Environmental Procedure

Environmental Procedure

EMS-01

E N V I R O N M E N T A L P R O C E D U R E – E M S - 0 1

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C O N T E N T S

PART 1 4

Scope 4

PART 2 5

Definitions 5

PART 3 6

Environmental policy 6

PART 4 6

Roles and Responsibilities 6 4.1 CEO 6 4.2 HSEQ Committee 6 4.3 HSE Manager 6 4.4 Staff and Site Operatives 6

PART 5 7

Inductions, Training, awareness & competence 7

PART 6 8

Planning 8 6.1. Environmental aspects 8 6.2. Legal and other requirements 8

PART 7 9

Communication 9

PART 8 9

Document control 9

PART 9 10

Emergency preparedness and response 10 9.1 Emergency Procedures – Identification 10 9.2 Training 10 9.3 Testing 10

PART 10 11

Checking and corrective action 11 10.1 Monitoring and measurement 11 10.2 Non-conformance and corrective and preventative action 11


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10.3 Records 11 10.4 EMS audit and review 11

PART 11 12

Operational Control 12 11.1. Operational Procedures 12 11.2. Method for preparation of COSHH Assessments 12 11.3. Waste Management 12 11.4. Testing of Operational Procedures 12

PART 12 13

Waste Management 13

PART 13 14

Chemical Storage 14

PART 14 15

Control of Dust & Emissions 15

PART 15 16

Spillage Control 16

PART 16 17

Water Discharge 17

PART 17 18

Energy Management 18

PART 18 19

Pollution Prevention 19

PART 19 20

Office Recycling 20

PART 20 21

Site Recycling and end of life 21

PART 21 21

Control of environmental management programmes 21

PART 22 22

Appendix A - Environmental Policy 22


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P A R T 1

SCOPE

This document sets out Lightsource BP’s environmental policies and procedures in relation to office-based staff,

staff who are travelling on business, Lightsource BP events on external premises and visitors to Lightsource BP

premises, construction activities where Lightsource BP are the principal or main contractor, asset management

activities and operation and maintenance activities, and how it meets the requirements of ISO 14001:2015.

The Objective of the EMS is to achieve the following:

a. Demonstrate commitment to effective

environmental management, environmental legal

compliance and environmental best practice;

b. Develop systems to achieve client environmental

aspirations;

c. During the first year of the systems

implementation, the system will be monitor and

recorded and then evaluate for specific targets to

be defined, by the HSQE Steering committee.

d. And develop systems that will ensure that

Lightsource BP is a leader in managing

environmental issues relating to our activities.

Visual image showing process:


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P A R T 2

Definitions

Environment Is defined as surroundings in which an organisation operates, including air,

water, land, natural resources, flora, fauna, humans and their interrelation.

Aspect Is defined as any element of an organisation’s activities, products or services

that can interact with the environment.

Impact

Is defined as any change to the environment, whether adverse or

beneficial, wholly or partially resulting from an organisation’s activities,

products or services.


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P A R T 3

Environmental policy

The environmental policy (Appendix A) is produced and review

by HSEQ committee in collaboration with the HSE Manager,

then signed and approved by the CEO. The policy is reviewed

on a yearly basis or after any significant change.

The policy is available electronically on the company intranet

and is displayed in the office.

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P A R T 4

Roles and Responsibilities

Lightsource BP ensure the availability of resources essential to

establishment, implement, maintenance and improvements of

the EMS. Resources include human resources and specialised

skills, organisational infrastructure, technology and financial

resources

Roles and Responsibilities are defined, documents and

communicated in order to facilitate effective environmental

management.

Lightsource BP’s top management have appointed a specific

management representative who irrespective of other

responsibilities has defined responsibilities for:

a. Ensure that the EMS is established, implemented

and maintained in accordance with the

requirements of the ISO 14001:2015 standards

b. Reporting to top management on the performance

of the EMS for review including recommendations

for improvements

The following personnel have a key role in the EMS:

4.1 CEO

Will sign and approve the EMS policy annually and is

responsible for ensuring adequate resources for development

and maintenance of the EMS are provided, and ensure all top

management comply with the EMS.

