Procedure: Controlling Environmental Effects

Introduction
All wineries have some detrimental impact on the environment. The extent of these effects will depend on a number of factors, many of which can be controlled by winery management and staff.

The main purpose of an environmental management system is to ensure the winery's activities are controlled to prevent unnecessary harm to the environment. Such harm can result from poor practices, ignorance and accidents. Examination of current practices, development of safeguards, written work instructions and training can all help to prevent unnecessary damage to our environment.

The best approach to controlling environmental effects is to systematically work through all of the entries in your Register of Environmental Effects in turn, and to think about the best ways of controlling each activity to reduce environmental effects and pollution risks. This is the function of this procedure.

Note that, during this stage of the EMS implementation, you are concentrating on reducing environmental harm from normal winery operations, reducing the risks to the environment from accidents, and achieving compliance with legal obligations. Later – in the Cleaner Production Program – you will concentrate on reducing costs by reducing wastage.

Procedure

Step 1: Decide what needs to be changed
Work systematically through the Register of Environmental Effects, including the linked risk forms and lists of legal obligations, and note all:

• all legal non-compliances (including non-compliance with any site licenses and agreements)
• all potential for accidental spillage, leaks and other pollution.
• any obvious wastage that can easily be reused, recycled, reduced or eliminated (this is addressed in more detail in the cleaner production module)

Record this information into the appropriate Environmental Risks Forms (accessible from the Register of Environmental Effects). (The layout and column headings in these forms may be changed as you wish.)

Review the effectiveness of all existing controls and work instructions. Identify what problems need to be addressed and what practices need to be changed, and record this information in the Environmental Risks Forms.

Involve winery staff in this and subsequent steps – they know most about the current practices and will probably come up with great ideas if they are fully involved.

Step 2: Decide Priorities and Design the Changes
The time and resources available for addressing the changes identified in the previous step are limited. Therefore, make a list of those changes that you consider most deserving of action at this time. Ensure that you include in this list actions addressing any legal noncompliances, which will be of highest priority.

Address each item in your list by designing appropriate controls or with other appropriate actions. The following hierarchy should be used in developing controls (the closer you can get to the top of the list, the more effective the control):

1. elimination of the environmental risk by removing or reducing the source of the risk
2. engineering controls (for example, bunding, fume scrubbing, alarms and interlocks)
3. maintenance work instructions or maintenance contracts with external parties
4. training and signs.
5. contingency planning to reduce the impact of an accident.

If the environmental risk cannot be eliminated, then a combination of 2, 3 and 4 may be best. Consider developing work instructions for activities which are critical to legal compliance, and for all activities in which staff need to be trained (work instructions are an invaluable training aid). Keep work instructions clear and simple – view this MS Word Document for a guide to developing work instructions.

If control of an environmental effect is difficult, expensive or needs further investigation or planning, it may be set aside as a longer-term improvement project. (Note that this does not comply to noncompliance with a legal requirement). The project may be initiated now or left to be considered in the Review Stage later on.

Step 3: Implement New Controls
Implement the new controls. Make the designed changes to equipment and practices. These changes will be most effective if operators are involved in their implementation.

Also assign responsibilities for maintaining the new controls. Prepare work instructions and ensure that appropriate staff are trained in their operation.

Next
Next procedure (Set Environment Policy).

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