ENVIRONMENTAL MANAGEMENT
6.
Section 6 – Environmental Risk Management Policy
Version:
03
Page:
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MANUAL
Issue Date:
12 January 2002
Authorised by: Marjorie Dickenson
ENVIRONMENTAL RISK MANAGEMENT POLICY
SimuLab will adopt a risk management approach to all environmental matters. To ensure this, it is
company policy to provide tools and training to all employees to follow this approach. Accordingly
this document will provide the following items to facilitate the process:

Risk Assessment Policy, procedures and forms.

Risk Assessment Checklists and management records relating to all major areas and aspects
of the workplace.
6.1.
6.2.
The Risk Management Process
According to company policy, risk management process should be undertaken as follows:
1.
Attend environmental risk assessment training.
2.
Familiarisation with SimuLab Risk Assessment Policy and Procedures.
3.
Use the tools provided to identify actual or potential hazards.
4.
Complete a risk assessment using the risk assessment severity table and/or checklists
contained in this document.
5.
Examine and implement control measures using SimuLab’s Risk Management Chart.
6.
Record the results of the procedure in the Risk Management Register.
7.
Communicate important information with fellow employees who may experience
similar hazards.
Risk Assessment And Control - Guidelines And Procedures
Environmental management systems include risk assessment in the workplace in order to
meet legislative requirements, and prevent damage to the environment.
Risk assessment is best undertaken by a team with multi-disciplinary skills, hence a team
approach generally provides better results. It is a stepwise process of continual
improvement. With each cycle, risk criteria can be strengthened to achieve progressively
better levels of risk management. For each stage of the process adequate records should be
kept, sufficient to satisfy independent audit.
Risk management can be applied at many levels in an organization. It can be applied at the
strategic level and at operational levels. It may be applied to specific projects, to assist with
specific decisions or to manage specific recognised risk areas.
SimuLab's risk management policy has been prepared in accordance with Australian
Standard AS/NZS4360:1999 Risk Management.
The main elements of the risk management process, as shown in Figure 1, are the following:
a) Establish the context/ identify the need for Risk Assessment
This step seeks to identify the important stakeholders, their perceptions and objectives, and
communicate with these parties. It should focus on the environment in which operations
occur. Assessment should endeavour to determine the crucial elements which might support
or impair the ability to manage risk.
b) Identify risks
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Identify what, why and how risks can arise as the basis for further analysis. This is best
achieved by using a risk assessment checklist, or conducting an environmental audit.
c) Analyse risks
Determine the existing controls and analyse risks in terms of consequence and likelihood in
the context of those controls. The analysis should consider the range of potential
consequences and how likely those consequences are to occur. Consequence and
likelihood may be combined to produce an estimated level of risk.
d) Evaluate risks
Compare estimated levels of risk against the pre-established criteria. This is most easily
achieved by using a risk assessment severity table, which enables risks to be ranked, and
also management to identify priorities.
e) Treat risks
Accept and monitor low-priority risks. For other risks, develop and implement a specific
management plan which includes consideration of funding.
f) Monitor and review
Monitor and review the performance of the risk management system and changes that might
affect it.
g) Communicate and consult
Communicate and consult with internal and external stakeholders as appropriate at each
stage of the risk management process and concerning the process as a whole.
This is continual task that would be performed at many stages of the work process. Some
examples of this may include:

Purchase of new or replacement plant, equipment, or chemicals.

Installation of new plant or equipment.

Normal operational procedures.

Maintenance and repair.

Change of work procedures.

Storage.

Decommissioning.

Disposal.
As part of the risk management process, managers should always request environmental
hazard information for any of the above. Examples of these include:

When purchasing new chemicals a material safety data sheet should be routinely
requested.

When designing new facilities or workplace procedures, a risk assessment provides a
means to set up environmental controls before use.

When procuring new plant or equipment restricting purchases to those which pose no
threat to the environment.
Figure 1. The Risk Management Process (after AS/NZS 4360:1999)
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Section 6 – Environmental Risk Management Policy
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MANUAL
Issue Date:
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Authorised by: Marjorie Dickenson
Establish the Context





The strategic context
The organisational context
The risk management context
Develop criteria
Decide the structure


What can happen?
How can it happen?
Identify Risks
Communicate and Consult
Analyse Risks
Determine
likelihood
Monitor and review
Determine existing controls
Determine
consequences
Estimate level of risk
Evaluate Risks


Compare against criteria
Set risk priorities
Assess
Risks
YES
Accept
risks
NO
Treat Risks





Identify treatment options
Evaluate treatment options
Select treatment options
Prepare treatment plans
Implement plans
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6.3.
Section 6 – Environmental Risk Management Policy
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Issue Date:
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Authorised by: Marjorie Dickenson
Undertaking a Risk Assessment
The recommended procedure or conducting a risk assessment is as follows:
1.
2.
3.
4.
5.
6.
7.
8.
Identify the risks both actual or potential.
Assess the risk.
Compare the risk against set criteria.
Establish risk priorities.
Control the risk using options from prevention of pollution hierarchy.
Prepare an action plan.
Implement the action plan.
Monitor and review the effectiveness of the control procedure.
More detail of each of these steps is provided below:
Step 1. Identify The Risks
In order to control risk you need to be aware that it first exists. Managers, supervisors, and
employees may identify risks by several means including both proactive and reactive
methods.
Proactive methods include:

Workplace environmental audits.

