Health, Safety & Environment Policy

Last Updated: February 2026

Next Review Date: February 2027

Health, Safety & Environment Management Policy

EK Recycling Ltd is committed to promoting the health, safety, and wellbeing of all employees, contractors, visitors, and the public. We recognise that effective Health, Safety & Environment (HSE) management is integral to our business operations and essential for achieving our sustainability goals.

This policy establishes our commitment to prevent accidents, injuries, occupational diseases, environmental incidents, and to comply with all applicable health, safety, and environmental legislation.

1. Management Commitment

Senior management is committed to:

  • Ensuring the provision and maintenance of safe systems of work
  • Providing adequate resources, training, and supervision to achieve HSE standards
  • Setting measurable HSE objectives and targets
  • Regularly reviewing and improving HSE performance
  • Fostering a strong culture of health and safety awareness
  • Involving employees in HSE decision-making processes
  • Ensuring transparent reporting and investigation of all incidents
  • Maintaining open communication with local authorities and regulatory bodies

2. Legal Compliance

EK Recycling Ltd is committed to full compliance with all applicable legislation, including but not limited to:

  • Health and Safety at Work etc. Act 1974
  • Management of Health and Safety at Work Regulations 1999
  • Control of Substances Hazardous to Health Regulations 2002 (COSHH)
  • Personal Protective Equipment (PPE) Regulations 2016
  • Manual Handling Operations Regulations 1992
  • Work at Height Regulations 2005
  • Environmental Protection Act 1990
  • Environmental Permitting (England and Wales) Regulations 2016
  • Waste and Contaminated Land (Northern Ireland) Order 1997
  • Control of Dust and Emissions from Construction and Demolition SPG

We will monitor changes in legislation and adapt our practices accordingly to maintain full compliance.

3. Risk Assessment Procedures

3.1 Systematic Risk Assessment

We conduct comprehensive risk assessments to identify hazards and evaluate risks across all operations, including:

  • Waste reception and sorting operations
  • Machinery and equipment operation
  • Site access and vehicle movement
  • Chemical and hazardous substance handling
  • Lifting and manual handling activities
  • Environmental impact and emissions

3.2 Risk Assessment Documentation

All risk assessments are documented, reviewed annually or when operational changes occur, and made available to all relevant personnel. Risk assessments are used to determine appropriate control measures and inform training requirements.

3.3 Dynamic Risk Assessment

Supervisors and managers are trained to conduct dynamic risk assessments to identify emerging hazards during daily operations and implement immediate control measures.

4. Employee Training & Competence

4.1 Induction Training

All new employees receive comprehensive induction training covering:

  • Company HSE policies and procedures
  • Site-specific hazards and emergency procedures
  • General health and safety awareness
  • Environmental management requirements
  • PPE requirements and proper use

4.2 Role-Specific Training

Employees receive training appropriate to their role, including:

  • Waste handling and sorting procedures
  • Machinery operation and maintenance
  • Hazardous substance handling (COSHH)
  • Manual handling techniques
  • Forklift and lifting equipment operation
  • First aid and emergency response
  • Environmental controls and monitoring

4.3 Competence Assessment

We ensure all personnel are competent in their assigned duties through:

  • Assessment of knowledge and practical skills
  • Observation of working practices
  • Refresher training at appropriate intervals
  • Certification and record-keeping

4.4 Continuous Development

We maintain a culture of continuous improvement through regular training updates, toolbox talks, and access to professional development opportunities.

5. Safe Systems of Work for Waste Operations

5.1 Standard Operating Procedures

All waste handling and processing activities are governed by detailed Standard Operating Procedures (SOPs) that specify:

  • Safe methods of operation
  • Equipment and machinery use
  • Hazard control measures
  • Inspection and maintenance schedules
  • Segregation of incompatible waste streams

5.2 Machinery and Equipment Safety

All machinery undergoes:

  • Pre-operation inspection and testing
  • Regular preventative maintenance
  • Immediate removal from service if defects are identified
  • Proper guarding and safety devices
  • Operator training and certification

5.3 Site Traffic Management

Vehicle and pedestrian safety is maintained through:

  • Designated traffic routes and parking areas
  • Speed restrictions and directional controls
  • Exclusion of non-essential vehicles from operational areas
  • Regular condition and visibility checks
  • Driver training and competence assessment

5.4 Waste Segregation and Contamination Control

We maintain strict waste segregation to prevent:

  • Hazardous material contamination
  • Cross-contamination between waste streams
  • Environmental release of contaminants
  • Worker exposure to hazardous substances

6. Personal Protective Equipment (PPE)

6.1 PPE Requirements

All employees working in operational areas are required to wear appropriate PPE including:

  • Safety helmets with chin straps
  • High-visibility jackets or vests
  • Steel-toed safety boots
  • Cut-resistant and chemical-resistant gloves (as appropriate)
  • Face protection and respirators (when dust or fume exposure risk is identified)
  • Hearing protection (in high-noise areas)
  • Eye protection against chemical splashes

