ENVIRONMENTAL CODE OF PRACTICE
Incident Management
Overview
The most frequently reported type of water pollution incident
involves fuels and oils. By following the guidance in this section
your facility can minimise the risk of pollution.
The Environment Agency finds that common oil pollution incidents
often happen in one of the five ways listed below:
- Oil is spilt during delivery or when storage tanks are
filled
- Storage tanks leak because they are not maintained, correctly
bunded or because they are vandalised
- Storage tanks are poorly designed
- Oil separators are not used on rain water drains, or they are
not maintained
- Used oil is poured into drains.
If a spill should occur:
- Use booms and absorbent materials to contain it
- Contact the agencies Emergency Hotline (0800 80 70 60).
- Do not attempt to clean up with detergents or emulsifiers, as
these will increase the risk of harming the environment.
Dealing with an incident
The following sections give specific advice for various types of
incidences.
Oil spills
If a spill does occur:
- Take immediate action to contain the oil and where possible
prevent it entering any drains or watercourses
- Where oil has been spilt into controlled waters, use booms and
absorbent materials which float on water and only absorb oils, to
contain the spill. These need to be anchored to prevent them moving
away from the site of the spill and spreading the polluting
material. You should contact the Agencies by calling the Emergency
24hr Hotline on 0800 80 70 60
- Where a spill has occurred on land ensure that it is contained
and it is not allowed to entering a watercourse either directly or
through a surface water drain. It is also vital that it does not
enter the ground, or groundwater and you should contact the
Agencies by calling the Emergency 24hr Hotline on 0800 80 70 60 as
they can give advice to minimise the risk of pollution. Coloured
drain covers will help you identify surface water drains
- Do not attempt to hose the spillage down or clean up with
detergents or emulsifiers, as these will increase the risk of
harming the environment
- Contaminated absorbents should be disposed of in accordance
with legislation as they may be classified as Hazardous Waste,
depending on the constituents of the spill. These wastes need to be
disposed of to an approved facility. Information on the disposal of
used oil absorbents is available from PPG8 and the Environment
Agency
Hazardous material spills
However carefully you handle hazardous materials you should
still be prepared to deal with a potential pollution incident.
Pollution Prevention Guidelines have been published by the national
environment agencies and provide advice for a number of different
operations, including a template for a contingency plan that can be
adapted to your own requirements. Copies can be obtained from your
local environmental agency office or downloaded from the relevant
agency’s website.
Incident planning
The following steps can be taken to ensure that you are prepared
for an incident.
- Ensure you have emergency telephone numbers to hand and that
staff know who to contact should an incident occur, e.g. materials
supplier, environment agency, local authority Environmental Health
Department, etc. In marinas and boatyards, bertholders and tenants
should also be aware of the contact for reporting incidents on the
premises
- Have suitable spill kits and absorbents to deal with any
spill
- Consider giving a member(s) of staff responsibility to deal
with any pollution incident and ensure that they are fully trained
in the correct procedures to follow, should an incident arise
- Remember to contact your sewerage undertaker if any hazardous
materials are accidentally discharged into the foul water drainage
network
If in any doubt of what to do should a spill occur, contact your
local environment agency for advice. The combined agencies operate
a free phone pollution hotline number, which is manned 24 hours a
day, 7 days a week: 0800 80 70 60.
The agencies combined guidance given in PPG11 on preventing
pollution on industrial sites provides basic advice. It explains
why a plan is needed, what information should be included and
provides a suggested template for those preparing a plan. It is
intended principally for organisations, authorities and employees
with responsibility for medium to large sites, but much of the
information is relevant to smaller sites and especially those where
high risk activities are carried out. The guidance aims to help
managers and operators consider the appropriate level of detail for
a specific site, taking into account the risks and the site
layout.
Oil Spill Dispersants used in the leisure marine sector
An oil spill in the marine environment is possibly the easiest
type of pollution to identify. In most cases, even the
smallest spill will produce a distinctive odour and an oily rainbow
effect (iridescence) on the surface of the water.
An estimate of the quantity of oil observed at sea is important
as guidance in planning the required scale of clean-up response.
