An Environmental Management Plan for Small Business
Why you need to be proactive with environmental management
Regardless of the industry, you are involved in your business has a responsibility to be environmentally compliant. Almost all businesses large or small will have some impact on the environment and as a result, should have an environmental management plan in place that helps minimise this impact.
It’s not the just the environment that benefits, however. There are plenty of additional benefits for environmentally friendly small businesses. For example small businesses with an effective environmental policy will also benefit in the form of cost cutting due to developing more sustainable practices, a distinct competitive advantage over business who are not environmentally compliant (less chance of negative publicity) and your business will be seen as environmentally responsible which in many cases will help open new doors and aid in your marketing efforts, helping position your business as a responsible entity.
Your legal obligations
It also just so happens to be the law. There are heavy fines in place for those businesses who are responsible for harming the environment and these laws are heavily enforced. As the public’s awareness of the environment increases the chances of being reported to the Environmental Protection Agency (EPA) or Department of natural resources and mining (DERM) also increase.
A business that has an environmental management plan in place reduces the possibility of being reported and is also seen as proactive when it comes to their environmental impact in the event that there was an issue reported.
What is an environmental management plan
So while it obviously makes sense to consider the environment where should a small business owner start the process of becoming environmentally compliant?
The main focus should be on the development of an environmental management plan (EMP). This is simply a plan that is unique to your business and outlines:
- Environmental issues the business may face
- The potential outcome of these issues
- How the business plans to manage these issues e.g. (monitoring and implementation)
In short, it’s essentially a plan that details the proposed risks your business may pose to the environment and how your business plans to minimise the potential of these risks and an operational guideline in the event of an environmental incident. It’s also an essential training resource for your current staff and any new employees.
As a small business owner, it’s easy to become complacent. We’re small business owners ourselves and understand the many obstacles and loopholes a business owner faces when it comes to safe work practices and an endless stream of paperwork to fill in.
An EMP, however, shouldn’t be seen as just another piece of documentation the small business owner has to complete to keep the authorities satisfied. It should be given the appropriate consideration from all staff and management. In short your responsibility to the environment requires ‘buy-in’ from all involved in your business. The most effective environmental management plans aren’t complicated, they are straightforward and understood by all involved. They are also monitored and refined over time to improve your workplace’s environmental practices. In some cases, this may involve appointing an environmental manager so your business has a staff member who is responsible for ensuring your EMP is followed and all staff is trained and understand their responsibilities.
Developing an EMP
Before developing an EMP for your business it’s helpful to take a closer look at what’s involved so you have a higher chance of developing an effective EMP.
1) Identifying your environmental impact
The first step is understanding what risks your business poses to the environment. This includes the potential to pollute waterways e.g. stormwater, wastewater, erosion or soil contamination, air pollution and noise pollution. It’s important to be thorough and includes all activities the business undertakes. If for example, the small business in question was a surf club one of these activities might include refueling of the rescue boats or vehicle washdown. In most cases, the list of activities will be fairly lengthy.
Once you have developed a list of activities carried out by the business it’s important to identify the potential risks these activities present. It’s suggested that the risks are prioritized e.g. low risk, moderate risk, and high-risk activities. This helps the business owner with focusing on the most urgent requirements first.
In the case of the surf club mentioned above, surf rescue boats typically being two-stroke engines may require that a small quantity of oil is stored on the premises. The impact of an oil spill could be considered a moderate risk and also draw unwanted attention in such a public location as the beach.
2) Involve your staff
You should also interview staff members and seek input on the environmental impact of your business. This is important, your staff will often be responsible for the activities that pose a potential threat to the environment and while helping identify the risks will also be on board from the start when developing your EMP. This will also help with training and be identifying the best candidate for the position of an environmental manager if this is required for your business.
3) Incident reports, previous environmental issues
Clearly, if you have recorded any previous environmental impact reports these should also be observed and considered before developing an EMP. This might include accident reports, environmental issues that arise as a result of severe weather events and complaints you may have received from the public.
