Pollution incident response planning for road transport businesses (logistics, transport, distribution)
You can reduce the risk and impact of pollution incidents from your road transport business with planning and preparation. Consider the good management of your high environmental risk activities, for example, washing and refuelling vehicles and storing and using oil and lubricants, to avoid harming the environment. If you need more advice on environmental issues or are thinking of moving towards ISO14000 please contact one of you safety and environmental consultants on 01453 800100 for advice and indicative costings. We can produce combined safety and environmental policies to cover the activities of your haulage / transport / logistics / distribution business.
If you carry dangerous or polluting loads also read netregs - guidance on carrying dangerous goods and consider the services of one of our experienced Dangerous Goods Safety Advisors (DGSA). Call 01453 800100 to speak to an experienced DGSA and receive a quotation on support on this issue.
What is a pollution incident?
A pollution incident is any discharge to land, air or water that could cause environmental damage.
Pollution incidents which could affect road transport businesses include:
- fuel drips or spills during refuelling of vehicles or bulk storage tanks
- leaks or spills from vehicles or equipment
- leaks from fuel or chemical containers, e.g. oil storage tanks
- release of hydraulic fluids from burst hydraulic hoses
- contaminated water entering a watercourse or drain, e.g. from washing vehicles, concreted areas where you park your vehicles, or contaminated firewater
- wind blown dust and waste from skips or containers at your freight or maintenance depot.
What is a pollution incident response plan?
A pollution incident response plan is a short document that outlines the actions your business will take to minimise the pollution caused by an incident.
Your plan doesn’t have to be complicated. The level of risk should influence the size, complexity and details of your plan.
Why do you need a pollution incident response plan?
Most businesses aren’t legally required to have a pollution incident response plan, but it will help you prevent a pollution incident occurring at your site. If there is a pollution incident on your site the clean-up costs could be expensive, particularly if you contaminate groundwater or neighbouring streams or toher waterways. You could also be committing a criminal offence and may have to pay compensation plus suffer irreparable damage to your reputation.
Please note: you must have a pollution incident response plan if you have an environmental permit (England and Wales), a pollution prevention and control (PPC) permit (Northern Ireland and Scotland) or are regulated by the Control of Major Accident Hazards (COMAH) Regulations.
What information should your pollution incident response plan contain?
Details of your business
You should include:
- the name of your business
- your address and the location of your premises or site and a description of the surrounding area
- a list of the operations that take place on your premises, including the number of employees present at different times of the day
Key staff and contact details
List 24-hour contact details for people and organisations that may need to be involved during or after a pollution incident. For example:
- staff who are responsible for making decisions and taking action in the event of a spill or leak
- the most senior responsible person
- the emergency services, your environmental regulator, the Health and Safety Executive and the pollution hotline (0800 80 70 60)
- your water company or authority
- local GP surgeries and hospitals with accident and emergency departments
- the sewerage undertaker in case pollutants enter foul drainage
- specialist clean up contractors
- the person responsible for keeping the plan up to date.
Document review dates
You should include:
- the date the plan was last reviewed - make sure that it is current and up to date - at least annually
- the date your workforce was last briefed on the plan contents - remember to allow for staff turnover and new sites and operations, ensure staff fully understand by asking questions which prove competence
Details of pollution risks at your premises or site
Include a detailed site plan that shows areas vulnerable to pollution, including the locations of storage and delivery areas, any other areas that could cause pollution, and locations of surface watercourses or culverts that could be affected by a pollution incident.
List the types of fuel, oils, gases and chemicals you store on your site. Include estimates of how much of these you normally keep on site to help the emergency services in an incident. Attach product data sheets and COSHH (control of substances hazardous to health) assessments for any substances that pose a risk to people or the environment.
Once you have identified possible sources of pollution, you can take action to reduce the likelihood of an incident. The following documents could be useful resources for this;
Water pollution
Environment Agency: Pollution prevention pays - getting your site right
How to deal with pollution incidents
Your plan should describe the actions to take in the event of an incident and who is responsible for them. The actions that you need to take will depend on your business activities.
