Examiners Report

NEBOSH Specialist Diploma in

Environmental Management
December 2005 examination

CONTENTS

Introduction

Examination paper

Workplace-based project

11

Examination statistics

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2006 NEBOSH, Dominus Way, Meridian Business Park, Leicester LE19 1QW
tel: 0116 263 4700

fax: 0116 282 4000

email: info@nebosh.org.uk

website: www.nebosh.org.uk

The National Examination Board in Occupational Safety and Health is a registered charity, number 1010444
T(s):exrpts/E/ED-2005-12

SS/JS/TAK/REW/200

Introduction

At the time of the December 2005 examination, there were over 1000 holders of the Specialist Diploma.
Many of these now hold responsibilities for environmental management on a full or part-time basis. As
there are few other nationally recognised professional qualifications in environmental management, the
Specialist Diploma has become an established route for those with a background in health and safety
wishing to acquire a specialist expertise in environmental management. The ability to see problems
and potential solutions from two different perspectives is a considerable asset. In many situations,
experience shows that workplace and environmental issues are closely related, often with the same
basic causes. By marrying the two disciplines in the Specialist Diploma syllabus, candidates are given
the opportunity to explore the relationships between the complementary approaches taken by the two
disciplines in dealing with problems.
The examination comprises a 3-hour written paper and a practical workplace-based project. The
written paper is based on the intended learning outcomes detailed in the course syllabus. The
examination questions reflect the contents of this syllabus and candidates are therefore advised to base
their preparations on this document. The questions set in the examination are designed to test a
candidates ability to:

advise management on likely environmental impacts;

advise management on actions needed;

make arrangements for appropriate actions; and

demonstrate an appreciation of the relationship between the actions taken to prevent harm to
people at work and those aimed at protecting the environment.

The standard that is required for the examination is determined by NEBOSH, guided by its Advisory
Committee comprising nominees from, amongst others, HSE, the Environment Agency, CBI, TUC and
IOSH and representatives of both private and public training providers. The Diploma Management
Panel, which oversees all aspects of the Specialist Diploma in Environmental Management, reports to
the Directors and Trustees, who are appointed from the Advisory Committee. Examiners for the
Specialist Diploma are selected from a team of well-qualified and experienced persons in the field,
typically working for enforcement agencies, local authorities, training providers and organisations within
industry.
The practical workplace-based project has proved to be an effective and valuable means of assessing
candidates abilities to put theory into practice. Candidates sitting this examination are required to
submit projects based upon an Environmental Audit proforma that has been developed by NEBOSH to
enable candidates to structure their practical work. From the quality of many projects submitted for this
award, the proforma has again shown itself to be a useful tool in this respect.

Examination paper five from eight questions to be attempted

General comments
This paper is designed to test the depth of candidates knowledge and understanding by sampling a few
key areas of the Specialist Diploma syllabus.
With a consistently high pass rate for the Specialist Diploma, it is clear that most candidates are well
prepared and have developed an acceptable examination technique. The most common failing is that
candidates clearly do not always read the questions with sufficient care and spend valuable time
providing details of related issues but ones that are irrelevant to the actual question being asked.
Question 1

(a)

(b)

With reference to relevant standards, outline the meaning and

purpose of life cycle assessment (life cycle analysis).

(6)

By using a suitable example, describe the stages of a life cycle

assessment.

(14)

International Standards Organisation ISO 14040 series (14040; 14041; 14042; 14043)
contains the specifications and requirements applying to life cycle analysis. The
technique is often used for assessing environmental aspects and potential impacts of a
product and may be used to compare impacts of a range of products in order to identify
those with least adverse impact on the environment. Most candidates who attempted
this question successfully identified the relevant standard and meaning of the term and
so gained most marks on this part of the question. Some neglected to explain the
purpose of LCA and so lost the opportunity of gaining higher marks on part (a).
Part (b) sought a description of form and content of each of the following stages in the
life cycle analysis methodology:
Stage 1 definition of goal and scope
Stage 2 inventory analysis
Stage 3 impact assessment
Stage 4 interpretation
Those candidates who gave a general description of each stage together with a
suitable example application, would have performed well in this part. Detailed
descriptions of the requirements of ISO14001 specification for environmental
management systems were not needed in order to answer this part.
In general, although not a popular question, those candidates attempting it generally
did reasonably well.

Question 2

Write a memorandum to the facilities manager for a large commercial

office building explaining the main requirements of the Hazardous Waste
Regulations 2005. Your answer should make reference to examples of
typical types of wastes produced at commercial offices that could be
classified as hazardous waste.