4.2 HSEQ Committee

The HSEQ committee will provide support to the HSE Manager

and assist with the development and implantation of the EMS.

4.3 HSE Manager

Has the overall responsibility for the implementation and

maintenance of the EMS, including legal requirements

regulatory compliance, and including the responsibility for the

identification and tracking of employees training in relation to

HSE including ISO 14001:2015 awareness training, hazard

communication training and emergency response planning.

4.4 Staff and Site Operatives

Have the responsibility to conduct their jobs in a manner to

support and comply with the EMS policy and procedures

including the prevention of pollution, legal compliance,

continuous improvements and reporting of incident and/or

accident (pollution and spills, or nonconformities).


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P A R T 5

Inductions, Training, awareness & competence

Lightsource BP, will ensured that any persons performing a task

on our behalf that may have the potential to cause a significant

environmental impact identified by the organisation are

competent on the bases of appropriate education, training and

experience and these records will be retained.

Lightsource BP has identified the training needs associated with

our environmental aspect and our EMS.

Lightsource BP has established, implemented and maintained

procedures to make persons working for us (or on our behalf)

understand:

a. The importance of compliance with the

environmental policy and procedures and with the

requirement of the EMS

b. The significant environmental aspects and related

actual or potential impacts associated with their

work and the environmental benefits of improved

personal performance

c. Their roles and responsibilities in achieving

conformity with the requirements in the EMS and

d. The potential consequences of non-compliance

from specified procedures.

This information is covered in our HSE training program. This

training is provided to all employees with an undertaking of the

EMS policy, their roles in support the policy, understanding of

significant aspects they impact and other EMS information.


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P A R T 6

Planning

6.1. Environmental aspects

Lightsource BP has established, implements and maintained a

procedure (Aspects, Impacts and Legislation EMS-02 &

Environmental aspects and Impacts evaluation criteria) that:

Identifies the environmental aspects of our activities, products,

and services within the defined scope of the environmental

management system that we can control and over which we

can be expected to have influence, taking into account planned

or new developments or new r modified activities, products

and services;

To determine those aspects which have (or can have)

significant impact(s) on the environment;

Lightsource BP documents the environmental aspects

information on EMS-02 and keeps it up to date. Significant

environmental aspects are taken into account in establishing,

implementing and maintaining our environmental

management system.

6.2. Legal and other requirements

Lightsource BP has established, implemented and maintained

procedures:

a. To identify and have access to the applicable legal

requirement and other requirement to which the

organization subscribes related to its

environmental aspects and

b. To determine how these requirements, apply to

our environmental aspects.

Lightsource BP, will ensure that the applicable legal

requirements and other requirements to which we subscribe

are taken into account in establishing, implementing and

maintaining our Environmental Management System.

At Lightsource BP we access the applicable Environmental

requirements through the internet, meetings and publications.

For Scotland this is achieved through Netregs -

http://www.netregs.org.uk/legislation/scotland.aspx

6.3. Objectives, targets and programme

Lightsource BP is committed to the continuous improvements

of its environmental performance and EMS system.

Improvements in environmental performance will be

accomplished through the establishment and documentation

of environmental objectives and targets, monitoring significant

environmental aspects, and regular EMS communications.

Lightsource BP has established, implemented and maintain

documented the environmental objectives and targets at

relevant functions and levels within our organisation. (EMS-03

Environmental Objectives)

Lightsource BP, will ensure the objectives and targets are

measureable where practicable and consistent with the

environmental policy including the commitments to:

a. Prevention of pollution;

b. Compliance with applicable legal requirement and

with other requirement to which the organisation

subscribes; and

c. Continual improvement.

