General management appropriate measures

These are the appropriate measures for the general management of a regulated facility with an environmental permit for treating or transferring healthcare waste.

1. You must have and follow an up-to-date, written management system that incorporates the following features.

You have:

  • management commitment, including from senior managers
  • an environmental policy that is approved by senior managers and includes the continuous improvement of the facility’s environmental performance

You plan and establish the resources, procedures, objectives and targets needed for environmental performance alongside your financial planning and investment.

You implement your environmental performance procedures, paying particular attention to:

  • staff structure and relevant responsibilities
  • staff recruitment, training, awareness and competence
  • communication (for example, of performance measures and targets)
  • employee involvement
  • documentation
  • effective process control
  • maintenance programmes
  • the management of change
  • emergency preparedness and response
  • making sure you comply with environmental legislation

You check environmental performance and take corrective or preventative action, paying particular attention to:

  • monitoring and measurement
  • learning from incidents, near misses and mistakes, including those of other organisations
  • records maintenance
  • independent (where practicable) internal or external auditing of the management system to confirm it has been properly implemented and maintained

Senior managers review the management system to check it is still suitable, adequate and effective.

You review the development of cleaner technologies and their applicability to site operations.

When designing new plant, you make sure you assess the environmental impacts from the plant’s operating life and eventual decommissioning.

You consider the risks a changing climate poses to your operations. You have appropriate plans in place to assess and manage future risks.

You compare your site’s performance against relevant sector guidance and standards on a regular basis, known as sectoral benchmarking.

You have and maintain the following documentation:

Staff competence

1. Your site must be operated at all times by an adequate number of staff with appropriate qualifications and competence.

2. The design and maintenance of infrastructure, plant and equipment must be carried out by competent people.

3. You must have appropriately qualified managers for your waste activity who are members of a government-approved technical competency scheme.

Accident management plan

1. As part of your written management system you must have a plan for dealing with any incidents or accidents that could result in pollution.

2. Your accident management plan must identify and assess the risks the facility poses to human health and the environment.

3. Particular areas to consider may include:

  • waste types
  • vessels overfilling
  • failure of plant and equipment (for example over-pressure of vessels and pipework, blocked drains)
  • failure of containment (for example, bund failure, or drainage sumps overfilling)
  • failure to contain firefighting water
  • making the wrong connections in drains or other systems
  • preventing incompatible substances coming into contact with each other
  • unwanted reactions and runaway reactions
  • checking the composition of an effluent before emission
  • vandalism and arson
  • extreme weather conditions, for example flooding or very high winds

4. You must assess the risk of accidents and their possible consequences. Risk is the combination of the likelihood that a hazard will occur and the severity of the impact resulting from that hazard. Having identified the hazards, you can assess the risks by addressing 6 questions:

  • how likely is it that the accident will happen?
  • what may be emitted and how much?
  • where will the emission go – what are the pathways and receptors?
  • what are the consequences?
  • what is the overall significance of the risk?
  • what can you do to prevent or reduce the risk?

5. In particular, you must identify any fire risks that may be caused, for example by:

  • arson or vandalism
  • self-combustion, for example due to chemical oxidation
  • plant or equipment failure and electrical faults
  • naked lights and discarded smoking materials
  • hot works (for example welding or cutting), industrial heaters and hot exhausts
  • reactions between incompatible materials
  • neighbouring site activities
  • sparks from loading buckets
  • hot loads deposited at the site

6. The depth and type of accident risk assessment you carry out will depend on the characteristics of the plant and its location. The main factors to take into account are the:

  • scale and nature of the accident hazard presented by the plant and its activities
  • risks to areas of population and the environment (the receptors)
  • nature of the plant and complexity of the activities and how difficult it is to decide and justify adequate risk control techniques

7. Through your accident management plan, you must also identify the roles and responsibilities of the staff involved in managing accidents. You must provide them with clear guidance on how to manage each accident scenario, for example, whether to use containment or dispersion to extinguish fires, or let them burn.

8. You must appoint one facility employee as an emergency co-ordinator who will take lead responsibility for implementing the plan. You must train your employees so they can perform their duties effectively and safely and know how to respond to an emergency.

