The Chiltern Lift Company Environmental Policy

Policy Introduction The Chiltern Lift Company resolutely acknowledges the importance of environmental

protection. The Company has made a strong commitment to meet this challenge by identifying what processes and actions could have an effect on the environment and by actively incorporating improvements to working processes and monitoring their effectiveness.

The Company’s Environmental Protection Policy demonstrates to our employees, customers and partners our concern for the environment, both presently and in the future.

The Chiltern Lift Company is committed to complying with current environmental legislation, in particular the Environmental Protection Act 1990.

The Chiltern Lift Company is a Registered Waste Carrier. Registration No: TWE/673732

Policy Statement Our policy is to protect and maintain the environment through good working practices

and to minimise the impact our actions may have upon it. We endeavour to reduce waste and to promote our standards within the lift industry. We also accept our responsibilities under the Environmental Protection Act 1990.

The Company ventures to minimise any potential risk to all our employees and members of the public likely to be effected by our work routines and processes, while employees themselves have a duty to take reasonable care to co-operate in the operation of this policy, to ensure its effectiveness.

The policy will be perpetually maintained with particular emphasis on any future changes in the nature and size of the business. To ensure this the policy, and the way in which it operates will be the subject of an annual review.

The allocation of duties for environmental matters and the particular arrangements, which we will make to implement the policy, are set out in the following pages of this document.

Signature of Director

S. Festorazzi Mr. S. Festorazzi – Director Date: 10/01/2014

Policy Objectives The understanding of the need for environmental protection forms an integral part of the The Chiltern Lift Co Ltd’s business philosophy. The company is committed to protecting the environment and accepts the responsibility not to compromise the ability of future generations to sustain their needs. The impact that any of our activities or those of our clients/contractors may have on the environment is an area of concern. We seek to reduce our consumption of non-renewable resources, and whenever practicable will select materials, which have the least negative impact on the environment throughout their life cycle. Environmental protection will have equal status to considerations for health, safety and quality. In confirming our commitment to protection of the environment we will treat environmental regulations that apply to our activities as minimum standards and where appropriate aim to better them. We will provide information to sub-contractors, customers and end users of our services to ensure that misuse will not be the cause of damage to the environment. Responsibility for the environmental policy and supporting statement lies with the company Directors. The company has appointed a management representative who has the responsibility for the continuous development of the Environmental Management System and for ensuring that this policy is reflected in all The Chiltern Lift Co Ltd’s activities; The environmental policy will be brought to the attention of all employees and will be made available to the general public via the company website; www.chilternlifts.co.uk. and will be reviewed annually to assess its effectiveness, compliance with environmental law and to ensure that it reflects changing needs and circumstances. Whilst recognising the fundamental responsibility of the company and its employees for environmental protection, particular attention will be paid to the following areas: Waste Management Waste will be kept to a minimum, compatible with best industry practises. Only licensed waste contractors will be used to dispose of waste. Our sub-contractors shall be encouraged to apply the principals of this policy and shall be required to comply with the minimum relevant legislation. Flora and Fauna at work locations Every effort shall be made to minimise the effects of the company’s activities on the flora and fauna within and around work sites. Site surveys shall be carried out to establish site specific conditions and the presence of any plant life within the vicinity. Recycling Whenever viably possible materials will be purchased from suppliers who obtain products from renewable resources. Noise/Dust Light All noise and debris will be suppressed, where practical, to ensure that only minimal disruption is caused to neighbouring businesses or the general public. Conservation of energy The management representative or job project managers shall introduce and monitor efficient and economic use of energy in the form of heating and lighting with the objective of reducing the use of energy. Training All employees shall be made aware of the objectives of this policy and the contribution expected from them. Employees with high risk tasks shall be trained in the environmental aspects associated with those tasks.

