICABLE

Concept of Duty of Care
Environmental Protection Act 1990
In disposing of a Directive Waste, there is a statutory duty of care defined by the
Environmental Protection (Duty of Care) Regulations 1991. The duty imposed by
these Regulations includes hazardous wastes. The Duty of Care regulations were enacted
under Section 34 of the Environmental Protection Act 1990 and implement a broad
framework Directive (75/442/EEC) on the control of both household and toxic wastes.
Regulations and a Code of Practice have been introduced to add detail to the Duty of Care
introduced at Section 34 of the Environmental Protection Act 1990. The Environmental
Protection (Duty of Care) Regulations 1991 define the documentation required to
exercise the duty of care. The Code of Practice provides practical guidance on how the duty of
care should be exercised.
Particular emphasis is placed upon preventing any other person contravening the law as to
unauthorised deposits, treatment or disposal of the waste. This requirement places a duty on
producers of waste to ensure that their wastes are transported and disposed of in accordance
with the provisions of the duty of care.
This duty of care extends from those producing waste through transporters of waste to final
disposal. An important feature of the duty of care is that whilst persons responsible for
transporting and disposing of the waste have duties to do so safely and effectively, that does
not remove from the organisation generating the waste the duty to ensure that the waste is
properly transported and disposed of. The Duty of Care and Code of Practice recommends that
producers should require to see the actual licences held by the transporters and disposers of
the waste. Licences to transport waste last for three years, so regular checking should be part
of the waste producer’s duties.
Similarly, some industrial waste producers arrange to follow the trucks of the waste
transporters to the disposal site once a year. The waste producer must ensure the proper and
safe disposal of waste, even after it has been passed on to another party such as a waste
contractor, scrap merchant, recycler, local council or skip hire company.
There are specific duties on producers of waste to ensure that wastes are only transferred to
persons who are licensed to accept or transport the particular types and quantities of waste
involved. To fulfil this duty it is not sufficient simply to ask the transporter if he is licensed to
transport and dispose of that type and quantity of waste.
The duty of care has no time limit and extends until the waste has either been disposed of or
fully recovered.
All employees and contractors working on a business’ premises should be given specific
instructions relating to how each and every type of waste that might arise is to be handled and
disposed of, and frequent checks should be conducted to ensure that they are followed. We
therefore see that this imposed a new responsibility not only on generators of waste. One
example of this is the duty of care related to the disposal of hazardous waste, for example, to
ensure that any waste consignment has the correct documentation, with an accurate
description.
Category Of Persons On Whom Duty Is Placed

