What is water pollution prevention? (Transcription)
Hello. My name’s David Cole and I’m Technical Director for Sandfield Penstock Solutions. Today I’m going to talk to you about water pollution prevention.
What is water pollution prevention?
So, water pollution prevention is what it says. It’s preventing the pollution of water. Really, when we look at water what we’re saying is we’re looking at preventing water getting into our streams, into the sea, into the brooks and local area, really, lakes and ponds.
How has water pollution prevention evolved?
I think we all have seen in the local media, with David Attenborough and the Blue Planet, that people are now actively looking at, hang on a minute, there’s a lot of pollution in our oceans, in our seas that we didn’t really think was there. There’s a lot of plastic, there’s a lot of mess, there’s a lot of chemicals. And I think what’s happened is that, especially in the last couple of years that the public have started to become interested in, actually, what’s in our food chain. Everything really around it now is the fact that everything that we do has a consequence. So, when we look at water pollution in the past it was looking at minor spills and a few chemicals, we saw some dead fish, and somebody’d react to it. What we’re looking at now is, it’s happening all the time. So, how do businesses actually manage, and make sure that the waste that they produce that goes down into the drainage network isn’t polluted?
Who is responsible for water pollution prevention?
So, when we look at water pollution prevention, the Environment Agency is the overall regulator that basically controls it. If you cause a pollution event, in other words, you kill some fish, or you impact the environment there’s a good chance you’ll feel the force of the Environment Agency. They could drive a prosecution which could cause you to be fined. You could go to prison if you are found to be culpable of actually causing a pollution event by neglect or as a deliberate act. So, that’s what you’ve got to be mindful of, that actually, water pollution is a crime. There isn’t really any excuse and every single one of us is actually involved with that. So, from major multinational business, they don’t want to cause a pollution incident and equally their employees are responsible just like they are. But ultimately, all of us as individuals, we all have a responsibility that if we carry out an act that actually causes the pollution of water or killed some fish, we’ve actually committed a criminal offence.
What are the risks to businesses that fail to prevent water pollution?
So, the big issue here is, if you have a water pollution incident, you’ve caused an incident, you’ve caused an event that could lead to a prosecution. So, what we have to look at is, how did it happen? Could it have been prevented and is anybody negligent? So, when we have an incident as a business, a business needs to look at what are their risks? So, if they’ve got materials on site that are potentially harmful to the environment, it’s their responsibility to look at how they move, handle and manage that material to make sure that they don’t have a pollution incident and that’s easier said than done because moving materials around a factory, you can’t always be overly protected but if a pollution incident does take place and a chemical does get spilled, it’s really important that that business or that individual has a system in place that stops it actually entering the drains, entering the water course and causing a fish kill or an environmental impact event.
What are the penalties if a business is found guilty of causing water pollution?
So, this is an interesting area because things have changed since previously, twenty years ago you’d get a minor, small little fine. It was a bit like a wrap on the knuckles, no matter how big your company was. But in 2014, the government produced the Environmental Sentencing Guidelines which is a guidance for courts to actually create some punishment when a pollution incident happens. This actually focuses then on the size of the turnover of the business. Really what they’re simply saying is if you’re a big massive multi-national company and you have a pollution event and you have actually got the money to have prevented that then you should be investing in making sure that your business operates best practice. There is no real excuse for a big multinational company to have a pollution event, be it from a fire or accidental spillage, it’s not acceptable. So, those fines now in recent years have increased. In 2016, Tesco’s for instance were fined eight million pounds for a single oil spill. Thames Water were fined twenty million pounds which was the largest fine to date for a pollution incident. So, these fines now have an impact and have changed massively.
So, when you look at it there are other penalties as a director or a person for a business if you could be seen as you actually deliberately caused a pollution act or it was negligent, you could go to prison and you can individually lose money. You can actually be individually fined, there is now a civil sanction which allows the regulator to actually get money back from individuals and you don’t really have much chance to appeal against those types of cases.
