Guidance

Climate change: risk assessment and adaptation planning in your management system

Plan for climate change impacts to and from your site. How to integrate climate change adaptation into your management system under an environmental permit.

• From: Environment Agency
• Published: 3 April 2023

Applies to England

First, check the main guidance on how to develop a management system under an environmental permit.

This guidance explains how to integrate climate change adaptation into your management system. You will need to consider:

• the risks to your business from climate change
• the risks your business creates due to climate change
• how to embed controls

The detail in your risk assessment and plan of action should reflect the risk that climate change creates for your operation.

Why you need to plan for climate change impacts

Climate change means that extreme weather incidents are becoming more common and more severe.

Climate projections show that over the coming decades we will face an increased risk of climate change impacts, including:

• extreme rainfall, leading to more frequent and severe floods
• heat waves
• drought
• rise in sea levels and tidal surges
• storms
• wildfires

All of these could have an impact on businesses directly, in your supply chains and for your consumers and markets. Planning for this will help you to:

• remain in compliance with your environmental permit, other obligations and regulations
• minimise your impact on the environment during an extreme weather event and the event’s impact on your operations, either through accidental release or abnormal operation
• improve your resilience and business continuity by avoiding unplanned start-ups, shutdowns and other business interruptions

The ISO 14090:2019 standard on adaptation planning can also help you consider climate change when you develop a management system.

You can complete the process in 6 stages.

1. Preparation

Review what processes you already have in place to:

• manage climate related risks
• build understanding and get agreement at a senior level for the need for action
• assemble the right team to develop a plan of action
• communicate to others in the business what you are doing and why – to help get support for developing a plan of action across the whole business

Your preparation work should be based on how complex your operation is.

2. Find potential impacts

Site-based impacts

Consider how vulnerable your site is to current and future climates. You should assess for a 4°C rise by 2100 and plan for a 2°C rise by 2050.

Find any site-specific issues. For example:

• access issues due to flooding or sea-level rise
• distance from areas where wildfires could break out
• risks from failure of essential site services (water, electrical supply, drainage systems)

Find out if there are significant receptors (people, animals, property and anything else that could be affected by a hazard) nearby. Examples are:

• Sites of Special Scientific Interest
• watercourses
• local nature reserves
• endangered species

Consider if their vulnerability to emissions or incidents increases with changing weather patterns. Consider if this creates a risk for your permit compliance.

You can get basic climate change impact data from the Environment Agency’s climate impacts tool. You can get more detailed analysis of the risks from the Environment Agency’s third climate change adaptation report.

Consider relevant impacts on any other sites your company owns or operates.

Find out if lessons learned from international operations, which may face different or more extreme weather, can be transferred to your site.

Consider how long are you planning for your site to be operational. The severity of climate change impacts could increase with time.

Example: increasing summer temperatures

With warmer summer air temperatures at a site, you may see an operational impact of needing more water. This may lead to an environmental impact of increased water abstraction, above your abstraction licence or permit limit.

Example: reducing summer rainfall

You may find a risk to operations from reduced summer rainfall which leads to lower river flows. This may not affect your operation directly, but the reduced capacity for the water environment to deal with any discharge may lead to environmental harm at a significant receptor. Or there may be a lack of water for dust suppression.

Example: extreme high daily temperatures

Very high summer temperatures may happen more often. The impacts of this are varied but could include:

• failure of control and monitoring systems due to heat
• failing infrastructure both on and off site, making logistics challenging
• failure of IT systems both on and off site due to data centres failing, or being closed down to protect the servers

Example: intense rainfall or snow

You may experience intense rainfall, especially during the winter months. The impacts are varied but can include:

• localised flooding, landslides and subsidence that can affect infrastructure, drainage and containment systems
• loss of buoyancy on floating roof tanks due to insufficient drainage capacity, leading to unplanned releases
• failure of warehouse roofing due to excessive snow build up, causing damage to stored chemicals and equipment
• overloading on protective inlet filters, causing equipment damage and failure

Sector-based impacts

Find climate hazards relevant to your sector or business activity. Consider how these climate hazards could affect your activities (known as a risk ‘pathway’) during normal and abnormal operations. Note any environmental impacts that could result.