As we have seen, the duty of care applies to all persons involved in waste generation,
importation, handling, transporting and disposal of directive waste, e.g. waste carriers, waste
brokers. The company or organisation which generates or imports waste is responsible until
its final disposal, although this does not apply to householders or occupiers of domestic
properties.
Typically authorised persons are:
• A waste collection authority.
• Any person who is the holder of a waste management licence under section 35 of the
EPA, or of a disposal licence under section 5 of the Control of Pollution Act 1974.
• Any person registered as a carrier of controlled waste under section 2 of the Control of
Pollution (Amendment) Act 1989.
• A waste disposal authority in Scotland.
Authorised transport involves:
• The transport of controlled waste within the same premises between different places in
those premises.
• The transport to a place in Great Britain of controlled waste which has been brought from
a country or territory outside Great Britain not having been landed in Great Britain until it
arrives at that place.
• The transport by air or sea of controlled waste from a place in Great Britain to a place
outside Great Britain.
This information was obtained from the HMSO (Stationery Office), “Waste management, The
Duty of Care, A Code of Practice”, ISBN 0 11 753210 X. It is available from their bookshop or
by telephoning 0870 600 5522, or see www.tsoshop.co.uk.
? Revision Question
17. Explain the concept of duty of care in dealing with waste.
(Suggested Answer is at the end of Unit C.)
EMERGENCY PROCEDURES
Need for Emergency Response Measures in the Event
of an Uncontrolled Release
Whilst emergency planning is a requirement of an Environmental Management System, it is
also a necessity under certain legislation, such as a Permit under the Environmental
Permitting (England and Wales) Regulations 2007, where certain conditions require
preparations to be made in the case of emergency conditions arising. Pollution prevention
guidelines (PPG 11, 18, 21) are available from the Environment Agency and SEPA.
The Civil Contingencies Act 2004 defines an environmental emergency as: “an event or
situation which threatens serious damage to …the environment of a place in the United
Kingdom” if it involves, causes or may cause:
“(a) contamination of land, water or air with biological, chemical or radio-active matter,
or
(b) disruption or destruction of plant life or animal life.”
There is also a common law duty of care on local authorities for such eventualities. Following
a flood in December 1979, Cardiff City Council and South Glamorgan County Council were
found negligent in their preparation and implementation of a flood emergency plan at Cardiff
Crown Court on 16 October 1987.
You will remember that your studies for Unit A of the National Diploma covered Emergency
Planning in some detail (Element A4). You may find it useful to look back at the appropriate
study material.
Emergency Situations
Emergency situations may arise from a variety of different circumstances.
Natural Events
Natural events such as high winds, storms or excessive rainfall can cause emergency
conditions to arise at a factory, e.g.:
• Winds may cause wind-blown dust.
• Rain can cause flooding or prevent discharges flowing away easily.
• Storm sewers may overflow.
Spillages and Containment Failure
Spillages can be caused by a variety of circumstances, e.g.:
• Road traffic accidents.
• Failure of pipes, hoses or other equipment.
Once again, an analysis of the risks should be carried out. A source, pathway, target analysis
should identify the pathways and targets. Appropriate emergency procedures and equipment
should then be put in place to reduce the risk to a condition which is as low as practicable.
The amount (and cost) of risk reduction measures will depend on the potential damage which
could be done if the substances escaped, and the sensitivity of the receptor.
Emergency plans can vary from complex off and on site emergency plans involving the local
authority and emergency services, evacuation procedures and closure of roads and railways, to
a small number of local procedures and spillage kits, to cover the spillage of a low risk
chemical in a low risk situation. The former scenario would be a requirement of the COMAH
Regulations 1999. Such sites will have an emergency officer, with a dedicated control room,
meteorological information, drain plans, road plans etc., and usually a media communication
officer. It is always prudent to practise emergency procedures, and most companies will have
invited the emergency services (particularly the Fire and Rescue services) to the site to
reconnoitre as part of the planning process. Having an inventory of the chemicals in use on
the site, and information concerning services (electricity, gas, water, etc.) is essential.
Disposal of Fire Water
Fire water can pose particular pollution problems. It has the potential to be contaminated with
a cocktail of combustion products, chemicals and possibly fire-fighting foams, all of which can
do harm to surface waters or sewage systems. Polluting a watercourse or the sewage system
may be an offence, even if there was an emergency situation prevailing. It is therefore
preferable to consider the disposal of fire water prior to the emergency situation. Possible
solutions include sacrificial areas, retention tanks and containment bunds. The Environment
Agency issues a number of advisory leaflets to explain best practice in this and other related
subjects. Known as Pollution Prevention guidelines, they are available from the Environment
Agency (EA) and are also on the EA website www.environment-agency.gov.uk. The subject of
fire water is discussed in PPG18, “Managing Fire Water and Major Spillages”.
Emergency Contacts
As part of any emergency plan, there need to be emergency contact numbers for the
Environment Agency, and the sewerage undertaker. Many companies also have arrangements
with emergency contractors who undertake to arrive within a specified timescale.
Emergency preparedness and response plans for such events may include the following
elements:
• On-site emergency response teams and equipment.
• Key personnel duties and responsibilities and contact details.
• Interrelationship with, and contact details for, off-site emergency services.
• Internal and external communication plans.
• Training arrangements and practice drills.
• Detailed response measures for each type of emergency incident − including personnel
response and equipment needs.
• Supportive data on inventories, locations, method of storage and potential effects on the
environment of the full range of chemicals held on the site.
All such plans should be practised and tested periodically and feedback given to promote
continual improvement.
Environmental Aspects of the Control of Major Accident

