EHQMS Procedure

Aspect Identification & Assessment

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Aspect Identification & Assessment

APPROVAL

The signatures below certify that this procedure has been reviewed and accepted and demonstrates that the
signatories are aware of all the requirements contained herein and are committed to ensuring their provision.

Name Signature Position Date

Prepared by

Reviewed by

Approved by

AMENDMENT RECORD

This procedure is reviewed to ensure its continuing relevance to the systems and process that it describes. A
record of contextual additions or omissions is given below:

Page No. Context Revision Date

COMPANY PROPRIETARY INFORMATION

The electronic version of this procedure is the latest revision. It is the responsibility of the individual to ensure
that any paper material is the current revision. The printed version of this manual is uncontrolled, except
when provided with a document reference number and revision in the field below:

Document Ref. Rev

Uncontrolled Copy  Controlled Copy Date

Table of Content

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s
1 ASPECT IDENTIFICATION & ASSESSMENT................................................................................................3

1.1 INTRODUCTION & PURPOSE.......................................................................................................................3

1.1.1 Process Turtle Map..........................................................................................................................................................3
1.1.2 References...........................................................................................................................................................................3
1.1.3 Terms & Definitions........................................................................................................................................................3
1.2 APPLICATION & SCOPE..............................................................................................................................4
1.3 ENVIRONMENTAL ASPECTS.........................................................................................................................4
1.3.1 Identifying Aspects..........................................................................................................................................................4
1.3.2 Impact Assessment..........................................................................................................................................................5
1.3.3 Significance Rating.......................................................................................................................................................... 6
1.3.4 Mitigating Impacts.......................................................................................................................................................... 7
1.3.5 Review................................................................................................................................................................................... 7
1.3.6 Reporting............................................................................................................................................................................. 7
1.3.7 Monitoring.......................................................................................................................................................................... 8
1.4 TRAINING..................................................................................................................................................8
1.5 COMMUNICATION & PARTICIPATION..........................................................................................................8
1.6 FORMS & RECORDS...................................................................................................................................8
1.7 ENVIRONMENTAL ASPECTS PROCESS MAP................................................................................................10

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1 Aspect Identification & Assessment

1.1 Introduction & Purpose
The purpose of this procedure is to outline your organization’s ongoing and proactive methodology for
identifying environmental aspects relating to our operations and product life cycle, and for the subsequent
determination of the significance of related impacts that may have actual or potential significant impacts on
the environment.

1.1.1 Process Turtle Map

With what With who

 Interested parties  Environmental Coordinators

 Operational activities  QEHS Manager
 Top management

Input Activity Output

 Customer requirements Identification of aspects and  Process improvement

 Compliance obligations determination of the  EHQMS improvement
 Areas of concern significance of aspects that  Conforming processes
 Organizational context have actual or potential  Impact controls
 Needs and expectations of significant impacts on the  Enhanced desirable effects
interested parties environment  Integrated actions
 Risk and opportunities  Evaluation of aspects
 Significant impacts  New practices

How With what measure

 Aspect identification register  Levels of compliance

 Scoring matrix  Objectives met
 SWOT/PESTLE analysis  Risk analysis
 This procedure  Risk mitigation scores

1.1.2 References
Standard Title ISO Clauses Manual Sections
BS EN ISO 9001:2015 Quality management systems N/a N/a
BS EN ISO 14001:2015 Environmental management systems 6.1.2 6.1.2
BS EN ISO 45001:2018 OH&S management systems N/a N/a

1.1.3 Terms & Definitions

Term Definition
Documented information Information (3.8.2) required to be controlled and maintained
Environmental aspect An element of our operations and activities that interact with the environment
Environmental impact The degree to which an aspect may affect our operations and the environment
Environmental condition A characteristic of the environment, determined at a certain point in time

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1.2 Application & Scope

This procedure describes the steps that your organization takes to ensure so far as is reasonably practicable
that environmental impacts and health and safety hazards are identified, assessed and controls implemented
to eliminate or mitigate the risk as far as is reasonably practicable. Consideration of past activities, current
activities and new customer requirements are taken into account.

