ASBESTOS & HAZARDOUS SUBSTANCES
OIL THE WHEELS
Ignoring legal requirements around hazardous substances can spell environmental disaster and damaged reputations. Alan Scrafton from Adler and Allan outlines best practice when it comes to dealing with oil – a substance nearly every business comes into contact with.
When we think of hazardous waste, often the first things that come to mind are toxic chemicals, which many businesses have nothing to do with. Hazardous waste, however, pretty much covers anything that could potentially harm the environment and includes food substances such as milk and, importantly, oil (i.e. fuel) – a substance that almost every business has on site.
For organisations that need to use large quantities of fuel, storing, transporting and disposing of this substance safely is essential to prevent spill risk. Since oil is among the most common pollutants in the UK, businesses that store and/or transport fuel are prime contenders for causing pollution.
LEGISLATION When it comes to oil, legislation for above ground storage tanks comes courtesy of the Pollution Prevention Guidelines 2 (PPG2). Complying with PPG2 will ensure the risk of spills is kept to a minimum, as well as helping to protect your business from legal backlash should a spill occur despite your best efforts.
As a starting point, PPG2 recommends insurance; not just to replace the oil lost, but also for environmental clean- up, with a high enough liability limit to cover your site and any neighbouring land. When it comes to water, in England and Wales it is against the law to cause pollution; non-compliance is an offence and may result in enforcement action being taken.
To reduce the risk of water pollution in particular, PPG2 recommends that oil is not stored:
• Within 50 metres of a spring, well or borehole
• Within 10 metres of a watercourse • In places where spilt oil could enter
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open drains, loose fitting manhole covers, or soak into the ground and pollute ground water
• In places where tank vent pipe outlets can’t be seen from the filling point
• Above roof level, as spilt oil can run down guttering connected to surface water systems
If you have to install a tank in one of these areas, additional environmental protection may be required, such as an overfill prevention device or oil separator – as used in forecourts.
DELIVERIES With fuel deliveries being a prime time for spills, making sure the site where they are received is suitably prepared is essential. The area around a tank where deliveries are made and, if applicable, oil is dispensed, should have an impermeable surface and be isolated from surface water drainage systems. This will prevent oil and/or contaminated water getting into the soil and groundwater. For forecourts, separators are essential for keeping hazardous oils from leaving a site. These should be regularly maintained; if filters get clogged, the risk of pollution and flooding is increased. Separators should be serviced at least twice a year.
DEALING WITH SPILLS If a spill does occur you need to be as prepared as possible, with plans in place to quickly stop pollution in its tracks. Part of these plans should include keeping the appropriate spill kits on site, essential for ISO14001 compliance. Spill kits act as a first line of defence, with versions available depending on the hazardous substance in question, but in many cases they will not be enough. Having an expert team on hand to
provide thorough clean-up round the clock is essential to avoiding the fines and damage associated with environmental pollution.
SPILL CLEAN UP Following a spill, there is a legal obligation, outlined by the Environment Agency and Defra, to clean up the area thoroughly, remediating land and water courses back to their pre-spill state. This will require expert support, with a post-spill assessment conducted in order to implement the best course of action. Remediation techniques range from physical – including the disposal of contaminated soils and recovering the pollutant – to biological and chemical to breakdown or neutralise the spill substance.
www.adlerandallan.co.uk
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