How to carry out a risk assessment for an Environmental Permit

How to carry out a risk assessment

When applying for or changing (varying) a bespoke permit, you must carry out a risk assessment.

When we will do your risk assessment

You can ask us to do a risk assessment for you in the following cases:

  • you are a farmer discharging certain substances to ground (waste sheep dip, pesticide, pesticide washings)
  • your activities discharge domestic treated sewage to surface water or to the ground

We will generally do your risk assessment if you are applying for a permit to discharge:

  • less than 15 cubic metres of treated sewage to ground, for example from a septic tank or small sewage treatment plant, outside a groundwater source protection zone 1 (SPZ1)
  • treated sewage or trade effluent into a river
  • less than 2 cubic metres of treated sewage to ground in a groundwater SPZ1, for example from a septic tank or small sewage treatment plant

You must do your own risk assessment if any of the following apply:

  • you are a water company or similar large operator
  • you are making a treated sewage or trade effluent discharge to surface water which contains specific substances or may have an impact on temperature
  • you are making a treated sewage or trade effluent discharge to a lake, estuary, coastal water or bathing water
  • you are making a trade effluent discharge to ground, including discharges which may have an impact on temperature
  • your discharge of treated sewage to ground is more than 15 cubic metres per day
  • your discharge to ground is more than 2 cubic metres per day and you are in a groundwater SPZ1

How to do a risk assessment

To carry out a risk assessment, you should:

  • Identify and consider risks for your site, and the sources of the risks.
  • Identify the receptors (people, animals, property and anything else that could be affected by the hazard) at risk from your site.
  • Identify the possible pathways from the sources of the risks to the receptors.
  • Assess risks relevant to your specific activity and check they are acceptable and can be screened out.
  • State what you will do to control risks if they are too high.
  • Submit your risk assessment as part of your permit application.
  • You must also include a copy of your risk assessment in your management system.

Risks from your site

In your risk assessment you must identify whether any of the following risks could occur and what the environmental impact could be:

  • any discharge, for example sewage or trade effluent to surface or groundwater
  • accidents
  • odour (not for standalone water discharge and groundwater activities)
  • noise and vibration (not for standalone water discharge and groundwater activities)
  • uncontrolled or unintended (‘fugitive’) emissions, for which risks include dust, litter, pests and pollutants that should not be in the discharge
  • visible emissions, for example smoke or visible plumes
  • release of bioaerosols, for example from shredding, screening and turning, or from stack or open point source release such as a biofilter

If you do not think any of them are significant risks, you will need to state why in your permit application.

You can ‘screen out’ potential risks from emissions to air, discharges to water or deposition onto land by carrying out tests to check whether they are within acceptable limits or environmental standards. If they are, you do not need to do any further assessment of the pollutant because the risk to the environment is insignificant.

The different risk assessments for specific activities explain ‘screening out’ in more detail.

For each risk that applies, identify each actual or possible hazard and state 9 usually in a table):

  • the hazard, for example dust, bioaerosols, litter, type of visible emission
  • the process that causes the hazard, for example shredding and turning green waste
  • the receptors, for example people, animals, property and anything else that could be affected by the hazard
  • the pathways (how the hazard can get to a receptor)
  • what measures you will take to reduce risks
  • probability of exposure, for example whether a risk is unlikely or highly likely
  • consequences (what harm could be caused)
  • what the overall risk is, based on what you’ve already stated in the table, for

Risks from noise and vibration

We may ask you to submit a noise and vibration impact assessment and a noise management plan if:

  • your activity uses noisy plant or machinery, for example cooling equipment or fans
  • you will be doing any noisy operations, such as loading or unloading, shredding, shearing, crushing, grinding, combustion, using trommels and conveyors or moving bulk materials
  • your activities are not contained within buildings
  • some of your activities take place at night
  • the area where you are planning to carry out your activity is sensitive to noise, for example rural areas may have quieter background noise levels than urban areas
  • there are sensitive receptors close to the site, for example houses or habitats

The noise impact assessment for human residential receptors must be done in line with the BS 4142:2014 standard and by a suitably qualified person.

When applying for a permit variation, do not include noise from the existing site (before changes) as part of the background. This is known as the ‘residual level’ in BS 4142:2014. Your noise impact assessment must consider all the noise resulting from the proposed variation ie the existing site and the variation together. Show both components clearly and then add them together to give a new total for site noise at the receptors. The impact assessment will be based on this new value, known as the ‘specific level’ in BS 4142:2014.

Sometimes waste activities operate alongside mineral activities, for example in quarry landfills. If the noise from waste activities is likely to have an impact on local receptors you must complete a BS 4142 noise impact assessment for these waste activities. Consider the impacts that will occur when activities are close to the restored level and close to receptors. Provide estimated durations for these.

If you are not sure whether you need a noise and vibration impact assessment and a noise management plan, contact us for advice through the pre-application advice service.

When you ask for advice through the pre-application service you must provide, at a minimum, the following information:

  • a description of your proposed activities
  • whether the activities will take place indoors or outdoors
  • whether operations will be at night
  • a map, with OS National Grid References included, clearly showing the site boundary

Read further guidance on noise impact assessments and noise management plans on Gov.uk

Identify risk of accidents

Examples of possible accidents include:

  • transferring substances, for example loading or unloading vessels
  • overfilling vessels
  • plant or equipment failure, for example over pressurised vessels and pipework, blocked drains, fire and contaminated water used to fight the fire escaping into the local watercourse or ground
  • releasing an effluent before checking its composition
  • vandalism
  • flooding
  • inadequate bunding around tanks

There could also be a risk of accidents related to your specific industry.

Assume that operator error will occur at least once every 100 times you carry out an operation, for example you may:

  • drop or damage a drum from a forklift
  • have a spillage from a tanker

Identify emissions

Emissions include:

  • releases to air, for example from storage of raw materials or wastes, or evaporating volatile organic compounds, dust or bioaerosols
  • releases to water and land, such as potential leaks or spills from storing or handling liquids or chemicals that could harm the environment
  • uncollected runoff from operational and storage areas
  • mud that could get off the site
  • pests that could get off site, such as flies
  • pollutants that are in your release at levels which do not need emissions limits but where you do need to use other measures to make sure they do not cause pollution

Read the guide to controlling and monitoring emissions on Gov.uk

Identify receptors

You must identify all the receptors that are potentially at risk from your site.

Focus on the main receptors that are at risk, for example for a sewage discharge to ground, the main receptor will be the groundwater beneath your site, but there may be other receptors nearby that you must also identify.

Receptors include:

  • protected sites and species
  • anywhere used to grow food or to farm animals or fish – check local maps or contact the Environment Agency
  • drain and sewer systems – you can ask your local water company about these
  • factories and other businesses
  • fields and allotments used to grow food
  • footpaths
  • groundwater beneath your site
  • homes, or groups of homes (such as villages or housing developments) – you can check local maps or ask your local council about these
  • playing fields and playgrounds
  • private drinking water supplies – you can ask your local council where these are located or ask your neighbours if they have a private supply
  • regionally important geological sites – you can ask your local council about these
  • schools, hospitals and other public buildings
  • water, for example ponds, streams, rivers, lakes or the sea
  • conservation and habitats protected areas and areas of scientific interest

In your risk assessment, you need to include a plan that’s to scale, for example on an Ordnance Survey map. It must show:

  • your site
  • all the nearby receptors

Check for protected sites and species

You are responsible for finding out if your development or activity is likely to affect a protected site, species or other wildlife. We may not grant your permit if your development or activity may damage protected sites or species.

Submit your risk assessment

Send your completed risk assessment to us as part of your permit application.

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