Statutory guidance

SR2021 No 15: generic risk assessment for storage and mechanical treatment of waste paper, cardboard and plastic for recovery

Updated 27 June 2023

Applies to England

The Environment Agency produces the generic risk assessments for all standard rules permits. These list the potential risks and how to manage them.

Check this generic risk assessment to understand:

• the potential risks of storing and treating waste paper, cardboard and plastic
• if your proposed activity has the same risks and can you apply for the standard rules permit
• how to manage the risks effectively

Each risk comprises:

• information about the source, pathway and receptor – and the potential harm to that receptor
• a judgement of the level of risk and justification of that judgement
• actions for managing the risk (through permitting) and a residual risk rating after managing it

Risk management involves breaking or limiting the source-pathway-receptor linkage to reduce the risk. If we set minimum distances we explain the basis of the distance, for example by modelling.

We will control the residual risk (after risk management) when we assess compliance.

If you need to check the meaning of any terms we have used (in the context of this risk assessment), see the explanation of terms.

Risks to people living in close proximity to the site

Dust

Dust travels through the air. We have assessed the potential harm as follows:

• general worsening of air quality
• nuisance and harm to human health
• loss of amenity

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as low
• overall severity of potential consequences as medium
• overall risk rating as medium

The reasons for giving the activity this rating is because: * the permitted waste types do not include those consisting solely or mainly of dusts, powders or loose fibres * all waste treatment will be within a building * the rule set does not allow any point source emissions to air

Managing the risk

To manage the risk we may require an emissions management plan. Taking this action will control the risk and rate it as ‘low’.

Odour

Odour travels through the air. We have assessed the potential harm as follows:

• nuisance
• loss of amenity

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as medium
• overall severity of potential consequences as medium
• overall risk rating as medium

The reasons for giving the activity this rating is because:

• the rules only allow for waste to be stored outside if baled or in enclosed containers
• the rules limit the maximum quantity and length of time waste can be stored
• all waste treatment will be within a building

Managing the risk

To manage the risk we may require an odour management plan. Taking this action will control the risk and rate it as ‘low’.

Noise and vibration

Noise and vibration travels through the air. We have assessed the potential harm as follows:

• nuisance
• loss of amenity

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as medium
• overall severity of potential consequences as medium
• overall risk rating as low

The reasons for giving the activity this rating is because:

• all waste treatment will be within a building
• emissions of noise and vibration will be minimised through the management system

Managing the risk

To manage the risk we may require a noise and vibration management plan. Taking this action will control the risk and rate it as ‘low’.

Litter

Litter travels through the air. We have assessed the potential harm as follows:

• nuisance
• loss of amenity

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as medium
• overall severity of potential consequences as medium
• overall risk rating as medium

The reasons for giving the activity this rating is because:

• any outdoor loading and unloading area be enclosed by wind shields, litter screens and, or walls to prevent escape of litter
• all treatment of waste shall take place in a building
• waste can only be stored outside if it is baled or in enclosed containers
• the rules limit the maximum quantity and length of time waste can be stored

Managing the risk

To manage the risk we may require an emissions management plan. Taking this action will control the risk and rate it as ‘low’.

Waste, litter and mud on local roads

Vehicle movements can cause waste, litter and mud on local roads. We have assessed the potential harm as follows:

• nuisance
• loss of amenity

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as low
• overall severity of potential consequences as low
• overall risk rating as low

The reasons for giving the activity this rating is because:

• waste can only be stored outside if it is baled or in enclosed containers
• waste will only be stored on surfaced areas
• the activities are unlikely to cause mud
• all waste will be kept securely

Managing the risk

To manage the risk we may require an emissions management plan. Taking this action will control the risk and rate it as ‘low’.

Pests, like flies or scavengers

Pests, like flies or scavengers, can travel through the air or over land. We have assessed the potential harm as follows:

• nuisance
• loss of amenity

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as low
• overall severity of potential consequences as low
• overall risk rating as low

The reasons for giving the activity this rating is because:

• the activities are unlikely to attract scavengers or lead to fly infestations
• pests will be minimised through the management system
• waste can only be stored outside if it is baled or in enclosed containers

Managing the risk

To manage the risk we may require management system improvements. Taking this action will control the risk and rate it as ‘low’.

Flooding of the site

Flood waters can flood the site.

We have assessed the potential harm as follows:

• waste could contaminate neighbouring and downstream premises

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as low
• overall severity of potential consequences as medium
• overall risk rating as low

The reasons for giving the activity this rating is because:

• we have set a limit to the maximum quantity of waste allowed on site

Managing the risk

To manage the risk we may require management system improvements. Taking this action will control the risk and rate it as ‘low’.

Risks to local human population and local environment

Fire by arson or vandalism

Fire can cause smoke to travel through the air and contaminated water to run-off over land.