9. You must also:

  • establish how you will communicate with relevant authorities, emergency services and neighbours (as appropriate) both before, during and after an accident
  • have appropriate emergency procedures, including for safe plant shutdown and site evacuation
  • have post-accident procedures that include making an assessment of the harm that may have been caused by an accident and the remediation actions you will take
  • test the plan by carrying out emergency drills and exercises

Accident prevention measures

1. You must take the following measures, where appropriate, to prevent events that may lead to an accident.

Segregating waste

2. You must keep apart incompatible or segregated wastes and substances by their hazardous properties.

3. You must segregate incompatible waste types into bays or store them in dedicated buildings. The minimum requirement is to use a kerbed perimeter and separate drainage collection. You must also have measures in place to prevent containers falling over into other storage areas.

Preventing accidental emissions

4. You must make sure you contain the following (where appropriate) and route to the effluent system (where necessary):

  • process waters
  • site drainage waters
  • emergency firefighting water
  • chemically contaminated waters
  • chemical spills

5. You must be able to contain surges and storm water flows. You must provide enough buffer storage capacity to make sure you can achieve this. You can define this capacity using a risk-based approach, for example, by taking into account the:

  • nature of the pollutants
  • effects of downstream waste water treatment
  • sensitivity of the receiving environment

6. You can only discharge waste water from this buffer storage after you have taken appropriate measures, for example, to control, treat or reuse the water.

7. You must have spill contingency procedures to minimise the risk of an accidental emission of raw materials, products and waste materials, and to prevent their entry into water.

8. Your emergency firefighting water collection system must take account of additional firefighting water flows or firefighting foams. You may need emergency storage lagoons to prevent contaminated firefighting water reaching a receiving water body.

9. You must consider and, if appropriate, plan for the possibility that you need to contain or abate accidental emissions from:

  • overflows
  • vents
  • safety relief valves
  • bursting discs

If this is not advisable on safety grounds, you must focus on reducing the probability of the emission.

Security measures

10. You must have security measures in place (including staff) to prevent:

  • entry by vandals and intruders
  • damage to equipment
  • theft
  • fly-tipping
  • arson

11. Facilities must use an appropriate combination of the following measures:

  • security guards
  • total enclosure (usually with fences)
  • controlled entry points
  • adequate lighting
  • warning signs
  • 24-hour surveillance, such as CCTV

Fire prevention

12. There are 3 fire prevention objectives. You must:

  • minimise the likelihood of a fire happening
  • aim for a fire to be extinguished within 4 hours
  • minimise the spread of fire within the site and to neighbouring sites

13. You must have appropriate systems for fire prevention, detection and suppression or extinction.

14. You must have suitable procedures and provisions to store certain types of hazardous waste, for example, fire resistant stores, automatic alarms and possibly sprinklers.

15. Your facility must have enough water supplies to extinguish fires. You must have an alternative type of fire protection system if you store or treat any water-reactive waste, for example dry powder extinguishers.

16. You must isolate drainage systems from flammable waste storage areas to prevent fire spreading along the drainage system by solvents or other flammable hydrocarbons.

17. You must regularly inspect and clean your site to prevent the build-up of loose combustible material (including waste and dust), particularly around treatment plant, equipment and other potential sources of ignition.

Other accident prevention measures

18. You must maintain plant control in an emergency using one or a combination of the following measures:

  • alarms
  • process trips and interlocks
  • automatic systems based on microprocessor control and valve control
  • tank level readings such as ultrasonic gauges, high level warnings, process interlocks and process parameters

19. You must:

  • make sure all the measurement and control devices you would need in an emergency are easy to access and operate in an emergency situation
  • maintain the plant so it is in a good state through a preventive maintenance programme and a control and testing programme
  • use techniques such as suitable barriers to prevent moving vehicles damaging equipment
  • have procedures in place to avoid incidents due to poor communication between operating staff during shift changes and following maintenance or other engineering work
  • where relevant, use equipment and protective systems designed for use in potentially explosive atmospheres

Record keeping and procedures

20. You must:

  • keep an up to date record of all accidents, incidents, near misses, changes to procedures, abnormal events, and the findings of maintenance inspections
  • carry out investigations into accidents, incidents, near misses and abnormal events and record the steps taken to prevent their reoccurrence
  • maintain an inventory of substances, which are present (or likely to be) and which could have environmental consequences if they escape – many apparently innocuous substances can damage the environment if they escape
  • have procedures for checking raw materials and wastes to make sure they are compatible with other substances they may accidentally come into contact with