Hazards Regulations
The Control of Major Accident Hazards Regulations 1999 (COMAH) implement EC
Directive 96/82/EC (known as the Seveso II Directive) except for the land use planning
aspects which have been implemented through amendments to existing planning legislation.
COMAH replaced the Control of Industrial Major Accident Hazards Regulations 1984
(CIMAH) which implemented the original Seveso Directive (82/501/EEC). COMAH gives
equal importance to safety and environmental risks and, where practical, they must be treated
in an integrated way.
COMAH aims to prevent and limit the effects on people and the environment of those major
incidents involving dangerous substances, e.g. liquefied petroleum gas, chlorine, arsenic
pentoxide. COMAH has a number of important requirements, including:
• Identifying major accidents.
• Limit consequences for persons and the environment.
• Implement accident prevention measures.
The Seveso Directives take their name from an accident at a chemical plant at Seveso, Italy,
in 1976, in which a safety disk in a reaction vessel ruptured and a plume of chemicals
containing trichloro-phenol blew 30 to 50m above the factory. The resulting fallout led to
dioxin contamination of a 3-4km2 area down-wind from the factory with significant adverse
health effects in the local population.
The Regulations are enforceable by a joint Competent Authority comprising the Health and
Safety Executive (HSE) (who provide Guidance notes on certain aspects, e.g. HSG190 and
HSG191) and the Environment Agency in England and Wales and the HSE and the Scottish
Environment Protection Agency (SEPA) in Scotland. The Environment Agency or SEPA is
concerned principally with the assessment of the environmental aspects of COMAH. In
addition, local authorities have an important role to play in relation to emergency planning. A
Memorandum of Understanding (MOU), which sets out the responsibilities of the joint
competent authority, has been signed.
COMAH Regulations
The COMAH Regulations apply to companies which manufacture, store or transport
dangerous chemicals (including petrochemicals, pharmaceuticals and agro-chemicals) and
explosives, i.e. flammable, explosive, toxic or which are dangerous to the environment in
quantities in excess of threshold quantities specified in Schedule 1. Approximately 1,200
establishments in the UK have the potential to suffer major accidents because they use or
store significant quantities of dangerous substances, such as oil products, natural gas,
chemicals or explosives.
The Regulations apply at two thresholds, known as lower-tier and top-tier, depending upon the
quantity of dangerous substances stored or used. If the lower-tier threshold is equalled or
exceeded, operators must notify the Competent Authority.
The regulations legislate that:
• All sites should be able to demonstrate that they can operate safely.
• The competent authority should be notified of major accidents.
• Companies with large inventories should prepare safety reports and an on-site emergency
plan, co-operate with local authorities in preparing an off-site emergency plan, and
provide information to the public.
The competent authority must be notified so that it can plan its assessment and inspection
programmes and ensure that operators comply with their duties under the Regulations.
Essentially, what is needed is information about the operator, site, processes and inventory.
Schedule 1 lists the substances to which the regulations apply.

