ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL

Issue No: 1
Issue Date: May 2016

L J Fairburn & Son Ltd

ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL

EMS1

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 ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL
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Issue Date: May 2016

CONTENTS

Section 1. Scope of Manual

Section 2. Company Profile
Section 3. Management Organisation/Responsibilities
Section 4. Environmental Management System Structure
Section 5. Environmental Policy
Section 6. System Procedures and Documentation
Section 7. Operational Procedures and Documentation
Section 8. External Documentation

Appendix I Register of Environmental Management System Procedures and

Documentation.

Appendix II Environmental Operations Controlled within the EMS

Appendix III Register of Environmental Forms

Appendix IV Structure of Environmental Management System

Distribution;

Operations Director
Quality Manager / System co-ordinator
Mill Manager
Transport Manager
Weighbridge control
Production
Engineers
Office File

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 ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL
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1. INTRODUCTION

L J Fairburn & Son Ltd Environmental Management System (EMS) covers the manufacture of
compound animal feed. The objective of the system is to operate to the requirements of the
Environment Agency.

The system has been developed by L J Fairburn & Son Ltd.’s personnel who make up the
Environmental Management Team headed up by the Operations Director and assisted by A V
Consultants. The team developed the structure for the Company system. The implementation of the
system was then audited by A V Consultants.

2. SCOPE OF MANUAL

This Manual describes how L J Fairburn & Son Ltd.’s Environmental Management System is controlled
and documented. However it is closely connected with both the Company’s Quality and Health &
Safety Systems. There are areas common to all three systems. For instance Management
Responsibility, Document Control and Training are detailed and controlled within the Quality System;
Contractors are controlled within the Health & Safety System Manual.

L J Fairburn & Son Ltd.’s Environmental Management System currently covers the feed mill only. It
does not extend to our sales/marketing functions or other non-manufacturing operations or to our
customers or suppliers.

The key to the Environmental Management System is the aim for Continuous Improvement as shown
by the Environmental Management System Circle below

ENVIRONMENTAL
POLICY

MANAGEMENT
REVIEW OBJECTIVES

PREVENTATIVE
ACTION

MEASURE
CORRECTIVE
ACTION

ANALYSE
DATA

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 ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL
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3. COMPANY PROFILE

L J Fairburn & Son Ltd

Introduction

L J Fairburn & Son Ltd is a major quality egg producer and as part of the strict quality control
approach manufactures all the compound feed required for the laying hens some 80,000 tonnes per
annum.

The Company has a Compound Feed Mill (Huttoft mill) on the site at Huttoft incorporating the latest
feed milling technology. The Mill is strategically located near the centre of farming operations.

L J Fairburn & Son Ltd.’s success stems largely from supply of premium eggs into the UK market. L J
Fairburn & Son Ltd.’s policy is to provide premium feeds to service the company farms, that set the
standard for the industry in terms of nutritional effectiveness.

Organisation

See Organisation Chart located held on the computer system.

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4. MANAGEMENT ORGANISATION/RESPONSIBILITIES

4.1 Objectives

The Company Management organisation ensures that the responsibilities and authorities are clearly
defined within an effective structure. Overall control of the Environmental Management System is
the responsibility of the Operations Director.

4.2 Reference

Organisation structure is held on the computer system; which outlines responsibilities.

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 ENVIRONMENTAL MANAGEMENT SYSTEM MANUAL
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5. ENVIRONMENTAL MANAGEMENT SYSTEM STRUCTURE

The Environmental Management System is structured as follows.

Policy

System Procedures EMS Manual

Registers/Objectives, Targets and Supporting Documents

Management plan. Records

Operational, Emergency and

Monitoring Procedures Procedures

Work Instructions

The system was developed using a top-down approach and compiled by the EMS Team:-

 Environmental Aspects and Impacts identified (Aspect is defined as ‘the cause of an

environmental effect’; Impact is defined as ‘the environmental effect itself’).
 Significant Aspects are identified using a scoring system of a combination of Likelihood and
Consequence.
 Company Environmental Policy produced.
 Company Environmental Objectives and Targets (CEOT) produced to reduce the impact of
significant Aspects (register held on the computer system).
 Site Objective and Targets derived from CEOT added to which are those arising from
improvement programmes from each site’s PPC permit.
 Operating Procedures developed (register held on the computer system) from which Site
Procedures and Work Instructions are produced.

The system is held together by a set of System Procedures which ensure a common approach to the
system and which also inter-relate to those within the Company’s Quality and Health & Safety
systems.
These System Procedures are held within the folder ‘Environmental Management System’.

An explanation for the various procedures is given below. Where reference is made to the computer
system the folders are set up as per Appendix IV.

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6. ENVIRONMENTAL POLICY

The signed, published policy is held within the Environmental Management System Manual folder
and is displayed on Company notice-boards and on the L J Fairburn & Son Ltd website.

MISSION STATEMENT

L J Fairburn & Son Ltd cares about the environment and is committed to protecting it. Our corporate
strategy is for all of our employees to do all that is practicable to achieve this.

OUR POLICY

 Design, operate and maintain all of our operations in an environmentally responsible manner,
complying with all relevant legislation.

 Continually improve environmental performance to prevent pollution, reduce waste and

minimise consumption of natural resources.

 Establish and maintain an Environmental Management System including procedures for

environmental monitoring and control of our operations.

 Produce environmental action plans with realistic and achievable targets.

 Provide adequate training and information to our staff, such that they able to comply with this
policy.

 The Company’s Environmental Policy and its implementation is the direct responsibility of the
Operations Director of L J Fairburn & Son Ltd and it will be reviewed on a regular basis to
ensure its continuing relevance.

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7. SYSTEM PROCEDURES AND DOCUMENTATION

Environmental Management System Procedures are the procedures developed to implement and
control the Environmental Management System. They cover the following categories:

 Environmental Aspects
 Legislation
 Objectives and Targets
 Training
 Communication
 Documentation and Record Handling
 Monitoring and Measurement
 Non-Conformance
 Audit
 Management Review

All Environmental Management System procedures are held on the computer system. A register of
these is detailed in Appendix 1.

8. OPERATIONAL PROCEDURES AND DOCUMENTATION

These are procedures needed to address the specific environmental aspects identified in the
environmental programme to ensure that activities on site are controlled and managed effectively
and to ensure consistency in operational matters.

The Environmental Policy, Aspects register and Register of Legislation alongside the requirements of
the Sites’ PPC Permits, were used to define the operational procedures required by L J Fairburn & Son
Ltd. These are described in Appendix II.

Company Procedures are held in the Operational Procedures folder within the Environmental
Management System on the computer system. The mill has its own procedures and work instructions
held in local files. Examples of these are held within the Generic Environmental Documents folder.

Template Forms – Templates for recording information arising from the various procedures are held in
a folder within the Generic Environmental Documents folder.

The Operational Procedures Register is detailed in Appendix III.

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9. EXTERNAL DOCUMENTATION

In addition to internal procedures a folder is also maintained on the computer system which contains
Guidelines and Codes of Practice obtained from External Sources.

The site has been issued with PPC Permit which is held on the computer system and in hard copy.
Permit conditions are included in the Environmental Management System.

APPENDIX I

Register of Environmental Management System Procedures and Documentation.

Procedure Name
EMS SP01 Environmental Aspects Evaluation
EMS SP02 Environmental Legislation
EMS SP03 Environmental Objectives, Targets and Management
Programs.
EMS SP04 Training
EMS SP05 Environmental Communication
EMS SP06 Documentation and Record Procedures
EMS SP07 Monitoring and Measurement
EMS SP08 Non Conformance
EMS SP09 Internal Environmental Audit
EMS SP10 Management Review

Document Name
Environmental Policy
CEAR Company Environmental Aspects Register
EROL Register of Legislation
CEOT Company Environmental Objectives and Targets
CETS Company Environmental Target Monitoring Summary
ETNA Environmental Training Needs Analysis Matrix

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APPENDIX II
Environmental Operations Controlled within the EMS.
Operation Level Relevant Procedure Notes
(See Appendix III)
Monitoring of PPC Operations
Requirements Director
Bulk Liquid delivery, Production EMS OP01 Local Work Instructions
Storage and Handling Manager based on this procedure
Drains and Interceptors Production EMS OP02 Local Work Instructions
Manager based on this procedure
Waste Management Quality & EMS OP03 Local Work Instructions
Production based on this procedure
Manager
Bag Filter Operation & Production EMS OP04 Local Work Instructions
Maintenance Manager based on this procedure
Plant & Equipment L J Fairburn & EMS OP05 Local Work Instructions
Change Son Ltd Board based on this procedure
Contractor Control and Production EMS OP06 Local Work Instructions
Training Manager based on this procedure and
Co. Health & Safety Manual
Purchasing – Operations EMS OP07
consideration of Director
environmental issues
Planned Preventative Production EMS OP08 Local Work Instructions
Maintenance Manager based on this procedure
Cooler Abatement Production EMS OP09 Local Work Instructions
Operation & Maintenance Manager based on this procedure
Potential Environmental Operations EMS OP10 Local Work Instructions
Nuisance Director based on this procedure
Ozone Depletors Quality EMS OP11 Local Work Instructions
Manager based on this procedure
Vehicle Movements on Transport & Work Transport Policy Co
Site Production Health & Safety Manual
Manager
Raw and ancillary Material Production Local Work Instructions
delivery, storage and Manager
handling
Emergency Procedure i.e. EMS Team EMS OP12 Contained within Site
- Spillage/Leakage of Emergency Plan and also
Oil/Chemicals. local Work Instructions and
- Failure of abatement Company Health & Safety
equipment. Manual
- Fire
Environmental Emissions Operations EMS OP13
Monitoring Director

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APPENDIX III

Register of National Environmental Forms

Form Name
EECF External Environmental Communication/Complaint Form
NCIR Non-conformance & Incident Report Form

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APPENDIX IV

Structure of Environmental System on Computer system

Quality Computer system Health &

System Safety

Environmental Management
System

System Generic Env Systems Operational External Objectives & Register of MCERTS
Procedures Environmental Manual Procedures Environmental Targets Legislation Monitoring
Waste Documents Documents

Aspects KPIs Forms Incident / Training EMS

Register Complaint Meeting PPC
Log Minutes Permit

Auditing Other files: Site Standard ES Review Agenda

Company Environmental target Monitoring Summary (CEOTS)

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DISTRIBUTION
S Hall Operations
Weighbridge
Director control
Quality Manager/ System
co-ordinator
R Clark Mill Manager
Transport Manager
Weighbridge
Control room
Office File
Workshop
Works Canteen

Authorised by: Operations Director Page 13 of 13

 Supporting information section 7

ENVIRONMENTAL MANAGEMENT SYSTEM

The proposed environmental management system for use by L J Fairburn & Son Ltd
Huttoft Mill installation will be brought into during the determination period of this Part
A Permit application. The EMS is bespoke and independently monitored.

Once a Part A operating permit is obtained it is proposed to monitor all environmental

issues using the system. Any additional or modified requirements or conditions will be
incorporated into the system. Currently it comprises the following supporting
information;

1. Contents and overview of the Environmental Manual

2. Monitoring forms

3. Work instructions

4. System procedures

5. Operational procedures

6. Aspects register

7. Audits

8. Training

9. External documents

10. Company environmental objectives

11. Emergency plan

12. Site closure plan

13. Site protection and monitoring program

14. Management structure

15. Environmental policy (mission statement)

 L J Fairburn & Son Ltd
ENVIRONMENTAL INSPECTION RECORD

RESPONSIBILITY: PRODUCTION MANAGER EMS F1 WEEK No. YEAR:

EQUIPMENT CHECKS Wk 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
Daily Checks Bag Check for leaks, burst
filters bags

Monday

Tuesday

Wednesday

Thursday

Friday

Pump isolation during

Tanks non production periods

Check for visible oil &

Drains grease

EQUIPMENT CHECKS 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52
Daily Checks Bag Check for leaks, burst
filters bags

Monday

Tuesday

Wednesday

Thursday

Friday

Pump isolation during

Tanks non production periods

Check for visible oil &

Drains grease
 Ian Mosey (Feed) Ltd

ENVIRONMENTAL INSPECTION RECORD

RESPONSIBILITY: MAINTENANCE ENGINEER EMS F2 WEEK No. YEAR:
EQUIPMENT CHECKS Wk 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
pipes, pumps, meters
Liquids handling &valves
EH levels & alarms.
Tanks Pipework sound

Bag filters replacement programme

Interceptors structurally sound
Interceptors empty and disposal
Bunds empty and disposal
Drains structurally sound
Hardstanding structurally sound
correct storage in
designated containers &
Waste area. No leaks
EQUIPMENT CHECKS 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52
pipes, pumps, meters
Liquids handling &valves
EH levels & alarms.
Tanks Pipework sound

Bag filters replacement programme

Interceptors structurally sound
Interceptors empty and disposal
Bunds empty and disposal
Drains structurally sound
Hardstanding structurally sound
correct storage in
designated containers &
Waste area. No leaks
 L J Fairburn & Son Ltd
Daily Odour and Noise Assessment Sheet Form 5
Taken at Mill Boundary

Week Commencing

Date Time Test Location Intensity Extent Sensitivity Offensiveness Comments Weather Conditions Noise Signed
(0-5) (0-5) (0-5) (0-4) (Internal or external sources) Wind speed/direction etc. (Internal or external sources)

West Site Boundary

Monday Northwest Site Boundary

Site Boundary at Gate

West Site Boundary

Tuesday Northwest Site Boundary

Site Boundary at Gate

West Site Boundary

Wednesday Northwest Site Boundary

Site Boundary at Gate

West Site Boundary

Thursday Northwest Site Boundary

Site Boundary at Gate

West Site Boundary

Friday Northwest Site Boundary

Site Boundary at Gate

West Site Boundary

Saturday Northwest Site Boundary

Site Boundary at Gate

Beyond site perimeter test - Taken from _____________________ Date __________Time ____________ Result ________________________________________

Additional Comments
 L J Fairburn & Son Ltd Environmental Management System
ENVIRONMENTAL EXTERNAL COMMUNICATION / COMPLAINT FORM (EECF)
Version No: 1 Issued Date: 30 May 2016 Issued By: Operations Director

Complaint / Comment Ref No.

Comment / Complaint received by: Date:

Passed to: Date:
Mill Manager informed? Date:

Type of Communication Complaint Request for Incident

Information
RD
DETAILS OF COMPLAINANT / 3 PARTY REQUESTING INFORMATION

Name:

Address:

Contact Telephone No.:

Contact e-mail:

ABOUT THE COMMUNICATION / COMPLAINT

How was the Customer Feedback Form

communication received
(tick appropriate box)? Written statement (letter / e-mail / fax etc)

Verbal feedback (phone call / face to face etc)

Brief description of
comment / complaint

(Attach copy of written

communication if
applicable)

Does the complaint / communication impact on our PPC Permit Conditions? Yes No

If Yes - has the Environment Agency been informed? Yes No

Follow-up

or
Corrective Action Plan
(as applicable):

Signed Mill Manager: Date:

Signed Quality Manager: Date:

VERIFICATION OF CLOSE-OUT / CORRECTIVE ACTION

Closed Out Verification Comments:

of Corrective Action

Signed: Completion Date:

Note: For all Complaints a copy must be sent to the Operations Director

Page 1 of 1
 L J Fairburn & Son Ltd Environmental Management System
NON-CONFORMANCE AND INCIDENT REPORTING FORM (NCIR)
Version No: 1 Issue Date: 30 May 2016 Issued By: Operations Director

Report Number:
Date and Time
of Non-conformance/Incident:

Area where Non-conformance/Incident

occurred:
Is Incident reportable under Site PPC Permit Schedule 5? Yes* / No

Description/Nature of Non-conformance/Incident:

Effects:

Immediate (Corrective) action taken:

Preventative Action proposed/taken (where appropriate):

Signed: Name: Date:

Copy To: Operations Director Ref EMS Procedures: SP05 and SP08

Page 1 of 1
L J Fairburn & Son Ltd Environmental Management System SEKPI

Site Key Environmental Performance Indicators :

Site
Units Target Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec YTD
Manufacture Tonnes 0.0
Electricity KWH 0.0
Primary Energy KWH/tonne #DIV/0!
Waste - General Tonnes 200301 0.0
Waste - Special Tonnes 200132 0.0
Waste - Vegetable Oil Tonnes 020304 0.0
Waste - Oil & Lubricants Tonnes 130208 0.0
Waste - Metal Tonnes 200140 0.0
Waste - Light Bulbs Kgs 200121 0.0
Reworks Generation % of NSM Max 2% #DIV/0!
Water Usage - Mixers Tonnes 0.0
Water Usage - Domestic Tonnes 0.0
Water - TOTAL Tonnes 0.0
Environmental Complaints Number 0.0
Environmental Accidents Number 0.0
Water Discharge Samples Number 1/Quarter 0.0
EMS Meetings Number 3/Annum 0.0

SEKPI V1
 WORK INSTRUCTION W.I. EMS 1

FATS DELIVERIES

Liquid RM spillages are a potential environmental pollutant. Care should

be taken to minimise this risk and as such the following instructions are
to be observed.

All deliveries are to be supervised by the Production Operative.

The Production Operative should check weighbridge documentation

and:-

 Assess that there is space in the tank to accept the load by

checking contents gauge
 Ensure that the driver has his own spill kit or knows the location of
ours
 Check that the drip tray under the fill point is empty
 Instruct the driver to report any spillage immediately.
 Instruct driver to sample the load via bleed valve
 On completion any leaks/drips collected in tray or bucket must be
disposed of as General Waste
 Ensure that signed delivery documentation is returned to the
weighbridge
 In the event of a spillage the implement:-

Emergency Spill Procedure WI EMS 3

PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 30.05.2016

Copies to: Mill Manager & WI File

 WORK INSTRUCTION W.I. EMS 2

RED DIESEL DELIVERIES

Diesel spillages are a potential environmental pollutant. Care should be
taken to minimise this risk and as such the following instructions are to
be observed.

All deliveries are to be supervised by a member of staff

The person supervising the delivery should check weighbridge
documentation and:-

 Assess that there is space in the tank to accept the load

 Ensure that the driver has his own spill kit or knows the location of
ours
 Check that the drip tray under the fill point is empty
 Check discharge pipe is correctly directed and give authority to
discharge.
 Make sure that the driver can see the tank contents whilst filling
 Inform the driver that he must stop discharging immediately,
should he discover a leak from his tanker or associated pumping
equipment.
 In the event of a spillage the implement -
Emergency Spill Procedure WI EMS 3
 On completion check tanker meter to ascertain delivered quantity.
 Any leaks/drips collected in tray or bucket must be disposed of as
Hazardous Waste
 Ensure that signed delivery documentation is returned to the
weighbridge

PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 31.05.2016

Copies to: Mill Manager & WI File

 WORK INSTRUCTION W.I. EMS 3

EMERGENCY SPILL PROCEDURES

In the event of a liquid spillage the following action must be taken:-

 Close isolation valve / Stop pump / Cease delivery discharge

 Ensure that the appropriate PPE is used prior to tackling spill
 Use Emergency spill kits, pigs and matting, to contain spillage
and prevent further spread. Spill kits are located adjacent to the
liquid filling points and near the main intake point.
 Summon assistance if required and notify the Mill Manager
 If the spillage threatens the drainage system use contents of the
spill kit to cover the gully in question.
 The Mill Manager or nominated deputy should notify the EA and
Emergency Services if required.
 The Mill Manager or nominated deputy must complete a NCIR
Non Conformance & Incident Report Form.
 The Mill Manager or nominated deputy should arrange for the
clean up and removal, of all spilled liquid, with an approved
waste disposal contractor.
 All drains should be jet washed clean before removal of isolation
bung
 Ensure that all contaminated pigs and mats are assessed and
disposed of as Hazardous or General Waste
 Report use of spill kit pigs and mats to the Maintenance
Engineer who will replenish stocks.
PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 30.05.2016

Copies to: Mill Manager & WI File

 WORK INSTRUCTION W.I. EMS 4

BUND AND PIPEWORK INSPECTION & PUMPING OUT

PROCEDURE

The following checks should be carried out on Tanks, Bunds and Pipe-
work each month to ensure that they are not damaged or filled with
rain water or contaminants.

Bunds
 Inspect contents of bund.

 Any fats pumped from the bund into an IBC it must be carefully
inspected to ensure it is not contaminated.

 Uncontaminated fats collected in the IBC, should be returned to

the appropriate storage tank as soon as possible.

 If the liquids pumped from the bund is found to be contaminated,

inform the Production Manager or Quality Manager.

 Check the condition of the bund walls. Look for signs of cracking,
damage or seepage. Report any adverse findings to the Mill
Manager or Quality Manager.

Tanks and Pipe work

 Check fill lines, end caps, valves and flanges for any leaks
 Check pipework support brackets, lagging and insulation
 Check vent pipes are clear,
 Report any adverse findings to the Mill Manager or his deputy

These monthly inspections should be recorded on the Maintenance

Engineer Environmental Inspection Actions Record EMS F2 sheet 2

PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 30.05.2016

Copies to: Mill Manager & WI File

 WORK INSTRUCTION W.I. EMS 5

BULK RAW MATERIAL DELIVERIES

TIPPED AND BLOWN

Dry raw material spillages are a potential environmental pollutant. Care should be
taken to minimise this risk and as such the following instructions are to be
observed.

