Top 5 Non-Conformances In The Education Sector
This covers such a broad range of areas including waste, energy use, construction and hazardous substances to name a few, that it is incredibly difficult to know where to start. In addition, environmental legislation can be difficult to decipher and difficult to determine whether you are legally compliant.
An Environmental Management System (EMS) is an effective, risk-based approach to identifying, prioritising and addressing your institution’s environmental aspects. The approach allows institutions to work at their own pace and address issues that are relevant and have the most significant environmental impact.
EcoCampus* audits conducted within the tertiary education sector, in partnership with NQA, provide a useful means to identify compliance issues which could cause significant environmental consequences and damage an institution’s reputation. Issues can be easily rectified through an EMS to ensure that the proper processes are in place and documented. Below, is a compiled list of the most common legal non-conformances raised during EcoCampus audits, two of which refer to waste.
Waste is an important issue for all Universities and Colleges and can be difficult to manage due to the nature and complexity of a typical campus. Some institutions choose to manage waste centrally, whereas others take a devolved approach.
The annual influx of new students, the variety of subject areas, the size of the estate and the variety of hazardous substances used within laboratories are all factors that contribute to the difficulties faced by staff when managing waste. In addition, waste management paperwork often creates confusion due to the use of codes, such as EWC, and the differing requirements for waste transfer and consignment notes.
1. WASTE DOCUMENTATION - MISSING, INCOMPLETE OR INCORRECT WASTE TRANSFER NOTES (WTN’S) & WASTE CONSIGNMENT NOTES (WCN’S)
Waste (England and Wales) Regulations SI 2011/988
Hazardous Waste (Wales) Regulations SI 2005/894
Being unable to produce WTNs or WCN’s or having illegible or incorrect information is a very common minor non-conformance during audits. A common mistake on WCNs is citing an incorrect Standard Industrial Classification (SIC) code. The SIC code should relate to the process in which the waste was produced, for Higher and Further Education institutions this is i.e. 80.30/2.
Poor communication internally between different schools and departments is also a typical issue. A robust process for managing waste documentation is required, which clearly states who has responsibilities for obtaining, checking and storing them.
Training should be given to those people who are involved in handling WTN’s and WCN’s, a review of waste documentation files and more regular checks are also recommended. These reviews could be built into your internal audit process and by spot checking records.
2. WASTE STORAGE – INCORRECT STORAGE OF WASTE & CONTAMINATION OF WASTE STREAMS
Environmental Protection Act 1990 Chapter 43 (Duty of Care)
Hazardous Waste (Wales) Regulations SI 2005/894
Waste should be stored in protected, designated areas. Different types of waste should be segregated, and it should be obvious to all where waste should be disposed of. A common issue is seeing hazardous waste contaminated with non-hazardous e.g. paint tins and solvents from art departments, cleaning products, oil rag contamination and toner cartridges all been added to general waste bins and skips.
Another example is recyclable materials contaminated with general waste or vice versa, often due to unclear signage or behaviour from students and staff. Also found, has been the lack of designated storage areas for waste that maybe is not disposed of regularly, such as Waste Electrical and Electronic Equipment (WEEE).
Problems with waste segregation can be avoided by awareness raising and training across all levels of the institution – all employees and students should know clearly how to segregate and dispose of their waste. It sounds obvious, but this is a difficult task to get right – intrinsically because it relies on so many people at each stage. A simple fix is using picture-board examples or signs detailing which types of waste should go where, and by following a standard colour coding system. Also, making full use of Environmental Champions (or similar) to promote behavioural change.
However, the sector has proven that even the most complicated waste scenarios can be managed with effective processes within an Environmental Management System (EMS).
The audit process has also highlights areas of best practice. Some Universities and Colleges are exemplary when it comes to avoiding landfill. A ‘zero waste to landfill’ objective is commonplace, which is partly achieved through diverting waste for recycling, energy from waste or sending food waste for anaerobic digestion.
Other best practice includes the use of a waste inventory, which lists all waste streams, responsible staff, waste carriers and disposal locations, relevant permit numbers and the storage locations for the waste documentation. This enables the institution to fully understand exactly how waste is managed and helps ensure legal compliance.
3. F-GAS MAINTENANCE & DOCUMENTATION – INCOMPLETE ASSET REGISTER & LEAK TESTING
Fluorinated Greenhouse Gases Regulations SI 2015/310
An environmental manager or equivalent is often unclear of the status and location of F-Gas documentation outside of their direct control. This includes the asset register and records to demonstrate that the servicing and leak testing of equipment has been completed in line with the legal requirements based on the Global Warming Potential (GWP) of each appliance.
Specialist training records are also often held by other departments and contractors. It is important to note that records must be kept for five years, this includes information on decommissioned equipment.
As with waste documentation, it is important to establish the process internally of who has the responsibility for obtaining and storing records and making sure regular checks are made.
Display Energy Certificates (DEC) are required to be shown in a prominent place clearly visible to the public in University and College buildings, with a total floor area of over 250m2.
A common minor non-conformance is either a failure to present a DEC or displaying an out of date certificate. Often, during an audit, the correct certificates are found stored electronically, but there has been a failure to replace certificated displayed.
5. INCORRECT EXTERNAL OIL STORAGE- RISK OF POLLUTION
Control of Pollution (Oil Storage) (England) Regulations SI 2001/2954
Not conforming with the requirements of the legislation regarding the storage of external oil supplies is a common occurrence. Types of oil includes petrol, diesel, bio-fuels, vegetable oils, synthetic and mineral oils. Storage type and location across an institution will vary and will depend on the quantities stored.
Institutions should have written procedures for its response to incidents, such as oil spills. There should also be a team trained in incident response, with spill kits and equipment needed to respond appropriately available and strategically placed. It is important, both internal staff and contractors are aware of both the spill procedure and location of spill kits. Non-conformances have been noted where contractor’s vehicles have unknowingly leaked polluting oil into drainage systems.
Author: EcoCampus *The EcoCampus scheme is designed to help institutions implement a formalised EMS in four phases (Bronze, Silver, Gold & Platinum), with an award certificates presented at each phase. At every phase you will receive online and telephone support, access to training workshop and webinars, access to a range of written resources and online materials, as well as an external audit conducted in partnership with UKAS accredited certification body, NQA. A joint audit of ISO 14001:2015 and EcoCampus Platinum is conducted at the final phase.