The QEHS Manager and Process Owners actively identify aspects and mitigate impacts associated with their
activities with the goal of achieving sustained benefit within that activity. All managers and Process Owners
are responsible for:

1. Identifying associated environmental impacts of products, activities and services;

2. Considering the lifecycle perspective with respect to:
a. Environmental impacts within the supply chain;
b. Environmental impacts associated with product use;
c. Environmental impacts of end-of-life treatment and/or disposal;
d. Consideration of the lifecycle perspective of procured goods and services.
3. Maintaining documented information regarding environmental aspects and significant impacts;
4. Prioritizing issues that could affect intended outcomes:
a. Enhancement of environmental performance;
b. Fulfilment of compliance obligations;
c. Achievement of environmental objectives;
d. Plus any additional issues that we set for ourselves.
1.3 Environmental Aspects
All business activities are assessed to ensure that any changes to processes and operations do not result in
adverse environmental impacts. On occasions where your organization does not have a degree of control or
influence over the environmental aspect, details are recorded in the Aspect Identification Register for
management review.

1.3.1 Identifying Aspects

Environmental aspects are identified by taking into account all business activities to ensure that all resulting
impacts that result from our processes, activities and operations are identified and assessed. Where
reasonable, both direct and indirect significant impacts are considered for mitigation and are recorded in the
Aspect Identification Register.

Using the Aspect Identification Register the QEHS Manager and relevant Process Owners identify all raw
materials, chemicals and utilities that are used as process inputs and all outputs such as products, services
and by-products. Outputs are considered as products, the waste produced, levels of recycled materials,
quantities of water discharge and air emissions for each process or activity.

Following the identification of environmental aspects, their impacts on the environment are calculated and a
significance rating is assigned. All of the organization’s activities are considered when identifying actual and
potential environmental aspects and impacts whilst taking account of:

1. Past environmental incidents;

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2. Air emissions to atmosphere;

3. Water usage and discharges to surface water groundwater and sewers;
4. Land contamination caused by spillages, etc.;
5. The production, re-use, recycling and disposal of controlled and special wastes;
6. The storage and management of materials;
7. Activities upon local ecology of operations, sites and premises;
8. Environmental noise;
9. Energy use and management;
10. Use of transport and vehicles;
11. Legal issues and other requirements;
12. Raw materials and packaging;
13. Office activities;
14. Landscaping and infrastructure;
15. Other relevant issues such as odors, particulates, lighting & pests.
When identifying inputs and outputs, the QEHS Manager considers all modes of operation since start-up,
shutdown, or emergency operations might introduce additional environmental aspects and impacts into our
processes.

1.3.2 Impact Assessment

Once the impacts have been identified they are prioritised in terms of their environmental impact to assist in
using them for setting objectives and targets and for identifying operational control procedures. Each aspect
identified is assigned a significance rating to indicate the relative importance of its related environmental
impact. The significance rating is used to define those impacts which are to be controlled through
environmental objectives and targets, or by the implementation of operational control procedures.

The assessment of the severity of an environmental impact drives management attention and supports
planning for mitigation. A qualitative risk assessment scheme consisting of qualitative probability and impact
scales is undertaken to ensure detailed understanding of the effects of each impact. The QEHS Manager will
engage with Process Owners to:

1. Identify the control measures already applied to each significant impact i.e. existing control
measures. These may be pro-active (reducing the probability) or reactive (reducing the impact);
2. Rank the probability of each impact occurring, after taking into account the actual effectiveness of
the existing control measures;
3. Enter the existing control measures and the associated current impact scores;
4. Undertake a risk assessment to provide more detailed understanding of the impact’s consequences;
5. Set objectives and targets for achieving impact mitigation.
Using the ‘significance determination’ section of the portion of the Aspect Identification Register the QEHS
Manager will evaluate each identified aspect to determine whether it is significant. The environmental
aspects will be considered to be significant if the aspect has an impact on the environment and meets the
impact significance scoring criteria for implementing mitigation, See table S1 below.