All deliveries are to be supervised by the Production Operative.

The Production Operative should follow the UFAS raw material intake procedure
namely:-

 Check weighbridge documentation

 Assess that there is space in the bin to accept the load, set up the routing.
 Inform the driver to report immediately if the pit fills or there is a spillage.
 In the event of a spillage, stop tipping/blowing, initiate recovery of all
material through dry brushing either into intake pits or bag up for
subsequent re-use or disposal. Do not attempt to wash down any spillage.
 Ensure that signed delivery documentation is returned to the weighbridge
 There is a risk of hydraulic fluid system failure with tipping vehicles. Should
this occur, spread waste meal over the oil to absorb it. Then bag up and
dispose of as Hazardous Waste.

PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 31.05.2016

Copies to: Mill Manager & WI File

 WORK INSTRUCTION W.I. EMS 6

LIQUID FILTER CLEANING

Filters used in liquid pumping and circulation systems require cleaning

from time to time.

These filters can contain environmentally harmful materials and care

must be taken to protect the environment from any possible
contamination as a result of the cleaning process.

 Do NOT clean filters in any sink.

 Transport the dirty filter in a bucket to the vehicle washing area

for steam cleaning ensuring all effluent goes to the interceptor.

 All cleaning rags and materials must be disposed of as Hazardous

waste as per WI EMS 10.

PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 31.05.2016

Copies to: Mill Manager & WI File

 WORK INSTRUCTION W.I. EMS 7

ON SITE REFUELING – Fork Lift Trucks

Red diesel spillages are a potential environmental pollutant. Care should

be taken to minimise this risk and as such the following instructions are
to be observed.

 Position the vehicle so as not to overstretch the flexible filling

hose.

 Drivers must be in attendance at all times whilst filling from the

Red diesel tank.

 Do not overfill the vehicle tank.

 In the event of a spillage then implement-

Emergency Spill Procedure WI EMS 3

 Spill kits are located near the red diesel tank.

 The valve on the pipe between the tank and the pump must be
locked shut whilst not in use.

PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 31.05.2016

Copies to: Mill Manager & WI File

 WORK INSTRUCTION W.I. EMS 8

WASTE DISPOSAL

There are several types of waste generated on site and care must be taken to
ensure waste is classified into the correct containers for disposal or recycling to
reduce the environmental impact. Waste storage receptacles are appropriately
marked by category.

Weekly checks of the waste storage receptacles are conducted by the Mill Manager
to ensure the area is tidy and no leakages are occurring.

The waste categories on this site are as follows:-

 Hazardous Waste – this must be collected in purpose provided containers for

recycling and includes:-

o Premixes
o Oily rags and soiled spill kits or absorbent granules used for oil and
lubricants
o Any part filled tins of paint for disposal
o Waste Oil and Lubricants – collected for recycling

 Paper & Cardboard – collected for recycling

 Plastic Sacks and other plastic materials – collected for recycling
 Scrap Metal – collected for recycling
 Wood (used pallets) – collected for recycling
 Production Waste – collected for recycling
 General Waste – all other waste disposed to landfill
Waste Transfer Notes must be completed and retained for 4 years for all waste
movements off site.
PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 31.05.2016

Copies to: Mill Manager & WI Files

 WORK INSTRUCTION W.I. EMS 10

NUISANCES

The site has potential to produce environmental nuisances; odour, dust and noise
which can affect people and their property outside the site boundary.

 Any nuisance complaints received from other parties must be reported

immediately to the Mill Manager or deputy who will record details of the
Complaint on the External Environmental Complaint Form (EECF) held on
the computer system

 Abnormal odours, noise and dust emissions must be reported to line

managers/supervisors immediately who must record the problem in the
Environmental Log.

 An investigation must take place to identify any problems and carry out
corrective actions to eliminate the cause of the nuisance.

 Inform the Mill Manager of the nuisance as soon as practical.

PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 31.05.2016

Copies to: Mill Manager & WI File.

 WORK INSTRUCTION W.I. EMS 11

ROADWAY & HARDSTANDING INSPECTION PROCEDURE

All concrete and tarmac roadways and storage areas are to be checked annually to
ensure that they are impervious to liquids and not damaged.

 The check should identify any areas which are cracked or sunk and which will
result in liquids including rainwater permeating into ground.

 This includes ensuring that sealed construction joints on concrete areas are
sound.

 The location of the damage requiring repair action should be noted on a copy
of the site plan (see work transport site plan) in order to assist if others have
to carry out the follow up measures.

 These annual inspections should also be recorded on the Maintenance

Supervisor Environmental Inspection Actions Record EMS F2 sheet 2

 In the event that areas are found to be porous, a repair schedule will be
implemented.

PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 31.05.2016

Copies to: Mill Manager & WI File

 WORK INSTRUCTION WI EMS 12

BULK VEHICLE LOADING

The Driver should check weighbridge documentation and –

 Assess that there is space in the vehicle compartment to accept the load and
ensure that the discharge spout to set to centre of compartment to be filled

 The driver should monitor the filling operation to prevent spillage.

 Vehicle compartments should not be overfilled. Product should be “levelled

off” before attempting to replace Roll Over Sheet.

 Vehicles must be sheeted before leaving the loading bay

 Clearance of vehicle bodies / blower/seal must be into the designated blow

out bin, which must be checked empty before use and must be emptied after
use, including the cyclone, to the appropriate Rework Intake.

 In the event of a spillage, stop loading. Initiate recovery of all material

immediately, through vacuuming or dry brushing, either into appropriate
Rework skip or Intake. Wet or contaminated material should be disposed of
in General waste.

 Ensure that signed delivery documentation is returned to the weighbridge

PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 31.05.2016

Copies to: Mill Manager & WI File

 WORK INSTRUCTION W.I. EMS 13

DAILY ODOUR & NOISE CHECKS

Unpleasant odours are a nuisance to neighbours therefore it is necessary

that these are monitored daily. Care should be taken to minimise this
risk and as such the following instructions are to be observed.

 The person undertaking this procedure should walk to the three

monitoring points as described on form 5
 Assess the level of odour and noise at each of the three
 Record observations in the appropriate place
 Report any abnormal readings to the Mill Manager who will
investigate the cause
 Occasionally about once a week a member of the office staff
should conduct these readings (office staff are more likely to be
sensitive to feed mill odours and therefore be more
representative of the community)

PLEASE DESTROY PREVIOUS COPIES

Signed: Rob Clark Date: 31.05.2016

Copies to: Mill Manager & WI File

L J Fairburn & Son Ltd Environmental Management System

EMS SP01: Environmental Aspects Evaluation

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

INTRODUCTION
This procedure describes how L J Fairburn & Son Ltd environmental aspects are defined and evaluated for
significance/priority.

DEFINITIONS

Environmental Aspect
Element of an organisation's activities or products or services that can interact with the environment.

Environmental Impact
Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an
organisation's environmental aspects.

REFERENCES
Company Environmental Aspects Register - held on computer system.

RESPONSIBILITIES
The EMS Team is responsible for completing and updating the Environmental Aspects Register.

ASPECTS METHODOLOGY
The methodology used to determine the significance of L J Fairburn & Son Ltd environmental aspects is
set out in the Environmental Aspects Prioritisation Methodology sheet within the Aspects Register.

In defining the company’s environmental aspects, all Company activities, products and services will be considered
with regard to:

 The medium (air, land, water).

 Extent (local, regional, global).
 Duration.
 Frequency.
 Economic consequence.
 Legislative requirement, control or limitation.
 Receptors affected (e.g. people, flora, fauna).
The aspects to be considered include those that result in the following impacts:
 Impacts and uncontrolled emissions to atmosphere.
 Controlled and uncontrolled discharges to water (including surface water run-off to storm drains).
 Solid and other wastes generated on site or elsewhere.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP01: Environmental Aspects Evaluation

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

 Contamination of land on site or elsewhere.

 Use of natural resources (land, water, air, fuels, energy, raw materials).
 Noise, odour, dust and visual impact.
 Any specific effects on particular parts of the environment, including ecosystems.
 Indirect effects over which the Company may have limited control (i.e. suppliers, contractors, customers,
disposal sites, etc.).
Aspects are considered under all conditions, including:
 Normal activity – classed as an activity which is planned and occurs frequently which causes an environmental
impact e.g. raw material delivery.
 Abnormal activity – classed as an activity which is a planned one off or rare activity which causes an
environmental impact e.g. maintenance activities.
 Emergency situation – an unplanned event which could occur and lead to an adverse environmental impact,
and would require immediate action e.g. spillage of fuel oil.

 Past activities, current activities and planned activities – most activities entered in the register will be associated
with current Operations, but the register should also contain environmental impacts connected to planned future
activities and also past activities conducted on site which had the potential to cause contamination of the land.

Each of the following columns within the Aspects Register must be completed:
 Reference number
 Environmental aspect
 Environmental impact
 Operating level
 Consequence rating of the event
 Likelihood rating of the event

SIGNIFICANCE/PRIORITY OF ASPECTS
Aspects are assessed for significance by determining the priority rating as outlined in the Environmental Aspects
Prioritisation Methodology (See overleaf)

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EMS SP01: Environmental Aspects Evaluation

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

Consequence (Consequence rating of the event): This scores the environmental impact according to the
severity of its effect on the environment. It is possible to assign a 'negative' score to those impacts that are
beneficial to the environment. This is the sites' relative contribution to the overall environmental impact.
Score Consequence Description of Environmental Consequences
Positive environmental improvement, reduced environmental impact
-1 Positive Good for public relations
Proactive use of renewable/sustainable resources.
Noticeable impact on-site only;
No outside complaints;
1 Minor
Small-scale use of renewable resources; and
Negligible environmental damage
Small potential for local adverse publicity;
Minor breach of emission limits, but no environmental harm;
Noticeable but low impact off-site e.g. discernable odours; and
2 Noticeable Low impact on global issues (e.g. ozone depleting substances); and
Small-scale use of non-renewable resources (e.g. oil-based);
Moderate use of renewable resources (e.g. timber-based)
Loss up to £100 and only small likelihood of complaints.
Noticeable environmental impact limited to a small area;
Losses between £100 and £1,000 and complaints possible, litigation
possible;
Moderate use of non-renewable resources or large-scale use of other
3 Significant resources;
Large-scale use of renewable resources;
Severe and sustained nuisance, numerous complaints, e.g. strong
odours / noise disturbance; and
Minor breach of permitted emission limits.
Moderate environmental impact within and outside the facility but no
lasting environmental damage;
Potential for adverse publicity;
4 Severe Losses between £1,000-£10,000 and complaints and litigation possible;
Hazardous substances releases with 1/2 mile effect;
Major breach of emission limits
Large scale use of non-renewable resources.
Damage to land beyond the facility boundary, reversible;
Local media interest, careful public relations required;
5 Major
Losses between £10,000-£50,000 and litigation expected; and
Serious toxic effect on beneficial or protected species in the area.
Severe widespread environmental damage, irreversible;
National media interest and adverse publicity;
6 Catastrophic
Loss of over £50,000 and litigation certain; and
Possible Site Shutdown.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP01: Environmental Aspects Evaluation

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

Likelihood (Assessment of frequency of reoccurrence), this is based on PPC H1 guidance

Score Likelihood (L) Description
1 Extremely Unlikely Occurs less than once in a million years
2 Very Unlikely Occurs between once per million and once every 10,000 years
3 Unlikely Occurs between once per 10,000 years and once every 100 years
4 Somewhat Unlikely Occurs between once per 100 years and once every 10 years
5 Fairly Probable Occurs between once per 10 years and once every year
6 Probable Occurs at least once per year
7 Frequent Occurs at least once a month
8 Very Frequent Occurs at least once a week
9 Almost Certain Occurs at least once a day

Calculation of Priority Score

The overall priority score is calculated by multiplying the consequence score with the likelihood score, this priority
score is then assigned a colour coding based on the following matrix which denotes the significance.
Likelihood Consequence
-1 1 2 3 4 5 6
Positive Minor Noticeable Significant Severe Major Catastrophic
1 - Extremely unlikely -1 1 2 3 4 5 6
2 - Very unlikely -2 2 4 6 8 10 12
3 - Unlikely -3 3 6 9 12 15 18
4 - Somewhat unlikely -4 4 8 12 16 20 24
5 - Fairly probable -5 5 10 15 20 25 30
6 - Probable -6 6 12 18 24 30 36
7 - Frequent -7 7 14 21 28 35 42
8 - Very frequent -8 8 16 24 32 40 48
9 - Almost certain -9 9 18 27 36 45 54

Positive environmental impact

Low environmental impact
Potential for moderate environmental impact
Potential for high environmental impact

ASPECTS REGISTER
The Aspects Register includes a description of all impacts that L J Fairburn & Son Ltd activities, products and
services may have on the environment. It also includes a note of the significance, based on the colour coding
system, of each aspect, taking into account the legislative or regulatory situation.
The Register includes a cross-reference to relevant legislation and other requirements, associated objectives and
targets and also operational control procedures for significant aspects.
The Register will be reviewed annually by the EMS Team. Once the review is completed the date of revision
and revision number will be updated on the Register, the previous version will be retained for record purposes
and the updated version will be incorporated into the EMS.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP01: Environmental Aspects Evaluation

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

The environmental impacts of any changes (actual or proposed) in our activities or areas of Operations will be
considered by the EMS Team and added to the Register if not already included, or removed if no longer
relevant.

Similarly, any changes in legislation, regulations or codes of practice (which might affect the significance of any
aspect) will also be considered. If there are any such changes to the Aspects Register, then the Operations Director
will bring them to the attention of the EMS Team at the next management review meeting.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP02: Environmental Legislation Register

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

INTRODUCTION

This procedure describes the method by which L J Fairburn & Son Ltd develops and maintains its Environmental
Register of Legislation (EROL). The purpose of the register is to identify environmental legislation and other
requirements applicable to the environmental aspects and associated impacts of L J Fairburn & Son Ltd activities,
products and services.

All procedures, documentation etc. referred to within this procedure are held on the computer system.

REFERENCES
Environmental Register of Legislation (EROL)

EMS SP09 Internal Environmental Procedure

RESPONSIBILITIES
The EMS Team is responsible for completing, updating and communicating the Environmental Register of
Legislation.

All staff are responsible for ensuring their activities are in compliance with legal and other requirements.

THE REGISTER
The Register includes a brief description of all environmental legislation which has a bearing on L J Fairburn & Son
Ltd activities and the ways in which these may have an effect on the environment. It includes a note of all Laws,
Acts, Regulations, Statutory Instruments, Approved Codes of Practice and Guidance Notes as may be issued by
the various governmental bodies in the UK. It also includes any non-regulatory environmental requirements such as
Trade Association Codes of Practice and any customer environmental requirements.

MANAGEMENT OF THE REGISTER

Review and Updating

The Register will be reviewed annually by the EMS team and revised where necessary.
The Operations Director is responsible for ensuring the review takes place, noting the review date on the review
page and recording whether any changes have been made.
Changes to the register will be required in the following circumstances:
 New environmental legislation or other non-regulatory requirement introduced;
 Changes to existing legislation or other non-regulatory environmental requirement;
 Changes to L J Fairburn & Son Ltd activities, products and services, resulting in changes to applicable
legislation or other environmental requirement.
Changes to environmental legislation shall be identified via the following means:
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L J Fairburn & Son Ltd Environmental Management System

EMS SP02: Environmental Legislation Register

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

 Legislative updates provided from Agricultural Industries Confederation (AIC).

 Croners

Changes to the Register will be reviewed by the Operations Director to identify the need to modify EMS
documentation (e.g. Environmental Aspects Register, objectives & targets, procedures, training materials etc) to
ensure the EMS reflects legal compliance requirements.

Communication and Compliance

The Operations Director is responsible for ensuring that changes in legislation are communicated as appropriate to
staff to ensure implementation and legal compliance.
All staff are responsible for ensuring that their activities are in complete compliance with legal and other
requirements, including the requirements of our Integrated Pollution Prevention and Control (IPPC) permit. Staff
should take personal responsibility for ensuring that they are aware of and refer to the current version of any
relevant legislation.

Monitoring of Legal Compliance

Evaluation of compliance with relevant legislation, regulations and other requirements is achieved via the internal
environmental audit process. This evaluation is recorded via the Internal Environmental Audit Report. See EMS
SP09

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L J Fairburn & Son Ltd Environmental Management System

EMS SP03: Environmental Objectives, Targets and Management

Programme
Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

INTRODUCTION

This document describes the procedure for establishing objectives and targets for continual improvement of the
environmental performance of L J Fairburn & Son Ltd operations.

All procedures, documentation etc. referred to within this procedure are held in the Environmental Management
System Folder on the computer system.

DEFINITIONS
Environmental Objective
An overall environmental goal, consistent with the environmental policy, that an organisation sets itself to
achieve.
Environmental Target
A detailed performance requirement, applicable to the organisations, or parts thereof, that arises from the
environmental objectives and that needs to be set and met in order to achieve those objectives.

REFERENCES

Company Environmental Aspects Register (CEAR)

Company Environmental Objectives and Targets Sheet (CEOT
Company Environmental Target Monitoring Summary (CETS)
Site Environmental Objectives and Targets Monitoring Sheet (SOTM) – held by Mill Manager

RESPONSIBILITIES
EMS Team: responsible for establishing Company objectives and targets, monitoring progress and determining
the schedule of the Management Programme.

EMS Team: responsible for establishing site objectives and targets.

PROCEDURE
Setting the Company Objectives
In identifying objectives, the EMS Team will consider:
 Legislative requirements as indicated in the L J Fairburn & Son Ltd Environmental Register of Legislation
(EROL).
 The views of any interested parties.
 The corporate goals of the company.
 The need to minimise environmental risk and liability.
 Evolution of the Environmental Policy.
 Significant/priority aspects that occur across all areas of the business.
 Results of internal and external audits.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP03: Environmental Objectives, Targets and Management

Programme
Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

Setting the Targets

For each objective at least one target will be set. A Company Environmental O&T Sheet (CEOT) will be created
which includes:
 The environmental aspect each objective relates to;
 The target reference number;
 Name of the objective/target ‘owner’;
 The date by which the target has to be achieved;
 The estimated resource requirements; and
 A list of the actions required in order to meet it.
The objective/target owner will liaise with the Operations Director who will regularly update the Company
Environmental Monitoring Summary (CETS) to record progress.
Site Objectives and Targets
The mill will maintain a Site Objectives and Targets Monitoring Sheet (SOTM) which will identify:
 Those targets cascading from the Company Objectives and Target Sheet (CEOT)
 Any additional Improvement Targets as stipulated in the PPC permit
Monitoring and Verification of Progress
Evidence will be collected to demonstrate achievement of the target, referenced to the appropriate target and filed.
When the action to be taken is complete, the ‘objective and target owner’ will update the relevant Sheet to indicate
that this is the case.
Environmental Objective and Target Monitoring
This will indicate which significant environmental aspect is being addressed by each target, and summarise target
deadlines and progress against them and the member of staff responsible.

Management Review
All objectives and targets are reviewed at the annual Company Management Review. The review will determine the
Environmental Objectives and Targets for the next 12 month period.
If timescales are not being met - or actions are not progressing - the EMS team will review the reasons and
reschedule the completion date, committing additional resources as necessary.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP04 Training

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

INTRODUCTION
This document describes the procedure for the identification of training needs and effective training of all persons
working on or behalf of L J Fairburn & Son Ltd whose work may create an actual or potential significant impact on
the environment.

All procedures, documentation etc. referred to within this procedure are held in the Environmental System
Folder on the computer system.

REFERENCES
Environmental Training Needs Analysis Matrix (ETNA)
General Environmental Awareness Powerpoint Presentation
Training Records – held locally

RESPONSIBILITIES
L J Fairburn & Son Ltd requires that all persons working on or behalf of the organisation, whose work may create
an actual or potential significant impact upon the environment, receive appropriate training. L J Fairburn & Son
Ltd shall ensure that personnel performing tasks which can cause an actual or potential significant
environmental impact are competent on the basis of appropriate education, training and/or experience. A
competency evaluation of all persons working for or on behalf of L J Fairburn & Son Ltd and therefore requiring
training will be highlighted through completing a training needs analysis.

PROCEDURE
The EMS Team has carried out a training needs analysis to identify training needs and completed a Company
Environmental Training Needs Analysis Matrix. This will be reviewed and updated on an annual basis as part of
the Management Review. Updates to the matrix may arise from incidents, environmental improvement
programmes, personnel changes and requirements for refresher training.

The Site EMS Team will review and update their local Training Needs Analysis Matrix on an annual basis.
Updates to the matrix may arise from updates to the Company Environmental Training Needs Analysis Matrix or
local incidents, environmental improvement programmes, personnel changes and/or requirements for refresher
training.

All personnel will receive general environmental awareness training using the General Environmental
Awareness Powerpoint presentation. The training package will communicate the following:

 The importance of conforming with the environmental policy and procedures and to the requirements of the
EMS.

 The significant environmental aspects of their work activities and the environmental benefits of improved
personal performance.

 Roles and responsibilities in achieving conformance with the environmental policy and procedures and with
the requirements of the EMS, including emergency preparedness and response requirements.

