Pollution Risk Assessment vs. Register of Environmental Aspects

[Peter West]

Hi All

I just stumbled across something whilst researching and writing my operating procedures.

When trying to work to satisfy clause 4.4.7 (Emergency Preparedness and response) i found that some people/companies included the equivalent of a pollution risk assessment in addition to their Register of Env. Aspects. Having read a few its clear that most of the details are the same i.e. incident, risk rating etc however the Risk assessment seemed to focus more on actual 'disasters' e.g. fire, flood etc., whereas the Register of Env. Aspects covers a more functional view of the office i.e. things that come from running the office (heating, lighting etc.).

In my opinion including such a risk assessment cannot hurt, and indeed goes along way to demonstrating that emergencies are considered and catered for. Do you agree? Or could it be conceived as overkill, and possibly duplication of data from the Env. Aspects.

Have any of you included such a form to go alongside your Operating Procedure for clause 4.4.7?

Thanks a lot

[Dr. L. Ramakrishnan]

Hi

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,

Ramakrishnan