Your environmental permit requires you to have a written management system. This is a set of procedures describing what you will do to minimise the risk of pollution from the activities covered by your permit. If you have a waste permit that was granted before 6 April 2008 that does not require you to have a working plan or management system, you will still need to manage and operate your waste activity in line with a written management system. If you are applying for
Your risk assessment will be part of your management system. You must submit a summary of your management system as part of your application if you are applying for a bespoke permit. You do not need to do this if you submit a B6.5 or B6.6 application form for a standalone water discharge or a groundwater activity, but you must have your management system in place before you start operating. You do not have to submit a summary of your management system if you are applying for a standard rules permit, but you must have your management system in place before you start operating. If you are applying for a standard rules permit for waste activities and plan to store combustible waste you will need to submit a fire prevention plan as part of your application. Once you are operating you must implement your management system or you will be in breach of your permit. What to put in your management system and how to organise it
The amount of information you will need in your management system will depend on how complicated and risky your activities are. If your permit is for low-risk activities, for example a small sewage treatment works, your management system can be simple. If you have a number of permits they may be covered by an overall management system. You may carry out certain things in the same way at different permitted sites and you may also have site specific procedures. You need to be able to explain what happens at each site and which parts of the overall management system apply. For example at some sites you may need to show you are carrying out additional measures to prevent pollution because they are nearer to sensitive locations than others. How to develop your management system
You can develop and maintain your own management system or use an environmental management system scheme or standard. If you have a larger site or carry out a more complex activity like installations and waste operations dealing with hazardous waste, the Environment Agency prefers management systems
An environmental management system may be certified against a standard such as ISO 14001. The organisation or individual carrying out certification may be accredited by a National Accreditation Body such as the UK Accreditation Service UKAS. Using an accredited certified management system is not a guarantee that you will meet all of your permit conditions. You are still responsible for implementing your system effectively and making sure you comply with each permit condition. However, the independent checks carried out for an accredited certified scheme or standard should result in greater confidence in your management system, and in your management of compliance.
This may lead to fewer checks from the Environment Agency. Confirm on your application form if you are using any of the following as the basis for your management system
Prepare your site infrastructure plan
If you are applying for a permit for a standalone water discharge activity or a point source standalone groundwater activity, you only need to read the section on Water discharge and groundwater activity. Your management system must include a plan of your site, drawn to scale. The plan must highlight where you do the activities covered by your permits and any exemptions you have registered. Waste, installations and mining waste permits
Your plan must also show any
Vulnerable locations
Your plan must also show areas particularly vulnerable to pollution that are on or near to your site, for example
Use the risk assessment guide to help you think about areas that are vulnerable to pollution. Drainage
Your plan must show your foul and combined drainage facilities marked in red and your surface water drainage, facilities marked in blue. It must also show
Water, gas, electricity
Your plan must show the location of mains water, gas and electricity supplies on your site, including
Water discharge and groundwater activity
If you are applying for a permit for a standalone water discharge activity or a point source standalone groundwater activity your site plan must show
If you are applying for a permit for a standalone groundwater activity where you are land spreading, your site plan must show
Site operations
Break down the operations that will be carried out on your site during start up, normal operation and shut down, into a list of activities and processes, for example unloading waste, storing waste, incinerating waste. For waste, mining waste, and installations, list the wastes that will be produced by each activity or process. List the steps you will take to prevent or minimise risks to the environment from each activity or process and type of waste. Be specific about the actions you will carry out to do this. For water discharge and point source groundwater activities, this will normally be the operation of a wastewater treatment works or effluent treatment equipment that is part of your activity and included in the permit. Site operations for a business that manages, treats or disposes of waste
If you are a waste operator you must include a waste storage plan that states
Fire prevention plans
If you need a permit for waste activities and you plan to store combustible waste you will need to write a fire prevention plan and submit it with your application. This must explain how you would prevent fire at your site or manage risks from fire if one occurs.
Read the fire prevention plan guidance for more information on how to do this. Site and equipment maintenance plan
You need a plan for how you will maintain the infrastructure of your site and any machinery. You must maintain any machinery according to the manufacturers or suppliers recommendations for example, following the instructions and guidelines of any manuals that came with your equipment.
