Paperinc LTD

Environmental
Management
Report
A Report on Outcomes Arising from the Effluent Escape

1841554 / Mir Sulaiman Amini

4-24-2019
Table of Contents
Executive Summary....................................................................................................................................... 2
Description of the problem posed to case-study company .......................................................................... 3
Identification of each of the processes, the wider benefits of the company’s business and the
environmental impact of the business ......................................................................................................... 3
Analysis and discussion of the law and environmental management issues which govern the problems .. 5
Recommendations to company .................................................................................................................... 6
References .................................................................................................................................................... 7

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Executive Summary
Waste water and effluent is the waste that contains materials and chemicals discharge from the
industry. Proper collection, treatment, discharge and disposal of waste water will help to protect
the environment and improve the quality of the water quality specially in river flow which is
important for fisheries and downstream abstraction.

The UK government related regulatory frameworks understand that the environmental issues that
are encountered every day is not only limited to UK alone and has effects on global level. There
has been development and improvements in environmental management systems. This report is
prepared to the board of directors for the possible liabilities and offences arising as a result of the
effluent escape due to the leakage and faults in the tank.

This report presents the liabilities and offences arising due to the effluent escape and discusses
the environmental improvement recommendation for the company for the future. Additionally, the
advantages of environmental management to be implemented in the company is also discussed
in detail.

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Description of the problem posed to case-study company
Paperinc LTD is the manufacturer of handmade paper located in Merkshire. The manufacturing
process creates waste water and effluent from de-inking operations, effluent, boiler operation,
cleaning operation and other treatment plants which is firstly treated and discharged to river Merk.

There was fault developed in the temperature gauge of the heated effluent tank with 20 degree
increase in temperature of the effluent release that has leaked the value. All the effluents where
discharged to the river Merk.

This was identified by a member of Haltham Angleer’s Association after noticing number of dead
fishes downstream from the plant. Also, the ABC Ltd’s staff noticed that the valve on the ILW tank
has leakage and HSW escaped into the river. The ABC Ltd’s staff has tried to tap off the valve to
prevent the flow of HSW into the river. As the tap was defected, it came off.

We have been informed by the staff of the problem and located an engineer to fix the problem.
Unfortunately, by the time engineer arrived at the site, the tank was empty, and the effluents were
released into the river.

Identification of each of the processes, the wider benefits of the

company’s business and the environmental impact of the business
In UK, there are several legislations and regulations that are in place to protect the environment.
These legislations and regulations are to mitigate the risks of environmental issues and safer
environment for all inhabitants.

Environmental legislation falls under a criminal law in the UK which is made by Parliament.
Contravention of criminal laws (environmental legislations) can result in fines, and sanctions on
business or prison.

Therefore, all the businesses that are operating in UK shall comply with all applicable
environmental legislation such as;

 Conservation of Habitats and Species Regulations 2010

 Control of Pollution (Oil Storage) (England) Regulations 2001
 Environment Act 1995
 Hazardous Waste (England And Wales) Regulations 2005

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  Hazardous Waste (Wales) Regulations 2005
 Land Drainage Act 1991
 Nitrate Pollution Prevention Regulations 2008 (England Only)
 Producer Responsibility Obligations (Packaging Waste) Regulations 2007
 Site Waste Management Plans Regulations 2008
 Water Industry Act 1991
 Water Resource (Environmental Impact Assessment) (England And Wales) Regulations
2003
 Water Resources Act 1991

(Source: Environment Agency, 2019)

The most relevant and important is the Environmental Protection Act 1990 and Environment Act
1995 which represents a whole range of criminal sanctions that are enforced by the appropriate
authority.

Most of environmental crimes impose a very strict liability on offender which makes is easier for
regulators to enforce and prosecute the environmental offences and constitutes a strong incentive
for the operator to mitigate or minimize the risks associated with environmental protection.

Without proper and sustainable water treatment, the waste water discharged to public sewer and
rivers can damage the environment and create different problems for the public, water resources
and wildlife.

The UK Government has key policy objective to help and protect the environment such as;

 Sustainable development
 Public health and environmental improvement
 Improve water quality in natural environment
 Reduce water consumption
 Reduce demand for waste water infrastructure capacity
 Climate change mitigation and adaption
 Waste hierarchy

The policy objectives of the above mentioned policies are to have a waste water infrastructure
that we can live within our environment limits, to meet the obligations set under Urban Waste
Water Treatment Directive, to meet the obligations set under European Directives like Habitats

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Directive and Water Framework Directive, reducing waste water production in households and
industries, to divert the surface water drainage away from the public sewer system and use
sustainable drainage system.