 Potential consequences of departure from specified operating procedures.

 An understanding of the regulatory requirements associated with each site’s IPPC permit and how they
affect their work and responsibilities.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP04 Training

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

It is the responsibility of the EMS Team to ensure all personnel receive the general environmental awareness
training.

Where the training needs analysis identifies further training is required in order for employees to be competent
in their roles in regards to the EMS, this will be undertaken. It is the responsibility of the Mill Manager to ensure
all training that is identified is carried out.

All training records of the environmental training are kept in the relevant training files.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP05 Environmental Communication

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

INTRODUCTION
This procedure describes how L J Fairburn & Son Ltd manages internal and external communication regarding
the EMS. The levels of communication include internal communication to various levels within L J Fairburn &
Son Ltd and communication to and from 3rd parties.
All procedures, documentation etc. referred to within this procedure are held in the Environmental Management
System Folder on the computer system.

REFERENCES
NCIR - Non-conformance and Incident Report Form
EECF - External Communication or Complaint Form
EMS SP08 - Non–conformance, Corrective and Preventive Action Procedure

RESPONSIBILITIES
rd
The Operations Director is responsible for internal communication within L J Fairburn & Son Ltd, and to 3
parties from the company. External communications on environmental issues received by the Operations
Director or by Mill Manager will be recorded.

PROCEDURE
Internal communication
Issues will be communicated by the Operations Director via e-mail.
Site issues will be communicated by the Mill Manager via:

 EMS awareness training via induction

 EMS Management Review reports
 Internal Environmental Audits
 Shift log books/Operational meetings
 Contractor Induction Programmes
 Office notice boards
Staff can also communicate queries/feedback on the Environmental Management System through the Mill
Manager or to the Site EMS team.
Communication of an environmental incident or non-conformity (including any deviation from a site’s PPC permit
– see section below) should be made following the Non–conformance, Corrective and Preventive Action
Procedure (EMS SP08) using the Non-Conformance and Incident Report Form NCIR.

External communication
L J Fairburn & Son Ltd has to communicate externally e.g. with regulatory bodies to comply with legal
requirements and to report environmental incidents on site. Communication is also received from external
sources; this may be a complaint or a general enquiry.
The following mechanisms are used to manage external communications regarding the EMS:

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L J Fairburn & Son Ltd Environmental Management System

EMS SP05 Environmental Communication

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

Communication from L J Fairburn & Son Ltd to 3rd parties

 The Environmental Policy and other information about the EMS is provided to customers and suppliers upon
request (this is the responsibility of the person engaging the contractor or supplier);
 The Environmental Policy is presented on the L J Fairburn & Son Ltd website and made available to interested
parties upon request.
 The Environmental Policy is displayed prominently in the office reception, and around the site.

 L J Fairburn & Son Ltd does not communicate its Significant Aspects externally.

Communication from 3rd parties to L J Fairburn & Son Ltd

 Any complaint registered by a member of the public, customer, supplier or other party will be handled by the
relevant manager using the External Environmental Communication Complaint Form (EECF).

 All such communications will be reviewed at the Site EMS Management Review meeting.

Communication in Respect of the PPC permit

Where notification of abnormal emissions to the Environmental Agency is required as per Section 5 of the Site
PPC permit, the notification must be made using Schedule 1 of the Site Permit.

All communications on environmental matters to & from Regulatory bodies must be kept on file.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP06 Documentation and Record Procedures

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

INTRODUCTION

This procedure describes the methods used to control the following documentation within the L J Fairburn & Son
Ltd Environmental System (EMS).
 Environmental Manual
 Environmental Procedures
 Environmental Forms
 Records

SYSTEM DOCUMENTATION CONTROL

System Documentation is controlled using the Document Control Procedures as detailed in the Company
Quality Manual held in the Quality Systems folder on the computer system.

RESPONSIBILITIES

The Operations Director in conjunction with the Quality Manager is responsible for placing the latest versions of
environmental documents on the computer system, and for recording amendments and identifying as “obsolete”
any of these superseded documents.

The Mill Manager is responsible for procedures and work instructions.

CONTROL OF RECORDS

Records include:
 All completed Forms
 Registers and Logs.
Records should be maintained in such a way that they are readily identifiable, retrievable and secure.

EMS Records

The table below shows specific records that have been identified as part of the EMS, and who is responsible for
their maintenance and disposal.

* Note – the retention time for records is as per the IPPC permits.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP06 Documentation and Record Procedures

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

Type of Record * Ref Responsible * Location Min retention

period
Environmental Aspects CEAR Operations Director Office 2 years
Register
Environmental Legislation EROL Operations Director Office 2 years
Register
Environmental Target CETS Operations Director Office 2 years
Monitoring Summary

Site Environmental KPIs * SEKPI Operations Director Office 2 years

Site Objective and Target SOTM Mill Manager Office 2 years
Monitoring Sheets
Training Records n/a Operations Director Office 4 years
Completed Complaint Forms EECF Operations Director Office 4 years
Completed Non-conformity & NCIR Operations Director Office 4 years
Incident Reports
Corrective Action Register Operations Director Office 4 years
Internal Audit Reports n/a Operations Director Office 2 years
EMS Meeting Minutes n/a Operations Director Office 2 years
EMS Management Review n/a Operations Director Office 2 years
Minutes
All Environmental Records n/a Mill Manager Site 4 years
except Waste records
Waste Records n/a Operations Director Office 4 years
Hazardous Waste Records n/a Operations Director Office 4 years

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L J Fairburn & Son Ltd Environmental Management System

EMS SP07 Monitoring and Measurement

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

INTRODUCTION

This procedure describes L J Fairburn & Son Ltd processes for monitoring and measurement for the activities,
products and services that can have a significant impact on the environment. All procedures, documentation etc.
referred to within this procedure are held in the Environmental Management System Folder.

REFERENCES
Environmental Aspects Register
Environmental Legislation Register Procedure (EMS SP02)
Environmental Objectives and Targets Procedure (EMS SP03)
PPC permit requirements – permit held on Site
Site Environmental KPI Sheet (SEKPI) – part of Site General KPI sheet held under Site KPIs.
Environmental KPI Sheet (EKPI)

RESPONSIBILITIES
The EMS Team is responsible for ensuring monitoring and measurement systems are in place.

Mill Manager has responsibility for specific monitoring and measuring systems on Site, and for updating the Site
KPI sheets.

PROCEDURE
L J Fairburn & Son Ltd will periodically evaluate its compliance with legal and other requirements which includes
IPPC permit conditions, checks against applicable legislation, checks against other requirements such as UFAS
requirements and compliance with environmental operational controls. Minor problems regarding compliance
shall be dealt with via the site EMS Team meetings, management and shift meetings

L J Fairburn & Son Ltd will periodically assess its progress in meeting its Environmental Objectives and Targets,
through the site EMS Team meetings and EMS Internal audits. The need to review and revise Environmental
Objectives and Targets shall be considered when changes occur to the Register of Environmental Aspects.

L J Fairburn & Son Ltd will periodically monitor environmental data in relation to the identified significant
environmental aspects. Environmental data identified to monitor the environmental performance is recorded via
the Site’s Environmental KPI sheet and includes:

 Primary Energy Consumption

 Waste (by Category)

 Rework Generation

 Complaint & Accident/Incident Reporting

 Water usage

Procedures for monitoring and collecting data on each of the issues are held on site. These procedures are
reviewed in line with monitoring and measurement requirements of the Site IPPC Permit.

The KPI sheets are updated monthly.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP07 Monitoring and Measurement

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

Annual reporting of KPIs is a Permit condition – refer to site Permit.

It is a condition of the Permit for some sites that other environmental measurements are undertaken on a
regular basis – refer to site Permit.

The KPI sheet (EKPI) is maintained by the Quality Manager, the data being pulled through from the Site KPI
sheets in order to monitor trends.

The performance information will be periodically assessed in the site EMS Team meeting.

Where monitoring equipment is used in relation to the collection of environmental performance information or
the control of environmental impacts, this equipment is maintained and calibrated in line with Site calibration
procedures. Details of environmental monitoring equipment to be calibrated are held in the Site Calibration
Register held by the Mill Manager.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP08 Non-conformance, Corrective and Preventative Action

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

INTRODUCTION
This procedure describes the steps that L J Fairburn & Son Ltd takes to identify and correct actual non-
conformities, as well as potential causes of non-conformity.

All procedures, documentation etc. referred to within this procedure are held on the Server unless stated
otherwise.

DEFINITIONS
Non-Conformity

A situation which does not comply with the requirements of one or more of the following:
 The Environmental Policy
 An EMS Procedure
 Relevant legislation (including the requirement of the Site PPC permit)

Incident
An event which does not conform to normal operational circumstances or conditions.

Complaint
Any expression of dissatisfaction by a customer, member of the public, or other third party whether justified or
not.

Corrective Action
Action taken in the short term to eliminate the cause of a non-conformity and prevent reoccurrence.

Preventative Action
Action taken in the medium to long term to eliminate the cause of a non-conformity and prevent reoccurrence.

REFERENCES
 Non-Conformance and Incident Report (NCIR)
 Environmental Communication (EMS SP05)
 Internal Audit Procedure (EMS SP09)
 Site Emergency Action Plan – held at each Site

RESPONSIBILITIES
All staff are responsible for reporting non-conformities and incidents whether they arise through internal audits,
internal or external communication or day to day activities.

The EMS team are responsible for reviewing the non-conformance information, implementing any changes to
the Environmental Management System and checking the corrective action has been completed.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP08 Non-conformance, Corrective and Preventative Action

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

PROCEDURE
Non-conformities and incidents may be identified and reported by any company employee, internal audit,
contractor, regulatory authority or member of the public.
The appropriate information will be entered on the Non-Conformance and Incident Report Form and submitted to
the Production Manager who will update and copy to the Managing Director.
Where notification of abnormal emissions to the Environment Agency is required as per Section 5 of the Site
PPC permit, the notification must be made by the Production Manager, or nominated deputy, using Schedule 1
of the Site Permit.
All incidences are reviewed at the EMS meetings and any changes required to the EMS system to prevent or limit
recurrence are recorded.
The EMS Team also reviews incidence reports at the Management Review Meetings to identify:
 Areas where incidents/non-conformities occur most frequently.
 Any changes to the Environmental Management System which may be required to prevent or limit
recurrence.

Preventative Action is based on the premise that the Environmental Management System is preventative in
nature, by causing us to:

 Carry out significant environmental aspects evaluation.

 Carry out an evaluation of compliance with legal and other requirements.
 Carry out internal environmental audits.
 Appropriately maintain and calibrate monitoring & measuring equipment.
 Ensure that staff are adequately trained.

These steps help to prevent problems from occurring. However, the pro-active identification of potential non-
conformities and implementation of preventative actions is part of the Management Review process.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP09 Environmental Audit

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

INTRODUCTION

This procedure describes the company’s processes for monitoring and evaluating internal compliance with the L
J Fairburn & Son Ltd Environmental Management System, and for identifying areas for potential improvements.

All procedures, documentation etc. referred to within this procedure are held in the Environmental Management
System Folder on the computer system.

REFERENCES
Environmental Audit Pack
Non-conformance and Incident Report Form - NCIR
Environmental Aspects Register - CEAR
Register of Legislation - EROL

RESPONSIBILITIES
The Quality Manager is responsible for planning the audit programme.

The EMS team are responsible for reviewing the audit reports and any non-conformances and making any
changes to the EMS as a result of these via the Management Review (EMS).

Environmental Auditors are responsible for conducting the internal audit and raising any non-conformances.

PROCEDURE
Scope

The audit programme will ensure that all areas of the EMS at the Mill are audited at least twice per year and is
based on the importance of an issue considering the significant aspects, incidents and non-conformities and
audit results.

An external auditor will be selected from the list of approved auditors.

Planning

When planning an audit, the auditor shall note the following as a minimum:

 Any relevant aspect listed on the Environmental Aspects Register so that the significance may be
reviewed.

 Compliance with relevant legal, regulatory or other requirements listed in the Register of Legislation.

 Those relevant procedures pertinent to the area/activity being audited are still appropriate and are being
followed.

 Progress towards appropriate objectives and targets as stated in the Environmental Management System
Programme.

 All incidents, non-conformities and corrective actions which have arisen since last internal audit (including
non-conformities raised at the last internal environmental audit).
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L J Fairburn & Son Ltd Environmental Management System

EMS SP09 Environmental Audit

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

Audit Process

The auditor will undertake the audit through interview, sampling and process area walkover, determining the
degree of compliance to the EMS, and noting any non-conformances. The auditor will use the audit checklist
held in the Auditors pack to aid the process.

Audit findings will be recorded on the Environmental Checklist and the Environmental Internal Audit Report
where additional comments are required. If non-conformances are identified, it is the responsibility of the
auditee to determine a corrective action plan and to ensure it is communicated and implemented appropriately
within an appropriate timescale.

Distribution of Reports *

The completed Internal Environmental Audit Report will be sent to the Operations Director and Quality Manager
as well as the auditee. The Quality Manager then files the report.

Review

The EMS Team will review and analyse audit findings and report within the Management Review.

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L J Fairburn & Son Ltd Environmental Management System

EMS SP10 Management Review

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

INTRODUCTION
This procedure describes L J Fairburn & Son Ltd processes for the Management Review of the Environmental
Management System.

RESPONSIBILITIES
The Operations Director is responsible for ensuring that the EMS is reviewed at planned intervals at least
annually to ensure its continuing suitability, adequacy and effectiveness. The Mill Manager is responsible for
ensuring that Site EMS meetings are held quarterly.

PROCEDURE
EMS Meetings are held quarterly – the agenda for these is held on the computer system.

Minutes of these meetings (including observations, conclusions and agreed actions) are maintained.

Minutes of the Site EMS Review Meetings are copied to the Operations Director.

Management Review inputs include:

 Audit results.
 Evaluations of compliance with legal requirements and other requirements to which the organisation
subscribes.
 Measurements of performance against EMS objectives.
 Status of preventive and corrective actions.
 Actions from previous management reviews.
 Incident / non-conformity reports and external communication / complaint reports.
 Environmental KPIs via Site Environmental KPI recording.
The review considers:
 The continuing suitability of the EMS in relation to changing conditions and information.
 The concerns of relevant interested parties.
 Whether any changes need to be made to the Environmental Policy.
 Whether any changes need to be made to the management system as a result of corrective actions.
 The relevance of Environmental Aspects as recorded in the Aspects Register.
 Legislation status and any new or impending legislation or regulatory requirements which may have a
bearing on Company activities.
 The extent to which objectives and targets are being met.
 The Environmental Programme for the period until the next Management Review.
 Review of the procedures.
 Whether or not the EMS is delivering the required improvement in environmental performance.
 Recommendations for improvement.

The EMS Team will make changes to the EMS or initiate actions it deems necessary and communicate changes
to the appropriate parties. This will ensure that the system continues to deliver continual environmental
improvement.

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L J Fairburn & Son Ltd Environmental Management System

EMS OP01: Bulk Liquid Storage and Delivery

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

INTRODUCTION
This procedure describes the method by which L J Fairburn & Son Ltd manages bulk liquid storage and delivery in
such a way as to prevent spillages and leaks. The main objective of this procedure is to ensure that no liquid is
released to surface water, groundwater or to land. Bulk liquids includes; Vegetable oils and Red diesel.

REFERENCES
This Procedure is implemented by Mill Procedures & Work Instructions.

RESPONSIBILITY
The Operations Director is responsible for this procedure and its communication to the Mill Manager. The Mill
Manager is responsible for its implementation on site.

HAZARDS
These liquids have a very high potential to pollute land or water. Even small quantities can pollute large volumes of
water and can be difficult and expensive to clear up. Oil can also contaminate land and could result in expensive
remediation/cleanup costs being incurred.

ACTIONS
These will be identified by Work Instructions held on site which will incorporate the following points.

Bulk Liquid Storage

1. All bulk liquid storage tanks must meet the requirements of the Control of Pollution (Oil Storage) (England)
Regulations 2001. Further details are contained in the Register of Legislation (Legislation Register) and
Pollution Prevention Guidelines 02 and 26 held on the computer system.

2. Tanks, bunds and pipework are to be checked monthly to ensure that they are not damaged in any way and
that they are not leaking. Refer also to the section in this procedure for waste oil tanks and for bund water
removal.

3. Liquid intake fill lines must be padlocked to prevent incorrect delivery.

Bulk Liquid delivery

1. All deliveries should be supervised wherever possible, in particular where a new contractor is making a
delivery or where an incident has occurred in the past.

2. The date and time for delivery should be booked when there will be a responsible person available to
supervise the delivery and contractors should be informed that they should ask for the relevant person
responsible when they arrive on site.

3. The delivery note provided by the delivery contractor must be checked to ensure it covers the correct
amount ordered.
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L J Fairburn & Son Ltd Environmental Management System

EMS OP01: Bulk Liquid Storage and Delivery

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

4. The delivery contractor will be taken to the correct fill point. Prior to filling, check that the tank(s) have
sufficient spare capacity for the delivery and record the amount already in the tank.

5. Prior to filling, check that the contents of the spill kit are present and that the kit is near to hand.
6. If the fill pipe is outside of the bund, then a drip tray must be placed under the fill point prior to coupling of
the fill pipe.

7. If the tanker driver is unable to see the fill gauge during filling, ensure that the fill gauge will be monitored on
their behalf.

8. Tanker hoses and associated couplings should be checked for leaks during delivery, if any leaks are
detected delivery must stop immediately.

9. In case of spillage all persons following this procedure must refer to the Site Emergency Plan and/or Spill
Procedure.

10. The fill gauge and the amount delivered should be as detailed on delivery note.

11. Lock the fill point.

12. Ensure delivery note is kept on file.

Disposal of waste oil

1. When pouring waste oil into the waste oil tank ensure that a funnel and drip tray are used to avoid causing any
spillage. A notice on the tank can help remind staff of this requirement.
2. The waste oil tank meets the same requirements as the oil storage tanks and should be checked at the same
time as the oil storage tanks are being checked. Refer to Pollution Prevention Guidelines 08 held on the
computer system.
3. The level of oil in the waste oil tank should be checked regularly and arrangements made for disposal as
appropriate.
4. Only suitably licensed waste disposal contractors are used to collect and dispose of waste oil. A copy of their
licence should be obtained and kept on file. Refer to Waste Management Procedure EMS OP3.
5. Collection should be supervised wherever possible so when collection is required the contractor must be
informed of informed that they should ask for the relevant person responsible when they arrive on site.

6. Before collection, check that the contents of the spill kit are present and that the kit is near to hand.
7. During collection use a drip tray if you think there is a possibility of spillage and cease pumping if any leaks
occur. In the event of a spillage follow the Site Emergency Plan and/or Spill Procedure
8. Ensure a waste transfer note is obtained for the oil which details the correct quantity removed. This note should
then be filed and retained for 3 years. See the Waste Management Procedure EMS OP3.
9. Disposal of bund water
1. All bunded areas are inspected on a weekly basis or more frequently in periods of heavy rain.

2. Where bunded areas are found to contain liquid, then the liquid must be removed as detailed below.

3. If chemical, oil or fuel spillages or residues are found within the bund, or should there be an accumulation of
rainwater in the bund this should be recorded and the appropriate corrective action taken.

4. If the liquid within the bund is an accumulation of uncontaminated rainwater then a manually controlled
positive lift pump should be used to transfer it into suitable storage containers. These containers can then
be drained to a foul drain or surface water via an interceptor. Refer to Drainage and Interceptor Procedure
EMS OP02.

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L J Fairburn & Son Ltd Environmental Management System

EMS OP01: Bulk Liquid Storage and Delivery

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

5. In the event that the spillage within the bund is found to be from oil, chemical or fuel, then a suitably
licensed hazardous waste disposal contractor should be contacted to organise disposal of the bund water in
accordance with Waste Management legislation See the Waste Management Procedure EMS OP3.

6. A waste transfer note should be obtained, filed and kept for 3 years.

7. In the event of other sources of contamination in the bund such as litter and solid debris this can be
removed and disposed of in general waste unless the debris is classified as special/hazardous waste.

Documentation

1. Ensure that all checks referred to above are documented.

LEGISLATION
Details of the legislation relating to this procedure are contained in the Register of Legislation (Legislation
Register) held on the computer system.

OTHER USEFUL REFERENCES

Environment Agency Pollution Prevention Guidance (PPG) Notes

PPG01 – General Guide to the Prevention of Water Pollution

PPG02 – Above Ground Oil Storage Tanks

PPG08 – Storage and Disposal of Used Oils

PPG26 – Storage and Handling of Drums and Intermediate Bulk Containers

CIRIA/Environment Agency Joint Guidelines – Concrete Bunds for Oil Storage Tanks

CIRIA/Environment Agency Joint Guidelines – Masonry Bunds for Oil Storage Tanks

Page 3 of 3
L J Fairburn & Son Ltd Environmental Management System

EMS OP02: Drainage System

Version No: 1 Owner: Operations Director
st
Issue Date: May 31 2016

INTRODUCTION
This procedure describes the method by which L J Fairburn & Son Ltd will maintain site drainage system in such a
way as to prevent the:

 Entry of any polluting substances to surface water.

