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Supporting the production and maintenance of incident response plans

Most industrial sites have the potential to pollute. Pollution can cause significant harm to human health and the environment, the effects of which may persist for decades. The clean-up costs and legal implications can be costly.

As a result sites which are deemed to present the greatest potential risk of polluting have a statutory obligation to formulate site specific plans to prevent or mitigate damage caused by pollution incidents.

PPG 21 recommends that sites that are not required under Control of Major Accident Hazards Regulations (COMAH) or Pollution Prevention and Control (PPC) Regulations but that have the potential to pollute, should prepare a Pollution Incident Response Plan (PIRP) to prevent and mitigate damage to the environment caused by incidents such as spillages or fires.

The Environmental Damage (Prevention and Remediation) Regulations 2009 came into force on 1st March 2009 and further imposes obligations on operators of economic activities requiring them to prevent, limit or remediate environmental damage. These obligations are in addition to those under existing regulations.

To assist companies achieve the objectives and requirements of the Pollution Prevention Guidance, we offer a wide range of services, including:

• Site specific Pollution Incident Response Plan (PIRP) formulation or guidance
• Update of existing PIRP
• Full range of pollution prevention equipment
• Spill response equipment and kits
• Pollution prevention and spill response training

What does a Pollution Incident Response Plan involve?

Each site must be viewed on a project by project basis, however a full Pollution Incident Response Plan would typically include:

• Full site inspection and risk assessment – identification of site drainage, modelling of British Geological Survey drift and groundwater maps, review of borehole records, hydro geological and groundwater vulnerability maps.
• Formulation of pollution prevention measures encompassing: flood, firewater run off chemical and oil spill
• Formulation of procedures for responding to incidents: first to scene protocols, identification of ‘in house’ response capabilities and point of escalation to external responder triggers.
• Frequency and level of training requirements
• Formulation of service and maintenance programmes for critical pollution prevention equipment.

DEFRA are looking at new measures to bring diffuse pollution under control in line with the Water Framework Directive targets. A key part of these measures will be to place obligations on industrial sites to demonstrate that they have an effective and current Pollution Incident Response Plan in place.

The commitment to an effective Pollution Incident Response Plan demonstrates compliance, due diligence, significantly reduces the cost of an incident and can form an integral part of an ISO 14001 maintenance and applications plan.

For a consultation and further information on Pollution Prevention Guidelines call Darcy now on 01732 843131 or complete the form below.

Please note this service is currently available throughout the UK only.