Clinical Waste Producer Audits Summer 2013

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Feb
21

The Company worked alongside WISenvironmental to carry out a review of clinical waste audit reports received from 30 customers of a clinical waste incinerator in England. The reports were assessed against a total of 18 criteria taken for the Environment Agency guidance document EPR5.07 and the EA Briefing Note ‘Clinical waste pre-acceptance, producer update, October 2010. A methodology was developed for gathering waste producer audit information in cases where the waste producer has not independently carried out a waste producer audit. This is the Clinical Waste Pre-Acceptance Form. This sets out the information needed to prepare a complete audit. The project included a set of detailed instructions on how to complete the form. The form has been used with success by the incinerator operator customers.

Clinical Waste Matters

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Feb
15

Working with our associates WISenvironmental, we have been engaged in repeat business as independent internal auditors by a major Midlands-based clinical waste incinerator operator, for whom we routinely provide planned maintenance and consulting services. On these audit occasions we were charged with determining the extent to which the organisation’s operational and management controls met with the ‘appropriate measures’ specified in the Environment Agency’s environmental permit compliance guidance. Non-conformities were reported as findings. Subsequent actions taken to deal with these resulted in more compliant operations which ultimately assist in avoiding prosecution and to gain a better level of trust with the EA.

 

We have also recently been engaged by the same client again through WISenvironmental to produce an overview of the often confusing and complex guidance published on the requirement for all waste healthcare and clinical waste producers to provide audits of their waste to their waste management contractors if they are to continue to have their waste accepted at a clinical waste incineration facility. The overview was entitled: ‘Clinical waste producer audits: a summary of guidance and best practice’. The review considered guidance documents and briefing notes published by the Environment Agency; best practice guidance published by other government departments, in particular the Department of Health; and trade associations including the British Medical Association and the Royal College of Nursing. The guidance will be made available to our client’s customers.

Breaking News in Brief February 2014

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May
2
  • January 2014: Company principal Rob Holmes renewed his certification as an EMS Principal Auditor with the International Register of Certificated Auditors.
  • September 2013: the Company carried out a 3rd annual EMS internal audit for bioMerieux. This also included updating the legal register and carrying out an Evaluation of Compliance audit. DNV carried out a periodic external audit late in 2013 and the recommendation to maintain certification to ISO14001 was recorded.
  • May 2012: bioMerieux have requested that the Company updates their Environmental Legal Register and then conducts the planned mid-summer environmental management system internal audit and the periodic evaluation of compliance with applicable legal requirements.
  • May 2012: director Rob Holmes has joined the Guildford-based WISenvironmental business development team to market their  Waste Technology & Process and Environmental Management & Compliance services in the area served by the Surrey Chambers of Commerce.

Compliance Audit Completed in Ireland

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May
2

Director Rob Holmes was engaged by AECOM to form part of a four-person team that conducted a comprehensive 5-day environmental, health and safety compliance audit for a leading US multinational organisation at their nutritional products manufacturing facility located in central Ireland. Rob evaluated plant compliance with environmental regulations and in particular the facility’s IPPC licence.

Recertification of EMS Principal Auditor Certification

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May
2

Director Rob Holmes’ certification as an EMS Principal Auditor has been successfully renewed by IRCA (International Register of Certificated Auditors) for a further three years until January 2015. The recertification process requires submission of records of at least 5 acceptable lead audits or sole audits, evidence that at least 45 hours of appropriate Continuing Professional Development has been completed during the 3-year period immediately prior to renewal of certification and a declaration that no complaints have been made in relation to professional conduct. The register entry can be viewed at find an auditor on www.irca.com.

UNEP Report ‘Environmental Assessment of Ogoniland’ Published

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Dec
2

WISenvironmental participated in the United Nations Environment Programme programme to independently assess the environmental impact of oil-field contamination in the Ogoni Region of south-west Nigeria. The team was managed by Rob Holmes. The over-riding objective of WISenvironmental’s task was to identify the range of possible full-scale remediation technologies available commercially for oil-contaminated soils and sediments and to present their indicative costs, resource requirements, operational footprint and possible output specifications. Site visits were carried out at the invitation of the operators by the project team process engineers to three locations in Belgium to witness and assess the suitability of soil washing, bioremediation and thermal desorption operations.