 Unconsented entry to foul sewer of polluting substances.

 Leakage of polluted water to ground.

REFERENCES
This is a Procedure which is implemented by local Site Procedures & Work Instructions

RESPONSIBILITY
The Operations Director is responsible for this procedure and its communication to the Mill Manager. The Mill
Manager is responsible for its implementation on site.

HAZARDS
The discharge of any substance other than clean rainwater to surface waters is against the law.

It is also unlawful to discharge effluent (e.g. vehicle washing) to foul sewer without a consent from the relevant water
authority. If you are in any doubt as to whether you need consent then contact your water authority to discuss.

Damaged drainage or interceptors can lead to the leakage of effluent into the ground. This could lead to
contamination of soils and pollutants may migrate through the soil to pollute groundwater.

ACTIONS
These will be identified by Work Instructions held on site which will incorporate the following points.

Site Drainage

1. The Mill Manager will ensure that a site drainage plan is available for the site and that it is up to date. Oil
interceptors and outfalls to surface water are marked on this plan.

2. Drain gullies and manholes should be colour-coded on site to enable easy identification of surface (blue)
and which are foul (red) drains

3. As a minimum, annual checks of the surface water drainage system must be carried out. This will be done
by inspecting at the point closest to where the surface water drain leaves the site or the final outfall to
surface waters during a period of rainfall. Checks will be conducted to see if water is passing through the
sewer or is coming out of the outfall (if not then the drainage system maybe leaking or blocked) and that the
water appears to be free from pollution. Any issues must be reported to the Quality & Mill Manager. If the
water appears to be contaminated they must contact the Environment Agency.

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L J Fairburn & Son Ltd Environmental Management System

EMS OP02: Drainage System

Version No: 1 Owner: Operations Director
st
Issue Date: May 31 2016

4. As a minimum, annual checks of the foul sewer drainage systems must be carried out. This will be done by
inspecting at the point closest to where the sewer leaves the site. Checks will be conducted to see that
effluent is passing through the drain (if not then the drainage system maybe leaking or blocked). Any
suspected leakage or damage must be reported to the Quality & Mill Manager.

Interceptors (also referred to as separators)

1. Access to interceptors must be clear at all times and should be checked regularly to ensure nothing is
obstructing access.

2. All interceptors will be checked at least every six months to see if they need emptying or repair.

3. If the interceptor is full and needs emptying then a suitably licensed waste contractor will be used. A copy
of their licence will be obtained and kept on file.

4. When the interceptor is emptied a waste transfer note is obtained and retained for 3 years as interceptor
waste is classified as special/hazardous waste. See operational procedure relating to waste management –
EMS OP03.

Documentation

1. Ensure that all checks referred to above are documented.

LEGISLATION

Details of the legislation relating to this procedure are contained in the Register of Legislation (Legislation
Register) held on the computer system.

OTHER USEFUL REFERENCES

Environment Agency Pollution Prevention Guidance (PPG) Notes

PPG03 – Use and Design of Oil Separators in Surface Water Drainage Systems

Page 2 of 2
L J Fairburn & Son Ltd Environmental Management System

EMS OP03: Waste Management

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

INTRODUCTION
This procedure describes the method by which L J Fairburn & Son Ltd will store and dispose of its waste in
accordance with UK waste management legislation. It relates to the handling and disposal of all waste arising at
L J Fairburn & Son Ltd mill.

It sets out how waste is identified, how it is stored and handled and how it is disposed of so as to reduce both
environmental and health and safety risks associated with these activities.

REFERENCES
This Procedure is implemented by local Site Procedures & Work Instructions.

RESPONSIBILITY
The Operations Director is responsible for this procedure and its communication to the Mill Manager. The Mill
Manager is responsible for its implementation on site.

HAZARDS
Under UK legislation any business that produces, imports, carries, keeps, treats or disposes of controlled
wastes must:

 Prevent the unauthorised disposal, treatment or keeping of that waste;

 Prevent the escape of waste;

 Ensure that waste is only transferred to authorised persons;

 Prepare and retain written descriptions of waste and Transfer Notes

DEFINITIONS *

WASTE

Waste is any object or substance that L J Fairburn & Son Ltd discard, irrespective of its toxicity or quantity.
Waste may represent a risk to personnel, external parties or the environment through its:

 Physical or chemical characteristics.

 Toxicity.

 Quantity.

 Method of storage, handling or disposal.

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L J Fairburn & Son Ltd Environmental Management System

EMS OP03: Waste Management

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

HAZARDOUS WASTE

Hazardous waste is those wastes which are considered hazardous to people and the environment through their
physical and chemical properties i.e. any material which is toxic, corrosive, harmful, irritant, flammable,
carcinogenic or mutagenic. This includes but is not limited to:

 Waste oils and oily rags

 Degreasers, paints and solvents (but not empty containers of these materials)

 Batteries

 Asbestos containing materials e.g. cladding.

 WEEE – see below

WASTE ELECTRICAL AND ELECTRONIC EQUIPMENT (WEEE)

The WEEE Regulations apply to electrical and electronic equipment (EEE) in the following categories with a
voltage of up to 1000 volts AC or up to 1500 volts DC.

 Large and small household appliances

 IT and telecommunications equipment

 Consumer equipment, monitoring and control equipment,

 Automatic dispensers,

 Lighting equipment other than household or filament lighting,

 Electrical and electronic tools other than those permanently fixed at a given place in industrial machinery
or an industrial location.

GENERAL WASTE

All other waste, e.g. packaging, office waste, waste product and obsolete equipment not included in the above
categories.

Note: If there is any doubt as to how a particular waste should be categorised – this should be discussed with
A V Consultants.

Mill Manager should list the different types of waste on site detailing responsibility and method of
disposal. Every opportunity should be taken to recycle or recover waste to minimise the effect on the
environment.

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L J Fairburn & Son Ltd Environmental Management System

EMS OP03: Waste Management

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

WASTE STORAGE AND HANDLING

1. It is the responsibility of the Mill Manager to ensure that each waste storage area is checked weekly to
ensure the area remains tidy and accessible, identify any leaks and any containment or storage issues.

2. Evidence of these checks is to be recorded. The Mill Manager is responsible for taking actions arising from
any issues found.

3. Waste storage receptacles (skips, bins etc.) should be checked regularly to ensure they are secure and will
prevent leakage, damage or escape through any means.

4. All waste receptacles are to be clearly labelled to enable easy identification of the waste and its main
hazards should leakage or containment breach occur.

5. Waste chemicals and other hazardous material are to be stored in a marked storage receptacle in a
specified area.

6. Waste must not be stored for more than one year.

7. Under no circumstances must any waste be burned on site or disposed illegally.

General waste

1. Solid general waste must be stored within specified containers and their location marked.

2. Waste streams should be categorised and receptacles clearly marked and appropriate instructions issued.

3. Waste drums, containers and pallets of waste material are not to be stocked higher than 2 metres to reduce
risk of accident by falling objects and incorrect handling.

4. The site should be checked for any litter and where this is found it is to be removed and put in the
appropriate bin.

Hazardous Waste

1. All hazardous wastes types are to be listed and the receptacles they are to be stored in, identified. The
method of disposal should also be identified, including the details of the person(s) responsible for arranging
disposal.

2. Hazardous waste must not be mixed with general waste. Mixed loads of general and hazardous waste will
be categorised as hazardous.

3. All hazardous waste disposals must be organised by a specialist waste handler.

4. Every movement of hazardous waste must be accompanied by completion of a waste transfer/consignment

note and this must be retained on site for a minimum of 4 years.

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L J Fairburn & Son Ltd Environmental Management System

EMS OP03: Waste Management

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

Waste Electrical and Electronic Equipment (WEEE)

1. All waste electrical and electronic equipment is hazardous

2. All WEEE must be stored, recycled and disposed of separately from other waste.

3. WEEE can be returned free of charge if it was sold after 13.08.2005 and/or it is being replaced with new
equivalent EEE. In this case the EEE supplier should be contacted for details of the relevant compliance
scheme.

4. WEEE must be disposed of to an approved authorised treatment facility if:

a. It was purchased before 13.08.2005 and is not being replaced by equivalent EEE.

b. The producer or their compliance scheme cannot be traced.

c. New EEE is purchased and it is decided through negotiation with the producer to accept the future costs
of treating and disposing of it.

CONTRACTORS
1. The Mill Manager is responsible for ensuring that contractors are aware of site emergency procedures,
waste disposal arrangements and the location of spill kits and first aid points. Any incident or near miss
involving a contractor should be reported to the Mill Manager as laid down in the Site Emergency
Procedure.

2. Only licensed waste carriers are permitted to remove waste from L J Fairburn & Son Ltd site and a copy of
their licence (authorisation) or exemption certificate to carry and or dispose of waste should be obtained
prior to any waste removal. Records of these licences are to be kept.

RECORDS
1. Waste consignment notes are to be kept for all waste removed from site as required by legislation.

2. The Mill Manager is responsible for ensuring that the type, quantity and destination of the waste being
disposed of is recorded and total amounts are reported and discussed at the Site EMS meeting.

3. Waste produced must have a written description including the European Waste Catalogue 6 digit codes.
See below.

4. The Standard Industry Classification (SIC) or NACE code for animal feed plants is 15.71.

5. The NASE code for the main polluting process on site is 105.03

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L J Fairburn & Son Ltd Environmental Management System

EMS OP03: Waste Management

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

WASTE DISPOSAL SITE VISITS

1. L J Fairburn & Son Ltd arranges for the safe disposal of site wastes and are responsible for ensuring that
waste is disposed of legally and that disposal does not present a risk to the environment, contractors or
local population, either by its method of disposal or ongoing presence.

2. The implications of waste disposal include :

a. Waste disposal sites to be audited:

 Prior to commissioning a new waste management contract;

 Where our site waste changes significantly;

 The disposal site is modified or the location changes;

 If changes to legislation require it.

b. When disposing of hazardous waste, copies of their certification evidencing permission to

dispose of our hazardous waste are checked and copies taken.

3. The mill manager must obtain confirmation that the receiver is registered to accept the specific waste.

WASTE DESCRIPTION AND CATEGORIES

The tables on the following page describe the wastes produced by L J Fairburn & Son Ltd site. In the event that
a site produces a waste not covered by this list, guidance on disposal must be obtained.

DOCUMENTATION

1. Ensure that all checks referred to above are documented.

LEGISLATION
Details of the legislation relating to this procedure are contained in the Register of Legislation held on the
computer system.

OTHER USEFUL REFERENCES

Waste Management the Duty of Care - A Code of Practice available from:

www.defra.gov.uk/environment/waste/management/doc/pdf/waste_man_duty_code.pdf

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L J Fairburn & Son Ltd Environmental Management System

EMS OP03: Waste Management

Version No: 1 Issued By: Operations Director
st
Issue Date: 31 May 2016

Waste Categorisation

European Waste
Waste Description Hazardous Catalogue WFD Codes

Waste Oil & Lubricants Yes 13.02.08 D15/R9 Reuse of Oil

Absorbents containing Hazardous

Yes 15.02.02 D10 Incineration on Land
Materials
Electrical & Electronic Equipment Recycling of other inorganic
Yes 16.02.13 R5
containing harmful materials. materials

Interceptor Contents Yes 13.05.03 D8 Biological Treatment

Solvents Yes 20.01.13 R2 Solvent Reclamation

Fluorescent Tubes & Other

Yes 20.01.21 R4 Recycling of metals
Mercury containing Substances
Paints & Adhesives which contain
Yes 20.01.27 R2 Solvent Reclamation
dangerous substances
Recycling of other inorganic
Batteries Yes 20.01.33 R5
materials
Construction Materials containing
No 17.06.05 D1 Landfill
Asbestos
Paints & Adhesives which do not
No 20.01.28 R2 Solvent Reclamation
contain dangerous substances

Prescription Medicines No 20.01.32 D10 Incineration on Land

Plant Tissue Waste (Process Recycling of organic substances not

No 02.01.03 R3
Materials) used as solvents
Recycling of organic substances not
Paper & Cardboard No 20.01.01 R3
used as solvents
Recycling of organic substances not
Vegetable Oils & Fats No 02.03.04 R3
used as solvents
Recycling of organic substances not
Pallets No 20.01.38 R3
used as solvents
Recycling of other inorganic
Plastic Bags & Wrapping No 20.01.39 R5
materials

Scrap Metal No 20.01.40 R4 Recycling of metals

General Waste including non

hazardous waste not segregated No 20.03.01 D1 Landfill
or process material.

Page 6 of 6
L J Fairburn & Son Ltd Environmental Management System

EMS OP04: Bag Filter Maintenance

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

INTRODUCTION
This procedure describes the method by which L J Fairburn & Son Ltd will maintain dust abatement equipment at
each site. The main objective of this procedure is to ensure that dust emissions are kept to a minimum.

REFERENCES
This will be referenced in the Site monitoring and planned preventative maintenance schedules.

HAZARDS
The emission of dust and particulates to atmosphere could cause a nuisance to residents and businesses in the
surrounding area. These emissions may also lead to the deposition of material on land or in watercourses and may
pose a risk to flora and fauna.

ACTIONS

Day to day Operations

1. A visual check on the air-out stack should be carried out daily to check if any particulate emissions are visible.
If there are visible emissions then the bag filters must be checked for clogging or damage and replaced if
necessary.
Regular maintenance
2. The filters should be checked on a regular basis. To ensure they are not clogged or damaged.
3. In addition to the above, care must be taken to follow manufacturer’s maintenance instructions.
Replacement
4. Worn or damaged filters should be replaced with a filter of the same or similar specification.
Documentation

1. Ensure that all checks referred to above are documented.

LEGISLATION
Details of the legislation relating to this procedure are contained in the Register of Legislation (Legislation
Register) held on the computer system.

OTHER USEFUL REFERENCES

Refer to manufacturer’s maintenance manual.

Page 1 of 1
L J Fairburn & Son Ltd Environmental Management System

EMS OP05: Plant and Equipment Change

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

INTRODUCTION
The aim of this document is to ensure that new and modified plant/equipment has been appropriately
commissioned and approved prior to the commencement of Operations in relation to environmental issues.

REFERENCES
This procedure should be read in conjunction with EMS OP07 Environmental Purchasing Procedure and Capital
Approval.

RESPONSIBILITY
The Operations Director is responsible for this procedure and its communication to the Mill Manager. The Mill
Manager is responsible for its implementation on site.

HAZARDS
If planned changes to plant/equipment on site is not appropriately reviewed and approved then there will be an
increased risk of the following:

 Unnecessary financial cost (e.g. excessive packaging requiring waste disposal, purchasing of energy
inefficient equipment incurring increased running costs).
 Increase in environmental damage (e.g. increased emissions, equipment containing hazardous
materials).
 Damage to L J Fairburn & Son Ltd reputation or environmental credentials.
 Non-compliance with PPC Permit.

ACTIONS

Plant and Equipment Change Review and Approval

1. For new plant or equipment, or when making modifications to existing plant or equipment the Mill
Manager will discuss the proposed changes with the Operations Director and independent advisors as
appropriate to establish the needs for the following:
 Changes to the Environmental Aspects Register.
 Changes to the Register of Environmental Legislation, including the need to gain prior approval from
Regulatory Bodies.

2. The above should be reviewed not only for when the modification has been made but also the
associated activities and risks of physically making the modification.
3. The Mill Manager will ensure that the relevant changes are made if required to other documents (i.e.
procedures, inclusion within planned maintenance schedules) will be made.

4. For any plant changes the implications to product quality and/or Health & Safety will also be taken into
account.

Page 1 of 2
L J Fairburn & Son Ltd Environmental Management System

EMS OP05: Plant and Equipment Change

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

Project Completion Certificate

1. Once approval has been gained the Mill Manager will sign off the project.
2. If appropriate, equipment will be added to the site’s planned preventative maintenance programme.
3. If appropriate the plant/equipment will also be subject to ongoing monitoring and/or calibration to ensure
correct operating parameters are maintained.

LEGISLATION
There is currently no specific environmental legislation associated with making changes to plant/equipment on
site although depending on the proposed changes prior approval may be required.
Details of the legislation relating to this are contained in the Register of Legislation (Legislation Register) held on
the computer system.

OTHER USEFUL REFERENCES

Page 2 of 2
L J Fairburn & Son Ltd Environmental Management System

EMS OP06: Contractor Environmental Risk Management

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

INTRODUCTION
This procedure describes the method by which L J Fairburn & Son Ltd manages the environmental risks associated
with contractors that work on site.

The main objective of this procedure is to ensure the risk associated with contractors, in terms of environmental
damage and legislative non-compliance, is minimised.

REFERENCES

Safety Instructions to Contractors (HS1) – held on the computer system.

RESPONSIBILITY
The Operations Director is responsible for this procedure and its communication to the Mill Manager. The
Production Manager is responsible for its implementation on site.

HAZARDS
Contractors conduct a range of activities on site using an array of materials and produce a variety of wastes. If
contractors activities are not managed on site this increases the risk of the following:

 Non-conformance with site procedures.

 Significant environmental damage.
 Non-compliance with environmental legislation.

ACTIONS

Refer to the Control of Contractor Procedures.

LEGISLATION
There is no specific environmental legislation associated with contractors work on site but non-compliance with
some could potentially occur from contractors work on site.

Details of the legislation relating to this are contained in the Environmental Register of Legislation held on the
computer system.

OTHER USEFUL REFERENCES

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L J Fairburn & Son Ltd Environmental Management System

EMS OP07: Environmental Purchasing

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

INTRODUCTION
The aim of this document is to assist L J Fairburn & Son Ltd staff integrate environmental considerations into
purchasing decisions. This document will ensure the company informs/seeks approval from the Environment
Agency when significant changes occur at a site or within the business and when key process and abatement
plant/equipment and/or Raw Materials are purchased.

REFERENCES
L J Fairburn & Son Ltd Capital Procedures
Environmental Equipment Purchasing Checklist (EPC)
Raw Material Purchasing Procedures

RESPONSIBILITY
The Operations Director is responsible for this procedure and its communication to the Mill Manager, Raw Material
Buying team and other nominated persons responsible for procurement on a mill basis. These people are
responsible for its implementation.

HAZARDS
If environmental issues are not considered as part of the procurement progress this increases the risk of:

 Unnecessary financial cost (e.g. excessive packaging requiring waste disposal, purchasing of energy
inefficient equipment incurring increased running costs).
 Increase in environmental damage (e.g. increased emissions, equipment containing hazardous
materials).
 Non-compliance with a site’s PPC Permit.

ACTIONS
Review of purchase/submission

1. The Mill Manager / Relevant Buyer/ Procurement Purchaser will review how the purchase could affect
the environmental impacts/risks at the site(s) and will raise any relevant issues with the Operations
Director who will update the Environmental Aspects Register if required.

2. The Operations Director / appropriate Independent Advisor will review how the purchase could affect
compliance with environmental legislation and impacts on the Company EMS.

3. The Mill Manager will seek approval from the Environment Agency where required if the purchase will
affect the conditions of the site’s PPC Permit.

Purchasing Guidance - Refer to the Environmental Equipment Purchasing Checklist (EPC).

LEGISLATION
There is no specific environmental legislation associated with purchasing materials other than informing/seeking
approval from the Environment Agency where required under the Pollution Prevention and Control Regulations.

OTHER USEFUL REFERENCES

N/A

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L J Fairburn & Son Ltd Environmental Management System

EMS OP08: Planned Preventative Maintenance Procedure

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

INTRODUCTION
The aim of this document is to ensure that all key plant and equipment is regularly maintained to reduce mill down-
time, increase efficiency and reduce/eliminate hazards.

REFERENCES
This procedure should be read in conjunction with procedure EMS OP05 Plant & Equipment Change.
Site Preventative Maintenance Schedule
Site Planned Maintenance Programme

RESPONSIBILITY
The Operations Director is responsible for this procedure and its communication to the Mill Manager. The Mill
Manager is responsible for its implementation on site.

HAZARDS
If planned maintenance is not carried out there will be an increased risk of the following:

 Unnecessary financial cost from mill breakdown time, inefficient running.

 Failure to meet customer requirements, possible legal failures
 Increase in environmental damage (e.g. increased emissions, leaks etc.)
 Health & Safety hazards

ACTIONS

Planned Maintenance System

1. A Planned Preventative Maintenance schedule covering all major equipment (examples listed below)
should be maintained by each site to ensure that this equipment is checked and maintained on at least
an annual basis.
2. Equipment should be monitored on a routine basis by mill/engineering staff who may be designated
duties by the Mill Manager.
3. Remedial / repair work must be organised by the Mill Manager and attended to either by in-house staff
or approved outside contractors.

Page 1 of 2
L J Fairburn & Son Ltd Environmental Management System

EMS OP08: Planned Preventative Maintenance Procedure

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

Type of Equipment Checks

Liquid Handling Systems Integrity of pipes, pumps, meters & valves. Drip trays in place and functional.
Tanks Leaks, Operating & Emergency high level systems & alarms. Pump isolation
during non-production periods. Bund wall integrity, security and emptying. Pipe-
work sound.
Air Emissions – Bag Filters Check for leaks (burst bags). Replacement programme.
Air Emissions - Coolers Iso-kinetic testing. Check for blockages in trunking, separation units etc. Check
blockage probe operation.
Drains Structurally sound, no blockages.
Waste Correct storage in designated containers, in designated areas. No leaks.