(20)

Many candidates demonstrated a clear understanding of the new Hazardous Waste

system as implemented in the 2005 Regulations.

A strong answer would have made reference to the purpose of the Regulations being to
implement the EU Hazardous Waste Directive. Under the new system, producers of
hazardous waste must register with the Environment Agency as a Producer unless exempt
from the registration requirement. Exemptions from registration include commercial offices
where less than 200 kgs of hazardous waste are produced in any twelve month period.
Contractors producing waste at the premises may also be registered as producers under
special arrangements for Mobile Service registrations. The producer is responsible for
assessing (characterising) whether a waste is a hazardous waste by reference to those
wastes which are listed in the List of Wastes Regulations 2005 annotated by a *. Better
answers referred to the distinction between absolute entries and mirror entries. For mirror
entries, testing may be required against the dangerous properties and thresholds listed in
the Regulations. Absolute entries are always hazardous waste irrespective of any
dangerous properties.
The ban on mixing hazardous waste and keeping it segregated from other wastes would
also have attracted marks, as would a brief explanation of the consignment note
procedures and the relaxation on the pre-notification requirement. Better answers
explained that consignment notes must bear producers registration number and the sixdigit code from the List of Waste Regulations (or European Waste Catalogue).
A well structured answer would have rounded off with reference to the requirement that if
waste is to be disposed of to landfill, the producer must ensure that the waste meets the
Waste Acceptance Criteria for the landfill, if necessary by pre-treatment.
A wide range of types of waste could have been mentioned as examples of hazardous
wastes including: computer monitors; fluorescent tubes; oils; batteries; paints/solvents;
asbestos; infectious waste from first aid treatment; and certain medicines.

Question 3

A commercial printing company, situated in a predominantly residential

area, currently operates a day shift only. Having secured new contracts
for printing mail order catalogues, it is now proposing to introduce a night
shift. Describe:
(i)
(ii)

the various sources of night time noise disturbance that could be

caused by the proposed change

(8)

how the company should assess whether these sources of noise

disturbance could cause complaints from local residents.

(12)

Night time noise is a common cause of local nuisance to residents near to industrial
areas. Noise emissions that are frequently involved include; works traffic and in
particular employees cars, fork lift trucks, delivery vehicles: process machinery and
equipment; service equipment and in particular compressors and fans; general factory
noise escaping through open doorways, vents etc; and other intermittent noise sources
such as tannoys, radios, employees shouting instructions etc.
In deciding whether or not introduction of a night shift will be likely to cause complaint
from local residents, the Company should undertake an assessment, using for example
the structure and methods established under British Standard BS 4142 which sets out
the methods for carrying out an assessment of noise arising from an industrial source.
They should then have explained the steps that would need to be taken such as:
measuring the existing background noise levels. The noise levels with the plant
operating at night; determining the changes in noise emission due to the change in
working times; assessing the actual increase against the levels advised in the standard
bearing in mind both that an increase of more than 10dB(A), for example, would be
likely to give rise to complaints and that adjustments may also be required to take
account of particular factors such as tonal characteristics and impact noise; and
evaluating the findings, taking into account any other issues such as the prevalence of
existing noise nuisance problems and the sensitivity of local residents. Good answers
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gave explanations of the above steps that showed a clear understanding of the issues
involved.

Question 4

Identify and describe the different pathways through which contaminated

land may affect human and other environmental receptors.

(20)

The presence of contamination on or in land may adversely affect people and the
environment through a number of different pathways. This question was designed to
allow candidates to demonstrate that they understood how contamination might
contribute a risk if a suitable pathway links a source to a receptor. Examples of
pathways that could have been described included the following.

Leaching and washing into surface waters giving rise to pollution in rivers,
streams and other surface water bodies and possible subsequent abstraction
for drinking water.
Vertical migration into groundwater and subsequent recharge into surface
waters or exposure following abstraction.
Migration of flammable, toxic and asphyxiant gases through soils and natural
fissures leading to inhalation or explosion risk.
Migration through soils and into drinking water supply systems through plastic
pipes and mastics.
Direct uptake of contaminants by crops and subsequent ingestion by animals
and people.
Direct contact with contaminated soils and possible ingestion, particularly by
children and site workers.
Dust blow from the surface containing hazardous substances leading to
inhalation or deposit on food or land.
Migration through and into building materials leading to their degradation.
Escape of gases and vapours from the land leading to odour nuisance.
Land stability effects leading to subsidence and landslip.
Exposure to radiation.
Combustion of flammable materials in the ground leading to a range of
potentially serious environmental and safety risks.