Legislative Compliance Regular environmental assessments shall be carried out to ensure compliance with the legislation and the application of best available practice in environmental protection. Environmental Objectives Objectives will be set, monitored and reviewed to provide a management tool for the company to achieve the objectives set out in this policy and help achieve continuous improvement in our environment performance. All employees are equally responsible for complying with this Environmental Policy and are encouraged to suggest improvements to this end. ASBESTOS POLICY The Chiltern Lift Company Limited will ensure that The Company complies with the fundamental requirements of Regulation 4 of the Control of Asbestos at Work Regulations 2002 (CAWR 2002). All staff are asbestos aware and have attended in-house training sessions given by senior supervisors trained in Asbestos Awareness by Connaught Compliance Services. In-house training is carried out at regular intervals of between 18 an 24 months. All staff members are made aware that there may be asbestos containing products installed in the premises they attend. The Chiltern Lift Company will not carry out work which is liable to expose its employees to asbestos until:

A suitable and sufficient assessment of the risk created by that exposure to the health of those employees and of the steps that need to be taken to meet the requirements of these Regulations has been undertaken.

Staff are advised that before undertaking any work or disturbing existing materials, to check the site Asbestos Register, where available. The Asbestos Register records where asbestos is likely to be present. They are also made aware that not all asbestos on site may have been recorded and that the Register may not be fully up to date. The appropriate precautions are to be taken. Under no circumstances should employees disturb any material which may contain asbestos without specific instruction and authorisation. In particular no abrading, drilling, breaking or removing of such material should be undertaken. The duty supervisor should be informed of any cases of asbestos at the earliest opportunity on 01628 527414 (24 hours) Work on Asbestos must be carried out by competent personnel employed by licensed contractors. NOISE IN ENGINEERING POLICY

The Chiltern Lift Company Limited will ensure that it complies with the fundamental requirements of The Noise at Work Regulations 1989.

Noise assessments shall be made by a competent person if noise levels exceed 85dB(A).

Noise assessments will be reviewed and if necessary updated if there is any reason to suspect that an existing assessment is no longer valid or if there has been a significant change in the work to which the assessment relates.

If an assessment is made and is clear there is no noise hazard, no further action is required. If a noise hazard is highlighted during assessment then a plan of remedial or precautionary

actions will be put in place to eliminate or reduce the hazard identified. All assessments will be recorded and retained for further use. Noise reduction measures shall be taken where reasonably practical. Information will be provided to all employees about risks to hearing. Ear protectors will be provided when and where required. Employees are obliged to use ear

protectors when provided and to report any defection protective equipment. WASTE MANAGEMENT POLICY INTRODUCTION This Waste Management Policy has been produced in support of the Chiltern Lift Company’s Carbon Management Plan and Environmental Policy. The Company is committed to reducing its impact on the environment by managing its waste in an efficient and sustainable manner. Landfill is a major source of methane, a powerful greenhouse gas contributing to climate change. Methane is produced when biodegradable materials such as paper, food and green wastes, decompose in the absence of oxygen. Putting waste into landfill is not environmentally sustainable and the Company, like society, needs to learn to do more with less. It is important to make better use of resources, putting materials to better use and thereby reducing our impact on the environment. To this end the Company has set a target reduction of 70% of waste sent to landfill by 2014. This will be achieved by implementing good waste management practises, including adhering to a waste hierarchy and ensuring waste is only sent to landfill as a last resort. The treatment of waste is governed by a wide range of legislation which is summarised below (Summary of Legislation). WASTE MANAGEMENT CONTRACT The Company’s waste management contract with Wycombe Trade Waste Limited (WTW) is central to its waste management strategy. Wycombe Trade Waste Limited has no vested interest in sending waste to landfill as they do not operate any landfill sites, relying instead on several large scale Materials Recycling Facilities to which the Company sends its recyclable waste. WTW offer a “co-mingled” recycling service which means they will accept all recyclable items mixed together rather than the traditional segregation of separate recyclables, an important efficiency gain. WASTE HIERARCHY The Company is committed to adopting the following waste hierarchy where there are materials that are no longer required:

Reduce – Avoid the need to discard materials in general, for example by asking suppliers to take back any packaging or re-usable items. This could form part of the tender process, purchasing only the quantity of items that are needed.

