What Do I Need in a Pollution Risk Management Plan?

All businesses have a general duty to manage and minimise pollution from their activities.  There are various legal requirements to support your pollution management strategy, working in tandem with site policies and procedures to manage pollution risk.  This blog will discuss the broad requirements of what should be included in your Pollution Risk Management Plan.

Policies and Procedures

You should have a set of site-specific policies and procedures to manage the pollution risks on your site.  A Pollution Incident Response Plan that includes all relevant information on how to reduce the chances of an incident and the actions to take if an incident does occur (read more here) is essential.  You may also have other written procedures to manage your pollution risk e.g. waste, spill response and refuelling procedures etc.

Pollution Controls

You should assess your site risk and put the appropriate controls in place to manage those risks.  Examples of pollution controls include:

  • Storing all liquids on appropriate bunds
  • Placement of the correct spill kit in at risk areas
  • Effluent discharge areas connected to foul drainage
  • Correct segregation and safe storage of waste
  • Interceptors on the drainage system to cover at risk areas at a minimum

Maintenance & Servicing

You should ensure that any equipment that you have that could cause a pollution risk is correctly maintained.  For example, you must ensure that any equipment containing F-gases (like air conditioning equipment) is regularly leak tested.  You should also maintain any infrastructure and pollution control devises.  For instance, regular planned maintenance on your drains and interceptors can help ensure they are kept in working condition and reduce the chances of pollution leaving your site (read more here).

Training

It is essential that your staff are aware of their responsibilities surrounding pollution prevention.  As a minimum, they should have a general environmental awareness, knowledge of emergency procedures and know about the procedures that they must follow e.g. waste, refuelling etc.  Additionally, you should have a dedicated spill response team who have been specifically trained to respond to an emergency scenario.  You should also consider when refresher training is required for all staff.

Regular Checks

When you have all the necessary procedures, controls, maintenance schedules and training in place, you must carry out regular checks to ensure they are being maintained correctly and continue to offer you pollution protection.  Regular inspections will highlight any spillages, bunds filling up or waste blowing around the site.  Auditing will check policies, procedures and records to ensure maintenance and servicing is being carried out.  These checks should inform your action plan to ensure any issues or opportunities for improvement are identified and acted upon.

You are required to demonstrate reasonable care to put in place and enforce proper systems for the avoidance of pollution.  A fully considered site specific pollution risk management plan, considering all risks and scenarios and the required controls and checks will go a long way to showing pollution management and control.