When establishing and reviewing its objectives and targets

Lightsource BP takes into account the legal requirements and

other requirements to which we subscribe and our significant

environmental aspects. Lightsource BP also consider our

technological options, financial, operational and business

requirements and view of interested parties.

Lightsource BP has also established, implemented and

maintained a program for achieving our objectives and targets.

The program includes:

a. Designation of responsibility for achieving

objectives and target at relevant function and level

of our organisation and

b. The means and time frames by which they are to

be achieved.

http://www.netregs.org.uk/legislation/scotland.aspx


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Each objective and target and associated program will be

documented (EMS-03)

The Lightsource BP HSEQ steering group will meet on a regular

basis (every 2 months) to discuss progress of the

objectives/targets, identify improvements to the EMS, and

implementation of corrective actions, Lightsource BP will also

maintain a continuous improvement log to track incremental

improvements in the EMS processes.

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P A R T 7

Communication

Lightsource BP has established, implemented and maintained a

procedure for internal and external EMS communication

(QHSE-MS-02) this procedure defines:

a. Internal communication among various levels and

function of the organisation;

b. Receiving, documenting and responding to relevant

communication form external parties

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P A R T 8

Document control

Relevant documents and records to the EMS will be controlled

in accordance with the following procedure:

a. Approve documents for adequacy prior to issue;

b. Review and update as necessary and re-approve

documents;

c. Ensure that changes and the current revision status

of document are identified;

d. Ensure that relevant version of applicable

document are available at point of use;

e. Ensure that documents remain legible and readily

identifiable;

f. Ensure that documents of external origin

determined by the to be necessary for the planning

and operation of the EMS are identified and their

distribution controlled; and

g. Prevent the unintended use of obsolete documents

and apply suitable identification to them if they are

retained for any purpose.


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P A R T 9

Emergency preparedness and response

To ensure, where applicable, adequate emergency

preparedness and response is actioned and communicated to

all personnel and external parties.

9.1 Emergency Procedures – Identification

The following emergency procedures have been identified

within our current processes:

a. Emergency Plan for Fire (site specific)

b. Emergency Plan for Soil and Water courses

contamination (including liquids and solids

c. In Development:

d. Emergency Plans for Interaction with protected

species. (As required)

9.2 Training

All staff are made aware of the Emergency Plans. The existing

Health & Safety Policy manual references general processes to

be adopted in light of any emergencies. As per the above

emergency procedures

9.3 Testing

Testing of the existing emergency plans are actioned by

recording on form Environmental Emergency Test Record

(EMS-04). Which details check items along with actual findings.


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P A R T 1 0

Checking and corrective action

10.1 Monitoring and measurement

To establish processes to maintain regular monitoring (EMS-04)

and measurement of environmental impacts against our

objectives stated in the company Environmental Policy

Statement.

10.2 Non-conformance and corrective and preventative action

All records of non-conformances are controlled and maintained

by the HSE Manager and documented in the incident

management system.

When a non-conformance is raised either from an internal or

external audit, or identified, an action plan will be created with

an investigation into the root cause and prevented action, this

will be included in the Incident database.

Where an environmental incident has occurred theses need to

notify to the HSE manager (either by email, phone, incident

form, etc.) and investigated will be undertaken where required,

these are recorded on an 8D Form. Non Conformances are

discussed at Management Review to allow a review of

corrective/preventive action performed for effectiveness

10.3 Records

All records shall be stored on the company’s intranet and

maintained by the HSE Manager

10.4 EMS audit and review

LSBP Will conduct regular internal audits to ensure compliance

with the internal requirements of LSBP and the requirements

of 14001:2015 with which we are accredited against and

ensure that it is effectively maintained.

The frequency of the audits will be as identified in the CL0X 02 -

Environmental Audit Schedule, where the designated audit

templates will be used to carry out the audits. Evaluation of

legal requirements will be done periodically and also scheduled

in with the Environmental audit schedule.

