The Flooring Contractors COVID-19 (Coronavirus) Update

Environmental Policy/Sustainability

Managing our activities

Our EMS is structured to help our business identify the environmental impacts resulting from our activities. It also helps manage and reduce those impacts, so that the environmental performance of the organisation is improved. This EMS will provide a methodical approach to planning, implementing and reviewing our environmental management.

We will therefore identify and control the risks that our activities pose to the environment and human health.

This EMS will:

  • identify where efficiency savings can be made;
    ensure compliance with environmental legislation;
  • identify and managing significant environmental impacts;
  • provide benchmarks for improvement;
  • help to manage resources.

It will also provide a way for our business to plan for and demonstrate that steps have been taken to reduce or prevent environmental harm occurring as a result of our operations.

It is the intention of THE FLOORING CENTRE to operate an effective Environmental Management System. We will therefore manage and operate our activities:

1. in accordance with a written management system that identifies and minimises risks of pollution, including those arising from operations, maintenance, accidents, incidents, non-conformances and those drawn to our attention as a result of complaints; and 2. using sufficient competent persons and resources.”

We will ensure that an EMS is in place, that it is adequate for the activities taking place and that it’s being implemented and communicated to all staff.


What will our EMS achieve?

An effective EMS will:

  • Minimise or prevent the risk of pollution to the environment by our activities which are being undertaken.
  • Be implemented at a strategic level and integrated into corporate plans and policies so that all our staff know their environmental responsibilities.
  • Assess our organisation’s environmental impacts and identify opportunities to reduce pollution to air, land and water.
  • Reduce waste.
  • Set out clear objectives and targets to minimise the significant environmental impacts.
  • Record environmental performance against targets and industry performance indicators to encourage continual improvement.
  • Ensure compliance with environmental legislation and take action to prevent and correct cases of noncompliance.
  • Deliver good resource management and encourage sustainable development and financial benefits.
  • Identify key interested parties and communicate company environmental performance to them clearly.


Identifying and minimising risks of pollution

This means that our staff are required to understand how the activities carried out by our organisation can interact with the environment and cause pollution. Every possible source of pollution will be identified and controlled. Once these potential sources of pollution are identified plans need to be put in place to minimise the chance of our activities causing environmental pollution.

A site plan or map can be useful in helping to identify the activities carried out on site. The map will include environmental considerations such as drainage (including both surface and foul drains), chemical and oil storage locations, location of waste skips, location of sample points for permits to discharge, wind direction, local neighbours, and potential areas of contaminated land and so on.

The site plan doesn’t necessarily have to be a highly technical drawing but does need to represent all the main features of the site and be drawn to scale. The route and final destination of the drains will also be identified on the plan. Consider what is involved with each activity that takes place on the site and the pollution which may arise from it. Consider the pollution risks under normal operations as well as under abnormal operations, that is, when something goes wrong. Accidents can cause significant pollution over a short period of time and need to be minimised.

Consider at a minimum:
-Process operation
-Plant and machinery
-Waste disposal
-Solid waste management
-Emissions/discharges for example, noise and odour
-Water use/discharges
-Raw materials used
-Storage of materials on site
-Transportation and distribution
-Energy sources and usage
-Product design Packaging

Consider how any potential pollution from the above activities could impact on the following:
-Air Water Land


Operations and maintenance

Written operating instructions will be provided to staff who are required to use any plant and equipment present onsite. The instructions will provide direction on how equipment is to be used to achieve the work objective and address any precautions which are to be taken as part of that work to ensure any risks to the environment posed by the use of the equipment are minimised or eliminated. These instructions will include details of what to do when things go wrong, that is, when the plant or equipment malfunction and how to stop a malfunction causing an adverse environmental impact.

As a minimum any maintenance advice provided by a manufacturer, supplier or installer will be followed. As many pollution incidents can be traced back to a maintenance failure it’s very important that the EMS includes a plan for proactive and preventative not reactive maintenance of the plant and equipment used on the permitted site.

Table 5 which can be found in Annex two is a simple maintenance checklist which, if used properly, could provide a plan for proactive maintenance.

