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Eh 70

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Health and Safety

Executive

The control of fire-water run-


off from CIMAH sites to prevent
environmental damage
Guidance Note EH70

This is a free-to-download, web-friendly version of EH70


(First edition, published 1995). This version has been adapted for online use
from HSE’s current printed version.

You can buy the document at www.hsebooks.co.uk and most good


bookshops.

ISBN 978 0 7176 0990 1


Price £4.00

This guidance is provided to help operators of sites subject to the Control of Major
Accidents Hazards Regulations 1984 (CIMAH) ensure that they have adequate
arrangements in place to deal with water used to fight fire on their sites. It may also
be useful in other circumstances where water is used to wash away hazardous
substances that have been released accidentally.

It is also aimed at the operators of major hazard installations, the emergency


services, local authorities and inspectors to provide advice for considering
measures to prevent and control fire-water run-off.

In addition, the guidance will also be useful to operators of non-CIMAH sites using
or storing hazardous chemicals.

HSE Books
Page 1 of 14
Health and Safety
Executive

©Crown copyright 1995

ISBN 978 0 7176 0990 1

You may reuse this information (not including logos) free of charge in any format
or medium, under the terms of the Open Government Licence. To view the licence
visit www.nationalarchives.gov.uk/doc/open-government-licence/, write to the
Information Policy Team, The National Archives, Kew, London TW9 4DU, or email
[email protected].

Some images and illustrations may not be owned by the Crown so cannot be
reproduced without permission of the copyright owner. Enquiries should be sent to
[email protected].

This guidance is issued by the Health and Safety Executive. Following the guidance
is not compulsory and you are free to take other action. But if you do follow the
guidance you will normally be doing enough to comply with the law. Health and
safety inspectors seek to secure compliance with the law and may refer to this
guidance as illustrating good practice.

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Contents
Introduction 4

Fire precautions 5

Emergency planning 6

Control measures 7

Further advice 11

Appendix 1: Legal requiremements 11

Appendix 2: Glossary of terms 12

Appendix 3: Bibliography 12

Further information 14

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1 This guidance is provided to help operators of sites subject to the Control of


Major Accident Hazards Regulations 1984 (CIMAH) ensure they have adequate
arrangements in place to deal with water used to fight fires on their sites. The
advice may also be useful in other circumstances where water is used to wash
away hazardous substances that have been released accidentally. Operators of
non-CIMAH sites using or storing hazardous chemicals will also find it useful. It
does not cover pollution as a result of routine process discharges.

2 This guidance deals with mitigating the effects of accidents but operators must
consider first how to prevent accidents. The key to accident prevention lies in a
good health and safety management system. A well-managed site where policies
have been set and implemented, where there is a systematic approach to risk
assessment and control, where performance is measured against pre-determined
standards and where the whole system is audited will be much less likely to have
an emergency to deal with. Advice on health and safety management can be
found in the HSE guidance booklet Successful health and safety management (see
Appendix 3).

Introduction
3 Water is the most widely used medium for fighting fires. It is cheap, plentiful
and very effective; it not only extinguishes flames but also takes heat from the fire
which helps reduce the risk of radiated heat, structural damage and reignition. It
also has the advantage that, in most circumstances, it is non-hazardous. Large
volumes of water are frequently used in fire fighting and, although some will turn
to steam in the heat, much will fall to the ground and drain away from the site
of the fire. This ‘fire-water run-off’ does not usually present a serious risk to the
environment.

4 If hazardous chemicals are involved, foam might be used to fight a fire rather
than water but there may still be a need for water to cool other property or plant
nearby, to reduce the risk of it becoming involved in the fire.

5 Water or foam used to fight fires at premises where chemicals are used or
stored can become contaminated with the chemicals and become hazardous itself.
(For example fire-water run-off from a fire in Basle, 1986, resulted in major pollution
of the river Rhine, extending many kilometres downstream and lasting many years;
the fire at Allied Colloids, Bradford, in 1992 resulted in severe pollution of the Rivers
Calder and Aire from fire-water, severely affecting aquatic life over 50 km.) In these
circumstances due consideration must be given to preventing it harming either
people or the environment.

Scope of the guidance

6 The purpose of this guidance is to provide advice to the operators of major


hazard installations, the emergency services, local authorities, and inspectors on
measures to consider for the prevention and control of fire-water run-off. This
is only one aspect of emergency planning and the guidance supplements that
contained in other HSE publications and elsewhere (see Appendix 3).

