Develop an Environmental Management System for a permit to discharge used sheep dip to land

If you have a permit to discharge used sheep dip to land you can use our suggested structure for your management system. It’s designed to help you meet the requirements of your permit conditions.

It will need to be modified to suit your site as some parts won’t be relevant to your operation and you may need to make some additions.

Record each discharge to land of used sheep dip

Your management system must include records of every occasion that used sheep dip is spread to land.  Each time you dispose of used dip you must record:

• date the discharge was made
• discharge location, state the field number or national grid reference and location within the field, or cross reference to an attached map showing the location (you may only discharge at specified areas within the discharge area as stated in your permit)
• spreading equipment used
• licensed brand name or chemical composition of dip
• what, if anything are you using to dilute the used dip (for example, slurry or water)
• discharge volumes in cubic metres, made up of volume of undiluted used/waste sheep dip, volume of water or slurry added to the dip and total volume discharged.
• area of land used for discharge in hectares
• application rate of sheep dip to land (cubic metres per hectare)

Prepare your site plan

Your management system must include a plan of your site, drawn to scale.  It should show where the following things are:

• permitted area(s) for sheep dip discharge
• site entrances and exits available to the emergency services and maintenance contractors
• the buildings and other main constructions, including dipping bath
• accident and emergency response items, for example, spill kits, sand bags, first aid kit
• vulnerable receptors - the things on site or nearby that could be affected by site operations, for example watercourses, springs, boreholes, ecologically sensitive sites, residential properties.

Training requirements

Your management system needs to explain who is responsible for what procedures and who is technically competent.

The Veterinary Medicines Regulations (VMR) require that if you want to buy sheep dip, you must hold a certificate of competence in the use of sheep dips. The dipping must also be carried out by, or under supervision and in presence of a person who holds either a certificate of competence in the safe use of sheep dips, or a NPTC level 2 award in the safe use of sheep dip.

Complaints record

You need a procedure that records:

• any complaints you receive in relation to activities covered by your permit, for example complaints from neighbours about noise, odour or dust from your site
• how you investigate those complaints
• any actions taken as a result of complaints

It can be used as evidence that you’ve taken appropriate action to rectify any issues if Natural Resources Wales receives complaints about your site.

Accident management plan

You need a plan for dealing with any incidents or events that could result in pollution.  The plan must identify potential accidents, for example equipment breakdowns or any other incident which causes an unexpected change to normal operations, such as bad weather.

It is also a good idea to consider near misses and what you could do to stop them happening again so that you reduce the risk of things going wrong.

For each potential incident, it must also state the:

• likelihood of the accident happening
• consequences of the accident happening
• measures you’ll take to avoid the accident happening
• measures you’ll take to minimise the impact if the accident does happen

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:

• the date it was reviewed
• when it will next be reviewed
• a list of emergency contacts and how to reach them
• forms to record accidents on

Consider taking the following actions, if you think they are relevant to the operations you carry out at your site:

• make emergency services aware of your activities
• take out insurance to cover the cost of clean up following an accident
• check whether you’re in a flood risk area and sign up for flood warnings
• develop a system to allow access to important information away from your site

Finally make sure that everyone on site knows about the plan, where to find it, and what it contains. It’s important that they know how to prevent accidents and what to do if there is one.

Preventing accidents and what to do if they happen

Below are examples of things that could go wrong and harm the environment and what to do if they happen. You should check if you can identify anything else particular to your site that could cause a problem. If you can then add it to the list.

Spreading dip onto frozen, waterlogged or cracked land causes pollution             

Prevention:

• Dip must only be spread onto land which is in an appropriate condition to receive it.

Remedial action:

• In the event of unsuitable spreading conditions store the dip securely in an appropriate container until spreading can occur

Spillage during transfer of the sheep dip to the farm or during storage before use

Prevention:

• Ensure dip and other chemicals are transported in a drip tray or similar container large enough to hold spillages and secured to avoid tipping.
• Ensure that the sheep dip concentrate storage area is of sound construction, is well maintained and located where it is unlikely to be damaged by vehicles.
• Ensure dip is stored away from drains and in a secure tray or bund to contain any spillage. Store dip concentrate in a properly constructed farm chemical store or approved steel cabinet in accordance with HSE Agriculture Information Sheet A/S16.

Remedial action:

• If spillages occur soak them up with an absorbent material and dispose of through a registered waste carrier.
• Follow the spill response procedure. It describes what to do in the event of a spill and where the kit is kept.
• Environmental pollution must be reported to Natural Resources Wales.

Spillages of sheep dip when transferring to a slurry tanker or vacuum tanker prior to spreading

Prevention:

• Ensure the tanker is filled with either water or slurry before adding the waste or used dip.
• Ensure that you know the capacity of the tanker and that all pipes used to transfer the dip from the bath to the tanker are free of leaks.

Remedial action:

• If spillages occur soak them up with an absorbent material and dispose of through a registered waste carrier.
• Follow the spill response procedure. It describes what to do in the event of a spill and where the kit is kept.

Environmental pollution must be reported to Natural Resources Wales.

Leakages due to faulty pipe work, holes in the dipping bath etc.

Prevention:

• Visual inspection of the dipping bath, pipe work and vacuum tanker, slurry tanker prior to use.
• Testing of the integrity of the dipping bath and pipe work by running water through them prior to dip and completion of inspection checklist.
• Preventative maintenance regime.

Remedial action:

• If spillages occur soak them up with an absorbent material and dispose of through a registered waste carrier.
• Follow the spill response procedure. It describes what to do in the event of a spill and where the kit is kept.

Environmental pollution must be reported to Natural Resources Wales.