Re: Pollution Risk Assessment vs. Register of Environmental Aspects
Section 4.4.7 of ISO-14001 requires that an "organization shall establish, implement and maintain a procedure to identify potential emergency situations and potential accidents that can have an impact on the environment and how it will respond to them"
By definition, as they can cause impact on the environment, both potential emergency situations and potential accidents, should have been identified under section 4.3.1 as environmental aspects.
All aspects will have impact on the environment; but some have potential to become emergency situations and accidents. These aspects will appear again under 4.4.7 discussions. This, therefore, need not be taken as duplication; in simple terms it is similar to Operational Control Procedures (4.4.6) for identified aspects - in this case (4.4.7) the aspects have potential to cause emergency situations or accidents.
Therefore, there is nothing harm in using a risk assessment table as a part of the procedure which needes to be "established, implemented and maintained" to identify potential emergency situations and accidents.
With best regards,