Why Should I Have a Contractor Ready for Spill Response?

You must have comprehensive policies and procedures in place to prevent spillages from occurring but incidents can still happen and you must act swiftly to prevent or minimise environmental pollution. Sometimes you will require support from external contractors.

When should you get an external contractor?

Smaller spillages that can be fully contained and cleaned up with the spill response materials on site can be dealt with by your internal spill response team. However, your team may not be able to deal with some types of spillages. For example:

• A large spillage that your staff and/or your spill response materials cannot deal with
• You are unfamiliar with the spilled material and how to deal with it
• The spillage has entered your drains or escaped site and may cause pollution.

What should your spill response team do?

Your internal spill response team must respond in the immediate aftermath of an incident and prioritise stopping and containing it. This may involve the use of drain covers and absorbent socks, pillows and pads to keep it away from drains and unmade ground.

What information should you provide?

When appointing a contractor, you must provide them with as much information as possible to ensure they can deal with it effectively and minimise pollution. You must inform them of:

• What the material is and how much has been spilled. If possible, you should provide the COSHH and Material Safety Data Sheet
• Where the material has spilled to. g. has it been fully contained in the yard area or has it escaped to nearby drains? If it has got into drains, has it been collected in an interceptor? If you have a drainage plan, you should provide it.
• What you have done so far.

What will your contractor do?

Your contractor should respond quickly to an incident and assess what should be done. The spillage should be fully cleaned up and decontaminated if required. All drains and interceptors should be inspected for contamination and inspections may be required off site to determine if pollution has escaped. Your contractor should provide a summary of what they have done and any further actions required. If the spilled material has escaped, you may need to inform the Environment Agency and carry out remediation works. Any waste should be dealt with according to legal requirements and you should get copies of waste documentation.

Swift, effective and informed spill response is essential to reduce the impacts of an incident. A specialist contractor may be required if you have a large or complex spill and expert response can help to prevent or minimise pollution. If you cause pollution, you may be liable for prosecution, fines and the cost of remediation; by demonstrating you have done as much as possible to prevent pollution (including prevention and response), you may reduce the consequences.

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I've Had a Spill, What Do I Do?

It is important to take actions to prevent pollution wherever possible, but sometimes accidents happen. If they do, you must be aware of the correct actions and procedures to follow to ensure that any impacts are eliminated or minimised.

Assess the risk and prepare

If a spill occurs, you need to assess the risk, including health and safety issues before you do anything else. You should identify what the spilled material is and ensure that no-one is hurt. Assuming everyone is safe, protect yourself by selecting the appropriate PPE for the spilled material. This should include gloves but other equipment such as goggles and overalls may be required, depending on the risk.

Contain spill

You must act to prevent the spread of the spilled material, in particular protecting drains. This is essential to ensure the spilled liquid does not contaminate a water source. Your spill kits should include equipment to block, divert or confine the spill, such as drain covers, booms and socks that will create a barrier and start to soak up some of the spill.

Stop the spill

If not done immediately, you should now stop the source of the spill. By containing the spillage first, you can ensure it does not spread to sensitive areas while you are stopping it. Spills can be stopped by using specially designed putty to plug a hole, turning a container upright or transferring the liquid to a new container.

Implement clean-up

Once everything is secure and safe, you can begin to clean-up the spill and decontaminate the area. If you are appropriately trained, have the correct equipment and the spill is small enough, you can use absorbent materials to being soaking up the spilled liquid. This may include absorbent granules, pillows and pads. Once the spill is absorbed, you will need to collect all of the absorbent materials and dispose of them correctly, usually as a hazardous waste. You will then need to assess the area to ensure all of the liquid has been cleaned up. If the spill is very large or particularly hazardous, you may need to contact a specialist contractor to help you deal with the clean-up.

Report

Once a spillage has been dealt with, it is important to report it. If necessary, you may need to inform the Environment Agency or your local sewage provider if any of the spilled material has left your site. If the spill has been fully contained, the incident should still be reported internally. This helps to ensure that any required lessons are learned to ensure the incident does not happen again. It is also important to ensure that any pollution control equipment is restocked.

In the event of a spillage, it is essential that you respond quickly to intercept and reduce contamination. You should have a spill response team that have been trained in how to respond to a spillage to contain it, taking into consideration site specific features.

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We've Cleaned Up a Spillage on Site, What Now?

Investigate the Underground Pollution Pathways

When cleaning up a spillage, you should take all reasonable actions to ensure that the spillage is fully contained, absorbed and that your drains are protected. Even if you think you’ve absorbed everything, there is a possibility that some pollution escaped to the drainage system so you should check along the drainage network, including under manhole covers and at outfall locations, to determine if there is any contamination. This should be done immediately after the incident and again a few days later to make sure no pollution has escaped your containment efforts. If contamination is discovered, it should be dealt with immediately to ensure it does not leave your site and cause pollution.