6.2 PPE Provision and Maintenance

The company provides all necessary PPE at no cost to employees and is responsible for:

  • Selection of appropriate PPE based on risk assessment
  • Proper fitting and training in correct use
  • Regular inspection, maintenance, and replacement
  • Proper storage and hygiene

6.3 Employee Responsibilities

Employees are required to:

  • Wear all prescribed PPE while on site and in operational areas
  • Inspect PPE before use and report defects immediately
  • Maintain PPE in good condition and properly store when not in use
  • Not remove or modify PPE unless authorised

7. Emergency Procedures

7.1 Emergency Response Plan

We maintain a comprehensive emergency response plan covering:

  • Fire prevention and evacuation procedures
  • Medical emergency response and first aid
  • Spill containment and environmental emergency response
  • Gas release or explosion response
  • Communication with emergency services
  • Incident recovery and resumption of operations

7.2 Emergency Equipment

We maintain and regularly test:

  • Fire detection and suppression systems
  • Emergency alarms and communication systems
  • First aid kits and automated external defibrillators (AEDs)
  • Emergency eyewash and shower stations
  • Spill kits and containment equipment

7.3 Emergency Drills

We conduct regular evacuation and emergency response drills to ensure all personnel understand their responsibilities and can respond effectively.

8. Environmental Controls

8.1 Dust Management

We minimize dust emissions through:

  • Enclosed processing systems where feasible
  • Local exhaust ventilation systems
  • Water spraying and damping during handling
  • Regular site sweeping and cleaning
  • Speed restrictions on unsealed roads
  • Air quality monitoring at site boundaries

8.2 Noise Control

We reduce noise emissions by:

  • Operating modern, low-noise machinery
  • Installing silencers and sound-damping enclosures
  • Restricting operating hours where required
  • Providing hearing protection for workers
  • Conducting regular noise monitoring

8.3 Water and Soil Protection

We protect water and soil quality through:

  • Sealed surfaces and contained drainage systems
  • Oil interceptors and treatment facilities
  • Proper containment of hazardous materials
  • Regular water quality testing
  • Sediment control measures
  • Prevention of groundwater contamination

8.4 Air Emissions

We monitor and control air emissions including:

  • Volatile organic compounds (VOCs)
  • Particulate matter (PM10 and PM2.5)
  • Nitrogen oxides and sulfur dioxide
  • Odour control measures

9. Incident Reporting and Investigation

9.1 Reportable Incidents

All incidents must be reported immediately, including:

  • Injuries requiring medical treatment
  • Work-related diseases or health conditions
  • Lost-time accidents (absence exceeding 7 days)
  • Dangerous occurrences with potential for injury
  • Environmental releases or spills
  • Near-miss incidents

9.2 Investigation Procedure

All incidents are investigated to:

  • Establish facts and circumstances
  • Identify root causes and contributing factors
  • Determine corrective and preventive actions
  • Prevent recurrence

9.3 Reporting to Authorities

RIDDOR-reportable incidents are reported to the Health and Safety Executive within 15 days. Environmental incidents are reported to the Environment Agency as required by permit conditions.

9.4 Learning from Incidents

Incident information is shared across the organization to prevent similar incidents and improve safety culture.

10. Monitoring, Measurement and Review

10.1 HSE Performance Metrics

We track and monitor:

  • Lost time injury frequency rate (LTIFR)
  • Total recordable incident rate
  • Near-miss reporting rates
  • Environmental compliance audits
  • Regulatory inspection findings
  • Employee health and wellbeing indicators

10.2 Inspections and Audits

We conduct:

  • Weekly site safety inspections
  • Monthly environmental monitoring
  • Quarterly HSE management reviews
  • Annual comprehensive audits
  • Regular third-party environmental audits

10.3 Policy Review

This policy is reviewed annually and updated to reflect:

  • Changes in legislation and best practice
  • Incident trends and lessons learned
  • Operational changes and new processes
  • Employee feedback and suggestions

11. HSE Responsibilities

11.1 Senior Management

Responsible for setting HSE strategy, allocating resources, and ensuring organizational compliance with this policy.

11.2 Site Managers and Supervisors

Responsible for implementing HSE procedures, conducting risk assessments, providing training, and daily monitoring of site conditions.

11.3 All Employees

Responsible for:

  • Following all HSE procedures and instructions
  • Reporting hazards and incidents immediately
  • Wearing appropriate PPE
  • Contributing to a positive safety culture
  • Participating in training and drills

11.4 Contractors and Visitors

All contractors and visitors must comply with our HSE requirements and site induction procedures before accessing operational areas.

12. Communication and Consultation

We promote open communication and consultation on HSE matters through:

  • Regular toolbox talks and safety meetings
  • HSE notice boards and signage
  • Employee suggestion schemes
  • Worker representation and consultation
  • Transparent incident reporting and investigation results
  • Engagement with local communities on environmental matters

This Health, Safety & Environment Policy is approved by senior management and represents our commitment to the health, safety, and wellbeing of all our workers and protection of the environment.

Last reviewed and approved: February 2026

Next review date: February 2027