Environmental Risk assessment

A SEMINAR REPORT ON

ENVIRONMENTAL RISK ASSESSMENT

Submitted by

Joshi Priyanka Govind

First Year M. Tech (Civil - Environmental Engineering)

DEPARTMENT OF CIVIL - ENV ENGINEERING, VEERMATA JIJABAI TECHNOLOGICAL INSTITUTE, MATUNGA, MUMBAI.

Environmental Risk assessment

INTRODUCTION

This paper summarises some of the basic principles and uses of environmental risk assessment. The information is based mainly on two sources, the Guidelines for Environmental Risk Assessment and Management published by the Department for Environment, Food and Rural Affairs (Defra) and Environmental Risk Assessment Approaches, Experiences and Information Sources published by the European Environment Agency. Given the wide-ranging nature of environmental risk assessment a large amount of other, more detailed, information and guidance is available for specific situations. Examples of such guidance (non-exhaustive) are given in the reading list, and the reader is directed to these for further information.

Environmental Risk assessment

ENVIRONMENTAL RISK ASSESSMENT

In order to understand what is meant by environmental risk assessment it is important to be familiar with the concepts of hazard and risk. These terms have different meanings and are not interchangeable. The following definitions are used here. Hazard: is the inherent potential for something to cause harm. Hazards can include substances, machines, energy forms, or the way work is carried out. Risk: is the likelihood that harm will actually be done by the realisation of the hazard during the work being carried out or by the way something is used,
Risk = Hazard Exposure.

In general, the term environmental covers the physical surroundings that are common to everybody including air, water, land, plants and wildlife. The definition used in the Environmental Protection Act 1990 is that the environment '... consists of all, or any, of the following media, namely the air, water and land'. Thus environmental risk assessment covers the risk to all ecosystems, including humans, exposed via, or impacted via, these media. The term environmental risk assessment does not normally cover the risks to individuals or the general public at large from consumer products or from exposure in the work place, where other specific legislation applies.

STAGES IN CARRYING OUT AN ENVIRONMENTAL RISK ASSESSMENT

Environmental risk assessment can be thought of as containing the following key stages1.

1. Hazard identification. This would typically include identification of the property or situation that could lead to harm. This step is sometimes also known as problem formulation.

2. Identification of consequences if the hazard was to occur. This step is sometimes also known as hazard identification.

3. Estimation of the magnitude of the consequences. This can include consideration of the spatial and temporal scale of the consequences and the time to onset of the

Environmental Risk assessment

consequences. When considering chemicals, this step can sometimes be termed release assessment. 4. Estimation of the probability of the consequences. There are three components to this, the presence of the hazard, the probability of the receptors being exposed to the hazard and the probability of harm resulting from exposure to the hazard. This step can sometimes be called exposure assessment or consequence assessment.

5. Evaluating the significance of a risk (often termed risk characterisation or risk estimation) is the product of the likelihood of the hazard being realised and the severity of the consequences.

A concept frequently used in environmental risk assessment is that of the source pathway receptor. In this model the pathway between a hazard source (for example a source of contamination) and a receptor (for example a particular ecosystem) is investigated. The pathway is the linkage by which the receptor could come into contact with the source (a number of pathways often need to be considered). If no pathway exists then no risk exists. If a pathway exists linking the source to the receptor then the consequences of this is determined. This approach is used in the assessment of contaminated land, but can be, and is, applied to many other areas. An EHSC note is available on the assessment of contaminated land.

At the end of the risk assessment process, existing controls should be recorded and further measures may need to be considered to reduce or eliminate the risks identified. Detailed consideration of risk management is beyond the scope of this paper but, in general

Environmental Risk assessment

terms, risk management can be achieved by reducing or modifying the source, by managing or breaking the pathway and/or modifying the receptor. The final stage is the evaluation of the significance of the risk which involves placing it in a context for example with respect environmental standard or other criterion defined in legislation, statutory or good practice guidance. The amount of effort and detail required in assessing each risk can vary widely, but is generally proportionate to its priority and complexity. Thus environmental risk assessments can be carried out on several levels. An example of a relatively common, simplistic, approach based on a risk ranking matrix is shown below. The meanings of high, medium, low and very low can be determined in various ways, for example using a descriptive or numerical scale, or often based on expert judgement. Once risks have been identified, the matrix allows the relative importance to be easily determined, and the risk can then be prioritised and an appropriate risk management strategy or plan can be implemented. Other relatively simple approaches include the use of assessment sheets whereby the materials and activities are listed, and any potential impacts for the environment are described