7 Appendix 1 outlines the main legal requirements relevant to this topic. The
guidance assumes that all necessary measures have been taken to prevent major
accidents. In particular it is assumed that operators are complying with existing
HSE guidance on the safe storage of chemicals (see Appendix 3). However, even
when all reasonably practicable measures have been taken, incidents may still

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occur and this guidance is intended to address those risks which remain, to limit
the consequences to people and the environment.

8 This guidance is not intended to specify how fires should be dealt with, or the
extinguishing medium to use. These are matters for discussion between the Fire
Authority and operators during preparation of emergency plans. The final decisions
will rest with the Fire Authority and, of course, the fire officer in charge of dealing
with a fire may vary them at the time, depending on the circumstances.

Fire precautions
9 The primary objective is to prevent the outbreak of fire, rather than have to deal
with its consequences. It is important that proper thought is given to appropriate
fire precautions. Proper risk assessment will reveal not only the routes by which
major environmental damage might occur in the event of fire, but also the areas
where fire precautions are inadequate.

10 Particular attention should be paid to the exclusion of potential ignition


sources. There are too many of these to list but, consider carefully for example
permitting smoking only in designated areas and exercising proper control over
maintenance activities, especially any involving hot-work. Also, consider electrical
and heating services in the storage area containing the environmentally hazardous
chemicals. Are they really necessary? If they are they must be properly installed and
maintained.

11 Consideration should be given as to how a fire can be controlled in its


early stages by either a limitation of the fuel available, segregation of flammable
or incompatible substances, fire compartmentation, its early detection and
extinguishing, or a combination of these. Advice on these matters should be
sought from the relevant enforcing authority. Changes to existing buildings can
have a serious effect, for example holes in walls for cables or pipes can reduce
compartmentation significantly.

12 Consider also the storage of environmentally hazardous chemicals outdoors


in a secure compound. Where they are stored indoors the combustibility of the
materials used in the construction of the building must be taken into account as
should the combustibility of packaging materials, the compatibility of the chemicals
themselves and housekeeping. Fire spread from adjacent stacks should also be
addressed.

13 The earlier a fire can be tackled, the greater the chance of successfully
extinguishing it and minimising the quantity of contaminated water. When
considering automatic fire detection (and possibly fire-fighting) equipment, seek
advice from the supplier(s), the relevant enforcing authorities and the insurers as to
its suitability. As well as its effectiveness, consider the potential of any effluent (ie
product carry-over and fire-fighting medium, whether foam or water) to damage the
environment. The water from sprinkler or deluge systems must be treated in the
same way as any water applied by fire-fighters.

14 A well-designed active fire suppression system can reduce the amount of water
which needs to be applied to control/extinguish a fire and this in turn can reduce
the scale and cost of other facilities.

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Emergency planning
15 Emergency planning is a matter for teamwork and it is essential to work closely
with the appropriate authorities and other bodies with an interest (some of these
are identified in paragraph 42).

Environmental hazard identification

16 The type and extent of the measures implemented at a major hazard installation
to protect the water environment from the effects of an accident will depend on
the likelihood of an accident occurring and the likely consequences. The likelihood
of an accident occurring depends on the nature and quantities of the hazardous
substances on site, the activities carried out on site and existing accident
prevention measures. The environmental consequences of an accident will depend
not only on the severity of the accident but also on the nature of the environment in
terms of the flora and fauna which it supports and its ability to recover if damaged.

17 It is essential to assess the risk that major hazard installations pose to the
environment on a site by site basis. Installations where similar activities are
carried out may pose different risks, depending on the environment around them.
Accidents may also cause environmental damage a significant distance away from
the installation; all possible routes of transport of contaminants should be identified,
for example drains and ditches.

18 The health and safety of people is always paramount and it is important to


consider indirect risks to people. Environmental contamination may result in long-
term exposure to hazardous substances, which may enter the food chain via the
air, water or soil. Decisions may have to balance the risks due to airborne pollution
if a fire is allowed to burn and risks to the environment if water is used to control it.

19 It is important to assess the routes by which contaminants can be carried


significant distances away from the site, where they may cause serious
environmental contamination, for example drainage systems and rivers and it is
important that suitable ‘water maps’ are prepared showing the location of all drains,
water supplies and water courses. Smoke plumes may carry significant quantities
of pollutants away from the site; knowledge of prevailing weather conditions,
including mean wind speeds and directions is required to assess this effect.

