Managing “significant” risks
A colleague has informed you that you need to manage your “significant” environmental aspects and impacts - apparently you could face legal action if you don’t. If this is the case, what do you need to do about it?
Get things straight
What are aspects and impacts? An aspectis an element of an organisation’s activities or products or services that can interact with the environment. An impact is any change in the environment, whether adverse or beneficial, wholly or partly resulting from an organisation’s aspects. Now you’re being warned if either of these are “significant” you could face legal action for failure to address them properly. What should you be doing?
What does “significant” mean?
“Significant” means just that. A simple definition is that if you don’t take action to alleviate either the effects or potential effects, your business will have a “significant” impact on the environment. Example. Spilling a hazardous liquid is covered by the Water Resources Act 1991, so any spill risks you’ve identified will be classed as “significant”.
Tip. Work to the rule that if legislation is directly applicable, it’s a “significant” aspect. Therefore, you need to take appropriate steps to:
1. Make yourself aware of any aspects which could have a significant environmental impact.
2. Identify and action ways in which the aspect can be managed.
Knowing what applies to your business
One approach - and the one required by the environmental standard, ISO 14001:2004 - is to carry out an exercise to identify what environmental legislation is directly applicable to your business and then collate this information in a list. It’s simple and potentially useful. True, but this isn’t necessarily the case. What you can end up with is a list which can run to 20 or more pages, which includes all manner of pieces of legislation that might, in certain circumstances, apply to your business! Instead of simply reviewing what legislation might be applicable to your business, you need to identify how they apply, and also what you need to do.
Tip 1. Once you are aware of any potential significant impacts your business could have, i.e. pollution to the ground etc., then go a step further by making sure you are fully aware of all possible ways you could fall foul of the law. The best option in this case would be to seek expert advice - usually from a consultant. But don’t ask for a legislation review - this isn’t that useful (unless you intend on going for ISO 14001:2004 accreditation). Instead, ask for a guide as to what practical steps you need to be doing to achieve legal compliance - if any are required, of course.
Note. Being aware of the specific piece of legislation that requires action isn’t actually that important - knowing what precautions you should be taking etc. is. Make this clear to the consultant at the start: i.e. “We only want to know what we should be doing, not what the regulations state.”
Tip 2. Make sure whoever provides advice does so in order of “significance”. You should then do any remedial works etc. as per the report - recording dates, actions, times, money spent or any other supporting evidence as you do so. Keeping records such as this can be used in mitigation - just in case something goes wrong. It is also clear evidence to an inspector that you are addressing any potential impacts following a risk based approach. This is what they’ll want to see.
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