Forecast probability, cost and time data is assessed for each impact based on the causes and effects
described, taking into account the existing controls and active responses.

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1. All aspects which elicit concerns of stakeholders, interested parties and our organization are
regarded as significant, if necessary controls have not been implemented;
2. All aspects which are subject to environmental legislation are regarded as significant, and therefore
noted as having a high impact/risk, if there is a breach or potential breach of legislation;
3. All aspects where insufficient information is available to make a reasoned judgement are regarded as
significant until further information is available.
1.3.3 Significance Rating
An inherent impact significance rating represents the level of risk in the absence of a controlled environment
and is arrived at after entering the scores into the Aspect Identification Register. For each impact that is
identified, an evaluation is undertaken to assign a specific score in order to determine the correct level of
action.

Impact significance (Table S1) is calculated by adding the impact, legal and quantity criteria, multiplied by the
frequency. The resulting significance score (Table S2) is then used to prioritise the appropriate level of action.
Any significance criteria scoring 4 are automatically highlighted red and should themselves be considered
significant and subject to treatment.

Impact Significance (S1)

Significance of Significance Criteria
Impact (S) 1 2 3 4
A. Impact Very low Low Average Great
B. Legal
No regulations Guidelines & ACoPs Standards Laws & Regulations
requirement
C. Quantity Low Average Large Significant
D. Frequency Almost never Rare Often Always

Significance Score (S2)

Impact Exposure
Score Exposure
Management Control Action (MCA) Timeframe for MCA
Activities in this category present minor levels of impact and/or
risk. The application of mitigation strategies to reduce the impact
1 to 7 Low is advised. Consider ways of modifying the process or 1 year +
implementing controls to reduce the impacts and risks to as low as
reasonably practicable (ALARP).
Activities in this category present serious and unacceptable levels
of impact and/or risk. Consider ways of modifying the process and
8 to
Medium implementing controls to reduce the impacts and risks to as low as Within 6 months
13
reasonably practicable (ALARP). Additional control measures and
monitoring may be required.
Activities in this category present high levels of impact or risk and
should not be allowed to proceed without very careful planning.
14 to
High Consider consulting specialists. The company should evaluate Within 3 months
19
whether the activity is actually necessary in the first place or
whether alternative processes are available.
Activities in this category present extreme levels of impact and/or
20 to
Very High risk, such as loss of life or breach of legislation and must not be Immediate
24
undertaken.

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1.3.4 Mitigating Impacts

The objective of this step is to identify how the identified impacts will be mitigated. Impact treatment
involves identifying the options for treating each impact, evaluating those options, assigning accountability
(for Very High, High and Moderate impacts) and taking relevant action. The following options are available
for treating impacts and may be applied individually or in combination.

Risk Option Risk Treatment

Controls are deemed appropriate. These must be monitored and contingency plans developed
Accept the Impact
where appropriate.
Shifting responsibility for an impact to another party by contract or insurance. Can be
Transfer the Impact
transferred as a whole or shared.
Reduce the likelihood by improving management controls and procedures. Reduce the
Mitigate the Impact
consequences by putting in place strategies to minimise adverse impacts.
Not to proceed with the activity or choosing an alternative approach to achieve the same
Avoid the Impact
outcome.

For each impact, the Process Owner must establish an appropriate level of treatment. Control measures in
addition to those already existing may be needed to achieve this level of mitigation. The QEHS Manager will
engage with Process Owners to develop a satisfactory response to each impact in order to:

1. Identify a response strategy to treat, terminate, tolerate or transfer the impact;

2. Identify response actions to improve control measures as required. These will be SMART;
3. Identify a response action owner for each action and confirm with them that they accept
accountability for implementing the action within the time allowed.
The Process Owner is responsible for the development of the response. When a response action is
completed, the impact should be reassessed (i.e. repeat Step 1.3.2) to reflect any newly introduced control
measures.