20 Even if it can be demonstrated that the likelihood of a major accident is


very low or that the environmental consequences of a major accident would be
negligible, normal precautions for the safe use, storage and transport of dangerous
substances still apply. If, however, one or more dispersion mechanisms are likely
to cause serious environmental damage then appropriate measures should be
adopted to control the risk.

21 The National Rivers Authority (NRA) or, in Scotland, the River Purification
Boards (RPB) should be consulted about the assessment since they hold factual
information about neighbouring water resources, ecotoxicology and water quality
criteria and should be able to provide information about the location, type, nature,
importance and sensitivity of all water resources at risk. These authorities may be
able to offer practical advice on the range of strategies and equipment available to
protect the environment and their suitability in particular circumstances.

22 For sites subject to the top-tier requirements of CIMAH the nature of risks
posed to the environment and details of that environment should be described
in the safety report. Guidance about the information required in a safety report is

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contained in the HSE publication A guide to the Control of Industrial Major Accident
Hazards Regulation 1984 (see Appendix 3). Consideration of the pollution risks to
water resources from contaminated fire-water should include:

n the sources of release of dangerous substances in the event of a fire and the
potential consequences;
n the properties of the substances present on site, for example toxicity,
flammability etc, and the potential for adverse reactions between them;
n the environmental behaviour of the substances such as solubility, volatility,
persistence, potential to bioaccumulate in the food chain and environmental
toxicity. Consider also products formed as a result of complete or incomplete
combustion of substances in fire or degradation in water. These may be more
persistent and harmful than the parent compounds;
n information about the location, inventories and process conditions, with
reference to facilities such as bunding, entry points to storm and foul water
drains, protective equipment associated with them, and the routes of water
flows to containment and treatment plants;
n information about the type and vulnerability of relevant water sources (obtained
from the NRA/RPB) which will include:

(i) sites within river catchments above public water supply intakes
and/or reservoirs where the discharge following an incident is likely to lead
to levels above agreed acceptable maxima for drinking water abstraction
(time of travel to intake, the importance of the intake and other similar factors
may need to be considered);
(ii) sites in close proximity to aquifers or close to water courses that flow to,
and can contaminate aquifers, particularly those used for public water supplies;
(iii) sites which pose a threat to waters of particular ecological value such as
sites of special scientific interest (SSSls);
(iv) sites where surface water, contaminated with hazardous substances,
discharges into a foul sewerage system. This could either damage the filter
beds of any receiving treatment works or, where receiving treatment works
do not have sufficient storage capacity to contain the fire-water run-off, result
in its diversion directly into the water environment, causing significant
environmental harm.

23 The NRA/RPB is able to offer advice and assistance to HSE inspectors and
manufacturers on assessing the potential risks of the site to the water environment.

The fire hazard

24 While this guidance is principally concerned with preventing serious accidental


damage to the water environment, it is also important to consider other routes by
which such major environmental damage might occur, for example by the ejection
of chemical containers as missiles during the fire, and smoke borne contaminants,
including the principal combustion products of the chemicals involved.

Control measures
25 If the assessment shows that the fire-water run-off is likely to cause serious
damage to the environment, means to minimise the risk should be provided.
This should comprise arrangements for containing the run-off, although in certain
circumstances alternative approaches to remove or minimise the risk might be
more appropriate. Some of these are discussed later but decisions should be taken

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only after full discussion with all the appropriate authorities; there is rarely, if ever, a
single correct solution.

Containment systems

26 There is a variety of containment measures which may be employed, ranging


from permanent structures to temporary systems. The following paragraphs
are intended to assist occupiers select the most appropriate measures for their
particular sites.

27 To size any containment system, knowledge of the anticipated quantity of run-


off from a fire is required and although this cannot be calculated with any precision
it should still be estimated. The size of the bund needs to be considered on a site-
specific basis having regard to the size of fire that is possible. Advice on this and
the fire-fighting arrangements in general should be obtained from the Fire Authority.
In discussing these matters, take account of the flammability of the building
structure and contents as well as any fire detection/suppression system; to tackle a
small fire may require only a few tens of cubic metres of water whereas a large fire
may require in excess of several thousand cubic metres of water.