Re-use – Just because an item is no longer needed it does not mean another department or person can’t make use of it. Consider passing on equipment to others before is it is disposed of. At tender stage consider getting suppliers to take back packaging for re-use.

Recycle – All organisations have a legal requirement to pre-treat waste. This can be as simple as segregating items for recycling, essential for the reduction of the waste at the Company.

Recover – Energy should be recovered from waste, where possible methods such as incineration or energy from waste (EFW), anaerobic digestion (AD) and mechanical and biological treatment (MBT).

Disposal - Any disposal of waste shall comply with the Environmental Protection Act 1990 Duty of Care.

DEFINITION OF WASTE The Environmental Protection Act 1990 describes waste as any substance which constitutes a scrap material, an effluent or other unwanted surplus arising from the application of any process or any substance or article which requires to be disposed of which has been broken, worn out, contaminated or otherwise spoiled; this is supplemented with anything which is discarded otherwise dealt with as if it were waste shall be presumed to be waste unless the contrary is proved. This definition was amended by the Waste Management Licensing Regulations 1994 defining waste as 'any substance or object which the producer or the person in possession of it, discards or intends or is required to discard but with exception of anything excluded from the scope of the EPA (Environmental Protection Act 1990). Having defined the material as waste various legislation, including the Environmental Protection Act 1990, the Controlled Waste Regulations 1992 and the Waste Management Licensing Regulations 1994, seek to further define the types of wastes as they are legally defined by the processes or premises from which they are produced. These are as follows:

Controlled waste - encompasses household, industrial and commercial waste. Household waste - is that which arises from dwellings of various types including houses,

caravans, houseboats, campsites, prisons and wastes from schools, colleges and universities. Commercial waste - comes from premises used wholly or mainly for trade, business, sport,

recreation or entertainment; excludes household and industrial waste. Industrial waste - waste from a factory or industrial process; it excludes wastes from mines and

quarries and agricultural wastes. Wastes from agriculture (non natural wastes) and mining and quarrying recently came into the

same controlled waste regime.

Some controlled wastes are further classified and subject to further regulation because of the nature of the waste and the need to handle them differently:

Clinical waste - waste from human or animal tissue, blood, excretion, body fluids, pharmaceutical products, swabs, dressings, syringes, needles, sharps, or any other waste that may cause the infections of persons coming into contact with it.

Hazardous wastes - hazardous for a variety of reasons including toxicity, explosiveness etc. They also must be handled and dealt with differently to other wastes.

Examples of these types of wastes which may be produced by The Chiltern Lift Company include:

waste chemicals (such as gear oil, hydraulic fluids) batteries (e.g. lead acid batteries, or significant volumes of batteries containing mercury or

cadmium) lamps, fluorescent tubes containing mercury. reclaimable metals (such as stainless steel waste, pvc coated cables).

All of these must be disposed of safely by an approved and appropriately licensed waste carrier.

WASTE TRANSFER NOTES There is a regulatory requirement to complete, sign and keep a Waste Transfer Note (WTN) for any waste transfer. The WTN contains an accurate description of the waste to enable the contractor to handle the waste correctly and lawfully. There is also an additional regulatory requirement to keep a copy of the description of the waste that is transferred for a period of two years. All hazardous waste movements must be accompanied by a Consignment Note that must include:

Details of address and poscode of the premises from which it is being removed Details of everyone involved in the movement of the waste An accurate description of the waste

Upon receipt, all Waste Transfer Notes and Consignment Notes must be sent to the Quality Manager to be archived. HOUSEHOLD WASTE RECYCLING CENTRES Household Waste Recycling Centres (HWRC - commonly termed the tip or dump). These sites are provided for the use of private households and must not be used for the disposal of wastes produced by the Company or any other business. DUTY OF CARE The Company has a legal duty to ensure that any waste produced is handled safely and within the law. This is the 'duty of care'. It applies to anyone who produces, imports, transports, stores, treats or disposes of controlled waste from business or industry. Commercial, industrial and household wastes (including hazardous/special wastes) are classified as controlled waste. The duty of care also applies to anyone that acts as a waste broker. A breach of the Duty of Care is a criminal offence and can incur penalties of up to £20,000 or an unlimited fine if convicted on indictment of a waste crime. The duty of care has no time limit, extending until the waste has either been finally disposed of or fully recovered and does not end when a Waste Transfer Note is received. Under the Duty of Care all businesses, including the Company, must:

