Should businesses investigate Environmental near misses like Safety near misses?
When a load falls from height and narrowly misses a worker, most businesses know what to do. The near miss is reported, investigated and corrective action is taken to prevent it from happening again.
But what happens when a drum of oil is nearly knocked over next to a surface-water drain? Or a damaged chemical container is discovered just before it starts leaking?
Nothing actually happened, so does it still get reported?
It should.
Environmental incidents can have serious consequences for a business. Just as breaches of Health and Safety legislation can result in enforcement action and prosecution, failures to comply with Environmental legislation can also lead to regulatory action, significant financial penalties, clean-up costs and reputational damage.
A spill, pollution event or incorrect waste disposal may not only harm the environment, it could become a costly compliance issue for the organisation responsible.
This is why environmental near misses deserve the same attention as Health and Safety near misses.
They provide an early warning that something has gone wrong, or nearly gone wrong, with your environmental controls. More importantly, they give you an opportunity to put things right before the consequences become much more serious.
What is an Environmental near miss?
An environmental near miss is an unplanned event or situation that had the potential to cause environmental harm but, through intervention, timing or sometimes sheer luck, did not result in a significant environmental incident.
Examples might include:
- A fuel or oil spill being contained just before reaching a surface-water drain.
- A damaged chemical container being identified before it begins to leak.
- Hazardous waste almost being placed into the wrong waste stream.
- Contaminated water being identified before it is discharged.
- A leaking fuel hose being discovered during an inspection.
- Waste being stored incorrectly but corrected before it causes pollution.
- A spill kit being found empty or incomplete before an emergency occurs.
At first glance, these events might seem relatively minor.
After all, no pollution occurred and no environmental damage was caused.
But each one tells you something important.
A control has failed, almost failed or may not have been there when it was needed.
We report Safety near misses, so why not Environmental ones?
Near-miss reporting is already an established part of good health and safety management.
If an employee nearly falls from a ladder, a vehicle narrowly avoids striking a pedestrian or an object falls without causing an injury, we don’t simply say:
“No one was hurt, so it doesn’t matter.”
We investigate because we understand that next time the outcome could be very different.
Environmental risk should be treated in the same way.
A small oil leak today could become a significant pollution incident tomorrow. Incorrectly stored chemicals could eventually enter a drain, soil or watercourse. Poor waste segregation could result in compliance issues or hazardous materials being handled or disposed of incorrectly.
The fact that environmental damage did not occur does not necessarily mean your environmental controls worked.
Sometimes, it simply means you were lucky.
And luck is not an environmental management system.
What can an Environmental near miss tell you?
Environmental near misses can reveal weaknesses that might otherwise remain hidden until a more serious incident occurs.
Perhaps employees have not received adequate environmental awareness training.
Maybe chemicals, oils or fuels are being stored in unsuitable locations.
Spill response equipment might be missing, incomplete or difficult to access.
Waste arrangements may not be clearly understood.
Inspections might not be identifying deteriorating containers or equipment quickly enough.
Drainage systems may not be adequately protected.
The important question isn’t simply:
“What happened?”
Businesses should also ask:
“What could have happened?”
That small change in thinking can make environmental incident prevention far more proactive.
Imagine a 20-litre container of oil is accidentally knocked over.
The spill is quickly contained and cleaned up. Nothing enters the drainage system, there is no visible environmental damage and everyone carries on with their day.
It would be easy to consider the matter closed.
But an investigation might discover that the container was stored next to an unprotected surface-water drain, there was no suitable secondary containment and the nearest spill kit was located in another building.
The spill itself may have been minor.
The weaknesses it exposed were not.
Next time, the business might not be so fortunate.
A near miss is an opportunity to prevent pollution
One of the biggest benefits of environmental near-miss reporting is the opportunity to take action before an actual environmental incident occurs.
Instead of waiting for a pollution event and then asking what went wrong, businesses can use near misses to identify problems while there is still an opportunity to correct them.
A simple reporting and investigation process can help identify root causes and introduce appropriate corrective actions.
Depending on the event, this might include:
- Improving chemical, oil or fuel storage.
- Introducing suitable secondary containment.
- Protecting surface-water drains.
- Reviewing waste segregation arrangements.
- Improving environmental inspection regimes.
- Relocating or replenishing spill kits.
- Improving emergency spill response procedures.
- Providing additional environmental awareness training.
Businesses should also look for trends.
One environmental near miss might be an isolated event.
Five similar near misses could indicate a much bigger problem.
If several sites repeatedly report damaged containers, incorrect waste segregation, small leaks or problems with the same type of equipment, the organisation has valuable information available to it.
That information can be used to prevent a potentially much more serious environmental incident.
The cost of ignoring the warning signs
There is another reason businesses should take environmental near misses seriously: environmental non-compliance can be expensive.
Depending on the circumstances and applicable environmental legislation, businesses responsible for pollution or other environmental offences can face investigation, enforcement action, prosecution and financial penalties.
There may also be costs associated with containing and cleaning up pollution, repairing environmental damage, disposing of contaminated materials, replacing equipment and dealing with disruption to normal business activities.
Then there is the potential reputational impact.
Customers, clients and supply-chain partners increasingly expect organisations to demonstrate responsible environmental management. A preventable pollution incident can raise uncomfortable questions about how seriously a business manages its environmental responsibilities.
Ignoring a near miss because “nothing happened” could therefore mean ignoring an opportunity to prevent a future incident with much greater environmental, legal and financial consequences.
Creating an Environmental reporting culture
There is also an important cultural element.
Many organisations have spent years encouraging employees to report health and safety near misses without fear of blame.
Why shouldn’t the same culture apply to environmental risks?
Employees should feel comfortable reporting situations where they believe environmental harm could have occurred, even when no pollution or damage actually took place.
The objective should not be to find someone to blame.
It should be to find the weakness before the weakness becomes an incident.
Environmental awareness also needs to extend beyond environmental managers.
Employees, contractors, supervisors and managers can all play a role because they are often the people who first notice a leaking container, overflowing waste area, damaged drain protection, poor chemical storage or incorrect waste disposal.
The more people who understand what an environmental near miss looks like, the more opportunities a business has to intervene early.
Don’t wait for the pollution incident
Environmental management should not only be about responding when something has already gone wrong.
Effective environmental risk management means recognising the warning signs beforehand.
Businesses already understand this principle when it comes to protecting people. Near-miss reporting allows organisations to learn from events where an injury could have occurred without waiting for somebody to actually get hurt.
Environmental protection deserves the same approach.
So, the next time a spill stops centimetres from a drain, a damaged chemical container is discovered just in time or contaminated water is prevented from being discharged, don’t simply clean it up and move on.
Report it. Investigate it. Learn from it.
Because an environmental near miss is more than an event where nothing happened.
It is a warning about what could happen next.
Learning from an environmental near miss today could help prevent pollution, environmental damage and potentially significant legal and financial consequences tomorrow.
If you require Environmental or Health and Safety support or guidance, please get in touch with our team for further assistance.
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