Key points
Regulators are cracking down on commercial organisations that pollute the environment. Over recent years, the levels of fines imposed for causing a pollution incident have significantly increased to eye-watering figures. Combined with the long-term damage to brand reputation and shareholder confidence, can you afford to fall behind on your environmental management processes and spill response strategies?
Within food manufacturing, you will use a wide range of liquids, that, if spilt, could have devastating consequences on the environment. You need rigorous processes in place to prevent spills as far as possible and ensure any spills are contained and cleaned up as safely and effectively as possible.
How to respond to spills
In the first instance, in the event of a spill, you need to keep everyone safe. This is your priority.
Put immediate safeguards in place
It’s vital to keep all personnel safe in the event of a spill. Even if the spilt liquid isn’t toxic, there are risks of slips and associated injuries. Immediately retreat from the spill area, warn other personnel and raise the alarm if necessary.
Determine the nature and hazard of the spilt liquid, and likely action
Before you respond to any spill, you need to know what you’re dealing with. If there’s no one working in the area who knows what the substance is, check the labels on the containers, SDSs, COSHH sheets, TREM cards, etc. You must also report the spill to the correct authorities, if necessary, at the earliest possible opportunity.
Risk assess the situation and foreseeable clean up actions
Before tackling the spill, you must understand all the potential risks and how to control them. Are there any fire, explosion or hazardous reaction risks? Are there any other risks to health and safety including exposure to fumes, skin/eye exposure risks, any concerns about slips, trips or manual handling? Will any safety systems be compromised?
Once you’ve assessed the risk, put your controls in place
Set up a restricted zone so no one can access the area who shouldn’t. Ventilate the area in case of any potential sources of ignition if there’s a fire or explosion risk. Brief your responders on the hazards, risks and safe working, ensuring that everyone has the correct PPE.
If anyone has been injured, notify the first aid team, assess injuries and call the emergency services, if required.
Immobilise the spill and/or isolate the source
Once the area is secured and your responders are fully briefed and kitted out with appropriate PPE you can start to coordinate your response to prevent any further escape of liquid and wider contamination. You want to contain the spill within your site and prevent it from escaping into the drainage system or watercourse but keeping it on a hard surface, where possible, and protecting drains and other escape routes.
Control and clean up the spilt liquid
You must NOT flush any spills to drain without gaining specific official consent. Instead, absorb liquids or pump into bunded tanks. All used materials must be handled with care.
Collect, package and label arisings and arrange correct disposal
How you deal with the waste is just as important as how you deal with the initial spill. Ensure that you detail containment accurately on labels and paperwork. Class the waste according to which liquid was spilt and consult an appropriately licensed waste contractor to ensure safe and compliant disposal. Make sure that your spill response equipment is restocked for future use.
Review the incident
Once the dust has settled, it’s important to critique what happened. How could it have been prevented? Could the response have been improved? Consider whether risk assessments need to be updated with new information and, finally, compile reports and plan follow up actions, if appropriate.
Do you have an environmental management system in place?
The most effective way to avoid pollution incidents is to set up an environmental management system (EMS).
One of the ways to ensure your EMS covers everything, is to look at obtaining the ISO 14001 certification. ISO 14001 is the internationally recognised standard for environmental management systems. It would give you a framework for designing and implementing an EMS within your organisation that will make sure you are compliant with environmental requirements, achieve your environmental objectives and reduce your impact on the environment.
Your EMS should include details on staff training.
Train your staff to ensure efficient spill response
Your personnel on the ground are your best first line responders in case of a spill. However, they need to know more than how to use spill kits. They must have a sound understanding of their responsibilities for site safety,[GU1] spill control and environmental protection so they can protect your site and the environment from pollution incidents.
If you’re seeking ISO 14001 certification or looking to maintain your accreditation, spill response training is essential. Investing in spill training also contributes to compliance with regulations such as the Control of Major Accident Hazards Regulations (COMAH).
Spill response training is available at various levels from basic first responder training to more advanced certifications that challenge delegates to think tactically.
What type of absorbents do you need for managing a spill?
The type of absorbents you need to keep on site will depend on the substances you are handling:
Aggressive chemicals
For chemicals such as phosphoric acid, sodium hydroxide and citric acid, you need chemical absorbents. These are designed for use with more corrosive and aggressive water-based chemicals. Chemical absorbents are easily identified by their yellow colour.
Water-based liquids
Maintenance absorbents will absorb most water-based liquids present within the food production process industry, for example: fruit juice, milk, glycerol, beer and ammonium hydroxide. Maintenance absorbents are grey in colour.
Oil-based liquids
For oil-based liquid (including lubricating oils, fuel oil, vegetable oil and freon) spills you want oil absorbents, which are either white or blue in colour for ease of identification. Oil absorbents are hydrophobic so naturally repel water and they’ll float on the surface of water when saturated with oils.
Do you handle highly flammable hydrocarbon-based liquids with a fire or explosion risk due to static charge? Anti-static absorbents are designed specifically for this use. They are also hydrophobic and white in colour.
Ensure you have the necessary spill response on site
You need quick and easy access to the necessary equipment to tackle spills. Y[GU2] our pollution incident response plan (PIRP) will form part of your environmental management system. Your PIRP[GU3] will detail your emergency response. To enable your staff to act in an emergency, you need to make spill kits available to staff in areas where spills are likely to occur – signage can help personnel quickly identify the location of the correct spill kit.
Spill kits need to be kept in good working order and fully stocked with the equipment your staff will need in the event of a spill. The size and type of spill kits required will depend on:
- Type and quantity of liquids you store on site
- Type of plant and equipment you will be using on site and the potential for leaks
- Type of processes you are undertaking
- The number of risk areas you may have.
You can purchase ready-made spill kits designed for spills of varying volumes of liquids. Handy grab bags can sit inside the cab of a fork life truck, or you can choose floor-mounted spill stations to keep rolls of absorbents and pads within easy reach in the workplace. For high-risk areas with large volumes of liquid being stored, you can get spill kits contained within 1,100-litre Euro bins.
Contain potential spills to stop spread
Prevention is always better than cure. Spills are part and parcel of working with liquids and sometimes can’t be totally avoided, however there are measures you can take to contain any potential spills to prevent their spread.
Secure storage with bunded sumps for any liquid-filled containers will ensure any spillages will be contained within the sump, as well as protecting containers from the damage from the elements or vandals.
Secondary containment bunded storage systems, such as bunded sump flooring and IBC sump pallets, help to maintain a safe and clean working environment as well as ensuring your compliance with guidelines and regulations including the Control of Pollution (Oil Storage) (England) Regulations 2001.
If a spill has occurred, as part of the response process outlined above, you will need to stop the spread of the spill and block any drains. Products including spill booms and drain mats are essential items for your inventory.
In an era where environmental consciousness is paramount, there are, rightly, severe repercussions for environmental negligence. Robust spill response strategies within industries like food manufacturing are vital. With the potential for catastrophic environmental harm from spilled liquids, stringent protocols are imperative to prevent incidents and mitigate their impact swiftly and effectively.
Businesses must invest in both infrastructure and staff training to ensure sites and the environment are protected. The cost of complacency far outweighs the investment in proactive measures, ensuring not only regulatory compliance but also safeguarding the environment for future generations.