The final report ‘Environmental Assessment of Ogoniland’ was published in late-2011 by UNEP. Over a 14-month period the UNEP team examined more than 200 locations, surveyed 122km of pipeline rights of way, reviewed more than 5,000 medical records and engaged more than 23,000 people at local community meetings. Detailed soil contamination investigations were conducted at 69 sites and more than 4,000 samples, including groundwater from wells drilled for the study, were analysed.

The findings in the report underline that there are, in a significant number of locations, serious threats to human health from contaminated drinking water  and there are concerns over the viability and productivity of ecosystems. The study provides the government, stakeholders and the international community with invaluable baseline information on the scale of the challenge and priorities for actions in terms of clean-up and remediation going forward.

Certification Success for Healthcare Products Company

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Dec
2

The company has been supporting the development of an ISO14001 certifiable environmental management system since the EMS programme’s inception at the Basingstoke-based UK headquarters of a healthcare products organization, which is a world leader in the field of in vitrio diagnostics. The pre-certification support culminated in the completion of two audits in late-2011 – a full-system internal audit and a legal compliance audit. Completion of subsequent corrective actions and closing out all audit findings helped ensure that no non-conformities were reported during the initial audit by DNV Certification Services in late-November 2011 when a recommendation for certification was made.

RSPB Role

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Dec
2

Director Rob Holmes has been appointed as an EMS Technical Consultant for the Royal Society for the Protection of Birds EMS. The voluntary role supports the implementation of certifiable environmental management systems across the organisation’s head office, 6 regional offices and approximately 200 nature reserves. The organization has commenced the process by carrying out an environmental review of a cross-section of offices and reserves. The review will identify all environmental aspects of the organization’s activities and how these are currently managed and will also enable the environmental aspects of significance to be determined.

Periodic Compliance Audit of Clinical Waste Incinerator

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Dec
17

Director Rob Holmes acted as the lead auditor in a WISenvironmental team commissioned by Veolia Environmental Services in the last quarter of 2010 to carry out an audit of the clinical waste incineration operations at the Tyseley Energy-from-Waste facility at Tyseley, Birmingham. The audit followed the much delayed publication in July 2010 of Environment Agency guidance EPR5.07 Clinical Waste in the ‘How to Comply with your Environmental Permit’ series and followed on from the need of VES to determine the level of compliance of current activities in relation to the ‘appropriate measures’ identified in the new guidance. WISenvironmental audited and reported on the following activities:

  • Measures undertaken pre-acceptance and upon delivery of the waste to the site;
  • Measures for waste storage and handling; and
  • Measures for the control of emissions to air, surface water and sewer

 

The audit was carried out during a four-day period of assessment during which, by processes of observation, examination of documents and from interviews, two senior auditors collected the information necessary through to verify that operational controls conformed with permit and ‘appropriate measures’ requirements or to identify ‘findings’ where operational controls were not in conformity. A plan to address the findings and to implement corrective actions has been drawn up on site.

A periodic audit was carried out on 22-23 February 2012. This audit included a review of the close-out of findings reported from the initial audit of October 2010.

Expert Witness Engagement

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Dec
17

 

Director Rob Holmes has been engaged as an exert witness by the Dublin law firm A L Goodbody in support of a civil action scheduled to be heard in the Dublin High Court in Spring 2011. This is being taken by the law firm’s Dutch client who is suing for damages resulting from the alleged misclassification and mismanagement of hazardous waste exported from a pharmaceuticals manufacturing facility in Ireland to an allegedly inappropriate and inadequately permitted treatment facility in Belgium under Transfrontier Shipment regulations. Process residues from the treatment facility were supplied to the animal feed chain. The matter came to light when Dutch pig farmers complained to their regulators of health problems in their animals and the identification of contaminants allegedly from the treatment facility in pig feed in mid-2002. The action is being taken against the waste producer and their waste brokers at the time of the incident.