Audits and review of the EMS will be in accordance with the

HSE Management Programme. It will be used for monitoring

and measurement of company environmental objectives.

Agendas will allow for regular monitoring and measurement of

environmental impacts, objectives and targets identified. For

operational control, refer to equipment calibration processes

contained within equipment manuals which are kept with the

responsible person or refer to the manufacture.

Reviews shall include:

a. results of internal audits and evaluations of

compliance with legal requirements and with other

requirements to which the organization subscribes,

b. communication(s) from external interested parties,

including complaints,

c. the environmental performance of the

organization,

d. the extent to which objectives and targets have

been met,

e. status of corrective and preventive actions,

f. follow-up actions from previous management

reviews,

g. changing circumstances, including developments in

legal and other requirements related to its

environmental aspects, and

h. recommendations for improvement.

Regular evaluation of compliance to relevant legislation, and

monitoring of any updates, when changes may be made in

April and October.


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P A R T 1 1

Operational Control

To identify and plan activities and operations associated with

identified significant environmental aspects in line with

company policy, objectives and targets.

The following areas are those under operational control and

are linked with environmental aspects, objectives and targets:

11.1. Operational Procedures

The following operational procedures have been identified and

are documented within Environmental Work Instructions

(EWI), covering the following main elements:

a. EWI 01 -Fuel storage

b. EWI 02 -Transport and vehicle maintenance

c. EWI 03 -Waste Management and Disposal

d. EWI 04 -Spillage Control

e. EWI 05 -Dust Control

f. EWI 06 -Energy Management

g. EWI 07 -Water Discharge

h. EWI 08 -Chemical Storage

i. EWI 09 -Noise

All the above operations are covered by specific Environmental

Work Instructions, with the addition of the following sections.

11.2. Method for preparation of COSHH Assessments

A qualified and experienced HSE team will be responsible for

carrying the necessary COSHH assessments. The HSE Manager

will be overseeing the process. The HSE manager, who is

qualified and experienced in Health and Safety issues, carries

out all preparation of COSHH assessments. Any material data

safety sheets (MSDS) sheets will be stored on the company

intranet, for any items that are not ‘off the shelf’ and available

in stores for the general public.

11.3. Waste Management

Where transfer of waste is applicable, waste transfer notes and

relative applicable documentation are retained on file, under

the duty of care regulations, including transfer point and final

disposal sites.

Where hazardous waste is applicable, suitable consignment

notes are retained.

11.4. Testing of Operational Procedures

The review and testing of operational procedures are actioned

by the HSE Manager


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P A R T 1 2

Waste Management

To fulfil the requirement of the “Duty of Care” Regulations set

out in the Environment Protection Act.

*See Environmental Work Instruction 03- Waste Management

When purchasing consumables consideration will be given to the

impacts caused during the disposal process

All waste generated by Lightsource will be disposed of

correctly – Lightsource currently holds a Upper Tier Waste Licence.

In no instance will fly tipping and burning waste be considered as methods of disposing of waste.

Where possible the generation of waste will be reduced giving

consideration to rethink, reduce and recycle.

Labelled skips/containers must be used for disposal of waste, which are emptied on a regular basis and waste transfer notes are

kept by the HSE Manager

When waste is to be disposed by a 3rd Party licensed waste carrier, the

carrier must provide a waste transfer note.


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P A R T 1 3

Chemical Storage

To ensure chemicals are stored in a safe and secure manner to

prevent any hazard or environmental impact

*See Environmental Work Instruction 08- Chemical Storage

All products shall be stored according to the material safety

data sheet

All chemicals shall be correctly labelled and

identifiable

An emergency point within the storage area will be established and contain a fire extinguisher, first aid equipment and spill kit.