You will need to record each time you carry out maintenance, for example, each time you check the calibration of monitoring equipment to make sure it meets the manufacturers recommendations. Contingency plans
You need a plan for how you will minimise the impact on the environment of any
Accident prevention and management plan
You need a plan for dealing with any incidents or events that could result in
The plan must identify potential accidents, for example
For each potential incident, it must also state the
Your accident plan must also say how you will record, investigate and respond to accidents or breaches of your permit. Your accident plan must also include
Consider taking the following actions, if you think they are relevant to the operations you carry out at your site
Online security protect your business
You can take some simple steps to protect your business against online security threats. Good online security will help make sure your business does not cause pollution. Any pollution that does occur is your responsibility as the permit holder.
See the National Cyber Security Centre website for guidance about online security. Contact information for the public
If you have a waste or installations permit you must display a notice board at or near the site entrance telling the public about the site. It must include
A notice board is optional for other permits and will depend on whether you consider that the public will need to see emergency contact information at your site. A changing climate
If your permit was issued
Climate projections for the UK suggest that we can expect
It is important you consider if a changing climate could affect your operations, including how this might affect your ability to comply with your permit. Plan for negative climate impacts on how you operate now, during and after any transition to net zero. Include the associated risks to local communities and the environment. These impacts and risks may change over the lifetime of the activity. Plan for the impacts of multiple events, such as supply chain failure and extreme weather, happening at the same time. Plan to complete changes to ensure your operations remain resilient at stages along a climate projection of at least a 2C global mean temperature rise by 2050. Do this by following and regularly updating your climate change risk assessment. Also, assess what further requirements may be necessary along a projected 4C rise by 2100. You do not need to assess risks or plan actions beyond the end of the life of your activity. To anticipate and prevent risks to local communities and to the environment, plan to test the effectiveness of your
Finally, plan timely reviews and revisions in response to new information or learning.
Use the adapting to climate change industry sector examples for your risk assessment when developing or reviewing your management system. You can also
Complaints procedure
You need a procedure that records
Managing staff competence and training records
You need to have enough staff and resources to make sure the site is run effectively in order to comply with your permit. Your management system needs to explain who is responsible for what procedures and who is technically competent. For each of your managers, staff and contractors make a list of any roles they carry out that relate to activities covered by your permit. You will also need a procedure to
If you have a permit for a waste, mining waste or installations permit you also need to look at legal operator and competence requirements. Keeping records
You must keep any records required by your permit. In some cases the permit will tell you how long to keep a record for. Otherwise you must consider how long youll need to keep different records for and write this in your management system. You must keep records to show how your management system is being implemented in line with the requirements of your permit and this guide. You need to keep
You also need to include copies of your plans with your management system if
If you manage, treat or dispose of waste
If you are a waste operator you must record the following for each delivery of waste to your site
You must also
Waste, mining waste or installations
If you have a permit for waste, mining waste or installations you will need to have a site condition report to record the condition of land or quality of groundwater on your site. Keep this up to date through the life of your permit and include the following information
If you want to cancel surrender your permit you will need to show you have taken the necessary measures to avoid any pollution risk from your activities. You also need to show that you have returned the site to a satisfactory state. This means that the condition of land and groundwater has not deteriorated as a result of your activities. Sites for waste, mining waste or installations may have to include the following plans
Review your management system
You must have a procedure for checking you are complying with your permit, procedures and management system. Record what checks are carried out, who did them and what action was taken. You must review and update your management system
You must keep a record of changes to your management system, particularly major changes such as
The Environment Agency may also review your management system and make recommendations for improvements after any accident, permit breach or other incident. It may also ask you to improve your management system if it thinks you have not identified or minimised risks from pollution. Site closure
You will have a period of site closure from when you stop operating until you are able to cancel surrender your permit if you have a permit for a
During this time you will need to continue to monitor emissions from your site. You will need to submit the site closure parts of the site condition report when you stop operating. Make sure people understand what you do
Your staff must have access to and understand any sections of the management system that deal with activities they carry out. It is up to you how you do this, for example whether you print the system out, or provide electronic copies. You must be able to show the Environment Agency your management system if asked. If you have an overarching management system for a number of sites you can provide both
Consider whether you need to provide information to interested parties such as neighbours and your local community to explain how you manage your activities to comply with your permit.