In more complex cases, it may be appropriate to use (semi)qualitative risk assessment approaches. Such approaches can define the pathway and consequences using modelling/estimation techniques that allow the level of exposure of a receptor, and the

Environmental Risk assessment

consequences to the receptor, to be better determined. In some cases probabilistic models can be used to estimate the actual probability of risk occurring.

USES OF ENVIRONMENTAL RISK ASSESSMENT

There are a wide range of uses of environmental risk assessment and, although the specific methodology and the responsibility for carrying out the assessment may vary, the core principles and the key stages of the process are fundamentally the same in each case. There is a wide range of legislation that encompasses the principles of environmental risk assessment in relation to chemicals. The European Environment Agency (1999) publication lists some of these but the area is rapidly changing and it is impractical to provide a complete list here. Specific guidance is often available for each piece of legislation. The principles of environmental risk assessment are also applied in a number of other areas, for example flood protection, noise pollution and planning. Some examples of the use of environmental risk assessment are given below. Assessing the impacts of chemicals used at existing sites (for example for the Control of Major Accident Hazards (COMAH) Regulations (1999), Environmental Permitting Regulations (2007) and other similar legislation). Assessing the impacts of products generated by individual companies/sites due to their use or transport etc. Assessing potential impacts of new developments, new sites or new processes as part of the planning procedure (for example in relation to the Town and Country Planning Regulations (1999) (as amended). This is often known as Environmental Impact Assessment or EIA. Assessing the impacts of products, processes or services over their life cycle (life cycle assessment or LCA). An EHSC note on LCA is available (see bibliography). Consideration of risks to the environment in a companys environmental management system (EMS) or eco-management and audit scheme (EMAS). Such schemes are based on

Environmental Risk assessment

continual environmental improvement in which risk assessment plays an important part. An EHSC note is available on EMS (see bibliography). Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation. Environmental risk assessment is a key component of determining the safe use of chemicals under this legislation.

1.0 Purpose and Objective The purpose of this procedure is to define process for hazard Identification, assessment and control of risks associated with these hazards and development of operating control procedures.

2.0 Scope This procedure applies to all activities and processes conducted within ACL premises.

3.0 Risk Assessment Methodology

3.1. Activity Risk Assessment

i) Identify the activities carried out in the departments. Following inputs shall be considered while identifying the activities: a. Up to date site layout diagram/ process flow sheets for identification of activities b. All activities having previous records of Incidents. c. Inputs from regular Plant & Management Review meetings/ Safety inspections/ records. d. All routine activities (those activities which are scheduled & carried out frequently) e. All non-routine activities (those activities which are not done in scheduled time or done occasionally) f. Examination of all existing OHS procedures and practices.

Environmental Risk assessment g. Activities of all personal having access to work place (including sub contractors & visitors). h. Facilities at the work places, whether provided by the organization or others. i. Facility layout chart j. Equipment Manufacturers Documents / IS codes for corresponding electrical equipment k. Any other relevant information

ii) Break the activities into sub-activities.

iii) Identify all relevant hazards related to each sub-activity. Consider who might be harmed, what might be damaged. Refer to the annexure II for categorisation of hazards and their subcategories.

iv) Identification of the hazards can be done through: a. Consultation with managers, supervisors, employees, OH&S Representatives, OH&S Committee, and others; b. Reviewing hazard reports;

c. Records of past incidents involving injury and illness highlight sources of potential harm; d. Review of plant and equipment maintenance records; e. Workplace inspections; f. MSDS; g. Task impact analysis; h. External sources of data and information; and i. Review of specific hazard types. j. Identify controls existing to control the hazard k. Review the control measures in place w.r.t the hazards identified and document the same.

v) Assessment of Risk a. Each hazard identified shall be estimated for the risk, taking into consideration the existing controls. Likelihood of occurrence of the event and severity level (i.e. consequence rating) shall be identified as per the adopted matrix. b. Assess the level of risks related to the identified hazard as per the risk classification matrix. c. Risks shall also be assessed with respect to the prevailing legislation.

vi) Control of Risk a. Depending upon the risk level, plan shall be prepared to control the risk. b. Risks shall be controlled as per the hierarchy of controls.