Schedule 2 describes the principles to be taken into account when preparing the operators’
major accident prevention policy document (aims and principles of action relating to major
accidents) and safety management systems (organisation, personnel, identification and
evaluation of major hazards, operational control, management of change, planning for
emergencies, monitoring performance, audit and review).
Schedule 3 requires that companies inform the competent authority of:
• The name and address of the operator.
• The address of the establishment concerned.
• The name or position of the person in charge of the establishment.
• Information sufficient to identify the dangerous substances or category of dangerous
substances present.
• The quantity and physical form of the dangerous substances present (or likely to be
present).
• A (brief) description of the activity or proposed activity of the installation concerned.
• The immediate environment liable to cause a major accident or to aggravate the
consequences thereof.
Schedule 4 details the purpose and contents of safety reports, e.g. description of installation,
identification of major accidents and accidental risk analysis and prevention methods,
protection measures, etc.
Under Schedule 5 of the Regulations, the operator must prepare a Major Accident Prevention
Plan (MAPP) which should demonstrate that there is an adequate safety management system
in place.
If the top-tier threshold is equalled or exceeded, operators must comply with additional
requirements to provide a Safety Report to the authority for approval, including details of the
types and quantities of hazardous substances (Section 7).
Under COMAH there is a requirement that a Site Safety Report is written which has the
function of identifying major accident hazards on the site and, inter alia, provides for an
estimation of the likely risks associated with the site and potential for major accidents which
could affect the environment. Where such risks are identified an assessment must be
undertaken to establish the consequence of the event in terms of the environment. In this
context ‘environment’ includes the air, the land and controlled waters. Should any sites have a
designated protected status or sensitive receptors in the vicinity then this has to be taken into
consideration. (DEFRA: Guidance on the Interpretation of Major Accident to the Environment
for the Purposes of the COMAH Regulations, 1999). The site safety report will cover:
• Major hazards arising from the consequences of potential accidents, especially the
possible extent and severity of an accident.
• Maps showing land use and the location of sensitive parts of the environment.
• Description of the environment and surroundings of the establishment.
• The ecotoxicology of substances that might be released in an accident.
• Protection and intervention methods designed to limit the consequences of accidents.
• Provisions made to mitigate post-accident impacts and aid the recovery of the
environment.
• A review when circumstances, including environmental ones, change in important ways.
The site safety report must include remediation (i.e. remedying environmental damage) and
clean up following an accident.
In assessing the environmental aspects of the installation for the purposes of the report,
attention focuses on the potential for harm to the environment (land, flora and fauna, etc.). It
has also focussed on any indirect effects on humans (such as the potential to contaminate
drinking water, food crops or water used for recreational purposes). The Health and Safety
aspects with specific consideration of potential harm to humans are contained in the main
body of the Site Safety Report. The Safety Report must be reviewed and revised at least every
five years.
A further requirement is to have an on-site emergency plan which covers features within the
boundary of the establishment, e.g. designated land, controlled waters (Section 9, schedule 5).
Under Section 10, Local Authorities must also prepare an off-site emergency plan for each top-
tier site (Further guidance HSG191). In the case of top-tier sites, the report must deal with
Major Accidents to the Environment (MATTEs).
COMAH places duties on the Competent Authority to inspect activities subject to COMAH and
prohibit the operation of an establishment if there is evidence that measures taken for
prevention and mitigation of major accidents are seriously deficient. It also has to examine
safety reports and inform operators about the conclusions of its examinations within a
reasonable time period.
The Environment Agency places information on COMAH establishments upon its Public
Registers which can be viewed at local Agency offices (Regulation 14, schedule 6).
As you will remember from your studies of Unit A, site operators have particular duties
depending on whether they operate on a lower-tier or higher-tier site. To remind you, the
requirements are as follows.
Lower-Tier Sites
Operators must notify the Competent Authority before operations with dangerous substances
begin. They must also take all measures necessary to prevent major accidents and limit their
consequences to people and the environment. Prevention should be based on the principle of
reducing risk to a level that is as low as is reasonably practicable (ALARP) for human risks and
using the best available technology not entailing excessive cost (BATNEEC) for environmental