Answers to this popular question were of a variable standard. Most candidates

identified water pollution pathways and inhalation and ingestion of dust. Better
candidates also identified some of the other possible routes. However, a significant
number of candidates attempting this question appeared to have been side-tracked into
discussions of causes of contamination, remediation techniques and/or legislative
requirements, none of which were relevant to the question and so scored little of any
additional marks.

Question 5

Demonstrate your understanding of each of the following terms in the

context of environmental hazardous substances. Give TWO relevant
examples to illustrate your answer in each case.
(i)
(ii)
(iii)
(iv)
(v)

Persistence
Bioaccumulation
Ecotoxicity
Biotransformation
Half-life.

(4)
(4)
(4)
(4)
(4)

This question was not popular with candidates, although this would have been a
relatively straightforward question to anyone who had studied Module A of the syllabus.
Persistence is when a substance is resistant to breakdown by chemical, physical and
biological processes under normal environmental conditions. Examples could have
included toxic metals and many chlorinated organic compounds.
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Bioaccumulation is where a substance is likely to accumulate within the tissues or

organs of an organism leading to an accumulation of concentration above background
levels and may then further accumulate through the food chain. Again examples could
have referred to mercury, cadmium, some pesticides, polychlorinated biphenyls etc.
Ecotoxicity is where a substance may exert toxic effects upon one or more components
of the ecosystem. Any toxic substances could have been referred to as examples.
Biotransformation is where a substance is changed into another substance by the
action of living organisms, typically by microorganisms. The case of methylation of
mercury in Minimata Bay was cited by some candidates as a suitable example.
Half-life is the time taken for the concentration of a substance to be reduced to 50% of
the original starting concentration. Many candidates referred to radioactivity as an
example, although the concept can be applied to any substance, irrespective of
radioactive properties.

Question 6

Describe the main features and requirements of the Eco-Management and

Audit Scheme (EMAS).

(20)

Similar to the preceding question, this was also surprisingly unpopular. EMAS is a
central pillar of the management systems component of the syllabus and should have
been easy for candidates to describe. A good description would have made reference
to the fact that participation opened in April 1995 as a voluntary scheme established by
an EU Regulation which aims to bring all business and authorities to improving their
environmental performance. It is open to all EU based organisations in private and
public sectors.
The main requirements of EMAS are:

Initial environmental review

Environmental policy with provision for legal compliance and commitment to

continual improvement of environmental performance

Planning covering all elements identified in the environmental review

Implementation including employee involvement, compliance by suppliers and

contractors

Checking and corrective action including an audit cycle of 3 years or less covering
environmental performance

Management Review

Certification under an approved accreditation scheme

Publicly available environmental statement meeting the requirements of Annex III

to the EMAS Regulation

Independent validation of the environmental statement

Better answers made mention of the role of ISO14001:2004 in meeting the

requirements of the EMS stages of EMAS from Policy down to Review.

Question 7

Compare and contrast the common law torts of private nuisance and
public nuisance, illustrating your answer with examples of typical
situations that may give rise to an action under the tort of nuisance and
referring to the possible defences and remedies available.

(20)

Quite a popular question with many candidates. Nuisance is one of the fundamental
principles of common law and has latterly been incorporated into statute as so-called
statutory nuisance. The common law nuisance has developed through two branches,
private nuisance and public nuisance. Private nuisance is basically an unreasonable
interference with a persons use or enjoyment of land, or some right over or in connection
with it. To be liable under the tort, it should be foreseeable that actions would be likely to
give rise to a nuisance. Typical activities actionable under private nuisance include:
encroachment (eg landslide); physical damage to land (eg migrating landfill gases killing
vegetation); interference with enjoyment of property (eg noise or smells). Private nuisance
is actionable by individuals with a direct proprietary interest in the land affected.
Liability for an unreasonable interference or nuisance depends on:
- duration of the interference;
- sensitivity of the claimant;
- any malice; and
- character of the neighbourhood.
Defences include:
- prescription continuing a nuisance for 20 years may legalise it by prescription;
- statutory authority; or
- act of God or a stranger.
Public nuisance is a crime as well as a tort. In essence it is similar to private nuisance,
except that it is well established that there is no need to have an interest in land affected
and prescription is not a defence. Persons affected are the public, or a section of it, which
suffer damage at large. Typical examples of public nuisance would be: wide scale fallout
of dust over a large number of properties; an offensive smell affecting a town centre; noise
affecting more than handful of properties.
Remedies under nuisance include:
- an injunction;
- right to take action to abate the nuisance, where notice is given to defendant, no
unnecessary damage is caused and the abatement is that course of action that
represents least cost to the defendant; and/or
- damages.
Many candidates produced very good answers being particularly well illustrated with
examples, including appropriate references to leading case law examples