28 It may be concluded that the provision of a permanent containment system


is the appropriate solution to deal with the run-off expected from a small fire. This
would also provide sufficient time to put in place larger, temporary, containment
measures in the event of a major fire. Provision for such temporary measures
would, of course, have to be previously agreed and arranged.

29 When deciding on suitable control measures to prevent or limit environmental


damage it is important to consider not only their effectiveness and cost but also
their compatibility with operator health and safety, ease and cost of maintenance,
how their installation will affect the overall safe running of the plant and how they
will be emptied if they ever need to be used. It is important that the contents of
a containment facility can be disposed of safely after an accident, without posing
further risks to people or the environment. Where it is proposed to use pumps to
transfer run-off water, consider back-up power supplies in case normal power is
interrupted as a result of an accident.

30 A potential benefit of a permanent containment system is that it is possible


the water may be reusable to tackle the fire, though this requires prior discussion
with the Fire Authority to determine any restrictions and whether there is a need
for any special equipment. It may also be necessary to arrange for this water to be
monitored for its suitability. This should be detailed in the on-site emergency plan.

Bunds

31 It is a sensible precaution to store environmentally hazardous chemicals in


bunded areas. Bund sizes need to be considered on an individual basis, taking
into account industry guidance such as British Wood Preservers and Damp-
proofers Association (BWPDA) guidance on timber treatment. The floors and walls
of bunded areas should be substantially impervious and provide for the localised
containment of spills irrespective of whether there is a fire or not, for example failure
of a container.

32 Ideally the capacity of the bund would be sufficient to take the entire inventory
of the chemicals stored within it, plus the foam or water from initial fire-fighting or
fire protection activities, but this may not always be achievable. An additional 10%
of the nominal chemical inventory may be adequate to provide for coverage of the

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chemical with foam or water in a drum storage area, for example, but much more
than this could be required in other circumstances and a bund sized to take 110%
of the entire chemical inventory would not provide sufficient capacity to prevent
fire-water run-off. However, it may provide sufficient time for emergency, temporary
containment measures to be brought into operation.

33 There are a number of situations where such sizing of the bund to take the
entire inventory is not normal practice, nor perhaps, reasonably achievable. For
example bunds enclosing a number of storage tanks will usually only have a
capacity equivalent to 110% of the largest tank present. Similarly in the case of very
large storage tanks the bund capacity may be less than that of the tank. In such
cases particular consideration is required for dealing with fire-water run-off and
would be expected to include the provision of permanent containment measures to
prevent pollution. In these or other unusual or difficult circumstances, further advice
may be sought from the relevant enforcing authority.

34 Particular attention should be paid to the ability of the bund walls to withstand
the hydrostatic pressure from the contained liquids and resist attack by the
chemicals as well as their structural integrity under fire conditions. Shallow bunds
may be provided with sloping kerbs to allow access by fork lift trucks.

35 It is essential that bunds are properly maintained. This includes keeping drain
valves closed, except for regular draining of rainwater, as well as checks on the
physical structure. Consider the possibility of the presence of dangerous levels of
toxic or flammable gases in confined spaces between high bund walls and tanks
before anyone enters the bund.

Lagoons and tanks

36 Permanent provision for the containment of large quantities of fire-water run-off,


typically several thousand cubic metres and above, may be achieved by lagoons
and tanks. These can be remote from, and may serve, several storage areas,
receiving the run-off via a gravity flow or pumped” drainage system.

n Lagoons should be provided with an impermeable surface membrane to


prevent pollutants soaking into the ground. They cover a relatively large area,
enhancing evaporation and the settling out of suspended solids.
n Tanks have the benefit of providing a relatively large storage volume in a small
area, though they are expensive compared to lagoons, particularly for the larger
volumes. Where available, an economical option might be to make use of a
redundant or spare tank.

37 Where there are a number of sites in close proximity it may be possible to


install shared facilities and reduce the cost.

38 In the event of an incident necessitating the use of a lagoon or tank it is


important that the emergency procedures ensure that any outlets from these, such
as surface water, sewer or foul/trade effluent, are isolated.

Emergency temporary containment

39 Emergency temporary containment of fire-water run-off may be provided by a


sacrificial area, site containment or portable flexi-tank. As discussed in paragraphs
31-35 the provision of bunds should always be a prime consideration, but if
reliance is placed on any of the following emergency systems, bunds would be
considered essential to provide sufficient time for these secondary containment
measures to be made ready.