The table below gives some guidance. Most difficult to assess are
water-in-oil emulsions and viscous oils like heavy crude and fuel
oil, which can vary in thickness from millimetres to several
centimetres.
| Oil Type |
Appearance |
Thickness |
Volume (m3/km2) |
| Oil Sheen |
Silver |
>0.0001mm |
0.1 |
| Oil Sheen |
Iridescent |
>0.0003mm |
0.3 |
| Crude & Fuel Oil |
Brown/Black |
>0.1mm |
100 |
| Water-in-oil Emulsions |
Brown Orange |
>1mm |
1000 |
(
http://www.itopf.com/spill-response/clean-up-and-response/aerial-observation/)
So, when there is a small oil spill, it is quite understandable
that boat owners, boatyards and marina operators would want to
remove the oil as soon as possible.
There are many ways in which you can manage an oil spill, for
example booming off the area and applying oil absorbent equipment
which should be removed and disposed of as hazardous waste.
However, the perception that oil dispersants can be used as a
“quick fix” may cause more problems than the original spill in the
first place.
It is important therefore for the manufacturers, retailers and
users of such oil dispersants to understand the legal requirements
when marketing, selling and applying these products in the marine
environment.
The Marine Management Organisation (MMO) is the new enforcement
authority in England and Wales whose remit is protect the marine
environment whilst Marine Scotland approves oil spill treatment
products in Scottish waters and the Northern Ireland Environment
Agency in Northern Irish waters.
The MMO was created following the enactment of the Marine &
Coastal Access Bill in November 2009, and replaces the Marine &
Fisheries Agency.
Although exempt under the Food & Environment Protection Act
(FEPA), the application of oil spill dispersants in the marine
environment is a strictly controlled activity.
Before ANY oil spill dispersant is applied in the marine
environment, the individual “depositing” it must ensure that they
seek approval from the MMO when doing so. This also applies
when oil spill dispersants enter the water from the deck of a boat,
pontoon or slipway.
An unlicensed deposit into the sea could carry a fine up £50,000
and/or up to a 2 years prison sentence.
A tier 2 offence – which includes not notifying the licensing
authority (i.e. MMO) of the use of an oil spill treatment product –
could carry a fine up to £500.
The dispersant used must also be registered on the MMO website as
an approved product which has met stringent efficacy and
toxicological tests.
These tests, if carried out by laboratories on behalf of the MMO
can cost in-excess of £10,000. If you have existing toxicity
and efficacy tests on the product which match the required testing
protocols, the MMO will charge around £2,000 to validate the
information. If a product passes the required tests it will
be added to the list. Each product will require re-assessment
after 5 years.
Many of the oil spill dispersants on the MMO approved list are
for the treatment of large scale spills from oil tankers or large
commercial ships which pose an immediate threat to marine wildlife,
infrastructure or human safety.
Advice from the MMO suggests that if there is a small scale
spill (e.g. less than 1 litre), it is often better to notify the
relevant authorities (Environment Agency and Harbour Authority) and
allow them to assess and manage the treatment.
Typically, small scale spillages of diesel will naturally
evaporate over 5 – 10 hours, leaving little impact.
Manufacturers and distributors of oil spill dispersants in the
UK have a duty of care to correctly label such products for their
suitability and the advice they give users.
BMF members who currently market oil spill dispersants as a
product which can be used by recreational boaters in the marine
environment may wish to review their advice, ensuring that messages
are appropriate and are legally compliant as negligent
misstatements could lead to prosecution from Trading Standards.
The product label must be agreed by the MMO before the product
can be approved. The label must contain the following
information:
1. Product name.
2. Name, address and daytime/silent hours telephone number of
manufacturer or importer/rebrander.
3. List of ingredients.
4. Oil treatment product (dispersant type, sorbent, bioremediant or
other).
5. A warning against mixing the product with any other
products.
6. Date of manufacture, batch number and expiry date (subject to
extension).
7. Recommended storage instructions.
8. Risk symbol and description.
9. Usage instructions including a statement that details that the
product should not be used in less than 20 metres of water or
within 1 mile of water less than 20 metres deep without the
approval of the licensing authority.
10. Basic safety instructions or caution and any appropriate
chemical hazard signs.
For more information and to download the MMO’s guide to the
approval and use of oil spill treatment products in the UK, visit
http://www.marinemanagement.org.uk/protecting/pollution/approval.htm
For information on trade descriptions and trading standards,
visit www.businesslink.gov.uk/unfairtrading