Waste Transfer Notes
Scrap Metal and Plastic

Risk assessments for your environmental permit.

You do not need to do your own risk assessment if you are applying for a standard rules permit and can meet all the requirements for that permit.  The Environment Agency has done generic risk assessments for all standard rules permits. These list the potential risks and how to manage them. You need to check the generic risk assessment for the standard permit you are applying for so you understand the potential risks and can manage them effectively. 

You must do a risk assessment if you want to apply for or change (vary) a bespoke permit, unless the Environment Agency can do your risk assessment.  If you are applying for a bespoke permit but most of your activities are covered by standard rules, you only need to do a risk assessment for the activities or risks that are not covered by the generic risk assessment for those standard rules. 

For example, if your site creates noise or odour problems for nearby homes, but otherwise meets all the standard rules requirements.

Follow these steps to do a risk assessment. 

1. Identify and consider risks for your site, and the sources of the risks.

2. Identify the receptors (people, animals, property and anything else that could be affected by the hazard) at risk from your site.

3. Identify the possible pathways from the sources of the risks to the receptors.

4. Assess risks relevant to your specific activity and check they are acceptable and can be screened out.

5. State what you will do to control risks if they are too high.

6. Submit your risk assessment as part of your permit application.

You must also include a copy of your risk assessment in your management system.

In your risk assessment you must identify whether any of the following risks could occur and what the environmental impact could be:

• any discharge, for example sewage or trade effluent to surface or groundwater

• accidents

• noise and vibration

• uncontrolled or unintended (‘fugitive’) emissions, for which risks include dust, litter, pests and pollutants that should not be in the discharge

• visible emissions, for example smoke or visible plumes

• release of bioaerosols, for example from shredding, screening and turning, or from stack or open point source release such as a biofilter

If you do not think any of them are significant risks, you will need to state why in your permit application.

The Environment Agency can ask you to redo your risk assessment if it thinks you have not been accurate enough about your risks or problems.

For each risk that applies, identify each actual or possible hazard and state (for example in a table):

• the hazard 

• the process that causes the hazard, 

• the receptors 

• the pathways 

• what measures you will take to reduce risks

• probability of exposure

• consequences

The Environment Agency may ask you to submit a noise and vibration impact assessment and a noise management plan if:

• your activity uses noisy plant or machinery.

• you will be doing any noisy operations, such as loading or unloading, shredding, shearing, crushing, grinding, combustion, using trommels and conveyors or moving bulk materials

• your activities are not contained within buildings

• some of your activities take place at night

• the area where you are planning to carry out your activity is sensitive to noise, for example rural areas may have quieter background noise levels than urban areas

• there are sensitive receptors close to the site, for example houses or habitats

The noise impact assessment for human residential receptors must done in line with the BS 4142:2014 standard and by a suitably qualified person.

If you are not sure whether you need a noise and vibration impact assessment and a noise management plan, contact the Environment Agency for advice through their enhanced pre-application service.

Examples of possible accidents include: 

• transferring substances, for example loading or unloading vessels

• overfilling vessels

• plant or equipment failure, for example over pressurised vessels and pipework, blocked drains, fire and contaminated water used to fight the fire escaping into the local watercourse or ground

• releasing an effluent before checking its composition

• vandalism

• flooding

• inadequate bunding around tanks

There could also be a risk of accidents related to your specific industry.

Assume that operator error will occur at least once every 100 times you carry out an operation, for example you may:

• drop or damage a drum from a forklift

• have a spillage from a tanker

Identify emissions

Emissions include:

• releases to air, for example from storage of raw materials or wastes, or evaporating volatile organic compounds, dust or bioaerosols

• releases to water and land, such as potential leaks or spills from storing or handling liquids or chemicals that could harm the environment

• uncollected run-off from operational and storage areas

• mud that could get off the site

• pests that could get off site, such as flies

• pollutants that are in your release at levels which do not need emissions limits but where you do need to use other measures to make sure they do not cause pollution

Read the guide to controlling and monitoring emissions.

