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Clean up our act

01 December 2021

From Toxteth riots to COP26, Miles Hillmann looks at how pollution control takes centre stage in 2022.

CERTAIN MAJOR events have driven companies to recognise the importance of effective spill and pollution control policies. In 1981, one of the outcomes of the riots in Toxteth, Liverpool was the instigation of the Mersey Basin Campaign which successfully cleaned up the dirtiest river in Europe and set the standard for river water quality. 

Then in 1996, following the privatisation of the water companies, the Environment Agency was created as an independent authority encompassing the roles of the National Rivers Authority, Her Majesty’s Inspectorate of Pollution and the waste regulatory role of the local authorities. And, in the 1990s, a series of Water Acts of Parliament became law. Some companies complied with regulation. There remained a lot of lip service. Recently increased public and corporate awareness of climate change agenda is causing major plc’s to reassess their exposure to pollution control. The Environmental, Social and Corporate Governance (ESG) issues are severely impacting their share prices to the extent that no CEO risks operating their pollution and spill control policies to less than best available practice. And these plc’s are increasingly requiring their network of suppliers to comply.

In the 1980s Britain had the dirtiest rivers in Europe and beside them industrial decline was manifest in dereliction, poor housing and social problems. These issues came to a head in 1981, when disturbances in Toxteth, an inner-city area of Liverpool, boiled over into full-blown riots. Arriving in Liverpool in the smoldering aftermath of these events the then Secretary of State for the Environment, Michael Heseltine, made his home in the Atlantic Tower Hotel overlooking the Mersey. 

As a result, a series of transformative events were initiated. Established in 1985, the Mersey Basin Campaign was the first major attempt to address the problems of water quality on the Mersey and its tributaries. 

The campaign was a partnership aiming to bring together public, private and voluntary sector action. This was groundbreaking in terms of British administrative practice. At the time most partnerships, where they existed at all, were between the public (government) and private (business) sectors.

By 1999, the River Mersey Campaign won the prestigious International Theiss Riverprize for the river basin clean up. 

By 2002 the authorities were sufficiently confident of the cleanliness of the River Mersey that high profile, international athletes contested the swimming leg of the 2002 Commonwealth Games triathlon in Salford Quays, an event unthinkable less than 20 years before.

Concern about water pollution and the environment turned into effective legislation in the UK with the enactment of a series of Acts of Parliament in the 1980s and 1990s. And in 2001 the Control of Pollution (Oil Storage) Regulations gave some force to the laws.

In 1996 the Environment Agency was established encompassing the activities of the National Rivers Authority, Her Majesty’s Inspectorate of Pollution and local authorities’ waste regulatory role, with the issues related to the recently privatised water companies high on their agenda. The Environment Agency is responsible for regulation of air and water pollution and flooding from rivers and the sea.

Major environmental disasters have generated huge publicity, including the oil tanker Exxon Valdez , which ran aground and spilled quarter of a million barrels of oil into the Alaskan waters in 1989 or, more recently, BP’s Deepwater Horizon drilling rig which sank pouring over 50,000 barrels of oil a day for over three months into The Gulf of Mexico in 2010. Shell and other oil companies continue to struggle with the worst example of systematic, unrestrained pollution which continues in the Nigerian Delta.

Environmental concerns have become more widespread in the 21st century with higher standards of living, increased quality of life and health, driven by public awareness campaigns and respected environmentalists, such as David Attenborough. 

But not only public awareness is stimulated, but importantly, major international companies, and not just oil companies, see the fines and costs of over $50 billion that BP incurred and environmental protection moves swiftly up their agenda. 

But for many companies only lip service was paid to spill control. Containment of oils and compliance with the Oil Storage Regs was recognised but otherwise provision for emergency clean up with spill kits was limit of pollution control.

Still by 2020 the Times was reporting that “England’s rivers are among the most polluted in Europe” That is the startling conclusion of an analysis by The Times of 55 million water-quality tests undertaken by the Environment Agency from 2000 to 2019. “In addition, half of all stretches of river monitored by the Environment Agency exceeded permitted limits of at least one hazardous pollutant last year, including toxic heavy metals and pesticides”. 

With the Environment Agency devoting increasing resources to flood control with a reduced budget, policing of spill control was starved of funds. 

However since 2020 the dramatic rise up the agenda of issues related to climate change has widened the concerns about pollution incidents from the Environment Managers in plc’s to the Financial Director and MD. The impact of Environmental, Social and Corporate Governance (ESG) comprise a label that has been adopted throughout the financial industry. Any major pollution incident would impact their share price. Corporate responsibility for pollution control has become a real financial issue.

How the most responsible companies effect spill control is no secret. It consists of:

Spill Risk Assessment Survey which identifies foul and surface water drains and maps them under and around the premises.

Effective Drain closure systems in the event of an emergency spill

Fire water pollution is the greatest pollution risk but with flooding becoming increasingly prevalent the ability to shut off drains in an emergency is crucial. Spills of oils and fuels can happen at any time. Penstock valves are the traditional method of drain closure but they have serious shortcomings in response to emergency spills. 

Intelligent pollution prevention devices activated by pH or hydrocarbon meters are increasingly retrofitted to provide instantaneous closure of drains day or night to prevent pollution.

Containment of oils and chemicals on site

The Control of Pollution (Oil Storage) Regulations 2001 require oils and fuels stored in the UK outside in quantities greater than 200 litres to be bunded.

This secondary containment can be provided by spill pallets, double skinned tanks or bunded stores.

For larger tank storage either permanent bunding of a size to contain 110% of the volume stored is required or, increasingly popular, are bespoke modular bunding systems for containment of tanks and on site.

Where access is required in working areas containment and lining of the working areas can be provided by drive over bunds. 

Working Spills Clean up 

Provision of suitable absorbents for regular working practices should be easily available and located close to the working areas to provide efficient access to absorbents

Emergency spill provision

Emergency spill kits should be located at points of potential risk e.g. loading and unloading bays, refuelling points, and H and S stations. Spillkits are suppled for general use e.g. maintenance, oil only or chemical spill kits packed in wheelie bins or portable bags, or those specific to the application ranging from biohazard spill kits to battery acid spill kits to mercury spillkits

Accredited Spill awareness and response training should be provided throughout the operational staff. Provision of the right equipment provides 50% of effective spill control. Training in awareness and the skills to respond to incidents among the staff provides the other 50%. The BSIF spill training accreditation ensures that training is done to the highest standards. Many leading companies are recognising its importance. 

Through adoption of these best practices plc companies and their suppliers minimise their pollution risks and meet their ESG responsibilities with not just social benefits but real financial benefits. Pollution control takes centre stage in 2022.

Miles Hillmann is managing director at Fosse Liquitrol. For more information, visit www.fosseliquitrol.com