Contingency plan and procedures

1. You must have and implement a contingency plan, which makes sure that you:

  • comply with all your permit conditions and operating procedures during maintenance or shutdown at your site or elsewhere
  • do not exceed storage limits in your permit and you continue to apply appropriate measures for storing and handling waste
  • stop accepting waste unless you have a clearly defined method of recovery or disposal and enough permitted storage capacity

2. You must have contingency procedures to make sure that, as far as possible, you know in advance about any planned shutdowns at waste management facilities where you send waste.

3. You must make your customers aware of your contingency plan, and of the circumstances in which you would stop accepting waste from them.

4. You must consider whether the sites or companies you rely on in your contingency plan:

  • can take the waste at short notice
  • are authorised to do so in the quantities and types likely to be needed – in addition to carrying out their existing activities

5. You must not discount alternative disposal or recovery options on the basis of extra cost or geographical distance if doing so means you could exceed your permitted storage limits or compromise your storage procedures.

6. You must not include unauthorised capacity in your contingency plan. If your contingency plan includes using temporary storage for additional waste on your site, then you must make sure your site is authorised for this storage and you have the appropriate infrastructure in place.

Treatment sites only

7. Your management procedures and contingency plan must:

  • identify known or predictable malfunctions associated with your technology and the procedures, spare parts, tools and expertise needed to deal with them
  • include a record of spare parts held, especially critical spares – or state where you can get them from and how long it would take
  • have a defined procedure to identify, review and prioritise items of plant which need a preventative regime
  • include all equipment or plant whose failure could directly or indirectly lead to an impact on the environment or human health
  • identify ‘non-productive’ or redundant items such as tanks, pipework, retaining walls, bunds, reusable waste containers (for example wheeled carts), ducts, filters and security systems
  • make sure you have the spare parts, tools, and competent staff needed before you start maintenance

8. You must carry out appropriate disinfection procedures when maintaining equipment (or parts of equipment) contaminated with untreated clinical waste. Using personal protective equipment (PPE), although essential to protect workers from exposure, should not be your primary control measure.

9. If you produce an end of waste material at your facility, your contingency planning must consider issues with storage capacity for end of waste products and materials that fail the end-of-waste specification.

10. Your management system must include procedures for auditing your performance against all of these contingency measures and for reporting the audit results to the site manager.

Plant decommissioning

1. You must consider the decommissioning of the plant at the design stage and make suitable plans to minimise risks during later decommissioning.

2. For existing plants where potential risks are identified, you must have a programme of design improvements. These design improvements need to make sure you:

  • avoid using underground tanks and pipework – if it is not economically possible to replace them, you must protect them by secondary containment or a suitable monitoring programme
  • drain and clean out vessels and pipework before dismantling
  • use insulation which you can dismantle easily without dust or hazard
  • use recyclable materials, taking into account operational or other environmental objectives

3. You must have and maintain a decommissioning plan to demonstrate that:

  • plant will be decommissioned without causing pollution
  • the site will be returned to a satisfactory condition

4. Your decommissioning plan should include details on:

  • whether you will remove or flush out pipelines and vessels (where appropriate) and how you will empty them of any potentially harmful contents
  • site plans showing the location of all underground pipes and vessels
  • the method and resources needed to clear any on-site lagoons
  • the method for closing any on-site landfills
  • how asbestos or other potentially harmful materials will be removed, unless we have agreed it is reasonable to leave such liabilities to future owners
  • methods for dismantling buildings and other structures, and for protecting surface water and groundwater at construction and demolition sites
  • any soil testing needed to check for any pollution caused by the site activities, and information on any remediation needed to return the site to a satisfactory state, as defined by the initial site report
  • the measures proposed, once activities have definitively stopped, to avoid any pollution risk and to return the site of operation to a satisfactory state (including, where appropriate, measures relating to the design and construction of the plant)
  • the clearing of deposited residues, waste and any contamination resulting from the waste treatment activities.

5. You should make sure that equipment taken out of use is decontaminated and removed from the site.