1.3.5 Review
Regular reviews are essential to ensure that aspects and impacts are being appropriately managed, and that
the relevant data about those aspects and impacts remains accurate and reliable. The QEHS Manager will on
a regular basis:

1. Engage with Process Owners to ensure that the current and forecast impacts severities reflect the
actual effectiveness of the existing controls and the anticipated effectiveness of the response plans,
and that response plans and existing controls are up-to-date)
2. Challenge the continued relevance of aspects and impacts and the adequacy of the control measures
and response actions;
3. Review and formally issue approval of the current Aspect Identification Register enabling it to be used
for reporting;
4. In the event that they will not approve (part of) the completed Aspect Identification Register, e.g. due
to the inadequacy of control measures and response actions, they will agree with the relevant risk
owner those additional response actions necessary, prior to approval.
1.3.6 Reporting
Regular reports are necessary to inform and provide assurance to Top management and other key
stakeholders, that impacts are being appropriately managed. Reporting must be based on current data

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captured in the Aspect Identification Register, which must be updated and reviewed in good time for the next
reporting cycle.

On occasion, it may be appropriate to escalate an aspect or impact to ensure it is assessed and/or managed
by the person or party best placed to do so (able and with appropriate authority). For example where a more
substantial or coordinated response is required than the current Process Owner can authorise or implement
will justify higher level assessment and/or management. The QEHS Manager will:

1. Escalate through established lines of management accountability all aspects and impacts that may
require mitigation. This may take place during formal reviews, or through other simple mechanisms
at management meetings;
2. Issue reports in accordance with requirements;
3. Provides key information such as statistical data on numbers of active impacts, unassessed aspects,
overdue actions, and others as appropriate.
1.3.7 Monitoring
Continuous systematic and formal monitoring of implementation of the environmental aspect and impact
process and outputs will take place against appropriate performance indicators to ensure process compliance
and effectiveness. Monitoring may take a variety of forms and range from self-assessment and internal audits
to detailed reviews by independent external experts.

1.4 Training
To ensure that adequate impact management competency levels are achieved and maintained, your
organization’s provides regular training courses in the impact management process and its application in our
organization.

1. Specific aspect management training sessions are held on an annual basis, aimed at providing an
overview of the management framework.
2. The training will be facilitated by the QEHS Manager. Additional ad-hoc training is provided as
required;
3. Instruments providing training on appropriate controls include job descriptions, inductions, policies,
procedures, terms of reference, charters, performance planning and review programs, contracts and
delegations.
1.5 Communication & Participation
Communication and consultation are important elements in each step of your organization’s environmental
aspect and impact management process. Effective communication is essential to ensure that those
responsible for implementing control, and those with a vested interest, understand the basis on which
decisions are made and why particular actions are required. Our communication approach recognises the
need to promote environmental aspect and impact management concepts across all management teams and
staff.

1.6 Forms & Records

All documentation and records generated by the environmental aspect and impact management framework
are retained and managed in accordance with the Documented Information Procedure.

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Title & Description

Aspect Identification Register
Legal & Compliance Register
Context & Interested Parties

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1.7 Environmental Aspects Process Map

Identify environmental Criteria for significance: Identify compliance

aspects using the 1. Impact on the environment obligations
register
2. Probability of occurrence
3. Legal/regulatory requirements

Significant Determine
Determine
consequences of
significance these requirements on
of impacts our environmental
aspects and impacts
Update the
environmental aspects
and impacts register
Not
Significant

Undertake standard Not compliant

operational control. Formulate Determine
Update register of objectives compliance
aspects and targets

Compliant

Determine new
objectives and targets.
Develop operational
control requirements

Implement and
Record within the
monitor impact
Legal & Compliance
mitigation. Report and
Register
review

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