A record that the maintenance checks were actually carried out when they were scheduled will also be kept.


Environmental Audits

The audits are used to determine:
a) Conformance to the management system
b) Conformance with EMS
c) Correct implementation and maintenance.

Results of internal audit provide information to the senior management team.

Audit programmes are based on:
a) Environmental / Health and Safety importance of an activity
b) Results of previous audits.

Audit procedures address audit scope, frequency and methodology together with defined responsibility for conducting and reporting audits.

THE FLOORING CENTRE conducts management reviews a minimum of annually. The agenda follows the Quality Management Review with the Addition of the following:

a) Review of Objectives and Targets and Improvement Plans
b) Review of Management Programmes and Objectives and Targets
c) Review of Significant New Legal Requirements
d) Results of any participation and consultation conducted Records are kept of the reviews



THE FLOORING CENTRE will put in place an accident management plan which can be put into action as and when required. It will be clearly communicated to all employees, managers and contractors who work at the site. An organisation’s accident management plan will form part of our EMS. To produce an accident management plan the following steps will be taken:

  • identify risks from the activities carried out that could damage the environment;
  • assess how likely they are to happen and the potential environmental consequences;
  • take action to minimise the potential causes and consequences of accidents;
  •  identify how to minimise the consequences will such accidents occur.

If an accident does happen and it may cause an adverse environmental impact, THE FLOORING CENTRE will be expected to:

  •  immediately do what it says in the accident management plan;
  • do whatever else is necessary to minimise the environmental consequences;
  • take all precautions to ensure the health and safety of both employees and external people is not compromised;
  • find out why the accident happened and take action to stop it happening again;
  • review the accident management plan.

The accident management plan will be reviewed at least every 4 years, if management or named responsible people change or as soon as possible after an accident. Any updates or changes needed must then be put into an updated accident management plan. If no changes are needed record the date of the review and the fact that no changes were needed. An accident management plan will include:

  • A site map, which will include all the information mentioned in section 2.2.1 as well as information on where accident response equipment such as spill kits and fire extinguishers are located.
  • A list of key contacts and contact numbers.
  • Information on preventing accidents which could occur on the site and what to do if an accident happens.


Incidents and non-conformances

All incidents and non-conformances will be recorded. This includes those reported by external people as well as those picked up in monitoring, reviews and audits of the site. Incidents that require investigation include any malfunction, breakdown or failure of plant or equipment or techniques and any near misses which affect or potentially affect the environment. Non-conformances include where the
management system is not followed as well as noncompliances with the conditions in the permit. If an incident or non-conformance occurs the EMS will be reviewed to find the root cause of the problem and steps will be taken to ensure that there is no re-occurrence. The findings of the review will be communicated to employees to ensure they understand any changes that need to be made to operations or procedures.

Table 8 will be useful in recording accidents and incidents which occur on site. Table 9 will be useful in recording nonconformances which occur on site. Both these tables can be found in the annexes.

Operatives will have site security measures in place, if necessary, to prevent unauthorised access to the site and any resultant pollution that unauthorised access may cause to the environment or human health.


THE FLOORING CENTRE maintains procedures for dealing with non-conformance; these will identify responsibilities and authority for:

  • Accident and incident Investigation
  • Initiating corrective/preventative action.
  • Identifying route cause
  • Continual improvement activities
  • Communicating the issues and effectiveness of actions taken



All complaints received by THE FLOORING CENTRE about their activities will be recorded and acted upon. Table 10, in the annexes, contains an example complaints record form. If the site receives a complaint this form will be completed. The forms can be used as evidence that any complaints received have been taken seriously and that actions have been taken to rectify any problems identified.


Staff training and competence

There will be enough competent staff to manage and operate the sites activities without causing pollution. Staff will be competent in the activities they are expected to carry out. Staff are expected to not only be competent in normal situations but also be adequately trained so that they are competent in abnormal situations such as plant failures or accidents. Staff roles and responsibilities will be clearly defined and names will be placed against each role and responsibility for example, who is the technically competent person for the site.

The training checklist and record forms tables 12 and 13 may help to ensure that the recording requirements for training received by staff are met. The training checklist can be used to identify the training required for each different role in the organisation. It will need to be modified for each specific site. The training requirements listed on the forms are examples only.