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n Sacrificial areas might be natural depressions, or ones specially created


to fulfil this function, for example a car park. They may be designed to have
inherent containment provision, or be readily adaptable in an emergency, for
example by the use of booms and similar devices. An aspect to consider is the
permeability of the ground and how to minimise soaking of the pollutant into it.
Discharge to the area may be by gravity or pump1.
n Site containment may be achieved by either a low kerb around the entire
site, or just the sensitive area. It essentially serves as a secondary containment
system to the bunding, should this overflow. The possible effects of this
containment on process operations and emergency services will need to be
assessed.
n Portable flexi-tanks range in size from about 10m3 up to around 250m3.
Important matters to consider include the compatibility of the tank material
with the chemicals it will contain, the time it takes to bring it into use and the
location of the tank and pumping arrangements. All these factors should be
detailed in the on-site emergency plan. Regular examination and maintenance
of such tanks is essential. Consideration might also be given to whether the
collected water can be re-used to tackle the fire.

40 With respect to sacrificial areas and site containment systems, particular


consideration needs to be given to how surface water, sewers and foul/trade
effluent systems will be sealed off, to prevent run-off water getting off site.

Other containment systems

41 Other containment systems which may be used include those below. All
have limited capacity, and their use needs to be discussed with the Fire Authority
beforehand to ensure they would have sufficient capacity in the event of fire.

n Catch-pits and interceptors provide for the rudimentary separation of solids


and also aqueous from non-aqueous solutions. They may also be used to
provide transitional containment for water-miscible products. They may be used
singly or as a series.
n Separators provide a specified design performance for removal of named non-
miscible hydrocarbons from water, allowing the subsequent discharge of the
water.
n Booms can be used to provide total containment, either by themselves, or to
fill gaps in other containment areas. They may be used as flotation devices to
contain lighter non-water-miscible hydrocarbons.
n Drain seals can be used to cover or block a drain, allowing the site sewer
system, or part of it, to be sealed and thus employed as an emergency
containment system.
n Sand bags while effective, have limited use. They are often not available and
take time to deploy.

Alternatives to containment

42 There may be cases, depending on the location of the site, where it may be
appropriate to allow a fire to burn under control. This option may minimise the
risk of a major environmental accident resulting in contamination of the water
environment but may cause other risks. There are a number of highly sensitive
issues to consider and forward planning is essential. Decisions on controlled
burning should be taken in consultation with relevant parties which will include the
manufacturer and their insurers, Fire Authority 2, Environmental Health Authority,
HSE, NRA/RPB, HMIP, Ministry of Agriculture, Fisheries and Food (MAFF) and
others. Factors to consider will include the effects on local populations, the risk

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of fire spreading to nearby property and the impact of deposition from the smoke
plume. Where controlled burn is considered to be appropriate the criteria for
the decision should be described in the CIMAH emergency plans. It must be
remembered that some application of water is likely to be required to ensure that
the fire burns in a controlled manner and adequate provision should be made to
contain the estimated run-off.

43 In certain circumstances, especially in areas where the risk of serious damage


to the water environment is identified, the re-location of any environmentally
hazardous chemicals to an alternative site may be worthy of serious consideration.
However, the advantages from this have to be balanced against the risks involved
in the transport operation.

Further advice
44 Further advice may be obtained from the HSE, Department of the Environment
(DOE), NRA or Fire Authority.

45 Advice about any operational aspect or the scope of the CIMAH Regulations
may be obtained from the local HSE Area Office.

1 Note comments in paragraph 29 re back-up power supplies for pumps


2 See note in Appendix 1 on Fire Services Act 1947

Appendix 1: legal requirements


1 Discussed below are the main legal requirements which apply to sites where
serious contamination of fire-water run-off is a possibility. There is, however, much
other legislation covering health and safety.

The Control of Industrial Major Accident Hazards (CIMAH) Regulations


1984, as amended (1988, 1990 and 1994).

2 The aim of CIMAH is to prevent major accidents affecting both people and the
environment and to limit the effects of any which do occur. For the purposes of
this guidance a major accident is a major emission, fire or explosion resulting from
uncontrolled developments leading to serious danger to people or the environment.

