Do You Understand Environmental Risk?
Most management systems only pay lip service to environmental risk assessment. The aspects register is only an assessment of impact, which leaves certificate holders and those responsible for environmental management with little steer as to the level of mitigation required.
While compliance obligations are widely understood and provide the 'licence to operate', surely the actual risk to any receiving environment needs to be better understood? Certainly more than a cursory line for 'waste' or 'spills' in a predominantly safety risk assessment.
In my experience, one of the most effective ways to manage this and to understand your organisations environmental liability, is when environmental risk is embedded within process safety management.
The big ticket considerations such as asset integrity, loss of containment and reliance on instrumented systems are largely the same, so we need to apply the same level of rigour and level of assessment.
Environmental assessment can be a very emotive subject, especially when its only impact based. The only way to establish meaningful and truly preventative controls is through detailed qualitative assessment based on real data.
The other challenge we have is that many environmental hazards or aspects, are planned rather than unplanned/emergency events as is always the case with safety.
Your environmental impact goes way beyond sustainability aspirations and failure to address this can, and will, have significant ramifications for your organisation.