There is also a delegation of responsibilities form, table 14. This form is to be used when a member of staff is away from work, for example annual leave, on long term sick leave or on maternity leave. This is to ensure that the duties normally carried out by that person are delegated to another suitably trained person.


Odour, noise and emissions

The Environmental Regulations require the control of pollution including odour, noise and emissions. The potential impacts of these need to be controlled as they can have serious adverse impacts on the environment and human health. Odour, noise and emissions will be included as part of a sites EMS, as the plans will include information on how to minimise adverse impacts arising from any odour, noise or emissions produced as part of the activities carried out on the site.


Documentation of legislation and other requirements

Operatives on site will keep a record of any applicable environmental obligations, permits, exemptions, codes of practice, legislation and any other requirements they are signed up to. The legislation which is relevant to the activities will be kept, preferably on a register along with the names of those people in the organisation who are responsible for ensuring it is complied with. THE FLOORING CENTRE use the Environment Agency website to identify which legislation is applicable. Industry codes of practice, for example, quality protocols being used on the site and nonregulatory guidelines will also be adhered to. Table 15 contains an example register of legislation and other obligations. Remember in order for any EMS to be effective it will be implemented, and there will be evidence in the day to day activities taking place on the site that the EMS is being used.


The procedures ensure that:

  • Documentation can be located
  • Documentation is reviewed, revised and approved by authorised personnel
  • The latest issues of documents are available issued at all appropriate locations
  • Documentation is promptly withdrawn when obsolete
  • Obsolete documents retained for legal and/or knowledge preservation purposes are suitably identified.
  • Procedures are maintained for the creation and modification of documentation. All procedures and work instructions carry issue status and issue dates. All forms will carry issue status.


1 – Management

1.1 General management

1.1.1 THE FLOORING CENTRE will manage and operate the activities:

(a) in accordance with a written management system that identifies and minimises risks of pollution, including those arising from operations, maintenance, accidents, incidents, non-conformances, closure and those drawn to the attention of THE FLOORING CENTRE as a result of complaints; and

(b) using sufficient competent persons and resources.

1.2 Avoidance, recovery and disposal of wastes produced by the activities

1.2.1 THE FLOORING CENTRE will take appropriate measures to ensure that:

(a) the waste hierarchy referred to in Article 4 of the Waste Framework Directive is applied to the generation of waste by the activities; and
(b) any waste generated by the activities is treated in accordance with the waste hierarchy referred to in Article 4 of the Waste Framework Directive; and
(c) where disposal is necessary, this is undertaken in a manner which minimises its impact on the environment.

THE FLOORING CENTRE will review and record at least every four years whether changes to those measures will be made and take any further appropriate measures identified by a review.


3 – Emissions and monitoring

3.1 Emissions of substances not controlled by emission limits


(a) if notified that the activities are giving rise to pollution, submit to the Environment Agency for approval within the period specified, an emissions management plan;
(b) implement the approved emissions management plan, from the date of approval, unless otherwise agreed in writing by the Environment Agency.

3.2 Odour


(a) if notified that the activities are giving rise to pollution due to odour, submit to the Environment Agency for approval within the period specified, an odour management plan;
(b) implement the approved odour management plan, from the date of approval, unless otherwise agreed in writing by the Environment Agency.


3.3 Noise and vibration


(a) if notified that the activities are giving rise to pollution due to noise and vibration, submit to the Environment Agency for approval within the period specified, a noise and vibration management plan;
(b) implement the approved noise and vibration management plan, from the date of approval, unless otherwise agreed in writing by the Environment Agency.


4 – Information

4.1 Records

(d) be retained for at least 6 years from the date when the records were made.

4.1.2 THE FLOORING CENTRE will keep all records, plans and the management system required to be


Risk management and mitigation

Data and information
Receptor Source Harm Pathway
What is at risk?
What do I wish to protect?
What is the agent or process with potential to cause harm? What are the harmful consequences if things go wrong? How might the receptor come into contact with the source?


