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SPILL PREVENTION, CONTAINMENT & RECOVERY TRAINING

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ENVIRONMENTAL MANAGEMENT SYSTEMS (EMS)

Legislation

So much of today’s legislation is based on European Directives. However, within the UK we can trace the first pieces of environmental legislation back to Acts of Parliament such as:

• The Health & Safety at Work Act 1974, now The HSW etc Act 1974.

• The Factories Act 1961.

As our environmental awareness increased, we realised that our response to spillages of liquids and powders could no longer be based on just the flammability or corrosiveness of such substances. We also have to take into consideration the environmental impact our actions may have.

This has lead to the introduction (since becoming full European Parliament members), of various new laws since the early 90’s.

These laws are reproduced in easy to follow guidelines and issued by the Environment Agency (EA/SEPA) as Pollution Prevention Guidelines (PPG) or through the Health and Safety Executive (HSE) as Health & Safety Guidelines (HSG).

SPILL PREVENTION, CONTAINMENT AND RECOVERY TRAINING

This handout is designed as a reference document and confirms in summary format, the training provided. The date of the training and those having attended can be obtained from the person within the company whose responsibility it is to document such data.

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ENVIRONMENTAL MANAGEMENT SYSTEMS (EMS)

Examples of Legislation & Guidelines are:

• The Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR)

• The Control of Pollution (Oil Storage) (England) Regulations 2001.

• The Water Environment (Oil Storage) (Scotland) Regulations 2006.

• PPG2 – Above Ground Oil Storage Tanks• PPG26 – Storage and Handling of Drums and Intermediate Bulk

Containers (IBCs)• PPG21 – Pollution Incident Response Planning• PPG18 – Managing Fire Water and Major Spillages• HSG51 – The Storage of Flammable Liquids in Containers• HSG71 – Chemical Warehousing• HSG176 – The Storage of Flammable Liquids in Tanks• Waste Oil Storage – Hazardous Waste Regulations 2005• CIRIA / EA Joint Guidelines - Bunds• Environmental Protection (Prescribed Processes & Substances)• Scotland Regulation 1991

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NOTES

Enforcing/Policing Legislation:

• 1990’s – The Government Policy – The Polluter Pays was introduced. Fines were increased to match the severity of spill pollution incidents.

• EA/SEPA work more closely with Local Water Authorities, the Health & Safety Executive and Councils. Their powers of policing are giving more teeth.

• It became illegal to pollute the environment accidentally as well as on purpose.• For worse case incidents courts can imprison offenders.• The legal costs, fines and clean up cost can run into hundreds of thousands of pounds. (Crown Court / Sheriffs Office –

No upper limit to fines)

Company Response:

A means to compliance is to install an Environmental Management System / H&S Policy. The EMS provides the framework to support an Environmental Policy and comply with Health & Safety Guidelines for spillage.

Examples of its contents are:• An Environment Statement, in support of the Environmental Policy• Spill Aspect and Impact assessment• Laid down procedures for all departments (Reporting and Actions plans)• A site drainage diagram*• A site map indicating areas and if applicable, risk areas• A Legal Register• A Hazardous Fluids inventory• A waste stream fluids inventory• A key personnel call out list (who to summon and when)• A training register• It must indicate the location of Spill Response Equipment.* The site drainage diagram should form part of an Incident Pack and be available for the emergency services to respond to incidents. It will be requested by the EA/SEPA, HSE or Local Authorities when conducting an environmental audit or responding to an incident.

The procedures within the EMS policy document must be known to all employees who have a responsibility to safely handle, transport or store fluids considered to be hazardous. This includes: Health & Safety, Environment Maintenance and Security personnel.

Key area of information to employees should cover:Training Recognition of risk areas. (Aspects & Impacts)Procedures Recognition of individual area procedures.Identification Recognition of spill response equipment.Rehearsal Recognition of the need to rehearse emergency proceduresColour coding of drains:

Blue – Surface WaterRed – Foul, Effluent, Sewerage

Spill Response:

GOOD HOUSE KEEPING AND DUTY OF CARE – BEST AVAILABLE TECHNIQUES

Daily Use and Emergency

Primary Containment:Containers and storage vessels must be robust, correctly marked and fit for purpose.