Restock Pollution Control Equipment

Whenever you have used pollution control equipment, such as spill kits or drain mats, you must make sure they are restocked as soon as possible. Ideally, this will include deployment of spill kit spares, which you will then need to be re-ordered. If you don’t have any spares on site, make sure you order replacement kits as soon as possible; you need to make sure you are covered if there is another spillage.

Report the Incident

All incidents should be reported internally. At a minimum, details of the incident, including date, time, what and how much was spilled should be included, as well as who was involved and what actions were taken to deal with the incident. The report should include the details of any contractors that were engaged to help clean up the spill and additional actions that were taken after the incident, including checking the drainage network. If pollution escaped the site, you may need to inform an external regulatory body. If pollution escapes to surface water, this would be the Environment Agency and if it escapes to foul water, this would be the water company. You should provide all relevant information and keep a record of the communications.

Investigate the Incident

Internally, you should investigate the incident, to find out how and why it happened and determine whether any controls can be put into place to prevent it from happening again. Any controls should be implemented and any lessons learned communicated to all staff so you can continually improve and help prevent pollution from your activities.

If you have a spill, quick and effective response is essential to prevent and minimise pollution escaping from your site. After the initial clean-up, you must make sure that there is no contamination in your drainage network, report the incident, investigate why it happened and implement any changes to prevent it from happening again.

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Do I Need to Train My Staff in Spill Response?

What should my staff be trained on?

Your spill response team should receive some kind of structured training. Although a tool box talk will be useful for most staff and cover the broader points of spill control, a more in-depth and detailed training session for those primarily responsible for dealing with an incident should be conducted. This training should include exactly what to do in the event of a spillage, including containment and clean-up and understanding of when additional support may be required. This training should be site specific, and driven by your Pollution Incident Response Plan (PIRP). Content should include taking into account site conditions such as drainage and interceptor arrangements, spill kit locations and locations of any sensitive areas. As well as the theory of how to respond to a spill incident, your team will need to understand how to respond in real life, so a practical demonstration and practice could also be beneficial.

How often should the training be refreshed?

Your spill response team should be familiar with the correct spill response and remember what to do if an incident does occur. Therefore, refreshing or re-training would be appropriate to make sure your team are reminded of exactly what to do. The frequency and type of training will be dependent on the complexity of your site and your pollution risk. For example, you may decide to do refresher training once a year with the use of tool box talk but more in-depth training, going through all the content every two years.

Is there anything else I can do?

In addition to spill training, it would be beneficial to have a spill drill. Similar to a fire drill, it allows you to simulate and practice what you would do during an actual incident outside of a classroom setting. A drill should be carried out with a non-hazardous liquid, in a location where a spill is likely and using real spill kits. You can decide whether it is an announced drill so there is minimal operational disruption or not so you can test your team’s real reactions. You will also need to keep track of who is spill trained in your organisation. You should have some spill responders on site at all times, which means you may need to train across shifts and may need to train new people if your existing spill response team leave or move to other positions.

Responding to a spill in a timely and effective manner is essential to help prevent pollution from leaving your site. Even if you use an external contractor to clean-up with major spillages on your site, you need to ensure you have an on-site team who is aware of the immediate actions to contain and stop the spill and how to deal with minor spillages. They should be regularly trained on site-specific conditions and you may also consider a spill drill.

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Do I Need Spill Kits on Site?

All sites, regardless of size, have a spill risk and need to take the appropriate measures to prevent them from happening and reducing the likelihood of a serious environmental incident if they do occur. Spill kits are essential equipment to have on site so you can quickly respond to any incident that does occur.

What do spill kits do?

Spill kits are collections of absorbent materials that are used to contain and clean up spillages of potentially hazardous substances. There are different types of spill kits for use on different spilled substances (read our blog here) and spill kit contents can vary according to your requirements. Spill kits should be in good condition, weather proof containers that are clear to identify and easily accessible.

How do I know if I need spill kits?

Most businesses will require a spill kit. Obvious spill risk areas like refuelling areas and oil and chemical storage areas will clearly need a spill kit but other areas that are less obvious should also be considered. For example, MHE charging areas, car parks and yard areas present spill risks. You should identify all spill risk areas (read more here) and ensure there is a spill kit close by that can be quickly deployed.

We call a contractor if we have a spill, surely we don’t need spill kits?

Having a contractor on-call to deal with an incident is a great idea to ensure a spillage is dealt with effectively and in a fully informed manner with consideration of the potential environmental impact. However, you’ll need to do something with your spillage before they arrive. This is what spill kits are for – you can use them to contain the spillage and protect areas such as drains and unmade ground. Spill kits often have booms (long socks) that you can put around the spillage so it doesn’t get any further and your spill kit may have drain protectors that you can put over your drains.