LEGISLATION
There is currently no specific environmental legislation associated with preventative maintenance on site
although depending on the proposed changes prior approval may be required.

OTHER USEFUL REFERENCES

Page 2 of 2
L J Fairburn & Son Ltd Environmental Management System

EMS OP09: Nuisance Management

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

INTRODUCTION
This procedure describes the method by which L J Fairburn & Son Ltd will manage potential environmental
nuisances (odour, dust and noise on site. The main objective of this procedure is to ensure that nuisances are kept
to a minimum.

REFERENCES
EECF – External Environmental Communication/Complaint Form
NCIR - Non-conformance and Incident Report Form
EMS SP08 - Non–conformance, Corrective and Preventive Action Procedure
EMS OP04 – Bag Filter Maintenance
EMS OP08 – Plant Maintenance
EMS SP05 – Environmental Communication

RESPONSIBILITIES
All staff on site are responsible for ensuring that their activities do not cause any environmental nuisance.

HAZARDS
The potential nuisances are noise from process machinery and vehicle movements, odour from process emissions
to atmosphere and dust from process emissions to atmosphere and vehicle loading / unloading activities. These
nuisances could affect human occupation/residences in the surrounding area.

ACTIONS
Day to day Operations
1. The correct Operating and maintenance procedures are covered in other Operating Procedures within the
Environmental System.

2. Abnormal odours, noise and dust emissions must be reported to line managers immediately. An investigation
must take place to identify any problems and carry out corrective actions. Consideration must be given by the
site manager if these abnormalities should be reported to the Regulatory authorities.

3. Site management and shift leaders will check for abnormal noise, dust and odour during daily mill tours.
4. Any complaint registered by a member of the public, customer, supplier or other party will be handled by the
relevant manager using the External Communication or Complaint Form (ECCF- reference EMS SP05).

Documentation
Nuisance observations and reports, both internal and external, must be documented.

LEGISLATION
Details of the legislation relating to this procedure are contained in the Register of Legislation held on the
computer system.

OTHER USEFUL REFERENCES

Page 1 of 1
L J Fairburn & Son Ltd Environmental Management System

EMS OP10: Emergency Procedure

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

INTRODUCTION
This procedure describes the method by which L J Fairburn & Son Ltd will manage emergency procedures (fire,
spillages and abnormal emissions) at each site. The main objective of this procedure is to ensure that emergency
procedures are in place to avoid any environmental impact.

REFERENCES
Health & Safety Manual
Emergency Action Plan
NCIR - Non-conformance and Incident Report Form

RESPONSIBILITIES
The Mill Manager is responsible for the implementation and maintenance of the Emergency Action Plan.

All staff on Site are responsible for implementing emergency procedures to avoid environmental pollution.

HAZARDS
The potential pollutants in an emergency situation are as follows:-

Fire – smoke, contaminated water and foam

Spillages of bulk liquids

Emissions – particulates

These pollutants could affect human occupation/residences in the surrounding area and contaminate land and
water systems.

ACTIONS

Fire

Fire prevention and control policies are documented in the Company Health & Safety Manual, copy found on the
computer system.

Fire detection equipment must be checked weekly and recorded in Mill Log Book.

Evacuation drills must be conducted annually and recorded in Mill Log Book

The Emergency Action Plan contains instructions on what to do in the event of a fire.

Page 1 of 2
L J Fairburn & Son Ltd Environmental Management System

EMS OP10: Emergency Procedure

Version No: 1 Issued By: Operations Director
Issue Date: 31 May 2016

Spillages

Site work instructions contain detailed instructions on procedures and actions to take in the event of a spillage of
bulk liquids or failure of bunding. Spillages must be reported to the Regulatory authorities

The Emergency Action Plan contains a register of each liquid held on site.

Emissions

In the event of abnormal emissions from abatement plant the process plant must be immediately shut down and
corrective actions taken to prevent further emissions.
Abnormal odour or dust emissions must be reported to line managers. An investigation must take place to identify
any problems and carry out corrective actions. Consideration must be given by the Mill Manager if these
abnormalities must be reported to the Regulatory authorities.

Site management and shift leaders will check for abnormal dust and odour during daily mill tours.

Documentation

After any Emergency e.g. fire, details of the emergency and the action taken must be documented in a specific
report to be held on Site.

LEGISLATION
Details of the legislation relating to this procedure are contained in the Register of Legislation held on the
computer system.

OTHER USEFUL REFERENCES

Page 2 of 2
 L J Fairburn & Son Ltd
ENVIRONMENTAL AUDITORS PACK

INDEX

I.D. Ref. Version

1. NOMINATED ENVIRONMENTAL AUDITORS Andy 1

(controlled issue master list) Vincent

2. ENVIRONMENTAL AUDIT REPORTS

i) Environmental Audit Report IEAR 1

ii) Summary IEAS 1
iii) Details of Non Conformance IENC 1
iv) Audit Trail IEAT 1

3. ENVIRONMENTAL AUDIT CHECKLISTS SESAC 1

4. WORK INSTRUCTIONS

i) Opening Meeting EAUD2 1

ii) Closing Meeting EAUD3 1

5. ENVIRONMENTAL AUDIT ASSESSMENT IEAA 1

Authorised: Operations Director May 2016

 ENVIRONMENTAL AUDITORS PACK
Section: 2(i)
L J Fairburn & Son Ltd

ENVIRONMENTAL
AUDIT REPORT REPORT NO:___________________________

PAGE NO:____________of________________

SITE Huttoft Mill HEAD OF DEPT_ Rob Clark_______

DATE OF AUDIT_________________ AUDITOR_______Andy Vincent ___

DEPT(S)____Mill, Office & Transport___________________________________ _

Reference Documents_____________________________________________ __________

1. AUDIT SUMMARY - see attached

2. NON CONFORMANCES

2.1 SIGNED OFF (Reference Nos) _____________________________________________

2.2 OUTSTANDING* (i.e. unable to sign off) (Reference Nos):_________________________

* Take a copy of the non-conformance and attach to this report.

2.3 RAISED THIS AUDIT ((Reference Nos)_______________________________________

2.4 CORRECTIVE ACTIONS - DATES AGREED and DOCUMENTED?

3. AUDIT DETAILS

3.1 AUDIT TRAIL - DETAILED ON Checklist and Audit Trail (IEAT) FORM

3.2 ADDITIONAL/POSITIVE COMMENTS ATTACHED (if applicable)

SIGNED:

_______________________________ _______________________________________
Departmental Head Lead Auditor

_______________________________
Date of Audit

COPIES: Note: It is the Auditor’s responsibility to ensure copies are circulated. Please double side copies of IEAT

DEPARTMENTAL HEAD
OPERATIONS DIRECTOR
QUALITY MANAGER

Authorised: Operations Director Form: IEAR Version 1

 ENVIRONMENTAL AUDITORS PACK
Section: 2 (ii)
REPORT NO:_________________
L J Fairburn & Son Ltd
PAGE NO: of ___________

ENVIRONMENTAL AUDIT REPORT: Summary

CLAUSES COVERED
DESCRIPTION PREVIOUS THIS NC REF NOS
VISIT VISIT
4.1 GENERAL REQUIREMENTS
4.2 ENVIRONMENTAL POLICY
4.3 PLANNING
4.3.1 Environmental Aspects
4.3.2 Legal Requirements
4.3.3 Objectives, Targets & Programme
4.4 IMPLEMENTATION AND OPERATION

4.4.1 Resources, Roles, Responsibility &

Authority
4.4.2 Competence, Training & Awareness

4.4.3 Communication

4.4.4 Documentation

4.4.5 Document Control

4.4.6 Operational Control

4.4.7 Emergency Preparedness & Response

4.5 CHECKING

4.5.1 Monitoring & Measurement

4.5.2 Evaluation of Legal Compliance

4.5.3 Non-conformity, Corrective &

Preventative Action
4.5.4 Control of Records

4.5.5 Internal Audit

4.6 MANAGEMENT REVIEW

SIGNED:

_________________________________ _________________________________
Departmental Head Auditor

_________________________________
Date of Audit

COPIES: Note: It is the Lead Auditor’s responsibility to ensure copies are circulated
DEPARTMENTAL HEAD
OPERATIONS DIRECTOR
QUALITY MANAGER
Authorised: Operations Director Form: IEAS Version 1
 ENVIRONMENTAL AUDITORS PACK
Section: 2(iii)
L J Fairburn & Son Ltd

ENVIRONMENTAL AUDIT REPORT:

REPORT NO:___________
Details of Non Conformance PAGE NO ____of_______
NON CONFORMANCE REPORT NO:
1. Details of Non Conformance

2. Agreed Corrective/Preventative Actions

3. Date Agreed for Completion of Corrective/Preventive Actions:

4. Signatures:

Departmental Head Auditor

Date of Audit

5. AGREED ACTION(S) COMPLETED - NON CONFORMANCE SIGNED OFF AT NEXT AUDIT

Auditor Date

COPIES: Note: It is the Auditor’s responsibility to ensure copies are circulated

DEPARTMENTAL HEAD
OPERATIONS DIRECTOR
QUALITY MANAGER

`Authorised: Operations Director Form: IENC Version: 1

 ENVIRONMENTAL AUDITORS PACK
Section: 2(iv)

L J Fairburn & Son Ltd

ENVIRONMENTAL AUDIT REPORT:

REPORT NO:______________
Additional Audit Trail
PAGE NO of ___

(Please list brief details of any observations, further information on non-conformances, additional audit areas
and any possible BDPs here)

SIGNED:

_____________________________________ _________________________________
Departmental Head Auditor

_____________________________________
Date

COPIES: Note: It is the Auditor’s responsibility to ensure copies are circulated

DEPARTMENTAL HEAD
OPERATIONS DIRECTOR
QUALITY MANAGER
Authorised: Operations Director Form: IEAT Version: 1
 ENVIRONMENTAL AUDITORS PACK
Section: 3

L J Fairburn & Son Ltd

Site EMS Audit Checklist

Auditor: ……………………………. Site: Huttoft Mill

Date of Audit:……………………………..

Environmental Management System Structure & Responsibility

EMS Requirements Verification Details OK Major Minor Obs

NC NC
Continue on sheet IEAT where necessary
How is the sites system
structured & documented.
Who is responsible for the
system, where is this
documented?
Are employees aware of
procedures, work instructions
etc?

Where is the Environmental

Policy held? Is it available to all
staff?
How often does a management
review take place?
Does an agenda exist?
Are follow up actions completed?

Are Environmental Audit reports

available? Are completed
corrective actions within
timescale and effective? Any to
be signed off at this audit?

Document Control – how are

documents approved &
amended. How are Company
Procedures dealt with? Are
obsolete documents retained?

Record retention – for how long

are records kept and where?

Authorised: Operations Director Form: SESAC Version 1 Page 1 of 11

Copies: Departmental Head, Operations Director & Quality Manager
 ENVIRONMENTAL AUDITORS PACK
Section: 3

L J Fairburn & Son Ltd

Site EMS Audit Checklist

Site: Huttoft Mill

Date of Audit: ……………………………….

EMS Requirements Verification Details OK Major Minor Obs

NC NC
Continue on sheet IEAT where necessary
Environmental Aspects
(EMS SP01)

Are Environmental Aspects

understood? What are the
specific Environmental Aspects at
Company level? Where is this
documented?

Environmental Legislation
Register (EMS SP02)

How is Environmental Legislation

dealt with?
Is there access to this at Site
level?
How are changes
communicated?

Are all legal monitoring

requirements (e.g. consent
conditions) included in a
monitoring schedule? Does it
match the consent?

Have all PPC improvement

condition responses been made
to the EA to the required
timescale?

Authorised: Operations Director Form: SESAC Version 1 Page 2 of 11

Copies: Departmental Head, Operations Director & Quality Manager
 ENVIRONMENTAL AUDITORS PACK
Section: 3

L J Fairburn & Son Ltd

Site EMS Audit Checklist

Site: Huttoft Mill

Date of Audit: ………………………………….

EMS Requirements Verification Details OK Major Minor Obs

NC NC
Continue on sheet IEAT where necessary
Environmental Objectives,
Targets and Management
Programmes (EMS SP03)
Are objectives & targets set and
achieved?
Do they consider PPC permit,
aspects and policy commitments

Where are these recorded?

Are all objectives & targets clear

and targets readily measured?

Are objectives clear or

ambiguous? Are associated
targets appropriate?
Can target achievement be
demonstrated?
Have appropriate timeframes
been set for targets and also
individual tasks relating to these
targets?
Ideally should include short-term
and longer term improvement
projects. Timescales need to
take account of other business
requirements and workloads.
Is responsibility (ownership)
assigned for objectives and
targets?

Are objectives and targets set on

a regular basis?

Authorised: Operations Director Form: SESAC Version 1 Page 3 of 11

Copies: Departmental Head, Operations Director & Quality Manager
 ENVIRONMENTAL AUDITORS PACK
Section: 3

L J Fairburn & Son Ltd

Site EMS Audit Checklist

Site: Huttoft Mill.

Date of Audit: ………………………………….

EMS Requirements Verification Details OK Major Minor Obs

NC NC
Continue on sheet IEAT where necessary
Training, Awareness &
Competence (EMS SP04)
Do staff have job statements
stating environmental
responsibilities?
Is there a clear process for
identifying training needs?

Is there a formal, documented

training needs assessment which
identifies all posts for which
specific environmental awareness
training is required?

Are staff training needs subject to

a regular (i.e. annual) review?

Is there a general environmental

awareness programme covering:
The regulatory requirements
associated with the PPC Permit
The likely potential environmental
impacts which may be caused by
plant under their control (normal
and abnormal circumstances)
Reporting procedures to inform
managers of deviations from
Permit conditions and for
managers to report deviations to
the E.A. Policy and EMS
awareness.
Benefits of improved performance
Roles and responsibilities
Emergency response.
Consequences of non-
conformance?

Is EMS training included in new

staff induction?

Authorised: Operations Director Form: SESAC Version 1 Page 4 of 11

Copies: Departmental Head, Operations Director & Quality Manager
 ENVIRONMENTAL AUDITORS PACK
Section: 3

L J Fairburn & Son Ltd

Site EMS Audit Checklist

Site: Huttoft Mill

Date of Audit: ………………………………….

EMS Requirements Verification Details OK Major Minor Obs

NC NC
Continue on sheet IEAT where necessary
Communication (EMS SP05)
How is the Company procedure
translated?

Does the procedure cover the

receipt, documentation and
responses to relevant external
communication?

Are environmental complaints

reported and communicated. If so
how?

Does appropriate corrective &

preventative action arise from
external complaints or
comments?

Monitoring & Measurement

(EMS SP07)
Is the above monitoring
procedure being followed? Are
appropriate records being kept?

Sample monitoring records for O&T

monitoring and ‘environmental’
monitoring (check validity of data?)

Authorised: Operations Director Form: SESAC Version 1 Page 5 of 11

Copies: Departmental Head, Operations Director & Quality Manager
 ENVIRONMENTAL AUDITORS PACK
Section: 3

L J Fairburn & Son Ltd

Site EMS Audit Checklist
Site: Huttoft Mill

Date of Audit: ………………………………….

EMS Requirements Verification Details OK Major Minor Obs

NC NC
Continue on sheet IEAT where necessary
Non-conformance,
Corrective and Preventative
Action (EMS SP08)
Is there is a procedure for
corrective and preventive action
which includes:
Investigating non-conformance
(and its causes)?
Taking action to mitigate
impacts? Initiating and
completing corrective &
preventive action?

Is responsibility assigned for

investigating non-conformance
and initiating
corrective/preventive action?

Emergency Preparedness &

Response
Is there an up to date procedure
(and work instructions where
appropriate) which identifies the
potential emergency situations?

Is it accessible in an emergency?
Does it include accidents e.g.
liquid spillage, cyclone failure,
etc?

Is the procedure adequate and

practical?

Are all personnel aware of

emergency procedures/actions?

Has any part of it been tested?

e.g. spillages
Is the recording required in the
Company Emergency Procedure
(EMS OP12) carried out?

Authorised: Operations Director Form: SESAC Version 1 Page 6 of 11

Copies: Departmental Head, Operations Director & Quality Manager
 ENVIRONMENTAL AUDITORS PACK
Section: 3

L J Fairburn & Son Ltd

Site EMS Audit Checklist
Site: Huttoft Mill

Date of Audit: ………………………………….

Operating Procedures

EMS Requirements Verification Details OK Major Minor Obs

NC NC
Continue on sheet IEAT where necessary
Have the following been
implemented?
Do Work Instructions link to
Procedure?
Are appropriate records kept?
EMS OP01 Bulk Liquid Delivery,
Storage & Handling

EMS OP02 Drains & Interceptors

EMS OP03 Waste Management

EMS OP04 Bag Filter Operation

& Maintenance

EMS OP05 Plant & Equipment

Change

EMS OP06 Contractor Control &

Training

EMS OP07 Purchasing –

consideration of environmental
issues
EMS OP08 Planned Preventative
Maintenance

EMS OP09 Cooler Abatement,

Operation and Control

EMS OP10 Potential

Environmental Nuisances

EMS OP11 Ozone Depletors

Authorised: Operations Director Form: SESAC Version 1 Page 7 of 11

Copies: Departmental Head, Operations Director & Quality Manager
 ENVIRONMENTAL AUDITORS PACK
Section: 3

L J Fairburn & Son Ltd

Site EMS Audit Checklist
Site: Huttoft Mill

Date of Audit: ………………………………….

Site Tour

EMS Requirements Verification Details OK Major Minor Obs

NC NC
Continue on sheet IEAT where necessary
Site Boundaries
Has litter escaped beyond
boundary?

Are noise/odour levels

detectable and likely to cause
a nuisance?

Any new issues which may

cause nuisance?

General Yard Condition

Are levels of litter and dust
acceptable?
Is there evidence of
spillages?

Is the site free from

obstructions?
Are areas of hard-standing in
a good state of repair?
Is redundant/scrap equipment
stored on hard-standing and
in an appropriate manner?
Are any transformers on site
free from PCBs?
Are there any invasive weeds
present on site (e.g. Giant
Hogweed, Japanese
Knotweed)
If there is a vehicle wash
facility, is there a possibility of
splashing causing potential
land contamination? If so
what precautions taken?

Authorised: Operations Director Form: SESAC Version 1 Page 8 of 11

Copies: Departmental Head, Operations Director & Quality Manager
 ENVIRONMENTAL AUDITORS PACK
Section: 3

L J Fairburn & Son Ltd

Site EMS Audit Checklist
Site: Huttoft Mill

Date of Audit: ……………………………….

Site Tour continued

EMS Requirements Verification Details OK Major Minor Obs
NC NC
Continue on sheet IEAT where necessary
Emissions
Are there any visible
emissions?

Is there any evidence of dust

discharge? On roofs,
cladding, roadways etc.

Is there any discernable smell

outside the plant?

Compressors – is oil
separated and collected for
disposal?
Site Drains
Are plans of the drain system
available
Are drain covers colour
coded?

Are drains clear of debris?

Are there any signs of spillage
or contamination?

Has the interceptor been

checked and records kept?

Is an authorised waste
contractor used to empty the
interceptor?

Are unauthorised materials

stored close to drains (Storm
water particularly)?

Authorised: Operations Director Form: SESAC Version 1 Page 9 of 11

Copies: Departmental Head, Operations Director & Quality Manager
 ENVIRONMENTAL AUDITORS PACK
Section: 3

L J Fairburn & Son Ltd

Site EMS Audit Checklist
Site: Huttoft Mill Date of Audit: ……………………………….

Site Tour Continued

EMS Requirements Verification Details OK Major Minor Obs
NC NC
Continue on sheet IEAT where necessary
Liquid Storage Areas
Types of liquid stored

Are liquids stored in

appropriate containers, clearly
labelled and safe?

Is there an accumulation of
liquids inside the bund areas
and by fill pipes?
Where do they drain to?

Are the bund walls sound and

leak free?
Are bunds adequate in size?
Are self bunded tanks
checked for integrity?
Are spill kits available and
clearly indicated?
Are they complete?

Solid Waste Storage Areas

Types of solid waste stored

Is waste securely stored in

appropriate containers and
clearly labelled?

Has any waste escaped, or is

being stored, outside storage
area?
Are skip covers in place (if
appropriate)?

Authorised: Operations Director Form: SESAC Version 1 Page 10 of 11

Copies: Departmental Head, Operations Director & Quality Manager
 ENVIRONMENTAL AUDITORS PACK
Section: 3

L J Fairburn & Son Ltd

Site EMS Audit Checklist
Site: Huttoft Mill Date of Audit: ……………………………….

Site Tour Continued

EMS Requirements Verification Details OK Major Minor Obs
NC NC
Continue on sheet IEAT where necessary

Are there any leaks from the

skips?
Are recycling opportunities
maximised - how?

