5468_14001pitfalls_0206.qxd 5/6/06 9:36 AM Page 34
THE ROUTE TO 14001:2004 THE ROUTE TO 14001:2004
Avoiding the Pitfalls Avoiding the Pitfalls
a73 Bulk storage can also be a problem area. If in tanks, the KEY REQUIREMENTS
means of filling and prevention of overfilling needs to be
a73 A procedure to identify potential emergencies and
checked and documented in procedures. There will also
measures to prevent them, respond to them and mitigate
often be a need for calibration and test of gauges and
any resulting environmental damage.
possibly earthing connections which prevent static sparking.
a73 Periodic testing of emergency procedures and updating
COMMUNICATION TO SUPPLIERS AND CONTRACTORS
of plans and procedures if necessary using experience
from actual emergencies or other sources, eg tests.
a73 This is a common problem area. Often Permit To Work
systems are non-existent, inadequate, or poorly
implemented. On one occasion the only copy of the
COMMON PITFALLS
permit was held by the contractor. This meant that in a73 Often there is no procedure in place to identify potential
the event of a problem occurring there might be no
emergencies. Companies tend to base their plans on pre-
evidence of instruction.
existing health and safety procedures, eg fire and perhaps
spillage. This can lead to a failure to identify all potential
OPERATIONAL CONTROL
emergencies, eg pollution control equipment which fails in
a19 OR ✘ COMMENT/PLAN
a power cut. It can also mean that the environmental
Is there a format for operational
control procedures and a mechanism to
consequences are not anticipated and therefore there is
decide when they are to be produced?
no plan to manage or mitigate them.
Operational control procedures in other
a73 Potential spillage of chemicals tends to be an issue in most
systems, eg QMS, are referenced from
the EMS?
EMS’, yet many companies do not identify the most likely
Operational control procedures are in
location for spills, nor do they properly equip and train
place for all relevant significant aspects? their staff. In three companies spill kits were kept under
They are subject to effective document
lock and key!! Frequently kits are not near points where
control and available where needed?
they are most likely to be needed, eg movements from
Communicated to suppliers and
stores, decanting areas and receiving areas. Often the
contractors where needed?
Material Safety Data Sheets are not readily available to
Permit to Work system in use if relevant? give guidance on how to deal with a particular spill.
Occasionally the spill kits are there but have not been
replenished since last use.
a73 If spill kits are in place the next potential problem area is
4.4.7 EMERGENCY PREPAREDNESS AND RESPONSE
competence and confidence of staff in their use. It is not
uncommon to find that staff are unaware of the contents
One source of potentially extreme environmental impacts is
of a kit or how to use it. Training is essential in this,
emergency conditions - fire and its consequences, chemical spillage,
including how to dispose of the waste after the spill is
flood. These potential impacts need to be identified and plans made
cleaned up.
for dealing with them.
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