Do we need anything else?

When you deploy spill kits, it is essential to ensure that your staff are trained in their use. You may consider having a core team of spill responders who are trained in the initial spill response and they are the only people allowed to deploy spill kits. You will also need to ensure that spill kits remain full and in good condition. You should implement regular checks of your spill kits and ensure there is a robust re-ordering process for when they are used.

Regardless of your business size, it is likely that you will need spill kits. The hope is that you will never need to use them, but if you do, it is essential that they are in place and you have trained personnel who can use them correctly.

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What Should I Be Looking Out for in my Spill Kit Arrangements?

Just having spill kits on your site will not be enough, you will need the right type, of the right quantity, in the right location.

What type of spill kit do I need?

There are 3 main types of spill kit: oil, chemical and general. Spill kits are typically specialist in what they will absorb, so oil spill kits will absorb hydrocarbons and chemical spill kits will absorb chemicals. General spill kits absorb everything, including water so are not suitable for use outside. You may also want to consider neutralisers like soda ash for use on an acid spill to make it safer to deal with. You should consider what your spill risk areas are, what the spilled material is and ensure there is the correct spill kit nearby.

How much spill kit do I need?

Spill kits come in sizes in litres, telling you how much liquid the kit can absorb, for example 30, 240 and 1000 litres. The aim is for you to have enough spill kit to contain a large spillage. If you have a large fuel tank, you will not store enough spill kit to absorb all of the contents; you will be looking at enough spill kit to contain the spillage until a specialist contractor can attend. You should also consider whether your spill risk justifies having spill kit spares on site. Some sites will use little spill kit and have a robust and quick re-ordering process whereas other sites will need spares to hand to cover after an incident.

Where should my spill kits be?

Spill kits must be accessible to your spill risk areas. If your areas are close together, you may have a spill kit station to cover multiple areas, but you must be able to get to them quickly and you must have enoug. They should be easily accessible, and you should be able to identify them quickly. You may have location signage as well as labels on your containers. A site plan that staff are aware of with spill kits marked on it will also be useful.

What else do I need to look out for?

Regular checks on your spill kits are essential to ensure they are full and in good condition. You should use good containers that are easy to see and are weather proof and not damaged. You may also want to consider using tamper tags on spill kits so they aren’t accidentally used as bins or kit taken out and used indiscriminately.

Spill kits are essential for sites to ensure you manage the potential pollution risk from storing hazardous substances. It is essential that you employ the correct spill kit, of the required quantity and place them in areas where they will be easily accessible.

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How Do I Know Which Spill Kits to Put Where?

Correct spill kit placement is essential for pollution management. When considering spill kit arrangements, there are a couple of questions you need to ask: Where do I need spill kits? How many do I need? What type of spill kit is required? How big does it need to be?

Site Assessment

You need to identify your spill risk areas. Specifically, where they are, the risk type and quantities of hazardous materials. The best way to do this is to walk around the site, looking at all areas and asking questions of the people who work there to find out what activities typically happen there. You should look out for fuel, oil and chemical storage areas, refuelling areas, MHE charging points, loading/ unloading areas and anywhere of high vehicle movement. It can be helpful to take a floor plan and mark the areas of risk so you have a visual representation of everything. You can also assess any current spill kit provisions, making note of the contents, type, quantity and positioning.

Types of Spill Kit

There are typically three types of spill kit (read more in our fact sheet here). Chemical spill kits are specifically designed to deal with chemical spills and are usually yellow; oil spill kits deal with fuels, oils and hydrocarbons and are white and general kits, usually grey, can be used inside for mild spillages. Once you have assessed your spill risk areas, you can determine the best type of kit for each area and any additional equipment you may need. For example, soda ash, that neutralises acids would be essential in areas where strong acids could be spilled, like battery charging areas. You also need to consider how much of each spill kit you might need, informed by how likely the spill is to occur and the quantities of potential spill material that are in the area.

Spill Kit Placement

You will need to ensure that all spill risk areas are covered by the correct spill kit type. Looking at your annotated floor plan, you will need to make sure that spill kits are accessible, but also in convenient locations where they won’t get in the way. You don’t necessarily need to have a spill kit in each spill risk area, but they will need to be close enough to get to quickly. Spill kit bins are useful for easy maneuverability.

Your pollution prevention plan should include the deployment of spill kits. You should start with identifying spill risk areas and determining the correct spill kit type and size for those areas. You can utilise existing kit and order any additional equipment you need and put them in accessible places, in easy to identify bins. Once you have deployed your spill kits, it is important to check them regularly to ensure they are always ready for use.