Probability of exposure Consequence Magnitude of Risk Justification of Magnitude
How likely is this contact? How severe will the consequences be if this occurs? What is the overall magnitude of the risk? On what did I base my judgement?


Action (by permitting)
Risk Management Residual Risk
How can I best manage the risk to reduce the magnitude? What is themagnitude of the risk after management? (This residual risk will be controlled by Compliance Assessment).


Environmental Policy Statement

THE FLOORING CENTRE, acknowledges the environmental implications of its activities and will ensure that all operations are carried out in order to achieve a high standard of environmental compliance.

James Harper, Managing Director recognises THE FLOORING CENTRE’s responsibility with regard to compliance with relevant environmental legislation standards and regulations and will work towards the most effective methods, and adopt a position of responsibility by committing to a policy of continuous improvement and pollution prevention.

This policy will be made available internally to our staff and externally to our suppliers, contractors and clients.

The environmental impact of any awarded contracts will be fully considered as an integral part of “new business” policy.

The principal contracting function of THE FLOORING CENTRE is the provision of Building related solutions and allied services for Public Sector and RSL clients

In doing so we will:

  • Provide guidance on recycling opportunities and promote the reuse of materials with a recycled content.
  • Ensure compliance with all relevant legislation, regulations and standards
  • Monitor progress on a regular basis with a view to improve environmental performance


Sustainability Communities Policy Statement

Approach to supporting corporate strategic priorities of up skilling local workforce, creating local employment opportunities, providing apprenticeships and other training opportunities.

THE FLOORING CENTRE is committed to promoting sustainable development and we believe we can contribute to aspirations by making a difference to the local community in which we deliver our services. The following are examples of how we will contribute to corporate and social responsibility.

We recognise the need to attract, recruit and retain motivated people using a fair and consistent approach to allow us to be an employer of choice.

THE FLOORING CENTRE’s recruitment process is based on our quality procedures so that a consistent approach is maintained across the company and ensures compliance with all legal requirements. It also ensures that all managers and supervisors who are involved in bringing people into the organisation are aware of the importance of getting it right and what they need to do to recruit people. THE FLOORING CENTRE has a robust procedure in respect of vetting and licensing of staff in accordance with BS7858 (Vetting and Screening) prior to working on any site in accordance with the requirements of the Private Security Industry Act 2001, and more recently Disclosure and Barring (DBS).

Our recruitment approach is as follows:

  • Job Centre Plus
  • Specialist Recruitment Agencies
  • Publications – local press & industry journals
  • Schools/colleges
  • Connexion Partnership service
  • Staff Referrals
  • Internal recruitment and promotion


THE FLOORING CENTRE – Employment and Skills Pledge THE FLOORING CENTRE will consider ways our service can create new employment opportunities and stimulate business opportunities locally by:

  • Fair recruitment practices offering opportunities for all, including employees working within the supply chain. Value creation by offering training initiatives, apprenticeships and skills development to individuals for all ages and businesses
  • Offering opportunities to contribute to the wider economic value of the area by developing a diverse business base and a diverse, skilled work force • Actively encourage local firms to compete for sub contract work (CEEQUAL)
  • Sourcing locally available materials
  • Develop diversity and equality initiatives to encourage small firms, ethnic minority businesses, social enterprise and voluntary and community sector suppliers
  • Training: jointly train our staff in equality, diversity and inclusion
  •  As a partnership we can demonstrate positive commitment by interviewing and recruiting disabled people by signing up to the Job Centre Plus Two Ticks symbol.


Local Benefits

THE FLOORING CENTRE commit to adopting the ‘proximity theory’ whereby, wherever reasonably practicable, we recruit new staff from within the community in which they are most likely to be employed. The company is committed to valuing and promoting diversity and opportunity in all areas of recruitment, employment, training and promotion. The Company will work towards an environment that is based on merit and inclusiveness, where all employees can develop their full potential, irrespective of their race, gender, marital status, age, disability, religion or sexual orientation.

The company is fully committed to the elimination of unlawful and unfair discrimination, and values the differences that a diverse workforce brings to the organisation. All employees are responsible for the promotion and advancement of this policy. Behaviour, actions or words that transgress the policy will not be tolerated and will be dealt with in line with the company’s disciplinary policy.