Stop anyone storing, disposing of or recovering any of their waste unless they have an environmental permit or an exemption. The business must check their permit, licence or exemption to make sure that they are within its conditions.

Make sure their waste is not illegally disposed of. Ensure that all waste is stored in a safe and secure manner e.g. in locked containers or in a

compound. Package all waste materials appropriately and robustly to stop them escaping from their or

anyone else’s control. Keep records of any waste transactions for a minimum of two years (three years in the case of

Hazardous Wastes). Make every effort to audit subcontractors to check for compliance with the law, this could be

from checking environmental permits to visiting the landfill sites to which the waste is destined.

RESPONSIBILITIES, ORGANISATION AND MANAGEMENT All staff Each member of the Company must take reasonable steps to minimise the waste they produce. Guidance on what to do with waste is included below.

Quality Manager The Quality Manager (QM) is responsible for ensuring that appropriate waste management services are provided to the Company through a registered and approved waste contractor. To this end, waste disposal services are the responsibility of the QM. The QM is also responsible for ensuring the Company has the correct permits and that they are renewed in an appropriate manner. Technical Services Technical Services produce waste and must ensure that their procurement activities minimise waste in accordance with this Policcy. Technical Services must also ensure that they have procedures in place to manage wastes in accordance with legislation, including the duty of care and with this Waste Management Policy including the Waste Hierarchy Management and Directors Management must ensure that their staff implement this policy in their day to day duties and that they are encouraged to co-operate with waste management and recycling in general. Managers must also take appropriate steps to ensure that staff abides by this policy and are encouraged to co-operate with waste management and recycling in general. WASTE CARRIERS If waste is removed by a carrier, under the duty of care any business must ensure that carriers are either:

A registered carrier of controlled waste. Exempt from registration as a carrier of controlled waste. A Waste Disposal Authority in England and Wales.

A registered carrier should be able to produce a current certificate of registration or a certified copy when asked. This certificate will show when their registration expires. A photocopy does not provide evidence of registration – staff must ask to see the original or a certified copy. Photocopies must be taken and passed to the Quality Manager having been dated and annotated to confirm that the original has been seen. If a carrier claims to be exempt, proof must be obtained. WASTE CONTRACTORS Any subcontractor engaged by the Company must conform to the Waste Management policy by providing:

A risk assessment for the works undertaken A method statement for the works undertaken A copy of their public liability insurance A copy of their employers liability insurance A company environmental policy

Any subcontractor dealing with wastes must also provide:

Copies of any permits issued by the Environment Agency, for example a current Waste Carriers License. Photocopies are acceptable and must be checked on the Environment Agency public register.

An audit trail for the waste concerned detailing any area where Company waste is destined, from cradle to grave.

A Waste Transfer Note (WTN) for all waste transfers. This can be an annual WTN for wastes which will not change in type over the 12 month period.

For transfers of hazardous waste a consignment note must be issued detailing the wastes to be transferred. The consignment note must detail the wastes using the European Waste Catalogue.