Observations by managers, supervisors, employees or other persons.

Consultation with staff, particularly those with experience in the job.

Information from literature (examples of this might include Material Safety Data
Sheets, product labels and other product information, manufacturer's instructions for
plant, machinery, equipment, environmental texts and journals, etc.).

Monitoring of equipment or areas. This is particularly useful for noise and airborne
contaminants.

Statistical analysis (examining the number of environmentally significant incident
reports).
Proactive identification of risks is always desirable as it prevents accidents from occurring.
Reactive methods include:

Accident investigation.

Complaints.
Step 2. Assess the risk
After a risk has been identified it is necessary to determine how significant it is. This allows
establishment of priority for control measures. In order to do this it will be necessary to
establish the effects and consequences of the risk for determining potential injuries, illnesses
or diseases which may result. It might also be necessary to consider environmental impact of
disposal of waste generated in the workplace from equipment or process failure.
When assessing the risk the following should be considered:

The factors which cause the risk - a risk may present more than one potential
method of harm. For example, the chemical hazard may present a risk by producing
toxic fumes, or being spilled into the sewage system.

The likely exposure - essentially the longer a person is exposed to the risk the
greater level of hazard. This is particularly important when examining risks posed by
chemicals and noise.

The severity - the greater severity of the risk the more likely that it may be caused.
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
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Individual differences - all individuals will react differently to situations, exposure,
psychological problems, etc. This should be taken into account when assessing the
risk to groups or individuals.
In order to provide a quick numerical assessment of the severity of a risk, it is convenient to
use a risk assessment severity table. An example of this is given in Table 1.
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Authorised by: Marjorie Dickenson
Table 1 – Assessment of Environmental Risk Severity
How likely is it to happen?
What type of environmental damage will occur?
Likelihood
that the
hazard will
cause harm
High level acute
environmental
damage
Medium level
chronic
environmental
damage
Low level
chronic
environmental
damage
Very likely –
Could happen
any time
1
2
3
Likely –could
happen some
of the time
2
3
4
Unlikely rarely happens
3
4
5
Extremely
unlikely - will
probably never
happened
4
5
6
Legend: 1 = very high - immediate action is required; 6 = very low - only take action when practical
Hazard:
Assessed by:
Assessment date:
Severity rating:
(1 – 6)
Comment:
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Authorised by: Marjorie Dickenson
Step 3. Control the risk
Once an environmental hazard has been identified and the risk assessed, control measures
must be implemented to reduce the risk associated with environmentally hazardous work
process or systems, and/or to minimise the potential for environmental harm to occur.
When implementing control measures to minimise risk the prevention of pollution control
hierachy should be utilised. This hierarchy is as follows:
Ideal
Source Reduction
In-process recycling
Other Recycling
Treatment & recovery
Control Mechanisms
Last Resort
Figure 2 – Prevention of Pollution Hierarchy
Source reduction is always the most desirable method for pollution reduction. This involves
implementation of procedures/design which reduces the amount of pollution produced.
In-process recycling involves the use of procedures/processes which allow the reuse of
pollutants/by-products of the process, by the process to reduce the amount of pollution.
Other recycling refers to the situation where there are pollutants produced in the process, but
these may be sent to an external source for reprocessing/reuse.
Treatment and recover refers to the situation whereby a waste material is recovered from a
process, treated to remove pollutants, the recovered material reused where possible, and
any waste disposed of in an environmentally appropriate manner.
Control mechanisms should always be the last resort. These prevent the escape of pollution
from the process into the environment. No attempt is made to reduce the amount of pollution
produced by the process. Waste material must be disposed of in an appropriate manner.
Once an appropriate control measure is chosen from the hierarchy, it should be applied and
its effectiveness assessed. Regardless of which control measure is utilised, information and
training should be provided to staff and other persons in the workplace which may be
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Authorised by: Marjorie Dickenson
affected. The training should always outline the nature of the risk and the safe operating
procedures which are implemented.
Step 4. Monitor and review
Once a system has been put in place, it is prudent to ensure the risk control measure does
not introduce any further risk, and that the original risks have been removed. It is important
to regularly repeat the risk management cycle, as the workplace is dynamic - people and
processes change. Review is an integral part of the risk management process.
All stages of the risk management process should be fully documented. The risk assessment
table in the risk management chart should facilitate this process.
6.4.
Consultation
Effective decision-making in risk management relies heavily on the consultation process. It is
important that during each of the steps of the risk management cycle, managers and
supervisors should wherever possible consult with staff when performing the assessment
and control process.
6.5.
Risk Management Records
SimuLab requires that all managers and supervisors maintain records of the following:

Workplace risk assessments.

Environmental incident reports.

Accident investigation reports.

Workplace environmental audits.

Records of training.

Plant certification and tests certificates.

Standard operating procedures and safe working procedures.

Material safety data sheets and chemical registers.

Building, plant, machinery and equipment commissioning data.

Maintenance requirements and contracts.

Waste disposal procedures and contracts.

Workplace inductions.

Other documents which might be used in the risk management process.
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