Environmental Risk assessment

i. Elimination of the hazard ii. Substitution/ Minimisation iii. Engineering controls iv. Segregation V. Administrative (Including reduction in Personnel/ Time Exposure) Vi. Personal Protective Equipment

vii) As per the hierarchy identified, Management shall prepare Management program to deal with the identified hazard and the risk associated with it.

viii) There shall be a review mechanism developed to assess the progress on the Management programs.

ix) Risk assessments conducted of all the activities will be documented.

x) The results of risk assessment shall be considered in setting OH&S objectives and targets/ Operating control procedures/ measurement and monitoring, Training and any other relevant control measures.

xi) Review of the risk assessments a. Risks shall be reviewed after the recommended controls are implemented and same shall be updated in the risk assessments. b. Risk assessments shall be reviewed annually or whenever there is any introduction of new process/ project/ activities/ raw materials/ personnel/ equipment.

3.2. Process hazard analysis (PHA):

i) PHA are a specialised risk assessment techniques and shall be used for more complex and /or more serious hazards and accident scenarios. ii) Either of the following techniques shall be applied for carrying out the process hazard analysis, depending upon the process for which hazard identification is to be carried out. a. HAZOP b. What if? Analysis c. Failure Mode and Effect Analysis

Environmental Risk assessment

d. Fault tree analysis e. Event tree analysis iii) What if? Analysis can be applied for the following process. (List is suggestive and not mandatory) a. Kiln operation b. Wagon tippler operation c. Truck tippler operation d. Working inside VRM e. Working/ cleaning inside ESP/ Bag filters f. Working inside cement mill (fully jam condition) g. Working inside coal mill h. Coal conveying system iv) HAZOP study can be applied for the following process- (List is suggestive and not mandatory) a. Power Plant operation. b. Coal mill operation v) Hazop/ What if can be applied for Hot air generation for mill operation. vi) Actions arising out of the PHAs shall be reviewed for their completion.

3.3. Responsibilities for conducting risk assessments and PHAs ii) PHA (Either of the technique) shall be carried out by a multidisciplinary team appointed by Unit Head. The team shall comprise various functions like Maintenance, Production, Quality, OH&S and other relevant functions. iii) Team shall identify activities carried out in the respective department and potential hazards associated with these activities. iv) HOD/In-charge shall ensure that team members involved shall be having adequate knowledge of the activity/ process and understand the assessment process. v) HOD/In-charge shall take responsibility for the quality of the risk assessment. vi) HOD/In-charge shall ensure that the detail of the assessment is agreed by the assessment team. vii) Team members shall be trained by Plant OH&S co-ordinator for conducting risk assessments. Refresher training shall be done on annual basis. viii) OH&S dept. shall provide necessary guidance for carrying out the risk assessment. If required professional consultants can be used.

Environmental Risk assessment

ix) Risk assessment shall be reviewed by the HOD/In-charge to validate the controls identified and proposed. x) HOD/In-charge shall review the status of Management programs and other controls identified. xi) Processes which require application of PHA technique shall be identified by the concerned HOD/In-charge. xii) Identified control measures shall be addressed by the respective HOD/Incharge. xiii) HOD/In-charge shall track the progress of the actions arising out of Risk assessments and PHA for their completion. xiv) HOD/In-charge shall own the responsibility of carrying out the risk assessment and PHAs. xv) Risk assessment and PHA shall be a formal process and shall be documented. xvi) Risk assessment and PHA conducted shall be reviewed at a minimum of annual basis or whenever there is a change in the process/ activity by the respective Team leader. xvii) Status of Risk assessments and PHAs shall be discussed in the monthly OH&S review. Plant OH&S co-ordinator shall co-ordinate the process and document the proceedings.