Secondary Containment:Bunds, Entrapment Gullies, Double-Skinned Storage Tanks and Interceptors. Spill Pallets, Drain Covers, IBC Pallets, Drum Racking and Storage Container Sump/Drip Trays, Over Packs and Drum Transporters.

SPILL RESPONSE ABSORBENTS:Loose: Powder, Sawdust and GranulesSynthetic: Normally composing – Polypropylene or Cellulose Wadding.

They come in three usage formats:Maintenance: Designed to cope with emulsified hydrocarbon spills, up to and including solventsChemical: Designed to cope with aggressive and chemical spills, up to and including most acids.Oil: Designed to deal with oil spills. Being hydrophobic they repel water and are therefore specfic in use.

Uses:

Pads: As individual items to protect works surfaces / recover minor spills. Collectively, to recover larger spills when packed within spill response kits.

Rolls: Similar to the pads but on a roll. They either come with dispensers or dispensers are provided separately. Normally used when larger lengths of absorbents are required.

Socks/Booms: Designed to isolate or contain a spillage. If more than one is used, it must be overlapped to ensure a secure barrier is formed. Socks can also be used on a daily basis to provide a containment barrier to machine bases were fluids habitually migrate or spill.

Pillows: Where rapid absorption of a leak is require, a pillow can be used. Also used as recovery mediums for hard reach areas, sumps, drains and culverts. Some have oil specific enzymes which can degrade hydrocarbons reducing the oil to harmless Carbon Dioxide/ Water allowing the pillows to be disposed of as dry waste.

Multi Format Rolls: A versatile absorbent which can be folded/unfolded and used as a pad, roll, sock or pillow.

PPE:

Goggles, Gloves, Overalls can come supplied with a spill kit or supplied separately. Operators of hazardous fluids must wear the correct PPE as laid down in the site policy. This is both for daily duties and for response to a spill.

Response to a Spillage:

• Only attempt to contain or recover a spill if safe to do so.• Do you have the correct PPE?• Can you identify the spill?• If you cannot identify what has been spilt, think ‘safety’, try to contain the spill or block its direction of flow to

a drain etc. Most important, without PPE you must not come into physical contact with the spill. Warn others, if necessary cordon off the area.

• The flow rate of the spill will determine if you will contain the spill or Block off any drain, culvert or manlid. If the spill is heading towards a drain etc. before you can contain it, then if safe to do so Block the drain. If the flow rate is slow and there is no danger to yourself, the environment or others, then contain the spill.

• If you need to send someone for assistance make sure you tell them to return to you.• There may be times when a spill is so unmanageable that there is no alternative but to guide it to a drain.

Correct procedures will identify this and indicate where in the drainage system the flow should be blocked to minimise the environmental impact.

• Procedures will also indicate routes that can be chosen if an area is covered by an interceptor.

Disposal of Contaminated Absorbent Wastes ( Waste Stream Management)

Waste disposal bags or secure containers are to be made available. Contaminated absorbents (loose and/or synthetic) must be placed in the bags/containers and held in a secure area (this is an area especially designed for the storage of such waste), and disposed of by an approved waste management contractor.

Any skips or similar contaminated waste systems if exposed to the elements must be provided witha secure cover. Not withstanding these, such systems must be secure from leaking. Legal compliance requires no taps, drains, holes or access panels.

Spill Kits:

• These are manufactured in the three formats: Maintenance, Chemical and Oil.• Sited at a potential spill area or for ready access.• These should be treated with the same respect as fire extinguishers. They are for emergency use only.• A universal kit can be used on a hydrocarbon (oil) spill but only a universal spill kit should be used on an

aggressive chemical/acid spill.• Spill kits are made up of a combination of pads, socks, pillows or as risk dictates i.e. all socks, all booms or a

combination. Before ordering a spill kit a Risk Assessment must be carried out to determine size of kit and correct type.

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