MRF Name / Logo MP08 - Environmental, legal and communication aspects procedure Section All Release/Amendment summary Initial issue Issue Date 1.0 dd/mm/yy Approved: Management Representative: Note: Within this manual template, red italic text should be replaced by MRF specific information and any guidance in ‘text boxes’ should be implemented. 687289329 MRF Name / Logo 1 Purpose This procedure describes the processes to identify the environmental aspects of MRF Name activities, products and services and the determination of those aspects that have a significant impact on the environment. This procedure also includes the identification of legal and other requirements and the determination of how these apply to environmental aspects and the communication with regard to environmental aspects and the environmental management system. This includes both internal and external communication. 2 Scope This procedure contains the following sections: 4.1 4.2 4.3 4.4 Environmental aspects Legal and other requirements Objectives, targets and programmes Communication 3 Definitions and glossary MD MR OM - Managing Director - Management Representative - Operations Manager 4 Procedure The MD and MR are responsible for the implementation of this procedure. The MD and MR are responsible for identifying Environmental Aspects of the business and determining those aspects that may have a significant environmental impact. The MD and OM are also responsible for identifying applicable legal and other requirements related to environmental aspects and ensuring that applicable legal requirements are taken into account in the implementation and maintenance of the environmental management system. The MD and MR is responsible for planning and overseeing Environmental Objectives, Targets and Programmes. The MD is responsible for the establishing the policy in relation to external communication of MRF Name environmental aspects. 4.1 Environmental aspects In the context of this procedure, an Environmental Aspect is an element of MRF Name activities, products or services that can interact with the environment and that MRF Name can either control or influence. These are taken into account when planning new or modified services or processes. The identification of environmental aspects in relation to the activities, products and services provided by MRF Name has been carried out as part of the environmental system implementation and will be included in the planning of any new services and processes. This will also include the determination of those environmental aspects that have (or could have) a significant environmental impact. An environmental impact is a change to the environment (adverse or beneficial) that wholly or partially results from a MRF Name environmental aspect. 4.1.1 Determination of significant environmental aspects Impacts/aspects identified during the ongoing review of MRF Name activities are prioritised by an impact/risk assessment procedure, the results of which can be used for the implementation of continuous improvement. Impacts are scored and ranked to enable the significant impacts to be identified and a priority allocated in a systematic manner. In addition to ensuring that there are appropriate operational management control procedures in place, MRF Name management will set objectives and targets for continuous improvement of the significant impacts. The following procedure has been used for the ranking of significant environmental aspects and impacts. This ranking is to be recorded on form MFxx (see Appendix A). 687289329 2 MRF Name / Logo Potential harm (A) Will harm be caused to the environment as the result of the aspect? The category of ‘Potential Harm’ is intended to evaluate hazard and risk associated with the ‘control of pollution’ i.e. environmental damage that could occur. When assessing the Potential Harm of an aspect, the inherent environmental hazard of the material and the location of the ‘incident’ is considered. Aspects associated with ‘Potential Harm’ may occur under normal, abnormal and emergency conditions. A 1 to 5 rating is used as follows: 1. Material that will not cause environmental damage. 2. Material that could cause limited environmental damage. 3. Material that could cause localised environmental damage. 4. Material that could cause substantial damage. 5. Material that could cause major environmental damage. Actual harm (B) Will harm be caused to the environment as a result of the consumption of resources or the disposal of waste? The category ‘Actual Harm’ is intended to evaluate environmental damage caused through the consumption of resources or the disposal of wastes. Aspects associated with ‘Actual Harm’ will occur under normal and abnormal conditions. A 1 to 5 rating is used as follows: 1. 2. 3. 4. 5. Consumption / disposal of Consumption / disposal of Consumption / disposal of Consumption / disposal of Consumption / disposal of environmental problem. a a a a a renewable / recyclable material causing no environmental damage. material / resource causing minor environmental damage. material / resource causing moderate environmental damage. material / resource making a contribution to a known global environmental problem. non-renewable material / resource making a major contribution to a known global Scale of aspect (C) The quantity or size of the environmental aspect. This aspect could be in relation to Energy Consumption in KWh / annum or Waste to Landfill in tonnes / annum. Again a rating of 1 to 5 can be applied. 1. Minimum quantity used or released. 2. Minor quantity used or released. 3. Moderate quantity used or released. 4. Large quantity used or released. 5. Major quantity used or released. Frequency of occurrence (D) Is the aspect likely to occur? When assessing the frequency that the aspect will / does occur, the effectiveness of the controls already in place should also be consider. A rating of 1 to 5 is applied as follows: 1. No evidence of occurrence. 2. Possible occurrence (1 x per year). 3. Probable occurrence (1 x per month). 4. Likely occurrence (1 x week). 