What is an Environmental Management System (EMS) Transcript
Hi, my name is David Cole and I’m technical director of Sandfield Penstock solutions and I’m going to talk to you today about Environmental Management Systems, EMS.
What is an Environmental Management System?
So, an EMS is an environmental management system. What it is, it’s a system that you have in place to control a major event, a major fire or major pollution event at your site.
An EMS, Environmental Management System is something that you should have set aside and you’ve worked out so that if you have a major event, normally a fire for instance with the potential of causing a pollution incident, that you’ve put in place control measures and you’ve understood what that risk is and made a design to give you a management system that allows you to control those types of events. Clearly “environmental” is looking at the environmental impact. Management is how you’re going to manage it and the system is the design you put in place that’s actually going to control that situation, so you don’t have a pollution incident.
How do you go about producing an Environmental Management System?
As a company, we would be looking at creating a spill model and looking at the risk. What most companies do is they carry out their own risk assessment. They look at where the risk elements are, so where is it that something’s going to leave the site? What is the potential impact? Is it going to get into a stream, a brook or into the ocean? and how are they going to control it? What are the impacts of an event happening?
How do you differentiate between a good Environmental Management System and a bad Environmental Management System?
That’s quite a difficult one to answer without upsetting too many people, but what we see a lot is that people put in place an Environmental Management System which is purely a tick box exercise. It’s purely an exercise saying, okay, we have a device there that we can block the drains, we have a spill kit there that we can put around to clean up the spillage and not a lot more because what you’re not looking at is what would an event actually look like? So how big, how much would that event be? What would happen if that event happened at the same time it was raining? What happened if that event happened at 3:00 AM on a cold, frosty morning, could the Environment Management System, they have actually work.
How do you go about producing an effective Environmental Management System?
So really for an effective Environmental Management System, you must fundamentally understand what that risk is and what is the problem and what does it look like. Now for us, that is part where we do our spill modeling because what we’re looking at is to assess what actually is the problem. So we’re looking at how big, how much chemicals are there on the side, what is the actual potential, when could this incident happen? Because it could happen at any time. So could it be controlled and what does it look like when we actually implement perhaps some drain closure devices. So we’ve actually got a 3:00 AM event where we’ve got a major fire, we’ve got a one in 10 year rainstorm event, what does it actually look like? Will the system that we’re actually going to manage and put in place, does it actually work? So that’s our process really. Because without that you’re doing an assumption base technique and you don’t really know actually what you’re doing.
Why should site designers and managers be concerned about Environmental Management Systems?
More and more now the environment agency is looking at how it can regulate pollution incidents. There’s lots of changes taking place, whereas really a pollution event is a crime, so a business itself doesn’t want to have a pollution event. They want to keep it in. They know that some disasters can happen, factory fires can happen, businesses can have major spills, but no business actually wants a pollution event. So what you’ve got here is that the important thing is if you understand what that impact can be at the beginning so you actually can put it into your design characteristics, you’ve got control of it. If you leave it until you’ve had an event and then you’ve obviously lost control, then what you end up there is you’ve got problems with the regulator because the regulator will be coming back asking you why didn’t this work?
If you just purely go where we’ve got a system in place, which is the security guard rings up the maintenance and the maintenance come down and respond to the pollution. That’s okay as long as it’s relatively small to control. But if not, we’ll say some catastrophic event where the security guard is one of the fire brigade. The fire brigade have turned up, the’re evacuating everybody out of your business and there is no time and there certainly isn’t anybody on the site who is going to go and put steel maps over the drain covers and put down a few sandbags around the drains where it leads out into the local river. If you don’t have time for that, it’s not going to work.
How would an Environmental Management System benefit you in the event of a disaster?
So one of the things that happens if you do have a pollution event is you’ve got to look at what you had in place and what you’d put in place to actually work. Now you could say that if you’ve got an Environmental Management System in place, which is there in front of the regulator and in front of everybody who’s assessing the disaster, the question is, well, if you’ve got a system in place, why did it fall over? What it’s going to do is it going to highlight areas where we have a system, we’ve got some equipment, when was it last checked, when was it last inspected? Who on-site was qualified to actually operate that equipment? So what you’re directing everybody to is certain specific questions. So if you have a particular, a manually operated valve has to be lowered at a specific time in an incident. If that happened at this particular time at night when nobody, no maintenance, nobody was on site, perhaps just a security guard, well maybe there’s nobody there at all at night. Who could operate that environmental management system? Nobody. So what you’ve really done is you’ve shown that as one area that there was a big gap, there was a big hole and it needs to be covered and that’s what you need to look at when you implement a management system that realistically works for you. It doesn’t mean you have to spend a huge amount of money. It means that you have to be honest and you have to cover your risk and then design a system that actually meets what you need as a business.
What is your recommendation for anyone producing an Environmental Management Plan?
So anybody wanting to look at Environmental Management System, we recommend them to follow our six-point checklist to understand the regulation, understand how that regulation works for your particular site, carry out a risk assessment and understand exactly what you need to do, design your system and how you’re going to implement it. Implement your design, measure, maintain and document the system that you’ve got in place. Don’t just stick with the original design, being prepared to move it along and advance as regulation changes.
If you have any questions, please do drop me a line.
You can contact me on www.penstocksolutions.co.uk
David Cole MSEE
David is a pioneer of the spill containment and water pollution prevention industry with 30 years experience. He was instrumental in the development of CIRIA736 with The Environment Agency and is passionate about preventing water pollution.