All products shall be covered by a COSHH

assessment

Stock quantity and records to be maintained by the HSE

Manager


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P A R T 1 4

Control of Dust & Emissions

To control and minimise the amount of dust and emissions

produced from work activities with a view to prevent incidents

which may be detrimental to the environment.

*See Environmental Work Instruction 05 – Dust Control

*The use of plant or equipment that can cause a dusty site must be wetted prior to use in order to prevent dust

emissions.

To reduce harmful emissions from vehicles and plant, all plant and

vehicles must be regularly maintained and serviced and engines switched off

when not in use.

All reports shall be kept on file and managed by the HSE

Manager


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P A R T 1 5

Spillage Control

To ensure staff deal with spillages in a safe and effective way to

prevent or minimise its environmental impact.

*See Environmental Work Instruction 04- Spillage Control

It is the responsibility of all members of staff to report spillages to management

In instances where the safety of the public or staff is at risk, the

emergency services and management should be notified

All spillages must be reported and recorded on the appropriate

form. Doc Ref: HSMS Doc 15

Every company vehicle has been issued with a spill kit. It is the responsibility of the individual to report to management if the spill kit has been used or removed.

Staff will be trained regarding their responsibilities in complying with the companies Environmental Policy and procedures and Work Instructions.


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P A R T 1 6

Water Discharge

To ensure that discharges do not contaminate ground water.

*See Environmental Work Instruction 07- Water Discharge

Interceptors shall be routinely cleaned to prevent any possible

contamination

All silted water discharged from site workings shall be directed to

public drain/ sewage system

Any discharge that does not conform to the company s

procedures shall be reported, recorded and reviewed

In the event of an accidental discharge of a pollutant into controlled waters drain or pipe, the HSE manager must be notified

immediately and who will then contact the regulatory authority (Environment Agency or

sewerage provider)

The HSE Manager will then investigate the incident and

record the findings.


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P A R T 1 7

Energy Management

*See Work Instruction WI006- Energy Management

Machinery / plant shall be switched

off when not in use

Where possible, the shortest routes to site wil l be taken

Vehicles shall not be left running when parked

Vehicles and plant shall be maintained to ensure optimum

performance

Office lights shall be switched off when not in use

Electrical equipment will be switched off when not in use


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P A R T 1 8

Pollution Prevention

This procedure states how pollution prevention will be implemented by Lightsource BP. Potential pollutants of concern include silt,

cement, concrete, tarmac, fuel, and petrol.

Small quantities of diesel fuel, gas oil and petrol must be stored in containers clearly marked with their contents

The Site Manager should examine bunds on a regular basis. Defects to the bund wall or lining should be repaired promptly using the appropriate techniques to ensure the bund retains its

integrity.

All vehicles and plant items should be used in a way that avoids unnecessary noise, fume and spillage pollution. Vehicles engines

must not be left running unattended unless there is a safety requirement.

Care must be taken when refuelling plant and vehicles to avoid spillage of fuel and oils. When refuelling drip trays and funnels should be used. Any spillages must be cleared and disposed of using approved methods. All spillage must be reported via the

incident report spillage form (HSMS Doc 15)

Any purchasing that might cause pollution may be avoided. Reliable suppliers who meet the requirements of ISO 14 001

should be used.


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P A R T 1 9

Office Recycling

This procedure states how recycling will be implemented by

Lightsource BP from Office Recycling

Waste containers has been provided for office paper/ cardboard

Any unwanted paper / cardboard must be put into the container.

The containers is empty daily, it will be disposed of by a registered carrier for

recycling.


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P A R T 2 0

Site Recycling and end of life

• At the end of life, lightsource BP will try to establish

a way to recycle all our products or re-use material

where possible. Many products can be turned at

the end of life to be properly recycled in line with

the WEE regulations.

• For products made of plastic, lightsource BP will

consider if it can be made of material that is more

easily recycled at the end of life.

• Lightsource bp will try to limit any packaging

required for our new products or establish if the

size be reduced, or the material changed to

something that does not use a non-renewable

natural resource.