Workforce development

THE FLOORING CENTRE recognises that the induction process and on-going staff development is key to welcoming and retaining staff to the organisation.

One of our current business development initiatives is to achieve ‘Investors in People’ accreditation which will formalise our arrangements in respect of on-going training for all of our employees. Our staff training policy ensures that we have sufficient reserves of trained and competent staff within each job set in order to meet the needs of the contracts we are working on but also allows the personal development of all our people, enabling them to be efficient and effective workers, competent in their particular profession or skill.

Training needs will be identified through the annual appraisal system which identifies individual needs in order for staff to achieve their own personal targets and to ensure that our members of staff are proficient in the competencies identified. We will ensure that all training adds value to THE FLOORING CENTRE and that of our clients’ businesses.


Qualifications and Experience

We are fully committed to ensuring all employees have access to tools to develop a broad range of knowledge and skills, enabling them to take ownership and drive their personal development.

Learning can take place initially through a college course and then training is either provided through visits to manufacturers’ factories and/or the opportunity to go on site with the manufacturer.

Initial induction programmes are provided for all key roles, followed by training with customer relations, good practice, and management development where appropriate.

We encourage continuous staff training and development both on site and within our offices. In order for our staff to keep on track with advances in technology, training and development plays a key part in the success of our business.

We currently have several employees who are on apprenticeship programmes with us, and several who have completed their apprenticeships and are now fully qualified engineers. All of our engineers are trained to the highest standard of City and Guilds qualification at college, and are provided with continuous on and off site training, including demonstrations and training on new and upcoming equipment and systems.

We include provisions for training courses in our yearly budget, and actively seek any local funding that may well be available to assist us with any of our training and development needs.

All our engineers are trained to the highest standards in City & Guilds 1 & 2. Induction training for new employees, including those joining the company for a short period includes:

Staff development will include the following initiatives:

  • Site Level Training/Toolbox Talks
  • Industry accredited courses
  • Apprenticeship schemes
  • Personal Performance Appraisal
  • Operative Skills and Performance Review
  • Annual training programme
  • External training courses
  • Employee award schemes relating to corporate identity, performance and customer focus.


  • Ensure our recruitment policy is aligned to the requirements of the Security Industry Authority in respect of vetting and training
  • Ensure that we are compliant with our transparent recruitment policy including our equal opportunity and diversity policy.


Resource Continuity and Assurance

THE FLOORING CENTRE enjoys a committed workforce with little staff absence and a very low staff turnover. Many of our engineers have trained with us and are very much part of our family business.

This provides the platform for working relationships to be developed and we will ensure that the engineers have ownerships of their own portfolio of buildings. This will further increase the user experience of our electrical maintenance service.

Our contract managers are responsible for all human resource / personnel matters and will be supported by our Merseyside based HR Manager at our headquarters.
This team will have the people skills, experience and knowledge to look after the welfare, training, development and HR interests of our team. They will treat each employee as an individual, helping them achieve their aspirations as this in turn will ensure the future success of the company and the service level that we are able to provide you.

Our policy is to create an environment in which our people want to be a contributing member of a successful team. We will look after their health and welfare, we will train them properly, and we will ensure that they are not expected to work in unsatisfactory conditions. We make every effort to ensure a balance between home and work life and ensure compliance with the Working Time Directive with regard to working hours and rest periods.


How waste from sites will be reduced, reused and recycled

We recognise the impact that our operations can potentially have on the environment. We will work to ensure our operations are aligned so that we can make wider sustainable improvements whilst also producing community focused strategies.

We will comply and help to achieve business corporate sustainability targets and ensure compliance with the law with respect to waste management and recycling..

The environmental impact of our operations is monitored at company, contract and site levels across all of our work streams. With monitoring in place, we then initiate actions to reduce environmental impact, such as route planning and more energy efficient engines.