So, when we look at a pollution incident, we just talked about the criminal side of it and how it can impact on a business if they go to court. But, ultimately, it might not go to court, but you will still have to pay for that clear up. And that clear up could be massive because that clear up, if it’s caused a major impact on the environment, you’re going to have to put that back to as it was before the incident. You’re going to have to protect your brand from the impact you’ve caused. So, there’s a lot of work to do and it’s a very expensive area to get involved in because nobody really knows what the impact is until after the event. So, surely, it’s better to not have the event in the first place.
What is businesses attitude to water pollution prevention?
So, over twenty years I’ve been talking to businesses all over the UK and some around the world about this whole subject of water pollution prevention. It’s never really been top on anybody’s agenda until an incident takes place and I think that’s probably one of the, areas that I always found disappointing. I’ve got a number of clients over the years they’ve had no interest in what I do to start out with. Then they’ve actually had a pollution incident, then they’ve had the regulator on site, then they’ve gone to court, then they’ve had the court costs, then they’ve had all the clean-up operations. And some of those sites that I’ve worked with, it would have been so simple just to have taken the attitude, pollution is a risk, it can happen. It’s just like getting into your car, we’ll take out car insurance because we know there’s a potential that we can have an accident and we could lose our car, we might need to replace the car, we could be seriously injured. So, we need insurance to protect ourselves and when it comes to the environment side of it, a lot of businesses, even quite large, take the attitude, it shouldn’t happen and the problem is, it does happen.
Is water pollution prevention actually achievable?
So, a number of sites we go to, always looking at water pollution as a complicated and difficult subject, so I think it gets pushed to one side because they look at it and they go it could be a tank over there, it could be this over here. We take a different approach. It actually is far more achievable than most businesses think it really is. All you’ve got to do is, first of all, accept that a pollution incident can happen. I think then what we like to do as a business, we like to take the guidance, the best practice guide which is Ciria 736 and we use that part of it, because there are some really good parts to it that actually allow you to look at volumes, give you a benchmark to work to. We take that benchmark and we say, right, that is our worst-case scenario. Let’s work the worst-case scenario and see what it looks like. Once you understand a worse-case scenario, everything else behind that is easy and sometimes that worst case scenario is far simpler once you actually understand it, to actually manage than you probably thought. And that’s our process and that can be done. There’s not many sites that I can think of where I would say it’s impossible or not affordable.
How affordable is water pollution prevention?
So, when you’re looking at spill modelling, which is what I’m still looking at with the assessments to look at water pollution containment, it’s something that can be done just by walking around the site carrying out some surveys and actually carrying out some topography to look at the site to create an animation of your risk. So, it can be done without anyone knowing you’re really doing it. Once you’ve achieved that then you’ve got an understanding of what you need to do. And the costs can be as low as probably a few thousand pounds. Up to hundreds of thousands of pounds depending on how far you want to go with it. But you can’t really make a decision until you actually have an understanding of what your risk is in the first place.
What is your recommendation for anyone looking to address these issues?
So, our idea would be that you follow our six-step process which is, one, to understand the regulation. Then, you need to understand how regulation fits in with your particular business. You then need to look at your risk and be honest about what your risk is, so you understand how much your potential is. Once you’ve done that, you need to do a design, understand that design. Then, implement the design, put it into place. Then, after that what you need to do is monitor, maintain and document the system that you’ve put in and make sure it continues to work and as guidance changes, move your system with the guidance so that you’re always improving so you keep on top of the system. I think water pollution prevention is absolutely essential. I can’t believe that there are so many companies that have pollution events every single year and we read about them in the press and we look at it with the David Attenborough type of approach which is really interesting. It’s there is plastic in our water but there’s also lots of chemicals and those chemicals are coming from the processes that we produce. And it’s about time that we’ve really took this as a subject and really got hold of it because it’s not that complicated.
I think water pollution prevention is something that’s achievable, it’s definitely affordable and any business, no matter how small, how large, should be looking at it right now. If you want any more information or want to get in touch, why don’t you go to our website which is www.penstocksolutions.co.uk.
David Cole MSEE
David is a pioneer of the spill containment and water pollution prevention industry with 30 years experience. He was instrumental in the development of CIRIA736 with The Environment Agency and is passionate about preventing water pollution.