3 CIMAH applies two levels or tiers of controls, depending on the nature and
quantity of dangerous substances present on site. At the lower tier, manufacturers
have the general duties to identify the major accident hazards, take adequate steps
to prevent major accidents, and to limit the consequences of any which do occur.
These duties include the provision on site of appropriate information, training and
equipment. Major accidents which do occur must be reported to the HSE, the
enforcing authority for the CIMAH Regulations.

4 At the so called ‘top tier’, where hazards are greater, additional duties apply.
Manufacturers must:

n prepare a written safety report which includes an assessment of the risks and
the precautions to be taken;
n prepare an on site emergency plan;

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n provide information to the Local Authority sufficient to enable an off site


emergency plan to be prepared;
n inform the public who may be affected by a major accident about how they will
be warned of major accidents and advised what they should do.

The emphasis throughout is on the need to consider risks in advance and to take
appropriate preventive and mitigatory action.

Other legislation

5 In England and Wales, the National Rivers Authority (NRA) is responsible for the
protection of the water environment from pollution under the Water Resources Act
1991 and the Water Industries Act 1991 (in the case of trade effluent consents).
In Scotland, the River Purification Boards (RPB) are responsible for the water
environment, enforcing the Control of Pollution Act 1974. Some major hazard sites
may also be subject to Integrated Pollution Control (IPC) which is enforced under
the Environmental Protection Act 1990 by Her Majesty’s Inspectorate of Pollution
(HMIP) in England and Wales, and Her Majesty’s Industrial Pollution Inspectorate
(HMIPI) in Scotland.

6 The Fire Authority which is set up under the Fire Services Act 1947 has
responsibility for tackling fires within its geographical area. The Fire Authority has
a duty under the Act to protect life and property, so prior discussion is essential to
avoid the potential for conflict between this duty and protection of the environment.

Appendix 2: Glossary of terms


Most terms used in this guidance are either self-explanatory or are explained in the
text but the following may be useful.

hazard
anything that can cause harm (eg chemicals, electricity, working with ladders etc)

risk
the chance, great or small, that harm will be caused by the hazard

bund
a low-walled area surrounding a tank(s) or other vessel(s) to retain spillage

boom
an inflatable barrier to contain spillage or divert its flow

Appendix 3: Bibliography
The following publications will provide additional information on some of the matters
raised in this document:

The Control of Industrial Major Accident Hazards Regulations 1984 (CIMAH): further
guidance on emergency plans HS(G)25 1985 HSE Books ISBN 0 11 883831 8

The fire at Allied Colloids Limited: a report of HSE’s investigation into the fire at
Allied Colloids Ltd, Low Moor, Bradford on 21 July 1992 HSE Books
ISBN 07176 0707 0

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A guide to the Control of Industrial Major Accident Hazards Regulations 1984


HS(R)21 (rev) 1990 HSE Books ISBN 0 11 885579 X

Her Majesty’s Chief Inspector of Fire Services guidance letter to brigades (DCOL
5/1987) Fires Involving Pesticides Home Office (available from the Home Office, Fire
Safety Division, Horseferry House, Dean Ryle Street, London SW1P 2AW,
Tel: 01712178730, Fax: 0171 217 8722)

Interpretation of major accident to the environment for the purposes of the CIMAH
Regulations (usually referred to as The Green Book) 1991 DoE guidance note

Memorandum of understanding between the CACFOA and the National Rivers


Authority 1993 National Rivers Authority, Bristol (available from Colin Harriman,
Operations Directorate, NRA, Rivers House, Waterside Drive, Aztec West,
Almondsbury, Bristol BS12 4UD, Tel: 01454624400)

Pollution prevention measures for the control of spillages and fire-fighting run-
off PPG18 1994 National Rivers Authority, Bristol (available from Colin Harrirnan,
Operations Directorate, NRA, Rivers House, Waterside Drive, Aztec West,
Almondsbury, Bristol BS12 4UD, Tel: 01454 624400)

Storage and handling of ammonium nitrate CS 18 1986 HSE Books


ISBN 0 11 883937 3

The storage of flammable liquids in containers HS(G) 51 1990 HSE Books


ISBN 07176 0481 0

The storage of flammable liquids in fixed tanks (exceeding 10000 m3 total capacity)
HS(G) 52 1991 HSE Books ISBN 0 11 885538 7

The storage of flammable liquids in fixed tanks (up to 10000 m3 total capacity)
HS(G) 50 1990 HSE Books ISBN 0 11 885532 8

The storage and handling of organic peroxides CS21 1991 HSE Books
ISBN 0 11 8856022

Storage of packaged dangerous substances HS(G) 71 1992 HSE Books


ISBN 0 11 885989 7

Successful health and safety management HS(G)65 1991 HSE Books


ISBN 0 7176 0425 X

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Further information
For information about health and safety, or to report inconsistencies or inaccuracies
in this guidance, visit www.hse.gov.uk/. You can view HSE guidance online and
order priced publications from the website. HSE priced publications are also
available from bookshops.

