Purpose

The purpose of this Standard is to place environmental management requirements on Contractors providing PSS to the MOD. This ensures that the MOD is compliant with environmental legislation, policy, and best practice as well as other relevant criteria including MOD policy, defence regulation and guidance. This Standard is intended to be tailored to represent the specific needs of the PSS and the intended application and operational context. 0.5 It is MOD practice that Defence Standards are used only where civil or open standards cannot be effectively applied in a military context. One of the goals of this Standard is that civil or open standards should be used as the basis for complying with its requirements. In practice, not all standards will fully address the requirements of this Standard, so Contractors proposing to use such standards need to carry out gap analysis and propose ways of addressing any shortfalls. 

This Standard can be applied to any MOD project and in any phase of a project’s life. Contractors shall use this Standard as required by the Contract. The effective application of this Standard requires close cooperation between all parties, as the responsibility for the achievement of environmental protection is shared by all stakeholders.

The intent is that compliance with the requirements within this Standard will facilitate MOD’s discharge of its environmental protection duties. 

The term PSS is used to describe all the articles or artefacts that are being delivered as defined in the Contract. This Standard is intended to capture a broad spectrum of deliverables, e.g.:

Product: A platform, power unit, weapon system, or its components. 

Service: Access to a commercially owned, commercially operated satellite communications system, catering, or a maintenance contract for military vehicles.

System: Air traffic control facility with integrated radar and radio equipment.

Under UK law, all employers have a duty of care to their employees, as well as the general public and the wider environment. The Secretary of State to Defence has issued a Health, Safety and Environmental Protection Statement which is to be applied throughout Defence. It requires that the MOD minimise work-related fatalities, injuries, ill-health and adverse effects on the environment, and reduce health and safety risks so that they are as low as reasonably practicable (ALARP), and that within the United Kingdom (UK) MOD complies with all applicable HS&EP legislation.

The MOD will discharge this environmental duty by placing contracts that ensure that:

All adverse impacts on the environment are reduced to acceptable levels, as agreed with the MOD. The acceptable level will be determined by working in accordance with extant environmental management standards, unless legislation, regulations, or MOD policy imposes a more stringent approach

All identified environmental aspects with adverse impacts, including those associated with end of life and disposal, are to be managed, and the associated environmental impacts and risks mitigated. Positive environmental impacts are to be exploited where possible.

Normally compliance with regulations and standards is sufficient to meet environmental management requirements. If the Contractor believes this to be the case, then this must be documented for agreement by the MOD. If this is the case, then many of the detailed environmental management requirements clauses may be removed during the tailoring process.

Traceability of evidence to support decisions is fundamental; without it, it is not possible to understand how the results of low level activities contribute to demonstrating satisfaction of requirements. If traceability is lost, then this can seriously undermine the validity of the approach to environmental management. Traceability is bi-directional (top-down and bottom-up).

Environmental aspects, where identified by environmental assessment activities as significant, will give rise to environmental impacts and risks that will require formal mitigation, control or exploitation. The aim of this will be to make negative environmental impacts and risks less likely to occur, less severe, and/or to exploit any positive environmental impacts.

The requirements are grouped in this Standard as follows:

1 & 2 - Scope and Applicability & Satisfaction of Requirements. Covers the scope of this Defence Standard to clarify responsibilities between the MOD and the Contractor, and the management of requirements. This includes the management of deviations from requirements.

3 – Environmental Management Requirements. Covers the management requirements for organisations to ensure that environmental management practices are defined and documented throughout the scope of the Contract and, therefore, environmental protection requirements are met. This includes the requirements for legislation, guidance, MOD policy, best practice, deliverables, interfaces and audits that Contractors need to deliver throughout the whole lifecycle of the PSS to ensure that environmental aspects are identified and managed; and good environmental practice is applied in design of the PSS and its supply chain.

4 – Roles and Responsibilities. Covers the organisation, competency and awareness of the roles and responsibilities, including the role of the Environmental Committee.

5 – Interfaces. Covers the management of interfaces such as organisational, technical, and interacting. It also covers Contractor and Independent Environmental Audits, and remedial action.

6 – Environmental Assessment and Control. Covers the requirements for Contractors to undertake a proportionate assessment of the environmental aspects to minimise adverse impacts and drive positive outcomes through-life and communicate them to the MOD. This includes requirements for recording and documenting aspects and impacts, as well as environmental reporting and change control.

 7 – Supply and Change Management. Covers the requirements for change management, including the management of change.