Through the EMS we are able to demonstrate our commitment to effective environmental management whilst also ensuring environmental legal compliance. In addition it allows us to:

  • Develop systems continuously to achieve client environmental aspirations
  • Ensure we are framework leaders in managing the environment
  • Demonstrate commitment to environmental best practice

It is our intentions at all times to build a supply chain within the locality within which we operate. We commit therefore to establishing fully developed supply chains within the geographical area in which we are operating. For example, our current nearest supplier is just 4 miles away from our control centre. If we were awarded work across the region, we would identify appropriate supply chain provisions within that area, which both supports the local area and reduces our carbon footprint. Any sub-contractors will operate to our stringent standards using developed programmes and quality plans.

THE FLOORING CENTRE recognises that all the products and services we procure have both environmental and social impacts and is committed to addressing these through our procurement procedures.

At all times THE FLOORING CENTRE will promote the philosophy of sustainable repair and reuse rather than dispose and replace.

The primary way in which we can influence these impacts is through engaging with our supply chain. Therefore, the overall aims of our sustainable procurement policy are to:

  • Provide a framework for bringing environmental and social criteria into procurement decisions,
  • Seek assurance from our suppliers and contractors that the environmental and social impacts of the products and services we procure have been minimized.

We endeavour to achieve this by:

Complying with all relevant current statutory regulations that impact on purchasing, and requiring that suppliers and contractors, and their supply chains, do the same. Also, giving a preference to procuring environmentally sustainable materials and services which:

  • Minimise climate change impacts
  • Minimise ecological damage, such as loss of habitats and biodiversity
  • Minimise the depletion of non-renewable resources
  • Re-use, recycle, refill, recharge and recondition
  • Ensure, where possible, all purchased goods have a recycled content
  • Have a low embodied energy/high Green Guide to specification rating
  • Reduce water use
  • Are accredited to a recognised environmental standard
  • Gives a preference to procuring materials and services which are ethically sourced. For those goods and services being sourced from developing countries, we expect suppliers to demonstrate that minimum supply chain labour standards have been met.
  • Uses local suppliers and contractors to minimise the environmental impact associated with transportation and to support the local economy, as appropriate.
  • Encourages all suppliers and contractors to have a health & safety policy and health and safety management system in place.
  • Encourages all suppliers and contractors to have an environmental policy and an environmental management system in place
  • For small companies, encourages the adoption of environmental policies which lead to improved environmental performance.
  • Continues to work with our suppliers to explore the challenges and opportunities associated with sustainable procurement.


Minimising carbon emissions and sustainable contract delivery

THE FLOORING CENTRE acknowledges the impact that our operations may potentially have on the environment. The clear objective of THE FLOORING CENTRE is to minimise any impact on the environment by maximising the sustainability of our service by:

  • Provide a framework for bringing environmental and social criteria into procurement decisions,
  • Seek assurance from our suppliers and contractors that the environmental and social impacts of the products and services we procure have been minimised.
  • Complying with all relevant current statutory regulations that impact on purchasing and requiring that suppliers and contractors (and their supply chains) do the same.
  • Giving a preference to procuring environmentally sustainable materials and services which:
    • Minimise climate change impacts and ecological damage, such as loss of habitats and biodiversity
    • Minimise the depletion of non-renewable resources
    • Re-use, recycle, refill, recharge and recondition
    • Ensure, where possible, all purchased goods have a recycled content o Intelligent route optimisation to reduce our carbon footprint and thereby increasing our efficiency and effectiveness. All our vans are fitted with tracking devices, reducing unnecessary mileage and we can monitor their driving habits to ensure they are driving in accordance with our fuel efficient driving policy
    • Our use of PDA’s integrated without IT led contract administration provides field base efficiencies and reduces our paper based systems.
    • Preventing pollution, reducing waste and ensuring that measures are implemented to protect and preserve natural habitats, flora and fauna;
    • Considering the effects that our operations may have on the local community o Promoting environmental awareness amongst our suppliers, contractors and partners by implementation of operational procedures;
    • Seeking to work in partnership with the community by behaving in a considerate and socially responsible manner;
    • Ensuring effective and expedient incident control, investigation and reporting

THE FLOORING CENTRE is a business committed to continuously improving economic and environmental standards, whilst providing cost effective, sustainable solutions to your requirements. We commit to working with you to help you achieve your carbon reduction targets.


Environmental Management System

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