Analysis and discussion of the law and environmental management

issues which govern the problems
The Environmental Protection Act 1990 defines the environment as “all, or any, of the following
media, namely the air, water, and land”. The companies can be convicted if failing to control
emissions of pollutants or causing polluting matter to enter a stream. The company’s license
holder is convicted of the offence and is liable to pay the penalty.

The Urban Waste Water Directive is responsible to regulate the urban waste water discharges
mainly sewage and discharge of treated effluents from industrial sectors. Company’s are required
to apply and obtain the applicable discharge permits that are issued by Environmental Agency
upon request by the company and approval of Environmental Permitting Regulations (EPR).

The legislation for discharge of wastewater states that “you may need an environmental permit if
you discharge liquid effluent or waste water (poisonous, noxious or polluting matter, waste matter,
or grade or sewage effluent:

 Into surface waters, for example, rivers, streams, estuaries, lakes, canals or coastal
waters
 Onto or into the ground, for example, land spreading waste sheep dip, or discharging
treated sewage effluent to ground via an infiltration system

There are different types of discharge permits that are issue by Environmental Agency for
industries. For Paperinc LTD, we ensure to hold an update Bespoke permit allowing the company
to discharge the effluent to the river stream.

Due to the inversion of the EU legislations in to the UK legal system, the enforcing officers can
now decide to prosecute the crime either under UK legislation or EU legislation or both. This
would make the industries to follow the appropriate guidance on water discharge and prevent any
criminal offence.

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As the effluent is discharge to the river without proper treatment and due to the fault in the
company’s treatment system, the company has committed damage to the environment as a result
of discharge to the river and is liable to pay the penalty as per Environmental Protection Act 1990.

As per UK law, a person or corporate who commits an offence under this section is liable to
imprisonment for a term not exceeding 12 months or a fine not exceeding ￡50,000 or both.

Recommendations to company
The company shall integrate the environmental management system into all the business
activities and recognize and accept all the responsibilities to identify and reduce the environmental
impacts resulting from the business activities.

The company shall ensure to comply with all UK applicable environmental legislations and
requirements.

The company must store all the hazardous materials and chemicals in safe area. The company
shall ensure that all the applicable permits are obtain and all the treatment and discharge process
is as per rules, regulations and guidance.

The company shall develop a Pollution Response Plan and Environmental Management System
(EMS) that meet the requirement of ISO 14001:2004 which contains the corrective actions that
will be implemented to reduce the chances of incidents or accidents causing pollution and damage
to the environment and continuous improvements at the work place.

Also, the company shall have scheduled preventive maintenance plans for the treatment plants
including tanks and incinerator to properly check the effectivity and efficiency of equipment’s and
ensure to have on-call support technical staff for emergency case.

Alternatively, the company can utilize a properly constructed septic tank to discharge the effluents
and transport it to any governmental approved areas. This would reduce the risks of effluent
discharge to the river and penalties associated but might have more cost on long term run.

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References
Anon., 2016. Climate change and eutrophication risk in English rivers, s.l.: Environment Agency.

Anon., 2019. Prevent pollution from paper and cardboard production. [Online]
Available at:
https://webarchive.nationalarchives.gov.uk/20120905032351/http://www.businesslink.gov.uk/bdotg/a
ction/detail?itemId=1087482875&r.i=1087487809&r.l1=1079068363&r.l2=1087321234&r.l3=10874802
02&r.s=m&r.t=RESOURCES&type=RESOURCES
[Accessed 16 April 2019].

Anon., 2019. Septic tanks and treatment plants: permits and general binding rules. [Online]
Available at: https://www.gov.uk/permits-you-need-for-septic-tanks
[Accessed 10 April 2019].

Richard Kneller, E. M., 2019. Environmental regulations and innovation activity in UK manufacturing
industries. Resource and Energy Economics, 34(2), pp. 211-235.

Robinson, E. S. a. J., 2013. UK Environmental Legislation and Its Administration in 2013- Achievements,
Challenges and Prospects. Journal of Environmental Law, Volume 25, pp. 389-409.

Watson, M., 2005. Environmental Crime in the United Kingdom. European Environmental Law Review,
pp. 186-192.

Watson, M., 2005. The Enforcement of Environmental Law: Civil or Criminal penalties?. Environmental
Law and Management, Volume 17, pp. 3-6.

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