• For a delivery service. Lightsource BP will consider

its packing materials and how they impact the

environment and consider biodegradable material

made another material available.

• Lightsource BP will consider the impact of our

recycle partners in line will our environmental

aspects which we can influence as well as those we

can contr9ol. Such as choosing a metal recycling

company that is closer to our facility, so it will be

more environmentally friendly.

• Lightsource BP have also considered the impact of

our delivery partners by identifying how our

delivery companies may impact the environment

through our PQQ process via reviewed

environmental policies and procedures.

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P A R T 2 1

Control of environmental management programmes

All accidents and incidents within vehicles, whilst driving on

company business, must be reported by the individual to the

HSE Manager on the Vehicle Incident Form (HSMS Doc 16 or

iAuditor Form - Incident, Accident & Near-miss Report). (This

procedure does not affect the driver's requirement to report

the accident to the Police and relevant motor insurers).

Vehicle incidents are also investigated using our fleet

management system, which also monitors vehicle idling and

excessive driving that can increase CO2 emissions.

If you are unable to report it personally, the duty to report it

falls to your line manager.

If you are involved in an accident or near miss at any location,

other than a Lightsource BP office, then advise your line

manager as soon as possible, and the duty to report it falls to

your line manager.

Note - Remember to report the incident to the Principal

Contractor/Contractor at the site you are visiting.

If you are involved in an incident, or have witnessed one, you

need to let the company know immediately. We can then

accurately record all incidents and take the necessary actions

to increase the safety & Environmental issues around our sites.

Any incidents at Lightsource BP’s offices involving visitors must

be reported in the same manner.


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P A R T 2 2

Appendix A - Environmental Policy

The Environmental Policy of Lightsource bp is determined by

the QHSE committee and reviewed annually. The current

Policy is as follows:

a. It is the Policy of Lightsource bp to manage its

activities in such a way that reduces their

Environmental impact to a practical minimum.

b. The Company is committed to continual

improvement of its Environmental performance

including prevention of pollution at source

wherever and whenever possible and intends to

achieve this by setting clear Environmental

objectives and regularly monitoring progress

against them.

c. In order to regulate the performance of Lightsource

bp, the Company will operate an Environmental

Management System which meets the

requirements of BS EN ISO 14001:2015

Lightsource bp will:

• Ensure that this Policy is understood, implemented, and maintained at all levels in the Company

• Ensure that all its employees are aware of the potential Environmental Aspects of their activities and the

Environmental benefits of improved performance.

• Conserve and protect the Environment by operating in a socially responsible manner according to the highest

practicable standards of Environmental Management available and the application of strict Quality

Management disciplines.

• Comply with all existing regulatory legislation, consent and codes issued at European, National and Local

levels and adopt a pro-active stance in anticipating future regulatory requirements.

• Operate and maintain all plant and equipment to the highest practicable standards and improve working

practices as and when new technology becomes available.

• Encourage an Environmental philosophy towards all materials, components and packaging. Be receptive to

modifications to product design and working practices as appropriate and set measurable objectives and

targets for continual improvement as defined in the register of Aspects.

• Minimise waste throughout the Company through better utilisation of raw materials, energy and water,

increased use of renewable, re-useable or recyclable materials and the development of a strategy for

minimising waste at source and a commitment to pollution prevention.

• Provide appropriate Environmental training for all employees and actively promote and encourage the

pursuit of Environmental excellence not only within the Company itself but throughout its suppliers.

• Carry out regular Environmental audits of the Company’s Environmental system in accordance with the

requirements of BS EN ISO 14001:2015.

• Develop a proactive means of responding to accidents or emergencies and thereby avoiding or minimising

Environmental damage.

• Deal only with reputable registered waste carriers who have been registered by the relevant local authority

Signed: Date: March 2019

Nick Boyle, CEO

Environmental Procedure

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