The industry sector examples for your risk assessment give predicted climate impacts for 2050 based on UK climate projections (UKCP18). There are different examples for each sector but the impacts are often common and give common issues and potential mitigations as a starting point.

3. Complete your risk assessment

You may have already completed a risk assessment if you recently applied for a new bespoke environmental permit. If not, you will need to check if you need to manage each risk before you produce an adaptation plan.

Complete a standard risk assessment

Complete your risk assessment based on:

• where your site is located – make sure you consider all known or reasonably foreseeable site-specific climate impacts, such as flooding if you’re in or near a flood plain
• consideration of current threats, as well as those predicted for a 2°C rise by 2050 and a 4°C rise by 2100
• your industry sector – consider using the industry sector examples for your risk assessment and information from any relevant trade bodies
• any process currently in place for your company to help you assess, manage, and report climate and sustainability risks

If your operation is at high risk: complete a more in-depth risk assessment

After you complete the standard risk assessment it may be clear that your operation is at a higher risk from climate change. If so, you should:

• complete a more in-depth risk assessment based on UKCP
• provide a greater level of detail for the timescales of more likely impacts

The Met Office has published guidance on how to use the UKCP18 land projections to help you choose the set of projections that meet your needs. You may need specialist advice to quantify some climate risks.

To develop a more detailed assessment you can follow:

• ISO 14090:2019 on adaptation
• ISO 14091:2021 on vulnerability, impacts and risk assessment

Consider the timing of risks and when they will become significant. It’s important to consider thresholds for action. Some risks may be immediate, needing urgent action. Others may be more gradual where you could act later.

Some future risks may need action now to make sure they are managed in the future. For example, if your risk assessment shows that you will need a different process in 5 years to cope with higher ambient temperatures, and it will take you 4 years to commission the new plant, then you should start work on this now. This is known as creating ‘adaptive pathways’. These allow you to carry out measures in phases based on the timing of the risks.

Summarise your evaluation of each risk in a table or suitable template.

Review your risk assessments periodically to make sure they reflect current scientific knowledge on climate impacts and your activities. You should record the risk assessment review requirements in your management system.

Nuclear sector

If you operate in the nuclear industry or a site for radioactive waste disposal, check the Office for Nuclear Regulation’s position statement on how the nuclear industry should use UKCP18.

Control of Major Accident Hazards (COMAH)

If you are in scope of the COMAH regulations, then you need to understand if climate change impacts could change the risk of a major accident.

You may need to assess climate change impacts in more depth when:

• assessing the risk of major accidents
• carrying out the necessary measures to control them

Guidance on best practice for climate change adaptation is continually improving. For the latest advice you should discuss climate change impacts on your operation with your COMAH competent authority team.

4. Find control measures

You then need to find control or management measures for the significant risks you identified.

These measures could:

• manage the risk – by introducing control measures to address the climate hazard, its effect on operations or environmental impact
• transfer the risk – such as by taking out insurance
• terminate the risk – such as by changing the process to remove the hazard

Gather information on options available to address the risks. Assess if they are reasonably practical and affordable to ensure compliance with your environmental permit.

You will need to justify your decisions. For example, adapting your current site to address the threat of flooding may be more expensive than moving your operations to another site with a lower flood risk. Consider the industry sector examples for your risk assessment.

Evaluate potential options, considering factors such as:

• the cost to implement compared to the protection or benefit gained
• how effective options are for continued compliance with your environmental permit, including the extent of risk reduction and any remaining risk to the environment
• practical considerations, including the timing of implementation
• opportunities to change your plans in the future to avoid ‘lock-in’ (where decisions taken earlier prevent later action or changes) and any need to gradually adapt operations as the climate changes
• uncertainty in the timing, likelihood, and severity of risks
• their ability to deliver multiple benefits for both adaptation and resilience

It may be useful to consider an adaptive pathways approach where measures are introduced in a phased manner over several years (or longer) as the climate changes and the impacts are better understood. This could fit in with the monitoring and review cycle in your plan.

