CPD: The importance of engaging with environmental controls

Environmental management and oversight is not traditionally something considered to be within occupational health’s remit. But environmental management can have a significant knock-on effect on health and wellbeing, and therefore it is important OH takes a proactive interest in organisational environmental control strategies, as Ndaba Mnkandla and Anne Harriss outline.

Occupational health practitioners traditionally have primarily concentrated on promoting the health and wellbeing of the workforce. Many may not have considered the effect of their organisation on broader public health issues including the impact of work-processes on the communities outside the organisation’s front entrance.

The effects of human habitation, industrial and other work processes has the potential to impact on community health resulting from emissions to air, water and land. Environmental pollution and climate change are topical, for example the effects of plastics on aquatic wild life hit the media on a daily basis. In part, this results from poor waste management.

About the authors

Ndaba Mnkandla MSc PG Dip BSc RN is an occupational health adviser. Anne Harriss MSc, BEd, RGN, OHNC, NTF(HEA), PFHEA, CMIOSH, FRCN, Hon FFOM is professor in occupational health and course director occupational health nursing and workplace health management programmes at London Southbank University

Similarly, in areas of London, sewers become blocked by plugs of fat and sewage waste referred to by the media as “fatbergs”. The Guardian (2017) reports one of these plugs was the length of two football pitches and weighed the equivalent of 11 double-decker buses. Commercial and domestic food preparation are major contributors to this problem. The public health implications of these blockages are significant.

OHNs, as public health practitioners, are well placed to influence their employers to reduce the environmental impact of work processes. However, environmental impact resulting from emissions to air, water and land may be poorly understood by OHNs.

This must change as a knowledge of environmental impact resulting from such emissions is encompassed within the Public Health England (2016) publication Educating Occupational Health Nurses – An approach to align education with a service vision for occupational health nurses.

This article gives an overview of the control of environmental emissions associated with the demolition project of an office block. The demolition site situated was situated near a river and surrounded by retail outlets. Pedestrians and cyclists use an adjacent public walkway.

The location is relevant as each could be affected by any emissions resulting from this demolition process, whether this is the adverse impact of traffic movements, high noise levels, ineffective dust suppression, or poorly managed hazardous waste or chemical spillages such as vehicle fuel.

Scope of work for project

The project tasks had the potential to impact significantly on the local environment and thus the broader local community. Work processes included:

  • Site Establishment and hoarding erection
  • Asbestos removal
  • Scaffolding erection
  • Building demolition including ground slab and foundation removal

In order to work towards reducing the environmental effects of work processes an environmental impact assessment (EIA) was undertaken. This is required by the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 2017. This formal procedure facilitates decision makers to take account of environmental information about projects within their decision-making scope (Bell et al, 2017).

The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 require such projects to undertake an initial EIA as this enables Local Authorities to make informed decisions regarding the environmental effects during planning permission phase. The detailed EIA considered the range of possible environmental effects of this work including air quality and possibly encountering contaminated land. Aspects considered as part of the environmental impact assessment were:

  • Air quality
  • Archaeology
  • Daylight, sunlight, sunlight amenity and solar glare
  • Environmental wind
  • Ground conditions and contamination
  • Noise and vibration
  • Townscape heritage and visual impact assessment
  • Waste
  • Water resources

Environmental management system

The company has an environmental management system compliant with the ISO (International Standards Organisation) 14001:2015 standard. This environmental management standard aims to reduce releases to air, water and land. ISO 14001 certification requires the holder to have considered all the environmental aspects of their operations. This includes having an environmental policy that underpins an integrated environmental management system with clearly defined objectives for environmental management (Turk, 2009).

Implementing an environmental management system has several advantages for the organisation, its clients and the wider public. The organisation can save costs from improved efficiencies and energy efficiencies. Commercially, the organisation can develop new business opportunities by improving its reputation and stakeholder confidence. Holding ISO 14001 demonstrates compliance with current and future regulatory requirements offering increased confidence from the public and communities (Feron-Vilchez, 2016). The elements of the environmental management system in place are explored below.