tasks. The aim is always to avoid the hazard altogether where possible.
The key documentation that needs to be prepared is the major accident prevention policy.
This basically demonstrates how the safety management systems will prevent major accidents
and consequently covers areas such as:
• Organisation and personnel.
• Identification and evaluation of major hazards.
• Operational control.
• Planning for emergencies.
• Monitoring, audit and review.
Top-Tier Sites
Operators must comply with the above, and rather than prepare a major accident prevention
policy, they must compile a more comprehensive safety report. The safety report provides
information to demonstrate to the Competent Authority that all measures for the prevention
and mitigation of major accidents have been taken. The safety report must include:
• A policy on how to prevent and mitigate major accidents.
• A management system for implementing that policy.
• An effective method for identifying any major accidents that might occur.
• Details of plant and operating systems to prevent any major accidents.
• Information on safety precautions built into plant and equipment.
• Information on measures to limit consequences of any major accident that might occur.
• Information about the emergency plan for the site.
The safety report needs to be kept up-to-date and reviewed every five years or after
significant changes. Top-tier operators also need to prepare and test an on-site emergency
plan and provide local authorities with information to enable them to prepare off-site
emergency plans. Members of the public who could be affected by an accident at a COMAH
establishment must also be provided with information.
Additional Legislation
In addition, some sites are subject both to COMAH and to the PPC Regime which establishes
a permitting process by the competent authority which covers accidental pollution. In
recognition of the potential overlap, it is proposed that operators be given flexibility in how
they present information required under both regimes. They can keep applications for PPC
permits and safety reports separate or they can combine them so that information which
serves both purposes is not duplicated.
The requirements for safe storage, handling and use, and the notification of any releases will
be part of the permit.
Major Accidents
A major accident is described in COMAH as an occurrence (including a major emission, fire or
explosion) resulting from uncontrolled developments in the course of the operation of any
establishment and leading to serious danger to human health or to the environment,
immediate or delayed, inside or outside the establishment, and involving one or more
dangerous substances. All parts of this definition are necessary for an occurrence to be
defined as a major accident.
Major Accident Evaluation depends on the event type, the event scale, the size and location of
the affected area, the evaluation of event progression, and the potential harm to the
population and the environment.
Major Accidents to the Environment (MATTEs)
The more extensive the areas and quantities of natural and semi-natural resources damaged,
the longer the effects are likely to last; and the more intense or severe these effects, the more
likely it is that the event will be regarded as a major accident to the environment.
MATTEs can be caused by a number of factors, e.g. fires, land contamination, contamination
from a spill, release of material to an aquifer, explosion leading to the release of noxious gases,
affecting a Site of Special Scientific Interest (SSSI), trees, wildfowl roosts, soil characteristics,
loss of habitat, loss of species, or loss of amenity, or spills to bodies of water leading to the
death of wildfowl, etc.
The damage which could occur as a result of a major event at a COMAH site from an
environmental viewpoint is detailed in Tables 1-12 of the DEFRA, Guidance on the
Interpretation of a Major Accident to the Environment for the Purposes of the COMAH
Regulations, June 1999.
This includes damage to: National Nature Reserves, Sites of Special Scientific Interest, Marine
Nature Reserves (land/water), Natura 2000 and RAMSAR Sites (land/water), designated land,
scarce and widespread habitats (land/water), aquifers or ground-water, soil or sediment, built
heritage (land/man-made), water, particular species (land/water/air), marine and freshwater
and estuarine habitats.
Judgment of the scale of events which would be classed as a MATTE is important. The key
parameters are a combination of recovery time, spatial extent of the damage and severity of
damage.
The COMAH Competent Authority issues Guidance to assist companies in the preparation of
the reports and the risk assessments: Guidance on the Environmental Risk Assessment
Aspects of COMAH Safety Reports, COMAH Competent Authority 1999.
The following methodology for carrying out the Risk Assessment is proposed: in order to carry
out a risk assessment, there must be an understanding of the nature of hazardous situations,
their outcome and likelihood. This must be followed by a reduction of the risks to a level as
low as reasonably practical (ALARP).
This process is shown in the following figure, which is taken from Guidance on the
Environmental Risk Assessment Aspects of COMAH Safety Reports, Version 2, December 1999,
produced by the Environment Agency.
Gather data, select team
Identify Hazard
Can hazard be Yes A

