TOG Environmental Protection

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1 Not Protectively Marked TOG Environmental Protection Part One Initial Attendance Considerations Aide Memoire and Flowchart Part Two Detailed Considerations to assist Incident Command Significant Hazards and Control Measures Part Three Incident Review Incident Review Considerations Part Four Document References Relevant References Additional Information Technical References Document Control Document Overview This Tactical Operational Guidance (TOG) provides incident Commanders with guidance on environmental protection at operational incidents. This TOG should be used in conjunction with, and supported by, other TOG, AHIS, Operational Articles and the Environmental Handbook. Ref No: Lead FRS: CP Date of Issue: Version No: 0.1 Review date: Protective Marking: Not Protectively Marked

2 Part One Initial Attendance Aide Memoire 1 Initial Considerations En Route Consult any site specific risk information (SSRI), site specific risk plan (SSRP) or Environmental risk/pollution plans Weather/ meteorological conditions Tidal influences Other influences, eg drought/low flows Commence environmental risk assessment process Identify ο vulnerable Aquifers/Ground water protection zones ο surface waters ο Areas of Natural conservation eg SSSI/Fisheries etc. ο Potential pollution pathways, eg surface water sewers Initial crew briefing Safe access / egress / RVP / marshalling areas Remain on identified tracks and paths for protected areas On Arrival Establish if there is an immediate risk to life or health from fire, injury, flood, hazardous chemicals etc. Identify pollutants and potential impacts, (estimated quantity and source) Liaise with Owner Occupier Identify the relevant TOG and AHIS Locate` site pollution/accident plan Carry out an Environment Risk Assessment Identify source, pathway receptor Identify appropriate measures to reduce environmental impact. i.e. modifying the operational strategy Implement Environmental protection measures. Request the attendance of HMEPA/EA Consider the need of additional protection equipment/epu Inform the relevant authority i.e. Environment Agency, Natural England, Local Authority etc. Control, reduce or eliminate environmental damage/pollution, using pollution control hierarchy. Reduce possibility of physical damage Monitor and record environmental protection activities 2 Incident Information Identify the impact of fire service operations on the environment, i.e. fire fighting media being used, pumping/discharge from or too open water source. Type and quantity of pollutant(s) involved Location of incident in relation to an environmental receptor Pathway to the receptor The point at which the pollutant can be contained, i.e. Pollution Control Hierarchy. Biosecurity, i.e. transfer of alien species/pathogens Possibility of short and long term environmental damage. Protective Review None NOT PROTECTIVELY MARKED Page 2 of 20

3 3 Resource Information Environmentally safe access routes Ground water maps Environment Agency information Specialist advice Risk Information Plans Site Accident Plans Areas of natural conservation information (SSSI etc.) Drainage Plans Availability of the an Air Quality monitoring team Environment Handbook 4 Risk Information to inform tactical planning Key Hazards Pollution of water Firewater run-off Fire Fighting with Foam Spillage of pollutants, damage to storage vessels/pipelines Air pollution: Smoke Plumes Toxic Gas Environmental Damage to land or Other Run-off and or deposition of Polluting Materials Physical Damage Key Control Measures Common Control Measures Environmental Risk assessment Operational/ Environmental Risk information (i.e. SSRI) Liaison with conservation bodies/environment Agency Use of environmental protection equipment/control devices. Pollution of water: Controlled Burn Containment of pollutants Recycling of fire water Reduction of Fire fighting media being applied Substitution of media Discharge to foul sewer (with approval of sewerage undertaker) Dilution/Pumping/Aeration Air Pollution: Controlled Burn Extinguish Removal or separation Air Quality Cell or appropriate function Environmental damage to land or Other: Access to specialist advice Containment of pollution Dilution Absorption Transportation Treatment Disposal Decontamination Defined paths tracks and paths in protected areas Diversion Protective Review None NOT PROTECTIVELY MARKED Page 3 of 20

4 5 Incident plan Common prompts What is the environmental impact of the tactical plan. Can the tactical plan be modified to reflect the environmental risk Disposal of waste including fire water, spilt chemicals used pollution equipment and water used for decontamination Incident specific prompts Legal Defence All three of the following actions must be in place for a defence to exist: Is there a risk to life or health Has the relevant Environment Agency been informed/requested Have environmental protection measures been taken and communicated to the relevant Environment Agency. Waste management responsibilities for the FRS, Environment Agencies, Highways agencies, local authorities and owner/occupiers. Liaison with sewage undertakers Consider alternative tactics like a controlled burn where, the risk of environmental damage is significantly increased when firefighting media is applied or cannot be contained. Protective Review None NOT PROTECTIVELY MARKED Page 4 of 20

