This blog focuses on the importance of site awareness and what you should consider when pollution planning.
Organisations have a general responsibility to ensure their activities do not cause environmental pollution. When managing a site, there are a lot of things to consider when pollution planning and this blog will focus on the importance of site awareness and what you should consider when pollution planning.
Understanding where your site is located and the risks associated with that is very important when pollution planning. This will include knowing whether you are in a groundwater protection area, if you are on a site at risk of flooding, whether there are any environmentally sensitive sites, such as SSSIs (Sites of Special Scientific Interest) nearby or if you have any neighbours that could be affected by your activities or could affect you. Understanding these risks will allow you to prioritise site specific controls. For example, if you are close to a SSSI, you may not be able to discharge water to surface waters as part of your activities. Or, if you are situated in an area of potential flooding, you may need to consider emergency actions for flooding events and ensure critical equipment is protected from water damage. Understanding your site location will also help responses if a pollution incident does occur and inform actions that need to be taken to clean-up or mitigate environmental damage.
Our previous blog (which you can read in this link) has discussed the importance of having an accurate drainage plan. In terms of pollution planning, a drainage plan will ensure you understand your pollution pathway and can prevent pollution from causing environmental damage in the event of an incident. A drainage plan will also inform you where high risk items such as waste and oil and chemical storage areas should be located and refuelling operations carried out. It can also be used to determine where it may be appropriate to discharge water such as floor wash effluent to the foul drainage system and where vehicles can be washed down.
You should also be aware of any vulnerable areas within your site boundary. This may include balancing ponds or areas set aside for flora and fauna. These areas should be managed and appropriate controls put in place as necessary. For example, if you have Great Crested Newts on your site, you may be required to install fencing around the area and carry out monitoring to maintain its condition. Any high-risk activities should also be situated away from these areas.
There are a lot of aspects that go into pollution planning and site awareness is just one of the things that needs to be considered. It is very important that you have an accurate, verified idea of what is on your site and the state of the surrounding area. This will allow you to plan your activities and emergency responses in a way to prevent or minimise the risk of pollution.
Last weeks blog (that you can read here), discussed the importance of site awareness when pollution planning. This blog will consider a further 5 things, that you should consider when pollution planning to ensure your site activities do not cause environmental damage.
With pollution, prevention is better than the cure. Actions to prevent pollution can include assessing the storage of high-risk items such as any liquids like oils, fuels and chemicals and waste. Everything should be stored safely and securely, considering measures to prevent leaks and spills such as bunding liquids and covering waste to prevent it from blowing around the site. They should also be located in appropriate areas such as away from drains and other vulnerable areas.
2. Pollution Control Equipment
Although we all hope that effective pollution planning will prevent incidents from happening, it is still important to consider the equipment required if an incident does occur to ensure that pollution is prevented or minimised. This will include spill kit provision, which should be matched to spill risk area and be of the correct type. In addition to standard spill kits, additional equipment such as drainage covers or soda ash (to neutralise acid spills) may be needed.
Putting robust controls in place to control pollution will help with managing your environmental risks but will only remain effective if maintained. You should be carrying out regular checks to make sure everything is in a good condition and there are no issues that need to be resolved. This will include visual checks of oil and chemical storage areas and bunds, checking spill kits for content and condition, assessing waste storage and segregation and making sure the site is clean and tidy. Any issues identified must be addressed and investigated to prevent them from happening again. It is also important to ensure that maintenance schedules e.g. for interceptors and tank testing are kept up to date to help prevent problems from developing.
4. Awareness and Training
All staff must be aware of the correct policies and procedures in place to prevent pollution and follow them and report any issues as soon as possible so any non-conformities can be rectified. There should also be a trained spill team who are known and aware of the site-specific circumstances and what to do in the event of a spill, including how to correctly use a spill kit.
5. Create a Pollution Incident Response Plan (PIRP)
Sites should have an easy to understand and accessible Pollution Incident Response Plan. It should include information about site awareness, all the considerations above and the actions to take in the event of an incident. This would include who the responsible people are and who should be contacted and when, including the regulatory bodies.
There are many aspects that must be considered when pollution planning and you will need to think of it from your site perspective. We have discussed a few things here that you should consider but it is very important to assess your site specifically, document your pollution planning controls and inform your staff. Comment below on the aspects you have considered when pollution planning.