screened
out?
No
Identify how harm
could occur
Can hazard be
Yes B
screened
out?
Justify
No
Maintain
records
How likely is it?
Can hazard be Yes C

screened
out?
No
Yes
No
Is it a MATTE
Are risks as low Yes

as reasonably
practicable?
Maintain controls
Record assessment
No
Make changes to make it so
MATTE Risk Assessment Process
? Revision Question
18. What is contained in the site safety report of the COMAH Regulations?
(Suggested Answer is at the end of Unit C.)
SUMMARY
Environmental Pollution
Various different industries affect the environment, such as: agriculture, construction, food
production, brick manufacture, metal finishing, timber and offices.
Releases that can affect both people and the environment include:
• Intended releases, for example, from chemical plants.
• Abnormal conditions that result in releases.
• Major releases following plant failure, as happened at Bhopal, Chernobyl and Seveso.
Toxic substances produce injury in some way to a human or animal body, for example, gases
such as hydrogen sulphide and hydrogen cyanide. Similarly, work with flammable substances,
including gases, is hazardous because of the risk of fire and explosion.
The release of toxic substances can result in pollution:
• The Environmental Permitting (England and Wales) Regulations 2007 control the release
of substances to land.
• The dispersion of pollutants to water is often caused by oils and fuel, or sewage;
waterways can both spread and dilute these pollutants.
• The National Air Quality Strategy sets air quality standards and objectives for eight priority
pollutants that affect health.
An environmental impact is: “any change to the environment… resulting from an
organisation’s environmental aspect”. Environmental aspects are: “an element of an
organisation’s activities or products or services that can interact with the environment”. This
could include polluting both water and land. The impact could be global, regional or local.
Pollution control strategies include:
• Prevention of waste.
• Minimisation of waste, including the 4R rule: Reduce, Re-use, Recycle and Responsibly
dispose.
• Rendering harmless certain substances.
Monitoring is carried out to check conformance (to the law) by the regulatory bodies, and to
monitor environmental quality. It is a means of demonstrating control and of enabling failures
to be recognised. Techniques include:
• Routine visual inspection.
• Instrumental monitoring.
Three approaches to sampling:
• A spot or grab sample.
• Collecting a sample over a period and then analysing it.
• A continuous monitored sample.
Two basic methods of sampling:
• Diffusion or passive sampling
• Mechanical or active sampling.

The necessity for the information to be provided to the public authorities and for the public
authorities to provide information is controlled by law, in particular the Environmental
Permtting (England and Wales) Regulaitons 2007.
Pollution Prevention and Control (PPC) seeks both to achieve pollution control and to regulate
almost all of the environmental impact of the operation of an installation.
BAT is the Best Available Techniques to prevent and reduce emissions and the impact upon the
environment.
The Environment Agency (EA) operates in England and Wales and is charged with protecting
and enhancing the environment and contributing towards attaining the objective of achieving
sustainable development. SEPA (Scottish Environmental Protection Agency) is the Scottish
equivalent.
Classification of Wastes
Wastes are classified as:
• Solids, liquids or gases.
• Hazardous or non-hazardous.
• Difficult.
• Flammable.
• Clinical.
• Biodegradable.
• Radioactive.
Directive waste is defined in terms of any substance or object in the categories set out in the
schedules to the Environmental Permitting (England and Wales) Regulations 2007
and Schedule 22 of the Environment Act 1995.
Waste can be categorised as:
• Controlled, such as: household, industrial, commercial.
• Non-controlled, such as: agricultural, mines and quarries.
Practical Waste Management

In terms of waste management, matters requiring attention include: minimisation, storage,
labelling, carriage and the Duty of Care.
Waste Disposal
Types of waste disposal include:
• Physical and chemical treatments of various types, including: pyrolysis, fermentation,
gasification, etc.
• Landfill, usually on large sites outside urban areas.
• Landraising, or above ground landfills.
• Incineration, which is used for the destruction of various types of waste, including:
domestic, liquid industrial and clinical wastes, sewage sludge and animal carcasses.
Disposal of waste electrical and electronic equipment is now governed by the WEEE
Regulations 2006.
Legal Regimes Applicable