Environmental policy

The organisation has a sound environmental policy that demonstrates their intent that operations will be effectively managed, environmental impacts minimised and that the operation of the business are continually improved. This policy, signed by members of the board of directors and the company’s environmental manager is displayed on the staff intranet, canteen, changing rooms, and offices. It clearly states what the organisation is committed to, their objectives and how they intend to achieve these. Some of its key objectives include:

  • Undertaking all activities in an environmentally responsible manner
  • Fostering a pan-company environmentally responsible culture
  • Compliance with applicable environmental legislation
  • Continually striving to prevent pollution, reduce waste and energy use and limit the use of non-sustainable natural resources

Site environmental management system

Prior to commencing work on any project the organisation develops site environmental management plans. Environmental aspects, impacts and the requirement for environmental assessments are incorporated within these plans.

Environmental structure

The organisation commits to collaborative working with other companies involved in this management of this demolition project including environmental consultants. Integral to this are the project and site managers. The project manager ensures all work is carried out in compliance with legislation and contractual agreements. The site manager has responsibility for the management of health, safety and environmental protection ensuring that all control measures are implemented including the reporting of all health and safety and environmental incidents and near misses.

Significant incidents are reportable to the Health and Safety Executive and any impacting on the environment including significant emissions such as releases to air or chemical or fuel spills that contaminate land, the aquifer or adjacent water courses are reported to the Environment Agency.

Site supervisors oversee the day-to-day application of preventative measures on site that reduce the environmental impact from work processes. They work with the environmental management team in the provision of workforce training on environmental management and monitor compliance with policies and operating procedures through regular audits.


The organisation has developed a number of targets. The organisation aims to have zero environmental enforcement notices and no formal cautions or prosecutions and has developed a number of targets to reduce:

  • The amount of waste disposed of via landfill
  • Fuel and energy use
  • Company vehicle emissions with a target of 80% of these being below 150gCO2/km

Employees are made aware of the organisation’s environmental objectives at the point of induction. New staff are issued with a staff handbook detailing the organisation’s corporate social and environmental responsibilities.

Induction training incorporates the importance of environmental management and the roles and environmental responsibilities of all staff. Environmental management is integral to the ethos of the company; to this end regular tool-box talks are delivered on environmental issues including waste management, noise prevention and spillage minimisation and management.


The organisation subscribes to the Considerate Constructors Scheme (CCS). The CCS was founded in 1997 by the construction industry to improve the image of construction by assessing and monitoring sites against a code of practice. Members of this scheme commit to care about appearance, respect the community, protect the environment, promote safety and value their workforce (www.ccscheme.org.uk/).

Environmental control measures – air

The main air quality impacts associated with demolition and construction activities include dust deposition, visible dust plumes and vehicle emissions including noise and nitrogen dioxide from vehicle exhaust (Holman et al, 2014). How these are managed is detailed below.

Environmental control measures – dust

Dust generated from construction sites can have an adverse effect on those working on site, on the local environment and the health of local residents (Kukadia et al, 2003). Most dust particles are too large to be respirable but they may affect the eyes, nose, mouth and skin. Larger dust particles can cause a nuisance by settling on surfaces of cars, buildings, windows and clothing (Holman et al, 2014).

The smaller dust particles (fewer than 10mm in diameter) are usually invisible and may not seem to be an obvious hazard but they are respirable and can penetrate further down the lungs to the alveoli contributing to respiratory and cardiovascular problems (Kukadia et al, 2003). Due to their size, particles can be picked up by wind and blown great distances even in light winds, consequently the detrimental health impacts are not confined to just the construction site (Holman et al, 2014).

Nuisance dust emissions from construction and other civil engineering activities are a common and well-recognised problem (Kukadia et al, 2003).

Several dust mitigation approaches and working practices are in place on this site. Site boundaries are screened providing shelter from the wind reducing fine dust particles being blown around/from the site. Handling and storage areas of demolition waste are sited as far away from public areas as is reasonably practical. Prolonged storage of debris on site is avoided. Until transfer off site fine, dry materials are sheeted. The haulage services liaise closely with the site to co-ordinate waste removal. All vehicles carrying dusty materials into/from the site are also sheeted preventing any escape of materials.