We have assessed the potential harm of smoke as follows:

• respiratory irritation, illness and nuisance
• injury to staff or fire fighters
• impact on air quality

Contaminated run-off could cause:

• pollution of the ground
• pollution of groundwater and surface water

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as medium
• overall severity of potential consequences as medium
• overall risk rating as medium

The reasons for giving the activity this rating is because:

• the risk of unauthorised access and arson is low
• all waste will be kept secure
• the fire prevention plan will set out control measures including security, fire prevention, fire detection and fire response
• there is a limit to maximum quantity of waste on site. In particular, waste plastics are limited to 500 tonnes at any one time.
• the site will not be located within a groundwater source protection zone 1, or within 50 metres of springs, wells or boreholes used for drinking water

Managing the risk

To manage the risk we may request fire prevention plan improvements. Taking this action will control the risk and rate it as ‘low’.

Accidental serious fire

Fire can cause smoke to travel through the air and contaminated water to run-off over land.

We have assessed the potential harm as follows:

• nuisance
• harm to human health
• loss of amenity
• deterioration of water quality

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as medium
• overall severity of potential consequences as high
• overall risk rating as medium

The reasons for giving the activity this rating is because:

• the rules limit the maximum quantity of waste and the length of time it can be stored. In particular, waste plastics are limited to 500 tonnes at any one time.
• the fire prevention plan will set out control measures including fire prevention, detection and response

Managing the risk

To manage the risk we may request fire prevention plan improvements. Taking this action will control the risk and rate it as ‘low’.

Risk to surface waters

These risks relate to surface waters close to and downstream of the site.

Liquid spills and contaminated rainwater run-off

This risk could cause water quality to deteriorate through:

• run-off from the site across the ground
• surface water drains and ditches
• run-off through the soil

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as medium
• overall severity of potential consequences as medium
• overall risk rating as medium

The reasons for giving the activity this rating is because:

• no liquid wastes can be accepted under the rule set
• all potentially polluting liquids will have secondary containment
• waste can only be stored outside if it is baled or in enclosed containers
• the site will not be located within a groundwater source protection zone 1, or within 50 metres of springs, wells or boreholes used for drinking water
• the fire prevention plan will contain measures for dealing with firewater

Managing the risk

To manage the risk we may require an emissions management plan. Taking this action will control the risk and rate it as ‘low’.

Risk to groundwater from liquid spills and contaminated rainwater run-off

Liquid spills and contaminated rainwater run-off can travel through soil and groundwater. The water could then be abstracted from a borehole.

We have assessed the potential harm as follows:

• contamination of public or private water supplies – this would require treating the water or closing the borehole

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as medium
• overall severity of potential consequences as medium
• overall risk rating as medium

The reasons for giving the activity this rating is because:

• no liquid wastes can be accepted under the rule set
• all potentially polluting liquids will have secondary containment
• waste can only be stored outside if it is baled or in enclosed containers
• the site will not be located within a groundwater source protection zone 1, or within 50 metres of springs, wells or boreholes used for drinking water
• the fire prevention plan will contain measures for dealing with firewater

Managing the risk

To manage the risk we may require an emissions management plan. Taking this action will control the risk and rate it as ‘low’.

Risk to protected sites

Protected sites include:

• National Parks and Areas of Outstanding Natural Beauty
• Marine Conservation Zones
• Sites of Special Scientific Interest
• Special Areas of Conservation
• Special Protection Areas
• Ramsar wetland sites

There can be a risk to protected sites from any source and by any pathway. We have assessed the potential harm to protected sites, they include (but are not limited to) the following:

• toxic contamination
• nutrient enrichment
• smothering
• disturbance
• predation

Judgement of risk

We have judged the:

• likelihood of the hazard affecting the receptor as low
• overall severity of potential consequences as low
• overall risk rating as low

The reasons for giving the activity this rating is because:

• sites are not allowed within a certain distance of these receptors
• dust and drainage controls are required as set out in other risks

Managing the risk

To manage the risk we may require an emissions management plan. Taking this action will control the risk and rate it as ‘low’.

Explanation of terms

Receptor

The things at risk and that need protecting.

Receptors considered include: atmosphere, land, surface waters, groundwater, humans, wildlife and their habitats.

A single receptor may be at risk from several different sources and all must be addressed.

Source

The agent or process that has the potential to cause harm.

A contaminant or pollutant (a hazard) that has the potential to cause harm. For example, the activity or operation taking place for which a particular hazard may arise.

Harm

The harmful consequence to the receptor if the hazard is realised.

Pathways

The route or means by which a defined hazard may affect a receptor.

Source-pathway-receptor linkage

There has to be a link between the source, pathway and receptor for there to be a risk.

Likelihood of exposure

This is the likelihood of the receptors being exposed to the hazard. The meaning of the definitions are:

• high – exposure is probable – direct exposure is likely with no or few barriers between the hazard source and the receptor
• medium – exposure is fairly probable - feasible exposure is possible as the barriers to exposure are less controllable
• low – exposure is unlikely – several barriers exist between the hazard source and receptor to reduce exposure
• very low – exposure is very unlikely – effective, multiple barriers are in place to reduce exposure

Overall magnitude of potential consequence

This is the severity of the consequence if the hazard is realised and may cause actual or potential harm.

This will have a high, medium, low or very low rating using attributes and scaling to consider ‘harm’.

Risk rating

We work out the risk rating by combining the likelihood of exposure with the magnitude of the potential consequences.

We assign these ratings:

• high risk – requires additional assessment and active management
• medium risk – requires additional assessment and may need active management and, or monitoring (or both)
• low and very low risks will require a periodic review