The Environmental Protection (Duty of Care) Regulations 1991 define a statutory duty
of care when disposing of a Directive Waste. The duty of care applies to all persons involved
in waste generation, importation, handling, transporting and disposal of directive waste, e.g.
waste carriers, waste brokers.
Emergency Procedures
An environmental emergency, as defined by the Civil Contingencies Act 2004, is: “an
event or situation which threatens serious damage to …the environment of a place in the
United Kingdom”.
Emergency situations may arise from a variety of situations, such as:
• Natural events.
• Spillages and containment failure.
• Disposal of fire water.
Emergency contact numbers for the Environment Agency and the sewerage undertaker must
be provided as part of any emergency plan.
COMAH aims to prevent and limit the effects on people and the environment of those major
incidents involving dangerous substances. The Regulations apply to companies which
manufacture, store or transport dangerous chemicals and explosives. They also apply at two
levels, lower-tier and top-tier, depending on the quantity of dangerous substances stored or
used.
COMAH requires a Site Safety Report and an on-site emergency plan. Top-tier sites must
include provision for MATTEs (Major Accidents To The Environment) in their report.

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NEBOSH National Diploma | Unit C

Element Title Page

C10 Environmental Pollution and Waste Management

INTRODUCTION ............................................................................................................................................. 10-2

PRACTICAL WASTE MANAGEMENT .............................................................................................................. 10-43

WASTE DISPOSAL ........................................................................................................................................ 10-46

LEGAL REGIMES APPLICABLE ...................................................................................................................... 10-52

EMERGENCY PROCEDURES .......................................................................................................................... 10-55

SUMMARY .................................................................................................................................................... 10-64

NEBOSH National Diploma | Unit C

Element C10 | Environmental Pollution and Waste

¾ Outline the need for emergency response measures.

Industry/Process Potential Environmental Impact

*VOCs = Volatile Organic Compounds

Abnormal Conditions Giving Rise to Occasional Releases

Major Releases Following Plant Failure

Principle of Source, Pathway, Target and Impact in

Behaviour and Dispersion of Gases

Release and Dispersion of Toxic Substances

− Groundwater pollution from contaminated land, landfill sites or accidental spillage.

Common Air Pollutants

Pollutant Occurrence Health Hazard/Effects

Pollutant Occurrence Health Hazard/Effects

Dispersion of Air Pollutants

Source, Pathway and Target Model of Released Substances, after HMSO

Examples of Environmental Hazards

Components that Affect the Atmosphere

Water and Land Pollution

Damage to Lakes and Coastal Waters

Managing the Impact

Pollution Control Strategies

Air Emissions Energy (heat, noise)

Packaging An Improvement in any

Pollution Control Methods

Disposal of Waste and Effluent

Need for Continuous and Grab Sampling and

Technical Guidance Notes (Environmental Monitoring)

Monitoring and Control

− A continuous monitored sample – where a sample is collected continuously over a

• Gas Indicator Tubes

Need to Keep the Regulatory and Local Authorities

Other Public Registers

Environment and Safety Information Act 1988

Best Practicable Environmental Option (BPEO)

Best Available Techniques (BAT)

Role of the Environment Agency/Scottish Environment

Scottish Environment Protection Agency

Hazardous and Non-Hazardous

Definition of Hazardous Waste

• Mixing with a non-hazardous waste.

Example of a Consignment Note

Records and Returns

Methods of Categorising Waste and Different

Controlled Waste Non-controlled Waste

Household Commercial Industrial Agricultural Mines, quarries

Inert Non- Hazardous

8. Define the following wastes:

(Suggested Answers are at the end of Unit C.)

PRACTICAL WASTE MANAGEMENT

The Duty of Care

• Scavenging by vandals, thieves, children, trespassers or animals.

(Suggested Answers are at the end of Unit C.)

3. IT and telecommunications equipment.