The plan should contain details of how to:
- stop incidents occurring, e.g. prevent leaks
- contain incidents, e.g. how to use spill kits to prevent spilled materials entering drains or watercourses, and include a list of all materials and equipment held on site to deal with pollution
- notify relevant contacts when an incident occurs, e.g. key staff, environmental regulators and emergency services
- decide whether an incident is significant or not
- clean up after any incident, e.g. how you will store and dispose of contaminated materials.
Dangerous goods guidance for road transport businesses
This guidance is relevant if you use commercial vehicles to transport dangerous substances, such as solvents, pesticides or fuel, by road. This could also include some household products such as paints or aerosols.
You will need to manage the risk of spillage during transport, which could lead to fire, explosions or environmental damage.
What you must do
If you transport dangerous goods, you must comply with certain legal requirements regulated by the Health and Safety Executive (HSE).
There are different classes of dangerous goods including:
- corrosive substances
- explosive substances and articles
- flammable liquids
- flammable solids
- gases
- oxidizing substances
- radioactive substances
- toxic substances.
You have a responsibility to identify the hazards of the goods you intend to transport, and meet requirements for packaging, labelling and documentation.
Vehicle Certification Agency (VCA): Guidance on dangerous goods packaging
There are some exemptions from the requirements for limited quantities or limited loads, for example some retail goods such as those delivered to DIY stores.
You can check the Department for Transport’s (DfT) database to find out if the goods you intend to transport are classed as dangerous goods and what you need to do.
For more information about what you have to do to transport dangerous goods, you should contact the HSE or the DfT.
HSE information on carriage of dangerous goods
Health and Safety Executive Northern Ireland
DfT: Carriage of dangerous goods
Ensure that your drivers keep their vehicles as secure as possible. You can still be prosecuted even if vandals cause pollution from your vehicles.
If you are transporting waste from domestic, commercial or industrial premises see our guidance for waste businesses.
If you are transporting hazardous/special wastes check what legal requirements apply to you.
Good practice
Ensure your drivers are fully trained to understand the hazards of the goods they are transporting and what to do in an emergency.
If you have a pollution incident call the Pollution Hotline on 0800 80 70 60.
Ensure all your goods are transported in a suitable container. Inspect and maintain your containers routinely.
Check container valves or doors to prevent leaks or releases of odour, dust or vapour.
Ensure your containers are labelled correctly and that manufacturers’ labels are clear and intact.
Make sure that drivers responsible for carrying goods supervise the loading of their vehicles. Before any loading is carried out, the driver should check containers to ensure they are not leaking and that caps and lids are secure.
Secure containers so they can’t move around during transportation to prevent damage or spills.
Make sure that your vehicles do not have parts which stick out into the load-carrying area as these could damage containers or packages. The load-carrying area should have impervious surfaces free from pockets or seams. This will make it easier to clean.
Prevent material escaping from open-topped vehicles by netting the load.
When carrying dangerous or polluting materials, avoid taking a route through environmentally sensitive areas where possible.
Nature conservation
Carry pollution control equipment suitable for the type of substance you are transporting. Include absorbent materials and sealing or containment materials, such as sealing putties and drain sealing mats. Also carry a shovel, as earth can be used as an absorbent or to make a barrier to contain a spillage. Absorbent materials used to contain spills may require separate recycling or disposal as hazardous/special waste. Check before you recycle or dispose of them.
You should not store oil for any length of time in tankers. Tankers are not designed for oil storage.
Further information on transporting dangerous goods
The Road Haulage Association (RHA) has a number of groups that provide specialist guidance, for example car transporters, milk carriers and livestock transporters.
The UK environmental regulators and the Fire and Rescue Service (FRS) have produced guidance on controlling pollution from spills on the highway and to minimise the environmental impact.
PPG 22 Dealing with spillages on highways (Adobe PDF - 100KB)
FRS: Environmental Protection Manual
The Chemical Industries Association runs the ChemSafe scheme, which provides assistance in the event of a transport incident involving chemicals.
ChemSafe scheme
