SPEN Contractor Environmental Audit

• Site conducted

  Select

• Conducted on

  Date

• Prepared by

• Location
  Address

Preparation Element

• Does the contractor hold an environmental managements system that is certified externally to ISO14001 or similar?

• Does the scope of the EMS include the work being undertaken for SPEN?
  
  A copy of the latest external audit report would enable this point to be addressed.
  
  Is everything in date? When is the next recertification due?

• Does the EMS include procedure(s) for the assessment of risks from site work and the implementation of controls?

• Procedure(s) should cover the relevant risks, including at least:
  
  pollution to water, land and air,
  
  protected species and features and INNS,
  
  noise/vibration/light management,
  
  incident/near miss reporting and response,
  
  site audits/tours.
  
  Controls should be identified and implemented for any significant risks identified.
  
  Procedure should also identify any permits/licences or GBRs applicable to the works and the controls for compliance.

• Has the contractor been subject to a regulatory intervention related to SPEN work or separately?

• Any form of regulatory intervention in response to incidents or inspections is considered here.
  
  Notices, regulatory actions requiring a response to the regulator, civil penalties and fines are all relevant.

• What environmental related training is provided to company staff?

• List of training should be relevant to the risks associated with the work. A description of the training needs assessment and delivery process should be included.
  
  Training records should be kept and described. Records kept on site should be specified.

• How is environmental information made available to staff such that work on site can be undertaken appropriately?

• What can you expect to see or the staff to know how to access from the site?

• How has the auditee considered waste, carbon and resource minimisation?

• What has been considered?
  
  Guidance on SWMPs Netregs SWMPs
  
  Consider the waste hierarchy – can it be shown to have been applied in the planning stage?
  
  How is the contractor planning to contribute to SPEN target of avoiding landfill for 95% of waste by 2023?

General Information and Incidents

• Is there any environmental notice/policy/information area at the site or accessible virtually?

• May well be covered by preparatory questions, staff can be asked what they know about it.

• If there is a site induction, does it cover environmental elements?

• Incident reporting, waste management, key control equipment

• Is there a site map with high-risk activity areas, fuel and chemical storage, waste storage, environmental receptors?

• Smaller sites may have limited information, but relevant information should be available for sites with significant risks.

• Have any environmental incidents occurred at the site?

• How are these logged, what were the incidents and what controls have been implemented? If final controls are not yet in place, what temporary mitigation is employed.

• Have there been any external or internal inspections or audits of the site?

• Any issues noted? Who has inspected and why (i.e. planned or reactive?)

• Are any arrangements in place for spill response and support either from external contractors or elsewhere within the company?

• What arrangements for support exist (if any).
  
  How is this actioned and how long would support take to arrive?
  
  Does it appear to be appropriate?

Permits, Licenses and General Binding Rules

• Are any environmental permits required for this work?

• Can the contractor demonstrate that they have considered this and implemented the elements that they require?
  
  If this was identified in the prep work, can you see it implemented on -site? This includes ecology licences and dealing with INNS. Are there standards for biosecurity?
  
  What if any GBRs apply on-site

• Has site drainage been designed to separate clean and dirty water?

• Is this working effectively? Is this regularly monitored?
  
  Are any temporary modifications to watercourses required?
  
  Are licences in place for works in watercourse and is a copy available on site?

• Have watercourse crossings been appropriately assessed and designed?

• Have they been correctly installed and maintained?
  
  Are the appropriate SEPA/EA/NRW permissions in place?

• Is the work taking place within the vicinity of any Private Water Supplies? Are appropriate mitigation measures in place?

• Is this working effectively? Is this regularly monitored?

Pollution Prevention

• Are polluting liquids stored in secondary containment?

• Can be dual skin tank, bund or bunded pallet/drip tray etc.
  
  Must be 110% or 25% of combined volume.
  
  No outlets without intervention.
  
  No valves etc.

• Are polluting materials stored away from water courses and drains as far as practicable?

• OSR regs require 10m from water courses and 50m from boreholes.
  
  How has the contractor applied this? What, if any, extra mitigation is in place if they cannot comply with this due to site constraints?

• Are spill kits available?

• Are they close to where they could be needed?
  
  Stocked
  
  Are operatives trained to use them?

• Are plant nappies deployed where appropriate?

• Refuelling and dispensing equipment.

• Are excavated materials stored appropriately to avoid silt run off issues?

• Stored away from drainage, protection between it and watercourse
  
  Covered if necessary.

• Are any silt management options in use?

• Silt socks,
  
  settlement tanks/ponds etc

• Are there any controls required from the risk assessment completed prior to works? If so verify that they are in place and effective. Note this can be from any aspect, such as protected species, INNS, water pollution etc.

• Review identified controls from the risk assessment and any permits etc.
  
  Can they be identified on site?
  
  Are there arrangements to maintain their effectiveness and check that they remain effective?
  
  If there are multiple items required either pick a sample or focus on one or two elements and check in more detail.

• In terms of dewatering the site/works, are there appropriate controls in place for dewatering?

• See Netregs dewatering link

• In terms of single-use plastic and general debris, is the contractor working to eliminate SUP and is plastic, litter and debris well controlled on site?

Waste Management

• Is there a site-specific waste management plan?

• Smaller jobs will not have a site waste management plan

• Are wastes being segregated by type appropriately?

• Check that hazardous wastes and non hazardous wastes are not being mixed.
  
  Segregation by type will enable recycling of wastes.

• Are containers appropriately specified for amount and type of waste?

• Are containers adequately containing the waste, i.e. large enough, suitable materials and practical for those filling them.
  
  Are containers labelled appropriately?

• Are records kept for wastes stored and removed from site?

• WTNs and Consignment Notes?
  
  Duty of Care elements if not covered in prep work – how is this considered?
  
  Is the site subject to a WML/permit or exemption?
  
  How is compliance managed?

• In terms of Waste Data, how is it tracked, is there a forecast or targets, and how is it reported both internally and to SPEN?

• Excavated Materials (See note/Instruction)

• Are excavated materials segregated appropriately?
  
  Is it stored away from watercourses and drains?
  
  Is any mitigation in required, if so is it appropriate?
  
  How will it be reinstated? Needs to be reverse order from extraction.
  
  Is it planned or >10m3? RPS cannot be used (30.10.2010)