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Using an environmental risk assessment to inform operational risk information plans

During risk visits, fire and rescue service personnel should ask the operator if they have produced an environmental risk assessment (ERA). If an ERA is available and highlights a risk to the environment from incidents on the site that the fire and rescue service may have to respond tp this information should be included in any Site-Specific Risk Information (SSRI) or Emergency response plans; this should include appropriate pollution prevention information.

If the operator does not have an appropriate ERA, it may be necessary for the fire and rescue service to recommend that the operator completes one. If the operator is unco-operative, the fire and rescue service should consider asking their local environmental agency for support.

To assist with the development of risk management plans, it may be necessary for a fire and rescue service to complete an ERA with a local environmental agency, for example, for an illegal or abandoned site.

Determining suitable prevention and response strategies

If an environmental risk assessment indicates a high or medium risk of pollution, site operators, in liaison with the fire and rescue service and environmental agencies, should consider how to reduce this risk to an acceptable level. The link between fire prevention or suppression and pollution prevention or reduction should be recognised by all fire and rescue service personnel who:

  • Advise operators
  • Advise environmental agency officers
  • Are involved in the regulation of sites that are also permitted by environmental agencies

Liaison between all parties should take place to identify the appropriate prevention and response strategies for all high and medium risk sites. At sites permitted by environmental agencies, agreed arrangements for how this should be done may already exist. In England these are set out in Appendix B,  Annex 2 of the EA/NFCC MoU. Further details are included in Developing incident response plans. For other site types such as BASIS sites an MoU exists setting out the appropriate arrangements.

These arrangements are based on a hierarchy of risk reduction methods, these methods should be considered together to create a holistic solution. For example, when a sprinkler system is installed, it may be possible to reduce the storage volume of any bunds or fire water containment tanks if all parties agree this will reduce the potential harm to the environment.

1. Prevention

Ensuring everything is done to prevent a fire or spill, for example by controlling sources of ignition and having a regular maintenance program is the most important part of the risk reduction strategy, this should include appropriate measures to reduce the likelihood and consequence of any release of pollutants caused by flooding.

2. Detection and suppression

Tackling an incident promptly may reduce the damage caused to the environment. Installing appropriate detection systems, overflow alarms, suppression systems or other fixed installations may help this by identifying an incident quickly allowing swift action to be taken to prevent or mitigate any harm caused. The provision and training of firefighting teams may also be considered. Environment agencies and other regulators may require such systems within an accident or fire prevention plan for sites they permit. See Pollution prevention and legal controls for more information.

Foam sprinklers installed in racking at a warehouse storing highly flammable materials

3. Containment

Although good preventative and early detection measures will reduce the likelihood of an emergency incident, they will not eliminate the risk of pollution from firefighting, spillage or other causes. Environment agencies therefore promote the installation of fire water and spillage containment systems that can store a predicted volume of fire water run-off or spillage until it can be safely removed and disposed. Examples of containment systems include:

  • Bunds
  • Containment lagoons and tanks
  • Drain shut-off valves
  • Oil separators
  • Emergency containment areas

More guidance is available in CIRIA report (C736) Containment systems for the prevention of pollution.

4. Mitigation

This involves planning for the use of firefighting and spill containment strategies, such as:

  • Reducing the amount of fire water generated, for example by:
    • Using sprays or foam branches rather than jets
    • Separation and quenching of burning material in a bunded pool
  • Recycling fire water run-off where this is not hazardous
  • Controlled or accelerated burn, when appropriate

The decision to adopt a strategy or combination of strategies should be made at the planning stage. This should be reviewed during the incident to ensure it will be effective and meet the objectives of the incident commander and the environment agency involved.

During the planning process, the risk assessment should consider:

  • The scale and nature of the environmental hazards presented by the site
  • Whether the products or building involved in fire are likely to be lost to it
  • The risks posed to people and the environment from smoke and run-off by adopting a controlled burn, or other firefighting tactic
  • The local topography and different meteorological conditions likely at the site
  • The type of fire, such as deep seated and smouldering, it is duration and the effectiveness of the tactics employed
  • The sensitivity of the local environment

As part of the planning process, a meeting with the site operator, local FRS and environment agency officer should take place to consider the best environmental option. Hazardous materials advisers will usually be the most suitably qualified fire and rescue service personnel to attend such meetings.

When agreement has been reached, the information should be included within the FRS Emergency response plan for the site. This should fit in with the operator’s incident response plan.