8 – Environmental Management Responsibilities - In-Service. Covers the requirements for managing environmental protection where a Contractor is supporting the MOD by providing a service to deliver Assured Capability throughout the in-service life of a PSS.

This Standard details requirements for the identification of the environmental aspects and the assessment of associated environmental impacts and risks. Where the identification of environmental aspects suggests a potential risk to human life, the relevant information shall be communicated to the appropriate safety management system.

The Contractor’s approach to environmental management must include the identification and assessment of all the environmental aspects linked to operation of the PSS, as appropriate for the CADMID cycle the Contractor has been contracted to support (usually the “Demonstration, Manufacture, In Service and Disposal” stages following a tender process). There must be consideration of any common issues by cross-referencing the results of hazard identification through the Safety Management System (SMS) and environmental aspects identified through the EMS. 

MOD acquisition programmes may take a common approach by combining safety and environmental management systems and, in many cases evidence or plans can be compiled into a single document, e.g. a Safety and Environmental Management Plan (SEMP).

Notes:

This Standard cannot place requirements on the MOD. 

MOD obligations are derived from extant government and departmental policy. Further details can be found within Part 2 of this Standard. 

What constitutes a significant aspect will be dependent upon the nature and scale of the PSS and its operating context, as well as the anticipated environmental impact.

SCOPE AND APPLICABILITY

This Part of the Standard sets out requirements for environmental management and associated assurance, and provides overarching objectives and principles that should be complied with in meeting these requirements. Part 2 of this Standard provides guidance on establishing a means of compliance with the requirements for the management of environmental aspects that will drive reductions in negative environmental impacts and the optimisation of positive environmental impacts. 

A requirement which uses the word “shall” identifies the clause or sub-clause as mandatory. Clauses using the word “should” are tailorable, allowing the Contractor the opportunity to consider an alternative approach in meeting the requirement. 

This Standard is to be applied to all PSS procured to meet diverse capabilities across all Defence systems and will therefore need to be tailored to reflect the needs of the PSS and contractual terms and conditions. The MOD will tailor the application of clauses and sub-clauses of this Standard or, in consultation with the Contractor, agree tailoring to reflect the following: 

The scope of supply: the deliverable PSS and information.

The scope of analysis: all the environmental relevant activities to be undertaken, which may apply to more than or less than, the scope of supply.

To address a broad range of scenarios, this Standard sets out environmental management requirements which require application in any given situation. 

Tailoring must be applied to capture the environmental management requirements for a specific project, taking into account the urgency of the need. 

The scope of contract encompasses the scope of supply and scope of analysis. It is negotiated during the early phases of a project where the scope of supply and the scope of analysis are determined. The scope of analysis would normally be applied to the PSS identified in the scope of supply. The scope of analysis may be greater than that applied to the scope of supply, e.g. where interfacing and integration with other PSS is required. In some cases, the scope of analysis may be less than the scope of supply, e.g. where equipment that has an Environmental Case is to be reused in a different operating environment. 

It is standard practice for the MOD to mandate a Contractor to have an EMS. As such, this Standard provides the framework for the Contractor’s organisation to direct and control its environmental management activities, including the organisational structure, processes, procedures, techniques, methodologies, ethical behaviours and ethos.

Notes: 

The guidance in Part 2 helps to analyse the different circumstances which can arise and to provide rationale for compliance with this Standard, as well as proportionality guidance. 

If the Contract does not include provision of services or products through-life (by the Contractor) then the clauses contained in “Section 8 – Environmental Management Responsibilities - In-Service” will not be applicable. 

The clauses can be tailored at a more detailed level, depending on the scope of contract, standards or the approach to regulation or policy in a particular sector. Guidance will be given on tailoring by the MOD, but this is likely to be project dependent. Tailoring can be done only by the MOD, or as suggested by industry and with the agreement of the MOD; and must reflect the relevant specific domain regulatory requirements and regulatory arrangements. iv. Tailoring can only be agreed by suitably qualified and competent MOD personnel.

This Standard is not intended to be applied to consultancy contracts for independent environmental audit services or manpower substitution services.

The introduction of scope of supply is intended to identify what is delivered and not delivered (including a service) to the MOD.

This Standard intends to cover a broad range of contractual scenarios, including contracts providing support to operations e.g. a PSS delivered and maintained by Contractors in an operational environment. For all PSS to which this Standard applies, the MOD will retain responsibility for operational risk management and would take account of the environmental impact assessment.