Published by HSE 04/11 Page 14 of 14

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Unmanaged fire-water run-off at CIMAH sites can lead to significant environmental impacts, including contamination of nearby water bodies, disruption of aquatic ecosystems, and degradation of water quality used for public consumption. It can affect aquifers, river catchments, and sites of special scientific interest, posing long-term ecological risks. Effective management strategies, compliance with regulations, and proper containment measures are crucial to mitigate these risks .

Emergency plans at hazardous sites should contain protocols for identifying potential water contamination risks, deploying containment systems, and coordinating with emergency services. Plans must include specific actions for different scenarios, establish communication lines with relevant authorities, and provide training for staff on containment operations. Regular reviews and updates, informed by risk assessments, ensure the plans remain relevant and effective in addressing new or evolving threats .

Key considerations for managing fire-water run-off include assessing the potential environmental impact, implementing containment systems, and ensuring compatibility with safety equipment. It is crucial to accurately estimate the volume of run-off and choose appropriate containment measures, such as permanent or temporary structures. The effectiveness, cost, operator safety, and ease of maintenance of these measures must be considered. Backup power supplies are recommended to ensure continuity during power interruptions. The ultimate goal is to prevent environmental damage while maintaining worker safety .

Sites near important water supplies should implement bunded storage for hazardous chemicals to prevent leakage. Bunds should be designed to take into account potential spillage and fire-water run-off, with the capacity to contain the entire chemical inventory plus additional for fire-fighting water if necessary. Additional measures involve understanding the proximity to aquifers and implementing containment strategies that consider the site's specific risks and environmental sensitivity .

Containment strategies for fire-water run-off in large industrial sites include the use of bunds, separators, booms, and drain seals. Bunds are critical for enclosing chemicals, while separators remove non-miscible hydrocarbons from water. Booms can serve as barriers or flotation devices for containment, and drain seals can block drains to utilize the sewer system as an emergency containment option. A combination of permanent and temporary systems is advised, adjusted to the estimated volume of run-off .

Aquifers and water courses are critical in risk assessments for sites storing hazardous chemicals, as they represent potential pathways for contaminants to reach drinking water supplies. The proximity to these water resources influences the severity of potential contamination incidents, necessitating rigorous containment and management strategies. Risk assessments must account for the vulnerability of these water sources and include measures to prevent run-off from entering water courses or seeping into aquifers, thereby protecting water quality .

Bunds effectively manage fire-water run-off by confining spills and providing additional run-off capacity. Key considerations include ensuring that bunds are sufficiently impervious and can contain the chemical inventory plus any water used in fire-fighting efforts. Site-specific assessments determine the bund size based on industry standards and potential risk scenarios. Proper maintenance, regular inspections, and emergency planning are necessary to ensure their functionality and integrity .

Controlled burning might be considered to minimize the environmental impact of fire-water run-off contaminated with hazardous substances. Decisions to use controlled burning require evaluating factors such as the effects on local populations, risk of fire spreading, and impact of smoke residues. Coordination with relevant authorities, including environmental and fire services, is essential, as well as provisions for applying water to manage the burn safely. The decision-making process should be outlined in emergency plans .

Pumps can efficiently transfer contaminated fire-water run-off to containment facilities, preventing environmental damage. Their advantages include control over flow rates and the ability to manage large volumes of water. Challenges include the need for back-up power supplies to maintain operation during power failures and ensuring that the transferred water is safely disposed of or treated without further risks. Careful planning and infrastructure considerations are necessary to mitigate these challenges .

Involving multiple authorities, such as the Fire Authority, Environmental Health Authority, and HSE, ensures comprehensive risk evaluation and response planning. These authorities provide expertise on environmental risks, fire control methods, and regulatory compliance, enabling effective prevention of water contamination and mitigation of fire hazards. Collaborative planning helps balance environmental protection with emergency response demands and operator safety .

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