Top Five things to Consider when you have an Environmental Permit
15 July 2015
As we have already discussed here, applying for an environmental permit can be a complicated and time-consuming process. But once you have the permit and you can legally commence your activities, the work doesn’t stop there. Whatever your permit is for, whether it be a waste operation, an installation or water discharge, there are common things you need to do to maintain and make sure you stay compliant with your permit. Here are our top five:
1. Maintain your Environmental Management System (EMS)
In order to be granted an environmental permit, you must have an EMS, which must be maintained throughout the life of your operation. There should be evidence that your EMS is in constant use, that day-to-day activities use the EMS correctly and staff are aware of all the relevant policies and procedures that apply to them. Used correctly, your EMS will ensure you are compliant with your permit and other associated environmental legislation. Non-conformity with your EMS will be seen as poor management and will call into question your ability to remain compliant.
2. Understand your permit requirements
Knowing exactly what your permit says and what that means to your site activities is essential. Even for standard rules permits, each site will be different. Requirements on the activities you do can range from numerical restrictions, e.g. the amount of waste you can accept or the effluent you can discharge to stating outcomes you must achieve. These outcomes are goals, for example, operating in accordance with a written management system. It does not specifically state what you should do so how you achieve that goal is up to you, giving you flexibility in how to achieve compliance.
All staff must be aware of their responsibilities under the environmental permit and the EMS and understand what they mean to them in their job role. In order to ensure this, there must be enough trained and competent staff to manage and operate the site in a way that is compliant with the environmental permit. This doesn’t have to be full time, directly employed staff, it can be contractors, but it is important to be able to demonstrate that they have the required competency and are aware of their responsibilities on your site. How you ensure your staff are competent and aware is up to you and should be included in your EMS.
4. Complying with requirements
Once you fully understand your requirements, and your staff are competent and aware of their responsibilities, it is important to comply with your permit. How you achieve this should be included in your EMS and always followed. This can include monitoring requirements specified within the permit, keeping records of compliance and activities and reporting requirements. In terms of reporting, you may need to regularly submit data, as specified in the permit, to the regulatory body. There may also be reporting requirements for incidents or emergencies that are essential to comply with.
5. Will anything change?
As your site continues to operate in compliance with its permit, you may experience changes to your operation e.g. new activities or an increase in production quantity. Throughout any changes, your activities must continue to comply with the limits imposed on you by your permit. If this is not possible, you will have to apply to vary your permit, for example, to expand and increase your capacity or site boundary. You will also have to inform the regulatory body of any changes in ownership of the site and if you decide to cease activities and retire your site.
If you have an environmental permit, you know that he regulatory body will inspect your site to make sure you are complying with your permit, your management system and taking the appropriate measures to safeguard people and the environment. They will also scale you on how well you are complying with your permit, which may affect the annual charges you pay to the regulatory body. By making sure you regularly consider the things above, you can make the visits go much smoother and potentially reduce the fees you pay each year.