Are special/hazardous wastes

and general wastes properly
segregated?
Are waste transfer records up
to date and complete?
Check availability of transfer
notes and copy of carrier
certificate or exemption.
Maintenance Area
Are there COSHH data
sheets for all maintenance
materials stored on site?
Check stores contents incl.
insecticides, herbicides, etc.
Are hazardous substances
stored in suitable
cabinet/store? e.g. paints,
solvents, insecticides.
Notes for Contractors
completed and returned?
Energy Conservation
Are CCL Meetings held and
acted upon?
CCL Evidence Pack
available?
Are lights switched off when
not in use? Are PIRs and light
sensors used?
Is there evidence of
unproductive plant running?
Are steam and compressed
air leaks surveyed?

Authorised: Operations Director Form: SESAC Version 1 Page 11 of 11

Copies: Departmental Head, Operations Director & Quality Manager
L J Fairburn & Son Ltd
ENVIRONMENTAL AUDITORS PACK SECTION 4.i

OPENING MEETING

1. Introduction and Welcome

2. Audit Purpose and Scope (IPPC/SITE PROCEDURES)

3. Review of Audit Programme

4. Guides: Who are they?

5. Logistics: - Lunch
- Facilities for Auditors (office)
- Protective Clothing/ Ear Defenders

6. Clarification - Confirm status of key documents

7. Objective evidence must be obtained

8. Reporting Methods - Non Conformances and the documents used

9. Confidentiality of Audit

10. Restrictions e.g. Hazardous areas

Sensitive Union areas relating to conflicts or redundancy

11. Audit as Sample Both acceptable and non conforming aspects of the system will
be seen and missed

12. Request Previous Audit Reports

13. Thanks and Arrange Time for Closing Meeting

Page: 1 of 1

Authorised: Operations Director EAUD1 Version: 1

L J Fairburn & Son Ltd
ENVIRONMENTAL AUDITORS PACK SECTION 4.ii

CLOSING MEETING

The following points should be covered in the Closing Meeting

1. Thanks

2. Objective and Scope Restate as this resets the context of the Audit.

3. Limitations: Remind the auditees that the audit was a sample, therefore deficiencies
may exist in areas not covered.

4. Presentation: Read through all Non Conformances and Observations. Auditees

should not need to make notes as the information provided should be sufficient.

5. Summarise: Present overall conclusion. This will be the auditors’ “informed

judgement” and must consider the seriousness of the Non Conformances.

6. Non-Conformance recording: Agree the Non Conformances raised and the

corrective action to be taken and timescales. The Non-conformance form (IENC)
sections 1 to 3 must be fully completed with Auditors and Departmental Head signing
and dating in Section 4.

7. Sign Off Previous Non-conformances i.e. Outstanding: If it has been agreed that
the corrective action for these has been implemented then the auditors should sign
these off in Section 5 and record the relevant non-conformance number(s) on the audit
summary report (IEAS) in Section 2.1. If it has not been possible to sign one off then
the relevant non-conformance number should be recorded under the Outstanding
Section 2.2. and a copy of the nonconformance must be attached to this audit report.

8. Feedback: Please leave blank Audit Assessment form (IEAA) with the auditee.

9. Copies of Reports: The Lead Auditor is responsible for ensuring that copies of the
audit report are circulated as per the circulation listed on the IEAS.

10. Questions and Depart

Authorised: Operations Director EAUD2 Version: 1

 Page: 1 of 1

Authorised: Operations Director EAUD2 Version: 1

 AUDITORS PACK
Section: 5

L J Fairburn & Son Ltd

ENVIRONMENTAL AUDIT ASSESSMENT
LOCATION: Huttoft Mill Date of Audit:

AUDITOR BEING ASSESSED: ______________________________________

Please return this form to the Quality Manager as soon as possible. Your comments will be used to assess the
auditing procedure and will help in future planning.

Please circle the appropriate response: Comments (please always comment if you have
marked 3 or 4)
1. How would you rate the Auditors' understanding of
the process:

1 2 3 4
Excellent Good Satisfactory Unsatisfactory

2. Was a clear plan drawn up and adhered to:

1 2 3 4
Entirely Mostly Partly Not at All

3. The Auditors kept to an agreed timetable:

1 2 3 4
Entirely Mostly Partly Not at All

4. Positive issues were identified:

1 2 3 4
Entirely Mostly Partly Not at All

5. The visit was constructive:

1 2 3 4
Entirely Mostly Partly Not at All

6. The Report was clear and objective:

1 2 3 4
Entirely Mostly Partly Not at All

7. Any Other Comments:

Signature _________________________________ Date ___________________________

Authorised: Operations Director IEAA Version: 1

 Production Drivers Engineers W/Bridge Transport Office M/Manager
General Awareness Presentation       
Environmental Management System File       
Work Instruction WI EMS 1 Liquids Deliveries   
Work Instruction WI EMS 2 Derv & Red Diesel Deliveries   
Work Instruction WI EMS 3 Emergency Spill Procedures      
Work Instruction WI EMS 4 Bunds Inspection & Pump Out Procedure  
Work Instruction WI EMS 5 RM Deliveries Tipped & Blown   
Work Instruction WI EMS 6 Vehicle Washing   
Work Instruction WI EMS 7 Liquid Filter Cleaning   
Work Instruction WI EMS 8 On-Site Refueling FLTs  
Work Instruction WI EMS 9 On-Site Refueling HGVs & LGVs   
Work Instruction WI EMS 10 Waste Disposal     
Work Instruction WI EMS 11 Instructions To RM Delivery Drivers   
Work Instruction WI EMS 12 Cooler Abatement Checks  
Work Instruction WI EMS 13 Plant Maintenance Envr Control Systems  
Work Instruction WI EMS 14 Nuisances    
Work Instruction WI EMS 15 Road & Hardstanding Inspection Procedure  
Work Instruction WI EMS 16 Bulk Vehicle Loading   
Work Instruction WI EMS 17 Vehicle Maintenance   
Work Instruction WI EMS 18 Observing Water Discharge For Oil & Grease  
Work Instruction WI EMS 19 Gas Oil Deliveries  
Work Instruction WI EMS 20 Daily Odour and Noise Checks 
Work Instruction WI EMS 21
Work Instruction WI EMS 22
Work Instruction WI EMS 23
Work Instruction WI EMS 24
Work Instruction WI EMS 25
DVD Drains, Drums, Tanks & Bunds       
 C J Fairburn & Son Ltd Environmental Training Matrix Key: Required
Environmental Training Needs Analysis Matrix ETNA

Requirements of PPC Emergency Procedures Energy

General
Environmental
and ES Spill
Awareness Waste Abatement Prevention Plant Planning &
Level Training Streams Emissions Accidents Communication Failures and Clean Up General Operation Procurement

Operations Director
Site Management &
Supervision

Office - CSD

Sales

Drivers

Process Operators

Warehouse

Maintenance

Procurement

Logistics Planners

Issued By: The General Manager Page 1 of 1 Date Issued: January 2008
 Version1

ENVIRONMENTAL MANAGEMENT SYSTEM TRAINING

I understand that L J Fairburn & Son Ltd operates an 'Environmental Management System' (EMS). I understand that the EMS is designed to e
compliance with the IPPC directive. L J Fairburn & Son Ltd holds an Operational Permit under the PPC Regulations enforced by the 'Environ
Agency'.

My Supervisor/Manager has access to all the current systems which make up the 'EMS'. I appreciate that I am freely entitled to refer to these
required.

I certify that I have received training in all the aspects of Environmental Management as they apply to L J Fairburn & Son Ltd. In particular I
I have received individual focused training, and I hold certificates and/or work instructions for my activities which might impact upon the env

Initials Date
General Awareness Presentation
Environmental Management System File
Work Instruction WI EMS 1
Work Instruction WI EMS 2
Work Instruction WI EMS 3
Work Instruction WI EMS 4
Work Instruction WI EMS 5
Work Instruction WI EMS 6
Work Instruction WI EMS 7
Work Instruction WI EMS 8
Work Instruction WI EMS 9
Work Instruction WI EMS 10
Work Instruction WI EMS 11
Work Instruction WI EMS 12
Work Instruction WI EMS 13
Work Instruction WI EMS 14
Work Instruction WI EMS 15
Work Instruction WI EMS 16
Work Instruction WI EMS 17
Work Instruction WI EMS 18
Work Instruction WI EMS 19
Work Instruction WI EMS 20
Work Instruction WI EMS 21
Work Instruction WI EMS 22
Work Instruction WI EMS 23
Work Instruction WI EMS 24
Work Instruction WI EMS 25
Work Instruction WI EMS 26
Work Instruction WI EMS 27
Work Instruction WI EMS 28
Work Instruction WI EMS 29
Work Instruction WI EMS 30
Work Instruction WI EMS 31
DVD Lock, Stop and no leaking barrels

I am satisfied that ________________________________________ is fully aware of L J Fairburn & Son Ltd's EMS and is able to comply w
its requirements.
 Section 9
External documents

The external documents comprise an electronic file with a significant selection of

environmental data and guides etc.
L J Fairburn & Son Ltd Environmental Management System
COMPANY ENVIRONMENTAL OBJECTIVES CEOT Version 1

Environmental Description Obj. Objective Completed?

Aspect Ref
CO1 Communicate Environmental Policy and where relevant
Environmental Procedures.
UTIL 1 – 3 Energy CO2 Reduce manufacturing energy consumption to meet or
Consumption exceed CCL targets
MAN2 Legal compliance CO3 Ensure Legislative Compliance ref abatement failures.
(Including 'Duty of
Care', Planning Ensure Legislative Compliance ref bulk liquid storage.
conditions, PPC)
WASTE 1- 15 Waste Disposal CO4 Review waste stream segregation to maximise recycling
opportunities
WATER 6 - 10 Accidental Water CO5 Review Accident Prevention Procedures.
Pollution.
CO6 Establish an environmental performance monitoring
system.
UTIL 3 Reduce water CO7 Review Non-Process Water Consumption to identify
consumption opportunities for reducing consumption.
RAW 21 Use of Office CO8 Reduce Paper usage
Consumables
MAN 6 Active Energy CO9 Reduce Energy Consumption (non-manufacturing)
Management
Procedures
RAW10/RAW13 Use of Packaging CO10 Reduce Plastic/Pallet Consumption
Materials

The targets and monitoring associated with these objectives are recorded on the sheet CETS.
Site targets are monitored and records are held locally.

Issued By: Operations Director Page 1 of 1 Date First Issued: May 16 Last Update:
 L J Fairburn & Son Ltd Environmental Management System
Accident Management Plan – Huttoft Mill
Version No: 1 Issued By: Operations Director
Issue Date: May 2016 Review date May 2017

Site Address Huttoft Mill

Sutton Road
Huttoft
Lincolnshire
LN13 9RA
Phone Number 01507 490297 / 462264
Grid Reference of Site TF 513765
Nature of Business Animal Feed Manufacture
Operations Director Sarah Hall

EXTERNAL DISTRIBUTION Copies To Date Sent:

Environment Agency
Fire Authority

Up to date copies of electrical drawings and Drainage plans are stored in Mill &
Office.

CONTENTS

Page
Emergency Contact Numbers 2
Hazards on Site 3
Inventory of tanks and stores 4
Raw Material Type & Description 5
Emergency procedures: 6
Immediate actions 6
Secondary actions 7
Distribution within Company 10
Site plan 11

Page 1 of 11
 L J Fairburn & Son Ltd Environmental Management System
Accident Management Plan – Huttoft Mill
Version No: 1 Issued By: Operations Director
Issue Date: May 2016 Review date May 2017

EMERGENCY CONTACT DETAILS:

Emergency Services 999 or 112
Local Police SKEGNESS POLICE 01754 762222
Local Fire Station SKEGNESS FIRE STATION 01754 898980

Hospital(s) LOUTH COUNTY HOSPITAL 01507 600100

Environment Agency Hotline 0800 80 70 60

Local Office

Office Hours Out of Hours

Electricity Supplier N POWER 0800 073 3000
Electricity Network WESTERN POWER 0800 678 3105
Fuel Supplier - VARIOUS WOLDMARSH 01507 602396
Local Authority LINCOLNSHIRE 01522 552222
COUNTY COUNCIL
Maintenance Contractor (electrician) MAINTENANCE - ELECTRICIAN –
RICHARD DISNEY HALLGATE 01754
07769 974398 762857
Mill IT support DIGICUBE 01507 306903

COMPANY CONTACTS (Out of Hours)

Mobile Home
Operations Director Sarah Hall 07775 888825 N/A
Mill Manager Rob Clark N/A N/A
Transport Manager HARRIET BUTCHER 07703 859498 N/A
Managing Director DANIEL FAIRBURN 07770 597777 N/A

An up to date list of all site personnel contact details is held by Operations Director.

Page 2 of 11
 L J Fairburn & Son Ltd Environmental Management System
Accident Management Plan – Huttoft Mill
Version No: 1 Issued By: Operations Director
Issue Date: May 2016 Review date May 2017

ACCIDENT MANAGEMENT SITE PLAN

The Accident Management Site Plans include information of relevance for dealing
with accidents that may pose a risk of environmental pollution and pin points the
location of key equipment.

This includes:

 Site drainage details

 Mains water stop tap
 Main electrical supply isolator
 Location of Fire Extinguishers
 Storage areas e.g. bulk liquids, chemicals, fuel
 Spill kits
 Emergency Isolation points for Drains/Sewers

HAZARDS ON SITE

Refer to COSHH Data Sheets

HAZARD LOCATION(S)

Vegetable Oils See Site Plan Ref Fat Tank, Tank farm

Lubricating Oils and Grease See Site Fire Plan Ref Flammable
Chemicals (Mill Press Floor & Ground
Floor)
Waste oil See Site Plan Ref Waste Oil

Power Substations See Site Plan Ref Sub Station

Paint/Solvents/aerosols See Site plan Ref

(Empties stored)
Barrels of Oil See Site plan Ref Flammable Chemicals
(Stored)

Page 3 of 11
 L J Fairburn & Son Ltd Environmental Management System
Accident Management Plan – Huttoft Mill
Version No: 1 Issued By: Operations Director
Issue Date: May 2016 Review date May 2017

INVENTORY OF TANKS AND STORAGE

Location No, of Tanks or Size of Tanks Total Storage Capacity

Stores
Main tank farm N.W of 2 x Vegetable oil 20,000 Litre 50,000 Litres
Mill building A1 & 2 30,000 Litre
Mill area ground floor Waste oil FORKLIFT ON REPAIR AND Litres
MAINTENANCE AGREEMENT
AND WASTE OIL IS DISPOSED
OFF BY 3RD PARTY

In mill block 11 x 7 – 7.5Tonnes & 80 Tonnes

Raw Material Blending 1 X 5 Tonne Bin 5 Tonnes 85 Tonnes
Bins
Raw Material Silos 18 x Raw Materials
situated on all facades of Silos varing sized 677 Tonnes 677 Tonnes
building from 16 – 80 Tonnes
capacity
In mill block 1 x Mineral Bin 20 Tonnes
Silo west facade 1 X Mineral Silo 28 Tonnes 88 Tonnes
Silo East facade 1 X Mineral Silo 40 Tonnes

Mill building various Bag stocks 25 Tonnes 25 tonnes

ground and 1st floor
Bulk out-loading bins Finished products 1 X 12 Tonnes bin
East of mill building 1 X 20 Tonnes bin 122 Tonnes
3 X 30 Tonnes bins

Page 4 of 11
 L J Fairburn & Son Ltd Environmental Management System
Accident Management Plan – Huttoft Mill
Version No: 1 Issued By: Operations Director
Issue Date: May 2016 Review date May 2017

RAW MATERIALS AND THEIR DESCRIPTION

Raw Material Chemical Nature / Composition

Cereal grains Natural product: Cereal grains

Oil seed products and by-products Natural product: Oil seed products and by-products

Minerals Minerals (e.g. key materials being limestone and di-

calcium phosphate with smaller quantities of other
minerals such as sodium chloride, calcium magnesite,
sodium bicarbonate )

Vegetable oil Natural product: vegetable oils

Medicated Feeding Stuff – prescription Medicinal feed additives approved for use in the
required (MFS) Medicated Feeding Stuffs – no relevant species category
prescription required (MFSX) - YES

Acidifiers and Antioxidants YES Complexes of dry powder or liquid acids or aldehydes

Premixtures of Vitamins and Trace Elements Mixtures of vitamins (A, D3, E, K and B group), amino
acids (lysine, methionine, threonine), trace elements
(iron, copper, manganese, cobalt, zinc, iodine and
selenium (from sources such as oxides, sulphates,
iodates and selenites) and palatability enhancers.

Probiotics and Natural Extracts YES Complexes of natural plant materials and extracts.

Amino acid YES DL-Methionine, L-Lysine and L-Threonine

Ancillary Materials

Mineral oils, greases and Food grade complex hydrocarbons with additives
lubricants

Solvent cleaners Petroleum distillates

Page 5 of 11
 L J Fairburn & Son Ltd Environmental Management System
Accident Management Plan – Huttoft Mill
Version No: 1 Issued By: Operations Director
Issue Date: May 2016 Review date May 2017

Detergent cleaning chemicals Disinfectants approved by DEFRA for the purposes of the Diseases of
Animals (Approved Disinfectants) Order 1978 (as amended) specifying
the dilutions at which they are respectively approved.

Composition: Aqueous solutions of alcohol ethoxylate, Sodium

hydroxide, tri-sodium nitrotriacetate and tetrasodium ethylene-diamine
acetate.

EMERGENCY PROCEDURES

These are detailed as follows:

1. Immediate Actions

Actions to be taken by the person first at the scene. These procedures should be
posted and trained into all employees.

2. Secondary Actions – following on from the above

A detailed list of accident types with their consequences and the actions to be
followed depending on the type of incident/accident.

3. Business Recovery – Senior Management Responsibilities

The actions to be taken in the event of a major incident/accident leading to a serious

disruption to business are contained in the Business Recovery Plan held on the
Computer system: Business Recovery & Emergency Plans.

IMMEDIATE ACTIONS

IF YOU DISCOVER A FIRE

1. Immediately operate the nearest fire alarm call-point.

2. Obtain help from other members of staff nearby.
3. If necessary contact emergency services
4. Extinguish all naked flames without putting yourself or others at risk.
5. Leave the building by the nearest exit and make your way to the site entrance
beside the mill house.
6. Inform your Manager or supervisor of what you know about the fire.

IF YOU DISCOVER AN ACCIDENT

Page 6 of 11
 L J Fairburn & Son Ltd Environmental Management System
Accident Management Plan – Huttoft Mill
Version No: 1 Issued By: Operations Director
Issue Date: May 2016 Review date May 2017

1. Summon first aid. The First Aiders are:-

ROBERT CLARK AND ANDY TEESDALE

2. Summon an ambulance, as needed.

3. Inform your Manager or supervisor.
IF YOU DISCOVER A MAJOR SPILLAGE

1. Raise the alarm for assistance.

2. Help the injured if it is safe to do so.
3. Identify product and in all cases wear and use appropriate Personal
Protective Equipment.
4. Stop the source of the leak/spill if possible.
5. Try to prevent the spillage reaching the drains using Spill Kits located at
key areas of the site. (Marked as on the site plan)
6. If necessary isolate site surface drainage system by inflating a drain bung
at the exit point. These are incorporated with the spill kits.
7. Any liquids running to drains or the main weighbridge MUST be stopped.
8. Notify your line manager or supervisor and the appropriate authorities if
required – see Emergency Contact Details above.
9. Store and dispose of waste arising as a result of the spill response
correctly and in accordance with legal controls.
10. Do not enter tanks or confined spaces unless trained in correct
procedures and not before all procedures have been satisfied.

Any incident or near miss including those involving a contractor must be reported
to the Operations Director.

SECONDARY ACTIONS – Follow appropriate procedures for type of accident as

described in the following tables.

Page 7 of 11
 L J Fairburn & Son Ltd Environmental Management System
Accident Management Plan – Huttoft Mill
Version No: 1 Issued By: Operations Director
Issue Date: May 2016 Review date May 2017

Accident Type Anticipated consequences Action to be taken (Prioritised)

Spillages
 If possible quickly stem the source
Overflow or failure of:  Refer to Emergency Spill Procedures to minimise
 Bulk raw material liquid storage tanks pollution
 Bund failure o Use Emergency spill kits, pigs and matting,
to contain spillage and prevent further
Failure of automatic liquid level control devices spread.
o If the spillage cannot be prevented from
Chemical spillage entering the surface water drain, then
isolate drainage system at isolation point
Surface water flooding using the inflatable bung.
 Contact Site Manager or deputy.
Off site pollution at risk of entering site  Soil contamination  Refer to COSHH data sheets if appropriate
 Effect on sewage treatment works  If necessary contact Environment Agency
Contaminated surface water from fire fighting or  Potential effect on human health  Reduce tank contents to a safe level
other emergency activity.  Make temporary repairs if appropriate
 Arrange for the clean up and removal, of all spilled
Power Failure – leading to liquid, with an approved waste disposal contractor.
Failure of automatic liquid level controls and shut  All drains should be jet washed clean before removal
off valves leading to overflow of storage facilities. of isolation bung.
 Dispose of contaminated materials safely
Solid food grade raw material/finished product  Assess cause and take preventative action
spillage during unloading and internal conveying.
 Record incident using NCIR form.

