Deviation 1
Internal control is lacking
Deviation from:
Regulation on hygiene, environment and systematic occupational safety in enterprises (the internal control regulation), Article 5, second paragraph, points 4, 6 and 7.
Comment:
In accordance with the internal control regulation, the company must introduce and exercise internal control appropriate to the nature, activities, risk conditions and size of the company and to the extent necessary to meet the requirements on health, environment and safety legislation. This means, among other things, that the Municipality must detect dangers and problems associated with the activity and, on this basis, evaluate the risks, as well as prepare the related plans and measures to reduce the risk conditions (point 6). This must also be prepared for the external environment, taking into account that the company must be able to fulfill its responsibilities under the Protection Against Pollution and Waste Act (the Pollution Act).
In accordance with internal control standards, the company must also implement procedures to detect, rectify and prevent violations of obligations under or under the Pollution Act (point 7). During the inspection, the following elements emerged:
a) Both the municipality of Gausdal and the sports team lack competence and knowledge of the requirements set out in the regulations and the measures that need to be implemented on the pitch to meet these requirements. Of course, interventions aimed at drainage and rainwater and the clearing and storage of snow were carried out, but it seemed that the municipality had not taken further care of the other regulated areas.
b) The municipality does not have an internal control system that complies with the Internal Control Regulations.
c) A written risk assessment for the external environment has not been prepared (§ 5, item 6). This risk assessment should at least include the risk of contamination of the external environment during the use, storage, re-use and delivery of the backfill material – banked and drainage water – snow removal, the list is not exhaustive .
d) Due to the lack of an internal control system, the municipality of Gausdal also does not have a functioning non-conformity management system where non-conformities can be recorded in the external environment.
e) Our impression is that, to some extent, the company has routines in place for the management of artificial turf pitches, but that they are not necessarily documented in writing. For example, there are no procedures for performing environmental risk assessment or non-compliance management in relation to the external environment.
Deviation 2
No measures have been introduced to minimize the spread of bulk fill via construction machinery and track users.
Deviation from:
Pollution Limitation Regulation § 23A-4 point c.
Comment:
According to section 23A-4 point c of the Pollution Regulations, outdoor sports fields where loose infill containing plastics is used must have “measures to prevent loose infill containing plastics from being spread off the field via users of the camp or by construction machinery and other equipment used for the maintenance and snow clearance of the camp”. There were no such measures during the inspection at the Linflåa sports park’s artificial regression track.
Deviation 3
Lack of information for track users
Deviation from:
Pollution Limitation Regulation § 23A-5.
Comment:
Pursuant to Section 23A-5 of the Pollution Regulations, the person responsible for sports fields where bulk infill containing plastics is used must ensure that users of the sports ground are made aware of the spread of loose infill containing plastics and measures to reduce the risk of such spread. We consider deviations 2 and 3 to be serious deviations.
