A report into spills prevention and containment, on behalf of the Environment Agency and the British Safety Industry Federation, shows there is a better way…
Published in the CIWM Journal April 2013
Late last year the British Safety Industry Federation (BSIF) and Environment Agency (EA) commissioned a report into the ugly truth about spills. The findings, based on listening to small, medium and large waste management operators’ experiences of spills show that money and the environment can be saved and businesses can adopt best practices by applying simple steps in spill prevention and containment.
The Ugly Truth
Spills are more common than you might think. Companies involved in waste activities caused 101 serious pollution incidents in 2011; 42 percent of all incidents were from sites regulated by the Environment Agency.
Even though there was a slight decrease in the number of incidents, the waste management sector is growing rapidly with over 190 000 people expected to work in it by 2020. The bigger the industry gets, the greater the potential for risks and increased accidents.
“Most (smaller companies) will only understand the full impact when it actually happens and by then it’s too late for them”
The EA estimates that a pollution incident costs an average of £30 000 for businesses in fines, clean-up charges and production losses. This is money that is lost to the business and in times of austerity can mean the difference between surviving or not.
In order to get an insider view on the problem, the BSIF and EA commissioned a research project in 2012, which involved 23 waste management industry figures openly discussing their experiences of spills. The findings are published in the Best Practice in Spill Prevention in the Waste Management Industry report, which can be downloaded for free on www.bsif.co.uk and www.environment-agency.gov.uk
Some of the telling quotes gathered from the research paint a clear picture of the dilemma faced by the industry:
“Spills for us are a daily occurrence across our sites.”
“Sooner or later you’ll trip up.”
“Most (smaller companies) will only understand the full impact when it actually happens and by then it’s too late for them. They haven’t got the learning process, due to their size, to see the risk.”
“Our only practical training is when a spill actually happens.”
The most common spills mentioned included spills as a result of moving oil and diesel, leachate, chemical spills and fire water run-off. Another relatively common cause of spills is the breaking of hydraulic hoses on lorries. This often happens away from site and can lead to a spill of up to 100 litres of hydraulic fluid. Several participants pointed out that they have limited control where spills can occur, for example when waste is delivered in unsafe and unsuitable containers and when there is vandalism on site. However, the company remains liable for these incidents and appropriate measures should be taken to prevent them.
Current Practices
When questioned about current practices, participants referred to a number of measures that can broadly be categorised under management procedures and control measures.
Participants spoke about carrying out risk assessments (a requirement of the legislation), implementing Environment Management Plans and staff training.
Many of the participants have an environmental management system that is certified to ISO14001 or is based on this standard. Operators are not required to be ISO14001 certified but the BSIF and EA do encourage operators to use recognised standards to manage their sites well.
One operator remarked: “If something unexpected does happen and you’ve got a plan to deal with it, it does make life so much easier.”
Regular inspections were also considered crucial in managing spill risks. These inspections could range from frequent visual checks to less frequent comprehensive inspections.
It was noted that: “If you’re doing it right, then everything is planned and structured for you, each week, each month, each year.”
The control measures referred to by participants included spill kits, double skinned tanks and sealed drainage systems (ie, a system that is not connected to surface or foul sewer such as a sealed sump).
A properly designed site and equipment also helped prevent spills and ideally this should be factored in when building a new facility. But participants acknowledged that spills could be prevented on existing sites by making relatively simple changes for example keeping traffic routes away from storage tanks, having storage above ground (on the basis that if you can see it, it’s easier to manage) and keeping the waste reception area separate from the rest of the site, with its own bunding and drainage arrangements.
Why Apply Best Practice?
Spills are costly and can lead to prosecutions, substantial fines and even the possibility of a prison sentence. Spills can also result in more frequent inspections from the EA. But the key consequence is likely to be the loss of reputation, leading to a loss of work and becoming ineligible to bid for certain contracts, particularly with public sector organisations. This could then lead to loss of profit and in extreme circumstances, business closure.
In the words of one participant: “We couldn’t afford not to operate to best practice,” while another participant remarked: “I’d point out that they’ve got more chance of winning more business.”
Participants agreed that fostering a positive culture through good leadership and active employee engagement were critical. One operator remarked: “It’s very easy for the guy at the top to kill it.”
But participants felt that good leadership, listening to employees and their suggestions for improvements were essential to going beyond mere compliance and helped achieve best practice.
“The EA recognises that “a carrot and stick” approach is useful and is fully committed to working in partnership with all operators to help them meet their legal obligations and environment responsibilities”
Training was also seen by participants as a key element of any spill prevention programme. Regular reviews and re-training ensure staff competence and practical demonstrations on spill response ensured the best possible actions are implemented immediately should a spill occur.
In order to encourage best practice, participants felt that a combination of incentives and penalties should be employed. It was acknowledged that while some operators would never comply with guidelines and would need to be penalised, those excelling in their handling of waste could be rewarded, eg with fewer EA inspections, which is what happens.
The EA recognises that “a carrot and stick” approach is useful and is fully committed to working in partnership with all operators to help them meet their legal obligations and environment responsibilities.
The EA has produced a number of guides to help the industry including Is your site right?, Pollution Prevention Pays and a range of Pollution Prevention Guidelines (PPGs). An educational DVD is planned that will include new posters to be displayed in sites. All information resources are free and are available on www.environment-agency.gov.uk/ppg.
The waste management industry works hard to manage all that is thrown at it. In the words of one operator: “We’re at the mercy of what the customer sends us.”
But waste operators have legal obligations and preventing and containing spills is a priority. Therefore, ensuring best practice is critical. It is in everyone’s interest to prevent spills and where necessary contain them safely. With this in mind the BSIF and EA have produced A Spill Prevention & Control Checklist for the Waste Management Industry, which is included in the report. The guide is designed as a checklist to help deal with spills. It looks at assessing the risk and provides simple questions as an aid to ensure your site and employees are well equipped to prevent spills in the first instance and handle them properly when they happen.
In making the report, the BSIF and EA welcome and appreciate the honest input of those who gave of their time freely and made some very insightful comments on the issues of spills.
The Last Word
Finally, in the words of one participant: “You’ve got to learn from your mistakes. No one’s perfect all the time.”
It was acknowledged by all participants that no one operator is perfect but lessons can be learned from each other and the report and checklist are attempts at sharing experiences and encouraging best practice across the waste management industry as a whole.
The Best Practice in Spill Prevention in the Waste Management Industry report is available free to download
www.bsif.co.uk
www.environment-agency.gov.uk