APPOINTMENT OF A WASTE CONTRACTOR Quality Manager The QM is responsible for the selection and appointment of all waste contractors in consultation with the Managing Director. Project Managers Project Managers may appoint a contractor to deal with waste arising from lift repair or refurbishment projects in consultation with the QM. All appropriate documentation will be sent to the QM for archiving. Managing Director The Managing Director may appoint a contractor to deal with waste arising from company operations in consultation with the QM. All appropriate documentation will be sent to the QM for archiving. REGISTRATION AS A CARRIER OF WASTE In the course of its daily operations the Company has to carry waste on the public highway. The Company is therefore registered as a waste carrier with the Environment Agency. Registration Reference: CB/VE5431JM This information can be found on the Environment Agency public register website. SUMMARY OF RELEVANT LEGISLATION The Environment Act 1995 - the Environment Agency has been made responsible for issuing waste management licenses and other aspects of waste regulation. The Environmental Protection Act 1990 - The majority of waste leaving the Company is controlled waste. This is described in section 74(4) of the EPA 1990 as the waste arising from household, commercial or industrial premises. Controlled waste includes waste from offices, food handling, shops and other domestic activities. The Environmental Protection Act 1990, section 34 - Imposes a "Duty of Care" on producers and handlers of waste, "to take reasonable measures to prevent the unauthorised deposit, treatment or disposal of waste." The Landfill Directive (last phase commenced 30th October 2007) – There is a requirement to pre-treat all non-hazardous waste. The legal definition of treatment requires a 3-point test. It must: 1. Be a physical, thermal, chemical or biological process (including sorting) 2. Must change the characteristics of the waste 3. must do so in order to a. reduce its volume or b. reduce its hazardous nature or c. facilitate its handling or d. enhance its recovery The Hazardous Waste Regulations 2005 - This legislation is relevant to those wastes that may be hazardous or toxic. They detail how hazardous waste should be kept, stored, treated and disposed of. In order to move this type of waste the Company has registered all sites that produce more than 200kg of hazardous waste per annum with the Environment Agency. Allhazardous waste movements are recorded using the consignment note system and these must be kept for a minimum of three years on file. Fines for not adhering to this legislation can be up to £5,000 and/or 2 years in prison. Safe Disposal of Clinical Waste 1992 - All clinical waste must be kept in lockable containers and collection, disposal and transfer must comply with current legislation. Waste Electrical and Electronic Equipment (WEEE) Regulations 2005 - These regulations aim to ensure that waste electrical and electronic equipment is disposed in an appropriate environmentally suitable way at the end of its operational life. They aim to cover all electrical and electronic equipment

used by consumers and professionals, which would more than likely end up in the waste stream. The key principle of this directive is producer responsibility for disposal. The Company has protocols in place for the disposal of white goods and electronic equipment. Batteries and Accumulators Regulations (2009) – This legislation prohibits the incineration and landfill of batteries and accumulators and also sets targets for the recycling of these items (25% by2012 & 45% by 2016) The UK currently produces 25,000 tonnes of batteries per year. GUIDANCE ON WHAT TO DO WITH WASTE Recyclable materials Paper, cardboard, plastics, tetrapak, coffee cups, glass, food cartons, tin cans etc must be placed in recycling bins. For further information on what can be recycled please see http://www.recycling-guide.org.uk/ General wastes Crisp packets, chocolate wrappers, polystyrene packaging etc must be placed in the general waste bins. Organic wastes Food wastes such as tea bags, fruit peelings etc must be placed in general waste bins. The Company is investigating the future collections of organic wastes for composting but currently this option is not available. Large recyclable materials Wood, metal, plastics, garden wastes, old furniture, etc which cannot be reused. Staff must these materials to the office premises to be transported for recycling. They will be taken to the relevant recycling compound where skips dedicated for different wastes and recyclables are located. Waste Electrical and Electronic Equipment (WEEE) (1) IT related WEEE such as PCs, keyboards, mice, monitors, printers etc., Staff must contact QM who will advise on disposal and has an agreement with an approved contractor to dispose of all IT related equipment. (2) Non-IT related WEEE such as televisions, heaters, desklamps, kettles, white goods etc. Staff should inform QM to have these materials collected. They will be taken to the relevant recycling compound where skips dedicated for different wastes and recyclables are located. Batteries Used batteries must be stored in the used battery collection bin in store 4. These will then be recycled. Hazardous waste Waste oils, fluorescent lamps, sharp boxes etc. Staff must contact the QM who will arrange for safe storage and disposal of these items. These items will be recycled.