Spill control training is often far down the list of health
and safety priorities at work but businesses that don't
meet their obligations can face serious consequences,
says Simon Evans
Spill control as a part of heaSpill control training is often far down the list of health
and safety priorities at work but businesses that don't
meet their obligations can face serious consequences,
says Simon Evans
Spill control as a part of health and
safety scheduling is seen as a
`dry` subject. Yet failure to plan
or comply with Pollution Prevention
Guidelines (PPG) means business
suffers. Dearly. In 2010, a UK water
company was fined £15k for polluting a
local river, however the true costs were
far greater. When added to the fine and
prosecution costs the actual incident cost
was £211,164! More recently, a global
petrochemical supplier was fined £2.8
million by the Scottish Environment
Protection Agency, not because of a spill,
but because they didn't fill in the
compliance paperwork correctly.
Health and safety professionals should and
must plan for spill. Basic steps are within
the capabilities of all staff, with specific
skills training for those tasked with
oversight of health and safety matters or
incident response. This applies to
businesses large and small as failure to meet
obligations to the environment can have
implications: Just ask the 40% of businesses
who suffered serious spill incidents in the
last two years and aren't around anymore
as a result. Or last month's court cases in
the environmental press, cumulatively
listing £1.8 million in fines - and more
than three years of custodial sentences.
Spill control is not only the law, it also
makes good business sense. Bruce
McGlashan, technical advisor - operational
partnerships and pollution incidents at the
Environment Agency, says: "A rapid,
proactive and appropriate response to spills
can prevent environmental damage and
reduce business costs. We recommend
you and your staff familiarise yourself
with the techniques available to do this.
"Attendance at appropriate spill control
courses is one way you can do this.
Further information can be also found in
our Pollution Prevention Guidelines
(PPGs) in particular PPG21 and PPG 22:
www.environment-agency.gov.uk/ppg "
Room for improvement
It often seems that businesses don't know
that they don't know about spill control.
In early 2012 we (spill control
manufacturer Lubetech) carried out
extensive research into PPG compliance
which uncovered uncomfortable truths
surrounding spill control training.
Current environmental and health and
safety training touch upon spill control,
but neither actively provide it. For
example: a customer purchased a spill kit
from our distributor, approaching us for
instructions on use. Subsequently
achieving a Professional Environmental
qualification, he says he STILL has little
idea how to work his kit in an incident.
Our figures suggest fewer than one
quarter of UK businesses are even aware
of the requirement for spill control, much
less trained or equipped to deal with it.
There are 2.5 million white vans on UK
roads. Carrying more than 25 litres of
fluids in the course of their business, they
are required to carry an appropriate spill
kit. Awareness? Between 9 and 13%.
Day-to-day spill management has
many resonances with health and safety
matters, so pollution planning under PPG
compliance complements both. As we
have discovered, 'Getting the Site Right' is
not merely about compliance, it's also
sound business sense. The difference
between survival and failure.
Basic provisions require all sites to
have knowledge of storing and handling
of oils, chemicals and other risky
materials; waste management; site
drainage, as well as contingency plans for
incident management. If any doubts exist
site-based or venue-based training can fill
those gaps in knowledge and close a gap
in health and safety requirements. During
such training the following questions
should be raised:
Are storage containers fit for purpose,
regularly inspected and maintained?
Are storage areas and containers sited
away from watercourses or drains?
Do you have a plan, equipment and
training to deal with pollution
emergencies?
Are company vehicles properly
equipped to deal with off-site incidents
and fulfil ADR requirements with the
carriage of appropriate spill kits?"
Today many companies operate under
or are seeking ISO 14001 accreditation.
ISO 14001 requires that the organisation
be aware of, and comply with, all relevant
regulations governing their wastes.
Emergency response procedures must be
documented, practiced, reviewed and
revised periodically. Section 4.4.7
(Emergency preparedness and response)
of ISO14001 states: "The organisation
shall establish and maintain procedures
to identify potential for and respond to
accidents and emergency situations, and
for preventing and mitigating the
environmental impacts that may be
associated with them."
A business unaware of its obligations
in spill control, unfamiliar with the
identification of the problem and
unprepared for the consequences of
contamination, is a heady potential for
risk and injury, not just damaging to the
environment. Ensuring that any
references to 'spill' in health and safety
training overtly states the need for further
and separate training should be
undertaken to qualify and inform what
'spill control' means and the obligations
for business at every level.
Simon Evans is marketing director at
Lubetech