Dust suppression methods control the air quality around site. Water sprays are used before and during any dust emitting activities. This prevents particles from becoming airborne, however they can also give rise to excessive amount of mud that can be picked up and transported by vehicles driving around site. To minimise this, the site has wheel-washing facilities and vehicles must have their wheels washed before leaving site. A road sweeper tours the site perimeter and local roads during working hours spraying water on to the road then scrub the dirt from the road collecting it in a storage container.

Environmental control measures – noise

Noise can cause a series of detrimental health effects including hearing loss, annoyance, cardiovascular disease, sleep disturbance, immune, biochemical, reproductive and performance effects (Li et al, 2016). It is the largest cause of complaints against construction and demolition sites (Environmental Agency, 2012) High levels of process noise is a statutory nuisance under Part 3, section 79 of the Environmental Protection Act 1990.

Noise levels that could disturb the local community generally must be avoided if prosecution is to be avoided. Under Section 61 of the Control of Pollution Act 1974 a developer can apply to the local authority for permission to undertake noisy work. The organisation had achieved this approval for this project. Their application included details of the proposed working times, location, methods, work equipment and steps to mitigate process noise. Baseline noise levels were established prior to commencing demolition work ongoing monitoring utilised strategically placed noise monitors.

The organisation uses a range of noise mitigation approaches and working practices minimising adverse impact on adjacent residential dwellings, business and leisure facilities.

A summary of these noise mitigation approaches and work practices is listed below.

  • Erection of scaffolding with acoustic properties around the site
  • Erection of noise barriers and acoustic sheds around very noisy activities
  • Demolition techniques undertaken minimise noise levels. For example the internal parts of buildings are demolition first, the outer shell being used an acoustic barrier.
  • Vehicles are regularly serviced reducing engine, exhaust and body rattle noise
  • Working hours are controlled: no demolition activities, including movement of noisy plant /vehicles occur outside agreed hours (8am – 6pm) Monday to Saturday without local authority permission
  • Avoidance of unnecessary engine revving engines
  • Equipment switched off when not in use
  • Site equipment and noisy tasks located as far away as possible from noise sensitive areas

Environmental control measures – exhaust emissions

Road vehicle exhaust emissions are the main source of air pollution; the 2 main pollutants are nitrogen dioxide (NO2) and PM10 (Rhys-Tyler et al, 2011). The organisation uses several initiatives to reduce exhaust emission from road vehicles and non-road mobile machinery which is defined as; “any mobile machine or vehicle that is not solely intended for carrying passengers or goods on the road” (Greater London Authority, 2017).

Truck and heavy goods vehicle movements are planned and kept to a minimum. Some construction material is transported by barges down the adjacent river reducing carbon dioxide (CO2) and Nitrogen oxide (NOx) emissions as well as reducing vehicle movements, congestion and noise.

Engine idling is prohibited; drivers are required to switch off their engines when not in motion. All haulage vehicles are fitted with fuel consumption monitoring devices, fuel reduction targets are in place and diesel particulate filters fitted where applicable. A log of all plant on site is kept and includes maintenance and servicing schedules.

Environmental control measures – water

Construction sites have the potential to significantly impact on the aquatic environment, silt and oil being the most common water pollutants (Environmental Agency, 2012). This can be detrimental to public health and the aquatic environment. Decomposing organic matter in water reduces its oxygen content, resulting in potentially harmful effects for aquatic life forms and can disrupt the ecosystem (Parliament. House of Lords, 2017).

Furthermore, the Environmental Permitting (England and Wales) Regulations 2010 state that is an offence to, “cause or knowingly permit an entry or discharge to inland freshwaters, coastal waters or relevant territorial waters of any poisonous, noxious or polluting matter; waste matter; trade effluent or sewage effluent except under and to the extent authorised by an environmental permit”. The organisation has control measures in place to limit pollution into the aquifer or nearby river.

Environmental control measures – fuel/oil/chemicals

Storage and use of fuel, oil and chemicals could pollute water as a result of accidental spillages. To prevent this, the site has purpose built fuel storage containers of good integrity and strength stored in a securely bunded facility built on impervious hard standing.