5. Certain to occur (daily or continuous). The sum of the ratings for A + B + C + D can therefore be used to determine those environmental aspects that have (or 687289329 3 MRF Name / Logo could have) a significant environmental impact. It should be noted that the categories Potential Harm and Actual Harm are mutually exclusive - scoring either category means that only a ‘1’ can be entered in the other. The MFxx form in Appendix A can be used to provide more detail about the significance evaluation of more complicated impacts. Completed forms can be used to make up the register of Environmental Aspects and Impacts using the above rating method. This also takes into account the aspect in Normal, Abnormal and Emergency situations and the applicability / significance of legal requirements where applicable. Where legal requirements are applicable, an additional score of 1 (low), 2 (medium) and 3 (high legal significance) should be added. The maximum environmental impact score using the above method is 19. Scores of 11 or above are considered to be environmental aspects that have a significant enough impact to be included on the Objectives, Targets and Programmes table. An environmental impact score of 14 or above will be treated as a priority. 4.2 Legal and other requirements MRF Name has established procedures to identify / give access to legal requirements and other requirements that are applicable to the organisation. This allows MRF Name to be aware of various requirements and how they apply to the environmental aspects of its activities, products and services. This information is also communicated to all persons or subcontractors working on behalf of MRF Name whose activities could affect compliance with these requirements. The following procedure is used in the identification and tracking of legal or other requirements: A source of environmental legislation reference documentation has been identified and links to this Internet site established. A register of sector specific UK legislation has been compiled and the applicability of this legislation to the activities carried out by MRF Name has been considered and included on the register. Where appropriate, other (non-legal) requirements have been included and the register also cross-references to the Register of Environmental Aspects and Impacts and any associated control procedures. To assist with remaining up to date with environmental legislation, an email update link has been established with the chosen environmental legislation Internet site. 4.3 Objectives, targets and programmes Environmental objectives and targets have been established in relation to organisational activities and product realisation. These have been documented in the Environmental Aspects, Objectives, Targets and Programmes table which is maintained by the MD / MR. This table includes the following data: Environmental aspects - by activity or product. Objectives – the improvement objective in relation to the aspect. Targets – the objective target. Programmes – the programme / activity required to achieve the objective. Indicators – the measurement use to indicate progress towards the objective. Operational controls – the controls and procedures used to ensure control / consistency of the programme. Monitoring and measurement – the periodic monitoring and measurement methodology to demonstrate progression towards achieving targets. The responsibilities for achieving objectives and targets are included in the Programme section of the Environmental Aspects, Objectives, Targets and Programmes table. The timescales for achieving objectives and targets are included in the Targets section of the Environmental Aspects, Objectives, Targets and Programmes table. Performance against the environmental objectives and targets will be included in quarterly company meetings where appropriate and will be further reviewed during annual Management Review meetings. Other elements of Monitoring and Measurement and Evaluation of Compliance are included in the Monitoring, Measurement and Improvement procedure MP12. 687289329 4 MRF Name / Logo 4.4 Communication Internal communication in relation to environmental requirements and performance is carried out through the quarterly company meetings. It is also the responsibility of the MD and MR to circulate environmental information within the organisation and to ensure that procedural and guidance information is maintained and made available through the computer network. It has been decided that information in relation to MRF Name environmental aspects will not be directly publicised, however requests for information remain welcome. The request for information, either from trading partners (e.g. customers), or the general public shall be directed to the MR. The MR shall confer with the MD if there is any doubt on how to reply (i.e. if the matter is confidential). The MR shall respond in writing to the enquirer. If appropriate, the MR is authorised to release an ‘uncontrolled’ copy of the Quality and Environmental Manual. The Quality and Environmental Policy is published on the company website and shall be made freely available to the public or other interested parties on request. The MR is the MRF Name representative in all dealings with regulatory bodies such as the Environmental Agency or local authorities etc. Any member of staff receiving a complaint about environmental performance from an external source shall direct the compliant to the MR, or if the MR is not available, to the MD. Further details in relation to the management of complaints is contained in the Monitoring, Measurement and Improvement procedure MP11. 5 Related documents Register of Environmental Aspects and Impacts Register of Applicable Legislation Environmental Aspects and Impacts Registration Form MFxx Environmental Aspects, Objectives, Targets and Programmes table Monitoring, Measurement and Improvement procedure MP11 687289329 5 MRF Name / Logo Appendix 1 – Environmental aspects and impacts registration form MFXX Impact / Aspects Reference No 1. Description of impact: Occurring under normal/abnormal/emergency conditions? 2. Legal or other requirement applicable? Applicability / significance of legal and other requirements (add to total score): High – Score 3, Medium – Score 2, Low – Score 1 3. Operational control procedures (direct and indirect): SCORING: HIGH SCORE = HIGH SIGNIFICANCE (SCORES OF 11 OR ABOVE) Potential Harm (A) RATING 1-5 Actual Harm (B) RATING 1-5 Scale of Aspect (C) RATING 1-5 Frequency of Occurrence (D) RATING 1-5 TOTAL SCORE ................................................ (inc. Legislation score) Date: ……………………….. 687289329 6