For an example of an adaptive pathways approach, check the Environment Agency’s Thames Estuary 2100 strategy. This was designed to be adaptable to different rates of sea level rise.

Document how you found and assessed options to mitigate and manage the effects of climate change on your operations. Keep records of the risk assessment and consideration of control measures. This will help you prove to the Environment Agency that you have taken all measures necessary to control natural hazards influenced by climate change.

5. Write your adaptation plan

Aim to write your climate change adaptation plan in line with a suitable standard, such as ISO 14090:2019. This should make it easier for you to embed it into:

• your management system
• formats or templates that your company uses, including those from your trade association

1. State the objectives and include a justification for the actions selected and timespan covered.
2. Document any assumptions made and any uncertainties.
3. Document the decision-making approach and data on which decisions are made.
4. Describe its relationship with existing site plans.
5. Describe any prioritisation process used and its outcomes.
6. Document how the adaptation actions address the most critical climate impacts and opportunities.

From the start, consider a wide range of options for each problem. This is so you do not reject and miss potentially workable options later.

You should try to find options with minimal or no secondary implications. These are known as ‘low regret’ or ‘no regret’ options.

You should try to find options that:

• are unlikely to become obsolete and which can cope with future events (‘future proof’ options)
• you can extend or improve later, as climate risks become clearer or more urgent

It’s essential you avoid the problem of ‘lock in’ – of not being able to change your approach when you need to.

You should plan for:

• critical future decision points
• how you will review your plan and consider different mitigations

Again, using an adaptive pathways approach may help. (Like in the Environment Agency’s Thames Estuary 2100 strategy.)

The outcomes of the assessment and adaptation plan should form part of your site management systems (where appropriate).

6. Monitor, record and review your plan

You should then monitor your climate action plan to check if:

• you are achieving its original objectives
• you are managing the priority risks
• the plan is still effective
• the plan needs changing

To help your monitoring, you should record severe weather events and near misses and the effect they have on your business.

You should monitor impacts on your supply chain where this threatens environmental compliance. For example, where your abatement technology for emissions to air relies on a particular chemical product.

Lost production time or environmental incidents caused by severe weather events could influence future decision making on the site. You should also learn lessons from any global severe weather events where impacts on industry have been similar to the risks associated with your business.

This monitoring is a vital element of climate change adaptation planning.

You should record what you’ve learned from near misses or events to inform the future planning process. You could log these in a table, recording the:

• date
• weather event
• extent of incident
• damage or effect to the business or environment
• immediate action taken
• proposed prevention or mitigation measures

You need to decide who will be responsible for reviewing the plan and how often they need will do this. These reviews could coincide with scheduled reviews of other business systems.

The Environment Agency recommends you review your plan every year, or sooner if a factor that has influenced your strategy changes significantly. For example, this could be when:

• you are affected by an extreme weather event or near miss
• important new climate change information becomes available

If your permit has a climate change condition, you must review and, if appropriate, update your climate change risk assessment at least every 4 years.

During a review, consider:

• the objectives of the adaptation intervention and if these were achieved
• if more, less or a different intervention is needed
• if the forecasting for the site plan is still relevant and appropriate
• if there is anything you can learn, such as from your neighbours or sector trade association

How the Environment Agency checks compliance

The Environment Agency will inspect or audit your climate change risk assessment and adaptation plan periodically. This will be as part of wider checks on your management systems during routine compliance assessment activities.

They will plan this regulatory work based on the significance of extreme weather threats, so that it’s proportionate to:

• the hazards and risks associated with your business
• the potential for climate change to influence the risk

They will also audit the adaptation plan after any significant pollution event that they believe was related to severe weather.

Published 3 April 2023