Once you have armed yourself with the above information it’s also wise to audit your workplace and indemnity any potential risks that may not have been picked up in the activities listed above. For example, you may have issues with liquid storage that need to be addressed or your personal protection equipment (PPE) may need to be renewed on a regular basis.
In some cases, it’s wise to engage an environmental consultant to assist with this step. As the business owner, you may even consider engaging the consultant to develop the EMP for you. While this sounds fine in theory it’s important that the environmental management plan is integrated into your business and treated accordingly as a result. If not handled by the business owner, management or staff then training will be required which can in most cases also be arranged by the consultant.
Controlling the impact of your business on the environment
The next step in developing your EMP should be the actions you will undertake to minimise the environmental impact of your business, this includes:
- Planning for reducing your environmental risks (e.g. better storage practices for hydrocarbons stored on the premises)
- Controlling the risk (e.g. performing regular environmental audits)
- Developing an action plan in the event of environmental issues. (e.g. a procedure for handling hazardous liquid spills)
Avoiding environmental incidents
Before you begin formally writing your EMP it’s also good practice to look at anyways you can avoid an incident occurring in the first place. A good time to consider how to avoid issues is after you have completed your site audit.
Methods to avoid an incident should be prioritized e.g. in the event of a warehouse that stores hazardous liquids the business owner or environmental officer should ask themselves the following:
- Can any potentially harmful liquids be replaced for a safer alternative?
In many cases, there are less harmful alternatives available that you may not be aware of.
- Are there any hazardous liquids you no longer require?
In many warehouse environments, older products that are no longer used may still be stored on the premises as it is difficult to safely dispose of them.
- Is it a suitable area for the task being carried out?
In the case of the surf club, there should be a dedicated refuel area (defined as a low-risk area when it comes to spills). A low-risk area would take into account locality to an open drain, proximity to fire hazards and other staff.
- Are there physical barriers in place to limit the spread of a liquid spill?
In most cases we are referring to bunding. Essentially bunding is a physical barrier that localises a potential spill in a storage area. Bunded pallets are also available as a secondary containment product.
Once we have looked into ways to minimise our risk it’s time to start developing an action plan, We’ll use the example of a hydrocarbon spill.
- Identify the risk
The main risk with any liquid spill is the potential to pollute our waterways via the stormwater network. There’s also the secondary concern of it being a slip hazard.
- Who’s responsible?
The EMP should outline who’s responsibility a particular environmental hazard would be.
- What resources should be used?
In this case, a fuel and oil spill kit which is hydrophobic (won’t absorb water) should be located in an easy to access area.
- What is the correct procedure?
The correct procedures for containing the spill (avoiding it entering the stormwater network) should also be outlined and included on the spill kit itself.
Again this shouldn’t just be seen as merely a requirement to keep the authorities happy. You can minimise your impact on the environment and reduce your risk of a fine by following basic protocol and not neglecting your environmental responsibilities.
Any action plan should be straightforward and easily understood by all staff. There shouldn’t be room for the steps to be misconstrued. It should also be obvious who the person responsible for the spill being addressed is. Our advice is to just keep it simple and effective and minimise any chance of the EMP not being followed to the letter of the law.
Maintenance and refinement
It’s not enough to simply have an EMP in place, it should also be monitored to ensure it is working as intended i.e. minimising your environmental impact. For this to be effective it needs to reviewed periodically and improved where possible.
This might include regular checks of storage areas, ensuring machinery is serviced regularly, regular training for staff checks to ensure correct procedures are being followed and getting regular feedback from your staff and any incident reports. Armed with this information you can refine your EMP over time to be more effective for your business.
It’s also important to stay up to date with current environmental legislation. Governing bodies such as the EPA consider it your responsibility to stay up to date with legislation that affects your business.
As an environmentally responsible business, it’s your duty to have systems in place for reporting incidents. It’s important that incidents are reported internally and if the incident is significant reported to the local authority. Report forms should be made available to appropriate staff and an incident report should be lodged.
As you can see, an EMP is essential for any environmentally responsible business. Developing an EMP doesn’t need to be complicated but it does need to cover all potential environmental issues your business may be at risk of causing. Trade Enviro can assist with helping you develop an effective EMP, for more information feel free to contact us.