Page 8 of 11
 L J Fairburn & Son Ltd Environmental Management System
Accident Management Plan – Huttoft Mill
Version No: 1 Issued By: Operations Director
Issue Date: May 2016 Review date May 2017

Fire
 Spreading between buildings and  Raise alarm on site
 Fuels and oils stores  Ensure all persons are evacuated from danger area
 Chemicals  Toxic and polluting smoke  If safe to do so, isolate power and fuel sources.
 Buildings  Wind dispersion of pollutants  Summon fire brigade
 Surface run off from fire fighting water  Contact Site Manager or deputy
 Surface run off from failed tanks,  If necessary contact Environment Agency
stores or pipe work  Liaise and follow instructions of emergency
 Exploding gas and fuel canisters services making them aware of risks and hazards.
 Dust and fibres from building materials Provide copy of Accident Management Plan
(may contain asbestos).  Refer to COSHH data sheets if appropriate
 Ensure fire fighting water and other liquids cannot
cause pollution – as above.
 Make temporary repairs if appropriate
 Arrange for the clean up and removal, of all spilled
liquid, with an approved waste disposal contractor.
 Dispose of contaminated materials safely.
 Assess cause and take preventative action
 Record incident
Abatement Failure  Shut down affected plant immediately
 Identify cause of pollution
 Grinder Exhaust  Dust emissions  Make temporary repairs if appropriate
 Local Exhaust Ventilation System  Arrange for the clean up and removal, of all spilled
contaminant, with an approved waste disposal
contractor.
 Dispose of contaminated materials safely.
 Assess cause and take preventative action
 Record incident using NCIR form
Page 9 of 11
 L J Fairburn & Son Ltd Environmental Management System
Accident Management Plan – Huttoft Mill
Version No: 1 Issued By: Operations Director
Issue Date: May 2016 Review date May 2017

DISTRIBUTION

NAME TITLE LOCATION

Sarah Hall Operations Director FARLESTHORPE HEAD
OFFICE
Rob Clark Mill Manager HUTTOFT MILLS
HARRIET BUTCHER Transport Manager BURGH LE MARSH
DANIEL FAIRBURN Managing Director ALL OVER
A copy is also held on the computer system under:
Business Recovery & Emergency Plans.

Page 10 of 11
 L J Fairburn & Son Ltd Environmental Management System
Accident Management Plan – Huttoft Mill
Version No: 1 Issued By: Operations Director
Issue Date: May 2016 Review date May 2017

Site plan showing spill kits  and fire assembly point

Page 11 of 11
Site Closure Plan

L J Fairburn & Son Ltd

Huttoft Mill

SITE CLOSURE PLAN

May 2016

1
 Site Closure Plan

Contents Page

1. INTRODUCTION Page 3

2. SITE ACTIVITIES Page 3

2.1 Installation Summary Page 3

2.2 Main Findings of the ASR Page 4

2.3 Potential Pollution Risks Page 5

Table 1 Table 1 - Main Potential Pollution Sources, Pathways and Impacts Page 6

3. CLOSURE PROCEDURES Page 10

3.1 Review of Accidents, Incidents and Near Misses Page 10

3.2 Review of Potential Pollution Sources Page 10

3.3 Decommissioning Page 12

4. MANAGING THE CLOSURE PROCESS Page 13

4.1 Responsibilities Page 13

4.2 Planning Page 13

4.3 Review Page 14

FIGURES

Figure 1.1 Site layout plan showing IED installation boundary and key activities Page 14

Figure 1.3 Site drainage plan Page 15

2
 Site Closure Plan

1. INTRODUCTION

Under Condition 1.4.1 Reference 3 of the IED Permit and in accordance with Section 2.11:
Closure, of the Food and Drink Sector Guidance Note (IPPC S6.10, August 2003), L J Fairburn &
Son Ltd is required to develop and maintain a Site Closure Plan “to demonstrate that, in its
current state, the installation can be decommissioned to avoid any pollution risk and return
the site of operation to a satisfactory state”.

The purpose of the Site Closure Plan is to address environmental pollution risks that may
occur during decommissioning of the site, and outline techniques to plan for and minimise the
effects of these potential risks.

The SITE CLOSURE PLAN draws on and references available information, including:

• Information and site plans included with the IED application submitted in June 2016;

• The Application Site report (ASR) submitted with the IED application;

• The site asbestos register;

• The register of hazardous materials held on site;

• Pollution, inspection and audit records; and

The SITE CLOSURE PLAN is designed to complement the Application Site Report (ASR) and is
designed to facilitate the Surrender Site report that is required to be submitted in the event
of site decommissioning or closure.

2. SITE ACTIVITIES

2.1. Installation Summary

The L J Fairburn & Son Ltd Blackdale site installation, operated by L J Fairburn & Son Ltd,
manufactures animal feed.

The installation activity is listed in Schedule 1 of the IED Regulations namely Section 6.8 A
(1)(d)(i):

“Treating and processing of vegetable raw materials intended for the production of food
products with a finished product production capacity of more than 300 tonnes per day”.

3
 Site Closure Plan

The activity undertaken at the installation includes 2 main production lines within the main
production building with several associated storage bins and bays.

The site is located in Lincolnshire in the Lincolnshire fens just off the A52 trunk road in the
village of Huttoft.

The site is centred on grid reference ; TF 513765.

The area of the installation covers about 2 acres.

The site comprises mill buildings, and associated storage tanks.

Production volume is anticipated to reach 100,000 tonnes by 2020.

The installation operates on a 24-hour basis, usually for 5½- 6 days per week and for 52 weeks
per year.

2.2 Main Findings of the ASR

An Application Site Report (ASR) was submitted in support of the IED Application. Whilst
focusing on land and water quality at the site, the ASR is one of the key references for the
purposes of producing this Site Closure Plan.

The main findings of the ASR are as follows:

Geology for Huttoft Mill

Alford (pronounced "Olford") is a town in Lincolnshire, England, It is situated approximately

11 miles (18 km) north-west from the coastal resort of Skegness, and at the foot of the
Lincolnshire Wolds, designated an Area of Outstanding Natural Beauty. Alford population is
about 3,500, measured at 3,459 at the 2011.
The Cretaceous sequence begins with the Wealden Group limestones, mudstones, sandstones
and siltstones which occur from Gibraltar Point in a band which narrows northwestwards to
the Caistor area. To their east, and stratigraphically above them, are the sandstones of the
Lower Greensand Group and beyond them the Chalk which gives rise to the Lincolnshire
Wolds and extends to the North Sea coast but is obscured along the coastal margin.

There is more detailed information in supporting information section 2 of this application

4
 Site Closure Plan

 Activities to be operated on the site relate to the treating and processing of grain,
additives and other materials to produce animal feed and associated activities;
 The site was purpose built for the treatment and processing of raw materials for
animal feed products and has been operated since 1979. Any contaminants that may
have been released by other historical industrial or agricultural activities may already
be present on site;
 Activities identified with a reasonable possibility of future pollution occurring include
delivery of red diesel for forklift trucks and front loader shovels.
 There will be a requirement for collection of reference data as part of the Site
Protection & Monitoring Programme for these areas of the site unless improvements
to pollution prevention measures were made in the interim. Improvements were
undertaken and the requirement to collect reference data was
reviewed.

2.3 Potential Pollution Risks

Table 1 summarises the main potential risks relating to sources of pollution on site, pollution
pathways and possible environmental impacts that may occur during decommissioning.

5
 Site Closure Plan

Table 1 - Main Potential Pollution Sources, Pathways and Impacts

Source Location Identified Identified Potential Pathway to Receptor Potential Impact

Receptors (during decommissioning)
Pollutant

Raw Materials, Packaging, Products and Wastes.

Drummed & Internal – stored Good grade liquid Local ground and  Infiltration into surface soils  Soil contamination
IBC liquid raw in dedicated raw materials groundwater.  Migration to and movement  Pollution of
drums in a within groundwater groundwater
materials
designated area  Migration through drainage  Effect on surface
network to surface water water
within the mill on
 Direct contact  Potential effect on
drip trays or
human health
sump pallets

Bagged raw Designated areas Good grade solid

materials (e.g. within the main raw materials
vitamins and process building
supplements and warehouses
and IBCs (tote
bins)

6
 Site Closure Plan

Drummed Internal – stored Including

liquid auxiliary in warehouse hydrocarbons,
materials (e.g. building and surfactants and
oils and point of use biocides
detergents)

Product Designated areas Local ground and  Infiltration into surface soils  Soil contamination
within the main groundwater.  Migration to and movement  Pollution of
Food grade solid within groundwater groundwater
process building Surface waters
and warehouses
raw materials  Migration through drainage  Effect on surface
network to surface waters waters
Waste oil Internal – stored Contaminated Local ground and  Infiltration into surface soils  Soil contamination
drums and in dedicated waste groundwater.  Migration to and movement  Pollution of
waste digest drums on drip hydrocarbons, within groundwater groundwater
trays within a food grade liquid  Migration through drainage  Potential effect on
network to surface waters human health
designated waste waste raw
 Direct contact (including
storage area materials
dermal/ingestion/inhalation of
vapours
Plant Infrastructure

Silos Internal – inside Food grade solid Local populace.  Dispersion in air  Particulates in air
main production raw materials Local ground and  Infiltration into surface soils  Soil contamination
Area and (e.g. cereals) groundwater  Migration to and movement  Pollution of
externally within groundwater groundwater
 Migration through drainage  Potential impact on

7
 Site Closure Plan

network to surface waters human health

 Direct contact (including
dermal/ingestion/inhalation of
dusts)
Tanks External – within Food grade liquid Local populace.  Dispersion in air  Soil contamination
dedicated raw materials  Infiltration into surface soils  Pollution of
Local ground and  Migration to and movement groundwater
bunded area (e.g.
molasses/soya
groundwater within groundwater  Potential effect on
 Migration through drainage human health
oil) and gas oil
network
 Direct contact (including
dermal/ingestion/inhalation of
dusts
Asbestos Refer to asbestos Friable asbestos Local populace,  Dispersed in air through the  Potential impact on
containing survey/register incorrect dismantling of human health
Groundwater, asbestos containing materials  Soil contamination
materials
soils  Deposition to soils, migration  Pollution of
to and movement within groundwater
groundwater
 Migration through drainage
network
 Direct contact (including
dermal/ingestion/inhalation of
fibres)

8
 Site Closure Plan

Demolition

Dust during Site wide Particulates Local populace.  Dispersion in air  Nuisance to local
demolition  Infiltration into surface soils populace
Local ground and  Migration to and movement  Contamination of
groundwater within groundwater soils
 Migration through drainage  Pollution of
network to surface waters groundwater
 Direct contact (including  Deposition on soils
dermal/ingestion/inhalation of
dusts)
Noise and Site wide Noise and Local populace  Dispersed in Air  Nuisance to local
vibration vibration populace
nuisance
during
demolition

Odour during Site wide Various odours Local populace  Dispersed in Air  Nuisance to local
demolition populace

9
Site Closure Plan

3. CLOSURE PROCEDURES

The closure and vacation of the L J Fairburn & Son Ltd Huttoft installation may pose
potential impacts on the environment, summarised in Chapter 2 of this report. Under the
conditions of the permit, it is necessary to adopt controls and practices to minimise any
environmental impacts whilst the site is operational. The following general principles will
also be followed during decommissioning.

3.1 Review of Accidents, Incidents and Near Misses

L J Fairburn & Son Ltd will conduct a comprehensive review of past accidents, incidents and
near misses by consulting incident logs and registers maintained within the Environmental
Management System.

3.2 Review of Potential Pollution Sources

The general principles will be applied for each of the potential pollution sources listed
below.
• Bulk storage bins
• Bulk storage tanks
• Bunds
• Unused materials
• Engineering materials
• Finished products
• Wastes
• Transformers
• Asbestos
• Drainage system

The following figures are included within this document to present:

Figure 1 - Site layout plan showing IED installation boundary and key activities, as presented
in the original IED application.

Figure 2 - Site drainage plan

3.2.1 Bulk Storage Silos

Raw materials are stored in bins located internally and externally within the installation:

These contain materials of vegetable origins, e.g. wheat and soya and minerals e.g.
limestone

10
Site Closure Plan

All storage bins would be emptied by incorporation into finished product and where this is
not possible the materials would be transferred to another mill to minimise waste
generation.

All bagged and IBC ingredients would also be transferred to the nearest compatible
Feed mill for incorporation into product.

3.2.2 Bulk Storage Tanks

Fat & Vegetable Oil; are used as ingredients in the animal feed. Approaching the point of
closure consumption of these materials would be carefully managed to ensure that all liquid
tanks were emptied and the materials used to make feed this will minimise wastage and
energy usage involved in transferring materials elsewhere. It also minimises the potential
for spillages. The empty tanks would be cleaned by approved specialists and any residues
would be disposed of by approved waste disposal contractor. The tanks would be of value to
another producer and would most likely be relocated to another feed mill. The bunds would
be cleaned and associated steel, brick and concrete works would be recycled.

Red Diesel; Diesel is used for the forklift operation and is stored in a self bunded tank, it is
also used to fire the boiler and a second self bunded tank is located in the bunded tank
farm. The fuel is dispensed to the forklifts via a key controlled pump located adjacent to the
tank. In the case of the boiler fuel there is a direct connection to the burner pump. In the
event of closure fuel stocks would be managed to ensure a nil stock on completion. Any
residue remaining in the tank and delivery system would be purged using inert gas and fuel
collected and used to power forklift trucks during the closure process. The tanks and pumps
would be transferred to another site or sold at auction.

Bunds

Decommissioning of bunds will, only occur after the decommissioning of the relevant
vessels they contain.

Bund water will be disposed in accordance with any potential pollutants, either to foul
sewer or as hazardous waste.

3.2.4 Unused Materials

Both raw materials and packaging materials which are suitable for their intended purpose
will be transferred to other sites. Materials which are unsuitable for use will be
appropriately disposed as waste.

Recycling or recovery opportunities will be maximised to minimise the quantity disposed to

landfill.

Special arrangements will be made for any hazardous wastes

11
Site Closure Plan

3.2.5 Engineering Materials

Workshop chemicals such as oils, greases, paints, aerosols, boiler chemicals etc. would be
transferred in their original packaging to other company sites as appropriate.

Any waste oils and solvents (including oily rags and other cleaning materials) would be
disposed of hazardous waste via a registered specialist contractor.

3.2.6 Finished Products

Finished product will be sold. Any finished product that cannot be sold will be disposed of
appropriately depending upon the nature of material and level of any contamination.

3.2.7 Wastes

All waste generated during the closure process will be segregated into streams appropriate
for recycling e.g. paper, cardboard, plastic, metals, oil etc. These waste streams will be
handled by registered contractors and all waste transfer documentation will be maintained
on file.

3.2.8 Asbestos

A full asbestos survey will be carried out on the site in the event of closure, however it is not
anticipated that any asbestos containing materials are present. This is due principally to the
age of the plant and buildings.

If the site was transferred to a new owner for continuing use it is anticipated that they
would take on responsibility for managing the asbestos risk. If the mill was to be demolished
then appropriate techniques would be employed to control the release of fibres from the
cladding sheets (as per HSE guidance HSG210) during the dismantling process. The sheets
would be removed intact and disposed of via a registered waste contractor as hazardous
waste.
L J Fairburn & Son Ltd will ensure that the Asbestos Register and current management plan
are up to date at the time of decommissioning.

3.2.9 Drainage System

The drainage system will be purged with water to clean the system, after all demolition
work is complete. Duty of care documentation and consignment notes will be held centrally
by L J Fairburn & Son Ltd for two years, or a minimum of five years for special waste.

3.3 Decommissioning

12
Site Closure Plan

3.3.1 Noise; the mill is surrounded by a several residential dwellings. All works would be
carried out to minimise disruption to the neighbours. The neighbours would also be
forewarned of any planned works.

Monitoring will be considered and undertaken as necessary to ensure the efficiency of

mitigation measures adopted.

3.3.2 Demolition of Buildings and Above Ground Infrastructure; if the mill buildings were
to be demolished then all of the preceding issues would need to be resolved first i.e. the
feed materials, liquids, fuels etc.

The plant would be made safe by isolating electrical, hydraulic and air supplies. The
production plant would be removed and sold/transferred to other sites.

The demolition engineers would be provided with copies of the drainage plans and
instructions not to put any materials into the surface water drains.

Air conditioning units would have their refrigerant recovered by a specialist contractor prior
to any dismantling work taking place.

The site would be handed over to a specialist demolition contractor once all equipment had
been removed and the site made safe and secure. This operation would be controlled by
CDM regulations and the planning would cover all environmental controls required which
would be recorded in the CDM file. The CDM file will include a copy of the Emergency Plan.

4. MANAGING THE CLOSURE PROCESS

4.1 Responsibilities; The Operations Director would have overall responsibility for the site
closure programme.

The Mill Manager would have day to day responsibility for implementation. Guidance and
support would be provided from the other members of the L J Fairburn & Son Ltd
management team and specialists as required.

The workshop facility would be maintained as long as the site was manned in order to
facilitate a controlled closure of the site. The engineering team would be retained
throughout the closure process as they have the necessary skills to ensure safe and
controlled shutdown of the operation.

The workshop is also the centre for specialist control measures such as emergency spill kits.

4.2 Planning; if the site was to be closed a senior management team would oversee the
planning of the process.

Any decision to close the site would take into account the environmental impact of the
closure and any associated demolition etc. that might be required. Technical expertise

13
Site Closure Plan

would be provided by the L J Fairburn & Son Ltd management team. EA, Local Authority,
Parish Council (including neighbours) and Workforce would be consulted on closure plans at
the appropriate stage.

4.3 Review; the Mill Manager will review the Site Closure Plan every 2 years to ensure that
the plan is up to date and additionally if there are related changes to the operation.

Figures

Fig 1.1 Site plan

14
Site Closure Plan

Fig 1.3 Drainage plan

15
Site Protection and Monitoring Programme
L J Fairburn & Son Ltd
Hottoft Mill

Version 1

Contents

Page 1 of 16
Executive Summary 3

1. Introduction 3

2. Objectives 4

3. Monitoring Programme 5

4. References & Revisions 8

5. Environmental Summary 9

6. Assessment of Land Pollution Potential. 10

7. Table of Polluting Substances associated with the Installation. 11

8. Assessment of the Effectiveness of pollution Prevention Measures. 13

Appendix 1 Site Plan 18

Appendix 2 Plant Overview 19

Appendix 3 Inspection and Monitoring Protocols 20

Page 2 of 16
Executive Summary

This document represents the Site Protection and Monitoring Programme (SPMP) for L J
Fairburn & Son Ltd, Hottoft submitted to the Environment Agency (EA) in pursuance of
Condition 4.6 of the Permit No EPR/HP3132/RN (the "Permit") authorizing “the treating and
processing of materials intended for the production of food products from vegetable raw
materials at plant with a finished product production capacity of more than 300 tonnes per day
(average value on a quarterly basis)”.

This document is Version 2.

The testing, inspection and maintenance programme for pollution prevention infrastructure at
the site (the Infrastructure Monitoring Programme) has been designed as detailed in Schedule
3. The results of the routine monitoring will be collated into a Monitoring Report and sent to
the EA on the 31st of January each year. The Monitoring Report will also contain
recommendations for changes to the SPMP (if any) to be formally agreed, in writing, by the EA.

An intrusive investigation for benchmarking purposes is not required in this case as no sources
were identified in the Site Condition Report (at the time of PPC application submission) as
having a ‘reasonable likelihood of pollution’. The measures in place plus further refinements
agreed will ensure that no pollution occurs. For the same reason an ongoing Environmental
Monitoring Programme is not proposed.

The potential sources of contamination identified in the Site Condition Report included the
vegetable oil and molasses delivery points; the minerals and salt delivery points; the light fuel
oil delivery point and the lubricating oils storage area which have containment measures
installed thus removing the need for collecting reference data in these locations. The site
drainage system was not identified as an area requiring the collection of reference because the
site run-off only consists of surface water drainage. Foul water associated with the site welfare
facilities is discharged to the public sewer under a trade effluent discharge consent.

1. INTRODUCTION

1.1 Introduction

L J Fairburn & Son Ltd is required to maintain a Site Protection and Monitoring Programme
(SPMP) for their installation Huttoft Mill, Sutton Road, Huttoft, Lincolnshire, LN13 9RA. This
SPMP has been produced by L J Fairburn & Son Ltd & AV Consultants, in accordance with the
conditions of the Permit EPR/HP3132/RN issued under Regulation 10 of the Pollution
Prevention and Control Regulations.

Page 3 of 16
This document is intended to be read in conjunction with the following supporting documents:
 Site Condition Report, dated 30 June 2016
 Permit, EPR/HP3132/RN dated

1.2 Installation Location

The installation is located at:

Huttoft Mill

Sutton Road

Huttoft

Lincolnshire

LN13 9RA

The centre of the site is at National Grid Reference TF 513765.