Question 8

A company is planning to construct a new energy from waste facility that

will be a Part A(1) installation under the Pollution Prevention and Control
Regulations 2000. In preparing its application for a permit, the company
needs to undertake an assessment to determine the likely effect of
emissions of exhaust gases from a proposed chimney at the facility.
(i)

(ii)

Describe the key stages and information that would be needed to

allow the company to use an air pollution diffusion model to
predict the likely effect of emissions from the chimney on ground
level air quality.

(11)

Describe, with the aid of diagrams, ONE method that could be

used to quantify ambient levels of EACH of the following air
pollutants downwind of such a chimney, and explain the principles
of operation of each method:
nitrogen dioxide
sulphur dioxide
particulate matter as PM10.

(3)
(3)
(3)

The principles and application of environmental modelling is specifically referenced in the

syllabus and so this should have been a relatively straightforward question to attempt.
The first part to the question required candidates to describe the following key stages and
information requirements:

Establishing the probable mass emission rates of key pollutants from the process
under different operating conditions using data from existing plants, theory or mass
balance calculations, etc.

Establishing the likely efflux velocity from the chimney based on stack gas velocity and
stack cross-sectional area and then a calculation of the effective stack height, taking
account of plume rise due to velocity and buoyancy.

Gathering and reviewing meteorological information to determine prevailing wind

directional frequency and velocities, stability profiles etc.

Applying a diffusion model to predict dispersion of emissions via the atmosphere

taking account of meteorology, ground terrain, surface roughness etc.

Establishing existing background concentrations for the key pollutants

Predicting the net increase in ground level concentrations above background arising
from the stack emissions for each pollutant and then comparison of resultant
predictions against relevant air quality standards and objectives.

Some candidates missed easily available marks on this part by digression into the theories
and roles of air pollution dispersion modelling, rather than concentrating on how a
modelling exercise would be undertaken.
In the second part of the question candidates had a wide range of techniques that could be
used to quantify emissions of the relevant substances. Use of diagrams helped
candidates in explaining how the selected techniques operate and their underlying
principles of operation. In general, this second part to the question was answered well.

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Workplace-based project

The workplace-based project is a valuable part of the assessment of a candidates ability to apply the
knowledge and understanding gained during the programme of study they have undertaken.
Yet again, the Moderators were pleased with the generally high quality of the projects that were
submitted. It is important that candidates, and their tutors, remember that projects are intended to be
written in a style that is valuable to management. Candidates are being assessed not on their ability to
impress those assessing the projects but on their ability to present assessments and arguments in a
way that will gain credibility with managers. It is important, therefore, that candidates are able to explain
why actions are required, for example where there is a possible breach of a legal duty.
In preparing their written project reports, candidates would be strongly advised to read carefully the
guidance provided with the Audit proforma. Projects are marked according to standard criteria which
reflect the guidance that is given.

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Examination statistics

Specialist Diploma in Environmental Management

December 2005 examination

Summary of examination results

Examination
date

June 2004

Number of
examination
candidates

Referred in
written
paper

Pass in
written
paper
(Grades A-D)

Examination
pass rate

Number of
candidates
submitting
project

Referred in
project

95

31

64

67%

86

22

35

54%

50

65
December 2004
June 2005

76

27

35

56%

51

December 2005

59

25

34

58%

36

Summary of award grades

Examination
date

Number
Fail
of eligible (project
candidates *
and
written
paper)

Referred
in project
only

Referred
in written
paper
only

Pass

Credit

Distinction

Number
of
Specialist
Diplomas
awarded

Percentage
of eligible
candidates
awarded the
Specialist
Diploma

June 2004

94

28

27

27

63

67%

December 2004

57

21

19

10

35

61%

June 2005

62

27

17

12

35

56%

December 2005

55

21

15

11

42

76%

eligible candidates are those who had completed both units of assessment by the time of the respective Results Panel (which,
for the December 2005 examination, was on 17 February 2006).

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