POLLUTION - 04.11.2021

Acting responsibly after a pollution event

Best of a bad job

When pollution and other events occur it’s very rare that there’s a deliberate act behind it. However, despite the lack of intent, the public may be quick to lay the blame at your door. The way to demonstrate that you are a responsible business is to act promptly to mitigate any damage, investigate the incident, and announce improvements which will be made. To prepare for the situation use our Environmental Incident Investigation Policy and Procedure (see The next step ). It will guide managers in the steps to be taken.

What’s covered?

Our document begins with a “General statement” which requires that all environmental incidents are to be recorded and that witness statements are to be taken where applicable. This establishes the importance of the subject by showing that even minor pollution events are to be reported. It goes on to remind all staff that they must co-operate with managers and follow the procedures. Section two of our policy outlines a little of the legal background and in particular gives the incident reporting numbers across the UK. For example, England, Scotland and Northern Ireland share the pollution hotline on 0800 80 70 60.

What’s an “incident”?

Section three outlines the different types of event that could be regarded as an incident. These include both accidental and malicious releases of a harmful substance to air, land, drainage systems or watercourses. We have outlined here two further terms: (1)“Major incident” ; and (2)“Minor incident” . In our definition the difference between the two is whether the regulatory authority needs to be involved.

Tip. If unsure whether the Environment Agency etc. should participate in the aftermath of a spillage, phone the pollution hotline.

Why investigate?

In the fourth section of the policy we’ve outlined some of the reasons for investigating incidents. Our intention is to ensure that those reading the policy understand their objectives at the time of an investigation. The main reasons to investigate are to identify what went wrong and why, and the improvements which are needed to prevent a recurrence. However, there are other equally important reasons. For example, an objective close to senior managers’ hearts will be “to prepare insurers, directors and other interested parties to the potential consequences and liabilities” .

The procedure

Our document ends by looking at the procedures to be followed including: (1) beginning the investigation as soon as possible; (2) completing a report and witness statements; (3) identifying what is required for remediation of damage and to prevent a recurrence; and (4) taking and testing samples.

Tip. Allocate the task of investigating incidents to different levels of management, depending on the severity of the event. Use relevant job titles in section five to adapt the document to your own organisation.

For an environmental incident investigation policy and procedure, visit https://www.tips-and-advice.co.uk , Download Zone, year 20, issue 05.