3.4. Risk Classification Matrix

i) Risk assessment shall be conducted on the basis of risk classification matrix. ii) This is the recommended risk classification matrix in order to ensure standardisation across all operations. Table A Example Matrix for Determining the Level of Risk

Environmental Risk assessment

3.5. RISK RANKING METHOD

i) Risk is the combination of the likelihood of a specific unwanted event and the potential consequences if it should occur. The rankings to be given are as under:

Environmental Risk assessment

v) Guidelines for taking actions on risk classification:

Environmental Risk assessment

a. High- Take Immediate Action b. Medium- Take action within 72 hours c. Low- Manage by routine practices

3.6. Risk Assessment Proforma

i) Findings of the risk assessment shall be recorded in a template which shall cover: (Sample Template Attached herewith as Annexure I) a. Location b. Description of Work activity c. Activity type d. Sub activity e. Population at risk (Identify all type of personnel at risk including people outside the work who may get affected.) f. Hazard category g. Hazard sub category h. Existing Controls in place i. Initial Risk Assessment: i. Likelihood of occurrence (From the matrix, identify the likelihood of event occurring with existing controls in place for each hazard) ii. Consequence (From the matrix, identify the consequence with existing controls in place for each hazard) iii. Risk Level (Classify risk level from matrix for each hazard) j. Corrective Action k. Responsibility for corrective action l. Target date for completion m. Remarks n. Residual Risk Assessment: i. Likelihood of occurrence (From the matrix, identify the likelihood of event occurring with recommended controls in place for each hazard) ii. Consequence (From the matrix, identify the consequence with recommended controls in place for each hazard) iii. Risk Level (Classify risk level from matrix for each hazard o. Administrative details for e.g- name of the assessor, date of assessment, review date etc.

Environmental Risk assessment

4.0 Operation Control Procedures:

i. After application of the control measures as per the hierarchy of controls, the applied control should be reflected in the existing Operational control procedures. Operational Control Procedures specify the way to carry out an activity or a process. ii. Written operating procedures assist operations personnel to manage safety by setting standards against which operational practices can be measured. iii. Operational Control Procedures shall provide clear instructions for safe operation of the facility, which is consistent with the hazard identification and process safety information available. iv. Operational Control Procedures shall be prepared by the respective dept. heads for the main equipments and processes and also for the following: a. Initial start up b. Normal operation c. Temporary operations d. Emergency operations including emergency shutdown e. Normal shutdown f. Start up following a shutdown or turnaround v. Operational Control Procedures shall provide information on the operating limits and where a deviation from normal operations could have safety consequences the following should be provided: a. Consequences of the deviation b. Steps required to correct or avoid the deviation c. OHS systems to be used and their function vii) Operational Control Procedures shall also address the following: a. Properties of and hazards presented by materials used in the process b. Special precautions required to prevent exposure to the materials c. Control measures to be undertaken if physical contact or airborne exposure occurs. d. Any special or unique hazards. viii) Operational procedures shall be made available at the point of use and all concerned personnel shall be trained by respective dept. heads in content of operating procedures and training records shall be maintained. Operational Control Procedures shall be maintained as a soft or hardcopy in a legible form.

Environmental Risk assessment

ix) Operational Control Procedures shall be reviewed and audited on annual basis by respective dept. head. Reviews conducted of the same shall be recorded.

5.0 Policies and Procedures:

Corporate OH&S shall prepare a policy on Drug and Alcohol abuse which shall be followed by the plants.

6.0 Literacy and Language:

i) OH&S Policy, Safety Instructions, Communication related to risks and operation control procedures shall be done in such language that can be understood by majority of Employees, Workmen and Visitors. ii) For those employees/ workmen who are unable to read or write or else not able to understand the written procedures, a system shall be developed for providing required OH&S information through audio visual programs and/ or verbal instructions.

7.0 Fitness for duty i) All employees shall be fit for duty. ii) Plant shall comply the medical fitness criteria as per applicable OH&S regulations.

Environmental Risk assessment

10.0 Distribution list All relevant ACL employees

11.0 References OHSAS 18001:2007 Occupational Health and Safety Management System IS 18001: 2007 Occupational Health and Safety Management System- Requirements with guidance for use AS/NZS 4360 Risk score calculator B 6- Management Commitment and Planning Procedure B7- Procedure for Induction and Training B5- Procedure for legal obligations