The Protection of Water from Pollution by Risk Assessment.

1) Purpose

All industrial sites pose a potential threat to our natural water environment. Pollution prevention from water comes down to basic common sense, general good house keeping and staff training. This risk assessment is intended to provide you with a simple but effective method of pollution prevention.

2) The Cost Of Getting It Wrong

The level of today's fines reflect the change in public attitudes towards pollution and polluters. Magistrates Courts can now impose fines of up to £20,000 for pollution offences, and in a Crown Court there is no limit to the fine. The polluter also has to meet the full costs incurred by the The Environmental Agency in bringing the case to court.

Even when a case is not taken to court, the cost of repairing the damage still has to be met and these costs are increasing. For example, restocking of fish can cost many thousands of pounds, and many insurance companies general policies no longer cover pollution clean up costs.

3) Legislation

3.1 Environmental Protection Act 1990

3.2 Environmental Protection, Water Resources Act 1991

NOTE: Particular attention should be paid to Section 93, which allows for the designation of "Water Protection Zones".

3.3 Environmental Protection Act (Part 2) 1992.

4) Introduction to Risk Assessment

Spillage's occur throughout the country every day, sometimes devastating wildlife habitats, killing fish and destroying the invertebrate life on which fish and many other animals feed. As a company we can not allow this type of incident to develop. The following risk assessment has been designed to provide factories with an effective management plan of pollution prevention.

5) Site Drainage

Company Title:

Address:

How long has the company occupied the site?		Years

Do you have accurate site drainage drawings?		YES / NO

When were the drawings last reviewed?		Years

Each factory will have two types of drains

a) Foul Water Drains

Designed to carry contaminated water away from the factory for treatment with the prior consent of the relevant water company. These should be painted red.		YES / NO

b) Surface Water Drains

Designed to carry only clean or rain water away to a local water course or river. This can be many miles away from the factory. These should be painted blue.		YES / NO

Have you ensured that there are no wrong connections either above or below ground level?		YES / NO

Sinks in manufacturing areas may be used as a convenient route for disposal. Have you checked that they are not incorrectly connected to a surface water system?		YES / NO

Direct Consent Discharge to a River

Do you have written permission to discharge to the river?		YES / NO / N/A


Do you regularly check that effluent discharges are within the discharge consent?		YES / NO / N/A

Do you have effluent treatment facilities?		YES / NO

Have you introduced a planned maintenance programme for effluent treatment facilities?		YES / NO / N/A

Have all personnel been formally trained to maintain your effluent treatment facilities?		YES / NO

Do you regularly check discharges from the effluent treatment plant?		YES / NO

Have you introduced a 24 hour system of early warning if the effluent treatment plant fails.		YES / NO


Deliveries of Hazardous Substances

Hazardous materials particularly those used for cleaning operations are potentially lethal. Basic safety care can avoid needless spillage's during delivery and save valuable raw materials.


Before Delivery
Check Capacity


Do you double check storage tank levels?		YES / NO
Are deliveries always supervised by a competent company employee?		YES / NO

Have you clearly labeled all containers with
a) The nature of the substance (e.g. corrosive toxic etc.)?		YES / NO
b) Maximum volume of contents to prevent over filling?		YES / NO
Have all storage tanks got well designed and constructed bund walls.		YES / NO

Have you introduced documented contingency plans to deal with accidents?		YES / NO

Are all staff aware of these contingency plans?		YES / NO

Do you clearly label loading/unloading areas?		YES / NO

Are all surface water drains in these areas isolated?		YES / NO

Have you provided catch pits for delivery points?		YES / NO

Have you fitted automatic cut off valves to all filling points to prevent over filling?		YES / NO

Where possible are all factory pipelines above ground level?		YES / NO

If you have pipe lines below ground level, have you provided protective sleeves or a duct?		YES / NO / N/A

Do you regularly inspect pipelines installed below ground level?		YES / NO / N/A


Bulk Storage Oils, Greases, Fats and Cleaning Chemicals


Do you have copies of the manufacturers handling notes?		YES / NO

Are bund walls and floors impermeable to the substances stored?		YES / NO

Have you ensured there are no breaches to the bund wall and floors particularly by drains?		YES / NO

Are overflow discharge pipes within the bunded area?		YES / NO

On storage tanks that are likely to corrode, do you complete documented thickness checks on tank walls, floors and roofs at least every 5 years.		YES / NO / N/A


Do you pump or bale water from bunded areas on a regular basis?		YES / NO

Do you use automatic or remote starters on pumps sited in bunded areas		YES / NO

Have you ensured no drains are sited within the bunded area		YES / NO

NOTE: Oils and fats are particularly heavy polluters, 4 litres of oil can cover an area equal to 2 football pitches.