Identify receptors

You must identify all the receptors that are potentially at risk from your site.

Focus on the main receptors that are at risk, for example these may be factories and other businesses, domestic dwellings, playing fields and playgrounds, etc.

In your risk assessment you need to include a plan that’s to scale, for example on an Ordnance Survey map. It must show:

• your site

• all the nearby receptors

Check for protected sites and species

You are responsible for finding out if your development or activity is likely to affect a protected site, species or other wildlife. The Environment Agency may not grant your permit if your development or activity may damage protected sites or species.

Pre-application stage

You can ask the Environment Agency to check for protected sites, species and other wildlife by using their pre-application advice service. Heritage and nature conservation screening will identify if there are any protected sites, species or other wildlife relevant to your proposed activity. If there are, the Environment Agency will give you a map and information pack.

Heritage and nature conservation screening will identify other protected features not currently found within Magic map, such as local wildlife sites and protected species. Find out how to use Magic map.

Application stage

When the Environment Agency receives your application they will check if it could harm protected sites, species or other wildlife. The distances they use for this screening vary between different activities and different receptors.

The Environment Agency will check if your proposed activity could affect:

• national parks

• areas of outstanding natural beauty

• sites of special scientific interest

• special areas of conservation

• special protection areas

• Ramsar sites (wetlands)

• marine conservation zones

• ancient woodland

• local sites

You can usually get information about local sites from the local ecological records centre.

When the Environment Agency determines your application they may carry out assessments to decide whether your activity could affect protected sites. They may need to notify or consult Natural England (or Natural Resources Wales) about these assessments. Natural England usually take 28 calendar days to respond. This may impact on the time it takes for the Environment Agency to determine your application.  The Environment Agency may need to ask you for more information to help them do these assessments. For example extra survey information or more details on your application. 

The Environment Agency uses the surveys and assessments you provide in their decision-making. If protected species are present, you may need a licence from Natural England or the Welsh Government to handle the species or carry out the proposed works.

The Environment Agency advises you to get the necessary licences, or agree mitigation with the relevant bodies (such as Natural England, Natural Resources Wales or wildlife trusts) before you submit your application.

You can check with any of these to find out if you have historic or listed buildings, or archaeological sites, near your site:

• your local planning authority

• the Institute of Historic Building Conservation

• the National Trust

• the county archaeologist at your county council

There are additional risk assessments you must do depending on:

• the activity your bespoke permit relates to

• where substances are released or discharged into the environment

When you’ve done one of those risk assessments it will show if you need to take further action regarding the substances you release.

You must do a climate change risk assessment for any new bespoke waste and installation environmental permit application if you expect to operate for more than 5 years.

When you complete the new bespoke permit application form and the bespoke intensive farming installation application form you need to calculate your climate change risk screening score (see section 6b on both forms).

If you get a screening score of 5 or more, you will need to complete your climate change risk assessment and submit it with your application form.

If you have a screening score of less than 5 you do not need to submit your risk assessment with your application form, but you must still complete the risk assessment. You need to keep it as part of your environmental management system.

You need to refer to your risk assessment in your management plan summary, which you must submit with your application. See the adapting to climate change risk assessment guidance for more information.

The screening process will help you decide whether your releases to air, water or deposited from air to land are a risk to the environment and whether you need to do a more detailed assessment of them. Assessing the impact of emissions which are not screened out and are a risk to the environment is known as ‘detailed modelling’.

Detailed modelling requires specialist knowledge. You can find a consultant to do it for you. They’ll charge for their services. Contact the Environment Agency if you want to do your own detailed modelling.

You will need to show how you are managing any risks appropriately by controlling and monitoring your emissions and through your management system. 

Send your completed risk assessment as part of your permit application to the Environment Agency.

Sept 2020

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