FMJ.CO.UK ENVIRONMENTAL MANAGEMENT FOCUS
CHANGE OF ENVIRONMENT
The experts from Adler and Allan off er some insights into the range of macro-economic events that
may have an impact on environmental management operations next year
DECEMBER/JANUARY 2021 39
The world remains in crisis as
the Coronavirus pandemic
continues to rage and climate
change action gathers pace. Closer
to home preparation will turn to
action as Britain leaves the EU
at the turn of the year, resulting
in several overnight changes to
regulation. Industries will use 2021
to prepare for the new Environment
Bill which will come into force in
2022, introducing legally binding
targets for nature, water, air, and
waste. Finally, changes in red diesel
legislation due in 2022 will require
industries to switch fuels and plan
new maintenance regimes in 2021 to
ensure they are prepared.
Let’s start with Brexit and the impact
on chemical manufacturing and
import.
REACH, BY BILL ATKINSON, CHIEF
SCIENTIFIC ADVISER
The legislation governing chemical
supply will switch from EU REACH to
UK REACH a er Brexit. Registration,
Evaluation, Authorisation and
Restriction of Chemicals (REACH)
applies to chemical substances
manufactured or imported into
the European Union in quantities
of one tonne or more per year. It
requires manufacturers, importers
or distributors of chemicals to
register them with the European
Chemicals Agency or ECHA, otherwise
they cannot legally be imported,
manufactured or supplied.
Registration with UK REACH a er
Brexit is likely to follow closely the
process under EU REACH. However,
as a UK-based storage facility, if
you handle chemicals going to or
coming from European countries, the
products may well have to comply
with both the UK and EU versions of
REACH.
It is the responsibility of individual
companies to assess their operations
and decide whether they need to
comply with both the UK and EU
regimes, or just one.
Brexit
It has been widely reported that a
no deal Brexit will not impact fuel
supply, but it could impact the routine
delivery of food and medicines. The
UK imports 40 per cent of its food,
with around a third coming from EU
member states. It is believed that
up to 60 per cent of hauliers might
not have the correct paperwork
on 1st January. This will inevitably
cause disruption, however, ensuring
your fuel infrastructure is safe and
compliant will leave you free to focus
on the paperwork required to navigate
Brexit.
ONGOING PANDEMIC, BY BRYAN
CHERRY, ENVIRONMENTAL RISK
SURVEY MANAGER
Environmental risks from business
operations are present regardless
of the current pandemic. However,
the changes brought about by the
pandemic can contribute to increasing
the likelihood of an incident occurring
and, therefore, making the associated
risks greater.
Some of these changes include key
sta absences, irregular sta presence
on site, increased workload/outputs
and irregular stopping and restarting.
These challenges could lead to an
increase in leaks and spills and a
greater impact from incidents as they
might not be identified as quickly or
responded to as e ectively.
Having an emergency response
contractor who is familiar with your
operations will ensure that if an
incident does happen, it can be dealt
with swi ly and compliantly.
Maintenance issues on sites
The same challenges could also
mean that maintenance schedules
get overlooked and as equipment is
used sporadically, this could result
in more maintenance issues. Having
an environmental risk reduction
specialist contracted to ensure your
maintenance regime continuity isn’t
interrupted will ensure your operation
remains safe and compliant and will
help give you one less thing to worry
about during this di icult period.
ENVIRONMENT BILL, BY MATTHEW
HUMPHREYS, NATIONAL ACCOUNT
MANAGER
The UK will introduce new legally
binding nature, water, air, and waste
targets from 2022. The Environment
Bill will set out the Government’s
ambition to ensure the environment
is protected following the UK’s
departure from the EU.
The introduction of the Environment
Bill will enhance wildlife, tackle air
pollution, transform how the UK
manages its resources and waste,
and improve the resilience of water
supplies. The targets imposed will
impact industries in di erent ways.
Regulated industries such as the
water companies have already been
put under huge pressure to reduce
spend throughout the current Asset
Management Plan Cycle (AMP) 7 cycle.
However, the Environment Bill will
drive requirements for wholesale
improvements in assets such as
bund and drainage installation and
maintenance across estates in
order to achieve a greater level of
environmental protection.
Businesses need to first identify
their environmental risks. A strategic
programme of remediation works
can then be scheduled based on the
level of priority that will help meet
the requirements of the Bill. We will
be working with all our customers
in 2021 to help understand their
specific challenges with regards to
the potential new targets and how
they can achieve them e ectively and
compliantly.
CHANGES TO RED DIESEL
LEGISLATION, GARY HICKEY,
SPECIALIST FUELS SERVICES
DIVISION DIRECTOR
In the 2020 budget, the government
announced that it will remove the
entitlement to use red diesel from
April 2022, except in agriculture
(as well as forestry, horticulture
and pisciculture), rail and for noncommercial
heating (including
domestic heating). These reforms are
important for tackling climate change
and improving the UK’s air quality.
Many sites still use red diesel for
back-up power generation which
will need to be replaced with white
diesel before 2022. There will be an
immediate cleaning requirement
for these tanks and companies will
need to consider adjusting their tank
maintenance schedules to adapt to
the new diesel formulations.
Companies using red diesel
across their sites will need to start
planning to switch fuels, and to
ensure operational continuity, should
consider changes required in tank
cleaning and maintenance regimes.
A CHALLENGING YEAR
No one can deny that 2021 is going to
be a challenging year. However, with
planning and the right partners you
can reduce downtime and ensure your
operation remains compliant while
you focus on getting business done.