This walled structure is designed to hold any accidental release providing at least 110% storage capacity to account for any rain water which may have collected within the bund (figures 6 and 8). Bund integrity is regularly checked and they are located more than 10 metres from unprotected drains and open ground.

This prevents accidental leakage to land and subsequent seepage to ground water. Containers are positioned on a stable raised platform and an overhead canopy protects them from rain and flash flooding. Action to be taken in the event of a spillage along with spillage kits and disposal bins are located near the storage containers.

The process to undertake following accidental spillage is delivered to staff via supervisor delivered tool-box talks. Chemical storage is kept to a minimum; chemicals are securely stored in a labelled storage facility and an inventory of chemical materials and COSHH assessment records are kept in the storage locations and in the site office.

Environmental control measures – land

The organisation has a site waste management plan (SWMP) specifically for this site. This ensures that the company handles waste in accordance with Section 34 of the Environmental Protection Act 1990 which places a duty of care to take all reasonable steps to manage and store waste safely (Environmental Protection Act, 1990). The SWMP details how the organisation:

  • Complies with all relevant legislation
  • Handles waste material efficiently and appropriately
  • Reuses, recycles and recovers as much material as possible
  • Reviews, revises and refines their processes continually reducing their environmental impact

Vehicle cleaning

The site has designated vehicle cleaning areas to minimise the spread of mud and dust by vehicles and plant onto public roads on leaving the site.

The vehicle washing area has rumble grids angled in such a way that they scrape the majority of the mud from wheels (Kukadia et al, 2003). Waste water from vehicle washing contains mud and contaminants including oil and foreign materials with the potential to enter the local sewage system. To prevent this, the site uses a closed water system that collects the dirty water in a large underground storage tank.

Silt and any heavy pollutants from this process settle at the bottom of the tank. Lighter pollutants such as oil are removed from the water using an interceptor. Any remaining water is transferred to a separate tank is known as grey water and re-used in the same vehicle washing bay. At the end of each day the storage tank is emptied and any silt filtered from the interceptor is removed and disposed of appropriately in a similar manner to site waste (see land waste control measure below).

Waste controls

To ensure legislative compliance the organisation only uses Environment Agency licensed waste hauliers, waste management contractors and landfill sites. All waste hauliers used by the organisation are vigorously vetted and regularly audited to ensure their legislative compliance and that they achieve appropriate environmental standards.

When waste leaves the site for disposal, transfer and consignment notes are completed. Transfer notes are retained for a minimum of two years and consignment notes for a minimum of three years. Consignment notes detail the type, quantity and containment of all transferred waste.

The SWMP aims to maximise the environmental and development benefits from the use of waste material and to reduce adverse effects of disposing of waste to landfill. The organisation adheres to principles of waste management hierarchy. This ranks waste management options in order of minimal environmental impact (Dept for Environment Food and Rural Affairs, 2011).

To minimise pollution to land from on-site activities the organisation has several control measures. Waste containers are impermeable preventing leakage into the ground.

Waste containers are clearly labelled and promote the segregation of wood, concrete, metals, plastics and cables. Figure 11 illustrates some of the skips that are placed near the activity producing specific types of waste. These containers are regularly checked to ensure they remain fit for purpose.

The organisation ensures they do not over order by planning and forecasting material they will need to avoid waste in the first instance.

All waste transported off site is covered, preventing any escape onto public roads. The organisation offers redundant equipment to the principal contractor for reuse as spares reducing unnecessary waste.

Hazardous waste

Hazardous waste is segregated and stored separately from other waste preventing cross contamination. The presence of asbestos containing materials is identified in advance of demolition works commencing. Asbestos containing materials are removed by licensed contractors and stored in sealed skips that are removed intact to a licensed facility.


Environmental management is effective on this demolition site. Robust, comprehensive policies and operating procedures are integral to how it is managed. There is a committed environmental management team.

A well-written, up-to-date environmental policy is clearly displayed and communicated across the site. Effective control strategies minimise the site’s environmental impact arising from emissions to air, water and land. Whilst finance is the driving factor for the business, it is clear that environmental wellbeing and sustainability are part of the organisation’s culture.

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