Have you sited oil and fat separators on any surface water drain particularly at risk? (e.g.: lorry fuelling and parking areas)		YES / NO

Have you ensured that oil and fat separators are properly designed and large enough to contain a spillage?		YES / NO / N/A

Do you regularly inspect fat and oil separators?		YES / NO

Do you regularly clean fat and oil separators?		YES / NO

Do you prevent water contaminated with detergent from entering oil and fat separators?		YES / NO

NOTE: Detergents will emulsify oils and fats, assisting the oils and fats to by-pass the oil and fat separator.


Security


Do you lock all valves etc. when not in use to prevent unauthorised access to storage facilities?		YES / NO

Bulk Storage in Drums or Containers

Are all drums and containers properly labelled?		YES / NO


Do you store drums and containers in a bunded area?		YES / NO

Do you decant substances from large containers in a bunded area?		YES / NO

Are all containers sturdy uncorroded and unlikely to leak?		YES / NO

Are all containers on site protected from accidental impact from vehicles?		YES / NO

Are containers moved around site on bunded pallets?		YES / NO

Where drums and containers are used in production areas, are they bunded?		YES / NO

Do you prevent drums and containers from being left unattended adjacent to any drain?		YES / NO


Cleaning of Heavily Contaminated Work Areas

All cleaning materials are polluting biodegradable detergents are not suitable for discharge to the surface drain


Do you prevent any surface area particularly yards, from being cleaned by hosing to a surface drain?		YES / NO

Do you ensure all vehicle cleaning is completed in a designated kerbed area with discharge to foul water drains?		YES / NO


Waste Storage and Disposal

The safe storage and disposal of wastes is an essential pollution prevention measure. You should consider methods to reduce waste volumes and to store it safely on site. The Environmental Protection Act 1990 places a "Duty of Care" on waste producers to ensure waste is properly dealt with.


Do you store wastes in designated areas?		YES / NO


Are waste storage areas completely isolated from surface water drains?		YES / NO

Are waste storage areas bunded?		YES / NO

Rubbish compactors often leak polluted liquids. These areas should also be bunded and in a covered area. If you have a rubbish compactor do you comply with these requirements?		YES / NO / N/A

The producer of waste also has a duty to ensue that waste contractors are registered with the local authority and informed of the natures of the wastes.

Do you comply with this requirement?		YES / NO

NOTE: Litter is also regarded as a pollutant and must not be allowed to enter a water course.

Ground Water Pollution

The incorrect storage of chemicals and waste on unprotected land can also do great harm to the water environment. The spillage of pollutants seep through the earth contaminating ground water. Once ground water is contaminated it is very expensive to clean up. It can also make water unfit for other uses such as drinking water.

De-Watering

The earth can be of some help in water pollution prevention on construction sites, particularly during factory extensions or maintenance operations.

Silt water must never be pumped directly to a river or stream. It will block out sunlight, choking water ways and upsetting natural ecosystems.

Silt water, as long as it is not contaminated (e.g. cement, lime gypsum etc.), should be pumped to a foul sewer settlement tank or grassed area.

Training

This risk assessment can be used as a basis for environmental awareness training particularly during induction. The responsibility for environmental protection remains with the factory. It is essential that all staff make every effort to prevent pollution. It is a useful exercise to give staff personal responsibility for regular checking of pollution prevention devices. Basic pollution prevention comes down to basic common sense, general good house keeping and staff training.

Emergencies

Accidents are inevitable, have contingency plans in places. Rehearse them and improve them. Pollution prevention pays.

Water Protection Zones

The Environmental Protection, Water Resources Act 1991, permits the enforcing authority to apply to the Secretary of State to designate "Water Protection Zones" where there is a record of accidental spillage's.

Where such a Water Protection Zone has been authorised, the designated authority can, (under Section 93), restrict or prohibit the storage of chemicals. These powers are in addition to the use of Improvement and Prohibition Notices which can force companies to ensure;

1) Improved bunding
2) Revised drainage
3) Reduce quantity
4) Distribute storage to a number of smaller locations, all of which have to be adequately protected.
5) Improve Management
6) To use alternative chemicals and substances.

In conclusion - Pollution Prevention Pays.


	Revised: December 01, 2004. Copyright © 1999/2005 Greencore Group plc. All rights reserved
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