The site covers an area of approximately 1 hectare and can be seen in the site plan below.
1.3 Details of Installation
The site is located within an area of approximately 1 hectare, with the site boundary comprising
secure fencing and a lockable gate.
The Hottoft installation manufactures compound and blended animal feeds i.e. feeds which are
suitable for consumption by an animal without further processing. The products manufactured
are based upon core formulations of cereals (such as wheat and barley), soya, and rape seed
plus specific additives, such as mineral supplements. The processing is undertaken to a specific
formulation on a batch basis, with the key stages being weighing, grinding & mixing.
Depending upon the specific formulation, the required cereals etc. are pre-ground prior to
being weighed out in a uniform grist size. The blended materials are then transferred to the
mixing stage of the process, where they are mixed with pre weighed supplements and
medicinal feed additives used for prophylactic and therapeutic treatment. Following this, the
mix is now the finished product.
The finished product is then stored in silos prior to being automatically loaded to bulk vehicles
for delivery to customers on an as required basis.
External areas comprise car parking areas, of tarmac & concrete hardstanding, storage areas for
ingredients (bulk and drums), waste, bulk chemicals including fuel/oil, and a small area of soft
ground.

Page 4 of 16
2. OBJECTIVES

2.1 Report Objectives

The objectives of this report are:

2.1.1 To audit the monitoring programme for the installation to:
 Review and if necessary amend the inspection, testing and maintenance programme
for pollution prevention infrastructure at the installation to ensure their continued
integrity.

2.1.2 There is no requirement for a site investigation to collect reference data as there were
no sources identified as having a ‘reasonable likelihood of pollution’.

The potential sources of contamination identified in the Site Condition Report included the
following:

 Vegetable oil delivery points. The fill points outside of the bunded areas are protected by
catch trays under each fill point which would contain any spills and leaks. There are
procedures in place for the regular inspection and emptying of these catch trays and there
has been no staining to the ground since the catch trays were installed. Pneumatic control
valves are fitted on each fill line inside the bund. Sealing lines are also closed on
completion of the delivery and the fill lines have sealed screw caps fitted to the lines when
not in use. Kerbing provided around the liquid intake area contains any spillages and spill
kits are available in the case of an emergency.
 Minerals and salt delivery points. Pneumatic control valves are fitted on each fill line. Any
material spilled during filling would be cleaned up immediately as outlined in the
procedure.
 Storage of lubricating oils (205 litre drums). The drums have secondary containment
consisting of bunded trays that are designed to hold the capacity of each 205 litre drum.
The need for collecting reference data in this location has therefore been removed.
 Site drainage system. The site drainage system was not identified as an area requiring the
collection of reference data because the site run-off only consists of surface water
drainage. Foul water only consists of discharge associated with the site welfare facilities
Therefore it is very unlikely that C J Fairburn’s installation could cause ground
contamination thus eliminating the requirement for the collection of reference data.

3. MONITORING PROGRAMME

3.1 Objectives of the Monitoring Programme

3.1.1 Objectives of Infrastructure Monitoring Programme

Page 5 of 16
To test the integrity of the pollution prevention infrastructure currently in place and evaluate
the monitoring, inspection and testing programme in place to maintain the infrastructure as
detailed in sections 2.2.2 (emissions to water and sewer) and 2.2.5 (Fugitive emissions to
surface water, sewer and groundwater) of the IPPC application.

3.1.2 Infrastructure Monitoring Programme

In general, infrastructure will be monitored as part of the maintenance systems on site.

Maintenance of plant and equipment as far as is practicable is essential to minimise

environmental impact, ensure safe working of plant and equipment and sustain the production
of product to the required quality.

The maintenance activity is split between planned work and emergent work and coordinated by
the Mill Manager and Operations Director using both an internal site services team and external
resource for specialist testing / inspections.

Routine work includes examination and testing due to appropriate statutory requirements,
regulations, manufacturers and suppliers recommendations and as part of the company
planned maintenance system. Frequency of testing depends upon these criteria.

Planned (preventative) maintenance is undertaken to ensure the integrity and function of

critical equipment for production as well as equipment essential for environmental health and
safety. This is to maintain identified equipment in a safe, efficient and reliable manner.

The Operations Director and the Mill Manager co-ordinate staff and relevant sub contractors.
Competency of external specialists and contractors is reviewed by the Operations Team.

Planned maintenance tasks carried out by maintenance personnel may be subject to a permit
to work. Sub contractors are required to submit a work method statement and in some cases
are issued with a permit to work. Any records of equipment inspected and tested are kept and
maintained in the Engineering Department.

Emergency work is classed as breakdown work and is reviewed on an immediate and daily
basis. Upon discovery of a fault with plant or equipment, parties with an interest, e.g.
Production Manager, will liaise with the Operations Director (or Engineering support) to discuss
details of the work needed.

Any waste generated by maintenance activities is disposed of appropriately. Hazardous Waste

will be contained and labeled and disposed of via an approved contractor.

The infrastructure monitoring programme is summarized in OP08 & SP07 from the
Environmental Management System and comprises the following inspection programmes:

Page 6 of 16
Surfacing
The majority of the operational areas are covered with concrete hardstanding or tarmacadam
that is in good condition. However, outside the installation operations area and outside the
installation boundary there are a number of vegetated areas.

To ensure the integrity of impermeable hardstanding a programme of visual inspections will be

conducted:

All areas – once every year

In addition informal inspection is almost continuous by the mill staff. The mill staff are all fully
briefed in the various aspects of the EMS and in the event of a fault of any description to the
integrity of the hard standing, the details will be reported to the appropriate person. The fault
will then be addressed by the appropriate mans whether an incident under the accident
management plan or routine maintenance.

Subsurface Structures

There are no underground storage tanks in use on site.

The only other subsurface structures on site are the effluent drains.

Secondary Containment

All of the permanent above ground storage tanks have secondary containment. There is a
procedure in place for the inspection of main containment infrastructure which is linked to the
preventative maintenance programme to maintain integrity.

Visual inspection (for leaks and cracks) – weekly

Tanks and Associated Pipe Work

There is a procedure in place for the inspection of main containment infrastructure which is
linked to the preventative maintenance programme to maintain integrity. This covers the
inspection of tanks and associated pipe work.

Visual inspection - weekly

3.2.1 Personnel Issues

The following personnel are responsible for undertaking the infrastructure monitoring
programme:

Page 7 of 16
 Inspection Type Frequency Responsibility
Storage tanks, bunds, Visual Monthly Mill Manager
pipework
Outlet to water Visual Monthly Mill Manager
course
W1
Infrastructure and site Visual Annually Mill Manager /
condition Operations Director

Personnel responsible for the inspection, testing and maintenance of pollution prevention
infrastructure are trained to an appropriate level to ensure compliance with the Infrastructure
Monitoring Programme. The site operates an Environmental Management System (EMS) and
all such activities are covered by ‘Work Instructions’.

3.3 Assessment and Reporting Procedures

The assessment and reporting procedure will be carried out within the remit of the site
management systems.

3.3.1 Assessment Procedure

For infrastructure an assessment of the potential for containment infrastructure to fail will be
undertaken. The assessment will be carried out by responsible persons with suitable technical
and operational experience.

A summary of infrastructure monitoring data indicating any noted dysfunction of pollution

control measures and corrective actions will be forwarded to the EA.

3.3.2 Reporting Procedure

Infrastructure monitoring will be recorded as will summaries of any pollution incidents and
failure of containment measures resulting in emissions.

Summaries of the monitoring data and results of the data assessment will be submitted to the
EA on 31st January each year following the initiation of the SPMP together with
recommendations for any amendments to the SPMP.

3.3.3 Recording and Data Management

All assessment sheets used for the infrastructure assessment are stored in a secure location.

4. REFERENCES

4.1 References

Page 8 of 16
Site Report, dated 30 May 2016

Permit --------- dated ------------

Revisions

The SPMP was modified on the following dates as follows; (first issue)

5.0 Environmental setting

This section provides an assessment of the site sensitivity in terms of the underlying geology, the
groundwater resources and the hydrological context of the site.

5.1 Topography

The site lies at an elevation of approximately 2-3m above Ordnance Datum (aOD) and is virtually level
and flat.

5.2 Geology

The geological map extract shows the area of installation site and the surrounding area.

Table 5.2.1 Summary of Site Geology & Hydrogeology

Alford (pronounced "Olford") is a town in Lincolnshire, England, It is situated approximately 11 miles (18
km) north-west from the coastal resort of Skegness, and at the foot of the Lincolnshire Wolds,
designated an Area of Outstanding Natural Beauty. Alford population is about 3,500, measured at 3,459
at the 2011.
The Cretaceous sequence begins with the Wealden Group limestones, mudstones, sandstones and
siltstones which occur from Gibraltar Point in a band which narrows northwestwards to the Caistor area.
To their east, and stratigraphically above them, are the sandstones of the Lower Greensand Group and
beyond them the Chalk which gives rise to the Lincolnshire Wolds and extends to the North Sea coast
but is obscured along the coastal margin.

There is more detailed information in supporting information section 2 of this application

5.3 Hydrogeology

The Lincolnshire Limestone forms an important aquifer in the Lincolnshire area. The groundwater
abstracted is used mainly for public supply, but also supplies agricultural, industrial and private needs.
The Lincolnshire Limestone crops out in the west of the study area, but dips gently eastwards where it is
progressively covered by younger deposits where confined conditions prevail. The direction of
groundwater flow generally follows the direction of dip to the east. The Lincolnshire Limestone aquifer
provides a good case study for examining the geochemical changes in groundwater chemistry which
take place in the direction of groundwater flow and as such the hydro geochemistry of the aquifer has

Page 9 of 16
been well-studied in the past. In addition to the effect of increased residence time permitting greater
water-rock interaction, the geochemical processes of carbonate dissolution and equilibria, ion-
exchange, redox reactions and mixing with old formation water are all significant in determining the
groundwater chemistry in the aquifer.

5.4 Hydrology

The Fens Area: The Fens cover a large area of eastern England, stretching from the Wash out to Lincoln,
Peterborough and Cambridge. Five different rivers, the Witham, Welland, Glen, Nene and Ouse, carry
water from surrounding uplands through the Fens and into the Wash.

Management Plans for the Fens: The Environment Agency has developed Catchment Flood
Management Plans for the Anglian Region with the aim of taking a broad view of flood risk at catchment
level over the next 100 years. Factors such as climate change, future development and changes in land
use and land management were taken into account in developing sustainable policies for managing
flood risk in the future.

5.5 Ecology

There are no Sites of Special Scientific Interest close to the site.

There are no areas of conservation, within 1km of the site.

5.2 Vulnerability of site to contamination

The sensitivity of receptors in the vicinity of the site to contamination is summarised in Table 5.2.1.

Table 5.2.1. Sensitivity of Receptors in the Vicinity of the Site.

Receptor Receptor(s) Sensitivity Reasoning

Type
Ground Minor Aquifer Low Localised aquifers groundwater body, bedrock and the localised
water aquifers groundwater body. Water course is the nearby drain
which in turn feeds the south Fen drain. The greatest concern is
nitrates run off, not associated with Huttoft mill.
Surface These comprise Low The site storm water run-off is directed to the nearby drain
water sections of the which flows into the South Fen Drain and ultimately the
man-made Fens north sea.
drainage system
Ecological None reported - Not applicable
Farming and Commercial arable Very low The operations at the installation will have no impact on
forestry farming these areas indeed the installation supports agriculture.
The fugitive emissions are organic residue from crops and
as such do not pose a hazard.

Page 10 of 16
6.0 Assessment of land pollution potential
6.1 Identification of Potentially Polluting Substances

A list of the major substances used, manufactured and stored within the installation (or waste by-
products from the manufacturing process) is contained in the supporting information Section 5,
elsewhere in this application. An assessment of their pollution potential has been made based upon
their properties, toxicity and the volume stored. This information is recoded in detail in the Aspects
Register of the Environmental Management System (EMS). The materials and substances used within
the installation are also assessed in the environmental risk assessments in supporting information
section 4.

7.0 Table of Polluting Substances

The tables below are taken from the Site Condition Report written by AV Consultants and
submitted in support of the PPC application in June 2016.

Assessment of Pollution Potential for Substances Associated with the Installation

Substance Liquid or Volumes Toxicity/ Fate/ Pollute land if Considered

(contaminants) Solid Stored Mobility released? Further?
Pollute land if
released?
Raw Materials
Cereal grains, Solid Various silos, bins Solid materials so limited mobility. Unlikely x
Oil & seed (grains) and flat store bays 100% of material ends up in
products & totaling 2,200 product. Large quantities used on
minerals tonnes site but biodegradable.

Vegetable oil Liquid 1 x 40 tonnes Biodegradable but mobile in the Possibly 

water environment. Used in
relatively large quantities.
Vitamins & Powder 20 or 25kg bags No persisting environmental Possibly 
mineral effects; large volumes stored and
additives potential suspended solids and
high BOD levels in surface waters.
Chemicals
Fuels, Oils and Greases
Lubricating oils Liquid In 205 and 25 litre Slight health hazard, not an Yes 
drums irritant, stable in storage.
Moderate to high biodegradability.
Waste oil Liquid Bulk storage Mobile especially below water Yes 
(hydrocarbons, tank bunded, table. Biodegradability and low
PAHs) transfer by hand toxicity vary according to chain
length.

Page 11 of 16
Substance Liquid or Volumes Toxicity/ Fate/ Pollute land Considered
(contaminants) Solid Stored Mobility if released? Further?
Pollute land
if released?
Products & Waste Materials

General wastes Solids Stored in skips Limited mobility, solids, Unlikely x

biodegradable.
Surface and foul Liquid Not known, Biodegradable but could impact Yes 
drainage drainage in groundwater quality locally.
(organic matter, pipework
chemical
residues,
hydrocarbons)
Scrap Metal Solid Stored in skips Limited mobility, solids, low Unlikely x
Degradability
Waste pallets Solid Stored outside, Limited mobility, solids, moderate Unlikely x
small quantities degradability

Assessment of the Effectiveness of Pollution Prevention Measures

Potentially Relevant Relevant Records Containment Measures Planned Likelihood

Polluting System Activity Of Pollution Testing & Of Pollution?
Substance Inspection
Regime*
Vegetable Oil Production Delivery No evidence of Primary: Tanker Delivery is Little
and leaks or spills at Secondary: Fill point Supervised, Likelihood
processing fill point Above small bund Tertiary: material would
Concrete hard standing and quickly solidify if
drainage system (adjoining soft spilt.
cover)
Storage No evidence Primary: Bulk storage Visual checks as Little
or records of tank part of normal Likelihood
spills/leaks Secondary: Concrete operations
bund
Tertiary: Concrete hard
standing and drainage
system
Transfer No evidence Primary: Above ground Little
or records of pipework Likelihood
spills/leaks Secondary: None
Tertiary: Indoor flooring

Page 12 of 16
Potentially Relevant Relevant Records Containment Measures Planned Likelihood
Polluting System Activity Of Pollution Testing & Of Pollution?
Substance Inspection
Regime*
Minerals Production Delivery Some Primary: Tanker Delivery is Slight
(bulk tanker & evidence Secondary: None supervised possibility
delivery) processing of minor Tertiary: Concrete hard
leaks and standing and drainage
spills at system
fill point

Storage No evidence Primary: Bulk storage Visual checks as Little

or records of tank part of normal Likelihood
spills/leaks Secondary: None operations
Tertiary: Indoor flooring

Transfer No evidence Primary: Above ground Little

or records of pipework Likelihood
spills/leaks Secondary: None
Tertiary: Indoor flooring

Vitamins & Production Delivery No evidence Primary: Flat bed lorry Delivery is Little
mineral & or records of Secondary: None supervised Likelihood
additives processing spills/leaks Tertiary: Indoor flooring
(pallet
delivery) Storage No evidence Primary: Plastic/paper Visual checks as Little
or records of bags part of normal Likelihood
spills/leaks Secondary: Pallets operations
Tertiary: Indoor flooring

Use No evidence Primary: Carousel bins Added to Little

or records of Secondary: None process by Likelihood
spills/leaks Tertiary: Indoor flooring trained
personnel

Potentially Relevant Relevant Records Containment Measures Planned Likelihood

Polluting System Activity Of Pollution Testing & Of Pollution?
Substance Inspection
Regime*
Lubricating oil Plant Storage Staining Primary: 205 litre drum Visual checks as Reasonable
maintenance and (2) and 25litre containers part of normal Possibility
evidence Secondary: Catch tray operations
of leaks Tertiary: Concrete
on ground hardstanding and storm
drainage system

Waste oil Oils arising Storage No evidence Primary:1,100 Litre Bulk Visual checks as Little
from plant or records of storage part of normal Likelihood
maintenance spills/ leaks tank operations
Secondary: Bunded tank
Tertiary: Concrete
hardstanding and storm
drainage system

Surface and Site Site No evidence of Primary: Underground No CCTV or Reasonable

foul drainage drainage drainage leaks but drainage network integrity testing Possibility
system possible given Secondary: None of network to
age of site Tertiary: None date

Page 13 of 16
Appendix 1 Site Plan

Page 14 of 16
Appendix 2 – Plant Overview
The Hottoft Mill installation manufactures compound animal feeds i.e. feeds which are suitable for
consumption by an animal without further processing. The installation has been in operation as a mill
since 1824 but as a feed mill since the 1050s it produces a wide range of chicken feeds to meet specific
customer demands. Products are manufactured on four process lines. Typical production from the
installation will total up to approximately 100,000 tonnes per year from 2020 of finished product. The
installation typically operates 24 hours a day, 5 or 6 days a week and for 52 weeks a year. There are
some directly associated activities which include storage and handling of raw materials and waste.

The products manufactured are based upon core formulations of cereals, vegetable proteins, oilseed
extraction products, vegetable oils etc, plus specific additives, such as mineral and vitamin supplements.
The processing is undertaken to a specific formulation on a batch basis, with the key stages including
weighing, grinding and mixing.

Depending upon the specific formulation, the required cereals etc. are put in enclosed weighers after
grinding to a uniform grist size. The ground materials are then transferred in enclosed conveyors to the
mixing stage of the process, where they can be mixed with vegetable oils. Following mixing the batch
becomes the finished product. The finished products are then conveyed to storage silos prior to dispatch
to customers. Products are automatically loaded into bulk vehicles for delivery to customers on an as
required basis.

Suitable controls are in place for handling of raw materials, wastes and products such that the potential
for emissions for these activities is minimised. Where appropriate, a range of abatement systems are
employed throughout the process to remove particulate matter.

The installation has a drainage system for surface water, to collect the water from roofs and
hardstanding areas. Surface water is then discharged to a nearby drain to the east of the site.

Appendix 3 - Infrastructure Monitoring Protocols

Infrastructure Protocol Monitoring Frequency Assessment Personnel

Roadways & hardstanding Visual inspection in All areas (& Appropriately trained
accordance with roadways) – annually personnel / managed by
developed ‘operating the Mill Manager
procedures’
Sub surface structures Visual inspection in Visual inspection of drains Appropriately trained
accordance with annually personnel / managed by
developed ‘operating the Mill Manager
procedures’
Secondary containment Visual inspection for leaks All bunds – once/month Appropriately trained
(bunding arrangements) or cracks personnel / managed by
the Mill Manager
Pipe work and bulk tanks Visual inspection for a loss All bulk tanks and Appropriately trained
of integrity associated pipe work personnel / managed by
annually the Mill Manager
Specialist statutory work As per relevant
(pressure systems etc) regulations
or manufacturers
recommendations

Page 15 of 16
Page 16 of 16
 Huttoft Mills Organisational Structure

MD

Directors

H&S Mill Manager Transport Group Finance

Manager Controller

Duty Mill
Manager
Finance / HR Admin
/Admin Support
Drivers Mechanic

Mill Ops
Admin Support

4.8.2016
 L J Fairburn & Son Ltd

ENVIRONMENTAL POLICY

MISSION STATEMENT

L J Fairburn & Son Ltd cares about the environment and is committed to protecting it. Our
corporate strategy is for all our employees to do all that is practicable to achieve this.

OUR PRINCIPLES ARE TO:

 Design, operate and maintain all of our operations in an environmentally responsible

manner, complying with all relevant legislation.

 Continually improve our environmental performance with the aim to optimise

energy consumption in relation to production levels and product quality, prevent
pollution, minimise waste and consumption of natural resources.

 Maintain an Environmental Management System including procedures for

environmental monitoring and control of our operations.

 Produce environmental objectives with realistic and achievable targets.

 Produce adequate training and information to our employees to ensure the relevant
knowledge and experience is acquired and maintained for successful implementation
of this policy.

 The Company’s Environmental Policy and its implementation is the direct

responsibility of the Directors of L J Fairburn & Son Ltd and it will be reviewed and
revised as necessary at regular intervals to ensure its continuing relevance.

This Environmental Policy can only be effective with the support and efforts of every
member of staff, our suppliers and contractors.

Sarah Hall

Operations Director Date

 ENVIRONMENTAL INSPECTION RECORD
EMS F4 WEEK No. YEAR:

Wk
EQUIPMENT CHECKS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

Drip trays in place & empty

Liquids handling (daily) RESPONSIBILITY: PRODUCTION MANAGER

Monday

Tuesday

Wednesday

Thursday

Friday

Spill kits checked and

replenished (weekly)

Bund wall integrity, security

Tanks & empty (montlhy)

EQUIPMENT CHECKS 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52

Drip trays in place & empty

Liquids handling (daily) RESPONSIBILITY: PRODUCTION MANAGER

Monday

Tuesday

Wednesday

Thursday

Friday

Spill kits checked and

replenished (weekly)

Bund wall integrity, security

Tanks & empty (montlhy)