5 Aide Memoire Flowchart Incident Info Site specific risk information (SSRI), site specific risk plan (SSRP) or Environmental risk/pollution plans Type and quantity of pollutant involved Location of incident in relation to an environmental receptor Consider What is the environmental impact of the tactical plan Use alternative tactics to reduce environmental damage or where fire fighting media is applied or cannot be contained. Identify owner occupier responsibilities Disposal of pollutants including fire water and water used for decontamination. Consider Pubic information Impacts on community, road, rail, local and national infrastructure. Identify both short and long term environmental impacts En-route Brief On Arrival Establish risk to life or health. Identify the pollution, Identify the relevant TOG and AHIS Carry out an Environment Risk Assessment. Introduce environmental protection measures to reduce the risk of damage. Request the attendance of HMEPA/EA/EPU Inform the responsible authority i.e. Environment Agency, Natural England, Local Authority and request attendance if appropriate. Liaise with sewage undertakers for disposal Safety Critical Actions Implement a safe system of work based on the nature of the incident and the applicable TOG and AHIS As Incident Develops Carry out an Environmental Analytical Risk Assessment (EARA) Liaise with conservation bodies Specialist Advice Closing Stages and Post Incident: Refer to TOG Resources Info Environmentally safe access routes Ground water maps Environment Agency information Areas of natural conservation information (SSSI etc.) Environmental Protection Equipment Drainage Plans Availability of the an Air Quality Cell Key Hazards Firewater run-off Fire Fighting with Foam Smoke Plumes Polluting Materials Physical Damage High pressure oil pipelines Other Hazards Hazardous Materials Eco-toxic Organic/Inorganic Pathogens Smoke Electricity Biohazards Working near water Irrespirable atmosphere Working near water Radiation Pressurised systems (tanks, pipework) Dust (what about cylinders/collapsing waste stacks etc Protective Review None NOT PROTECTIVELY MARKED Page 5 of 20

6 Part Two Detailed Considerations to assist Incident Command 1 Initial Considerations 1.1 Identify if there is a priority to protect the environment. 1.2 The saving of life and risk to life or health of both casualties and personnel must remain a priority. 1.3 Identify the pollution (estimated quantity and source). Hazmats (refer to Hazmat TOG) Products of combustion (smoke plume, gases etc.) Waste produced as a result of fire service actions i.e. fire water, decontamination water. 1.4 Identify the relevant TOG and AHIS to manage the incident 1.5 Carry out an Environment Risk Assessment as part of a DRA to establish the impact of the tactical plan. 1.6 Identify appropriate measures to reduce environmental impact. i.e. modifying the operational strategy 1.7 Inform the responsible authority i.e. Environment Agency, Natural England, Local Authority etc. 1.8 Implement pollution containment hierarchy by illuminating/reducing pollution: At source, close to source On the surface In drainage or along a pathway Contain, Manage, treat pollution at the Receptor 1.9 Reduce physical damage 1.10 Monitor and record environmental protection activities 2 Incident Information Gathering 2.1 Common a) Who or what is at risk b) What options are there for containment c) Identify the presence, location and vulnerability of any environmental receptors: Protective Review None NOT PROTECTIVELY MARKED Page 6 of 20

7 TOG Environmental Protection Ground water protection zones, sensitive aquifers and surface water bodies, Water abstraction points Areas of natural conservation i.e. SSSIs, other protected sites or sensitive habitats. Land which if contaminated by a substances or organisms may cause a significant risk to human health Fisheries Community resources, facilities and other amenities d) CHEMET/Smoke plume prediction systems and to provide current and predicted weather conditions e) Waste disposal responsibilities for the FRS, Environment Agencies, Highways agencies, local authorities and owner/occupiers. 2.2 Fires a) What is burning b) Unprotected exposures c) Volume, flow, method of containment of Firewater run-off d) Volume, flow, method of containment of Foam e) Drainage plans f) Environmental vulnerability of open water sources (rivers, lakes, ponds and streams) used for fire fighting or discharge. 2.3 Rescues a) Volume and types of fuels and oils, which may have entered drainage systems. 2.4 Hazardous materials and environmental protection a) Incidents involving spills obtain COSHH or relevant hazard information, risk to and environment actions. b) For commercial premise or transport identify the presence of hazard information or pollutions control plans c) Identify the any need to contain the water used for the decontamination of personnel and equipment, its anticipated quality, potential polluting effects and method of disposal. 3 Resource Requirements Resources that are available or may be required and arrangements needed to manage them 3.1 Resources a) Environmental Grab Pack b) Request the attendance of HazMat and Environmental Protection Advisor (HMEPA) Protective Review None NOT PROTECTIVELY MARKED Page 7 of 20

8 c) Additional Environmental Protection Equipment/Environmental Protection Unit d) Environment Agency Officer e) On and off site liaison f) Subject mater expert advice g) Water management equipment 3.2 Resource management a) Sectorisation b) Identify a RVP for oncoming resources which that does not create additional 4 Risk Information Consider and review significant hazards and appropriate control measures. The table below identifies the significant hazards and control measures identified through pre-planning. Utilise this information where relevant and the risk information gathered at the incident to develop risk assessments appropriate to the dynamics of the situation. 4.1 Significant Hazards 4.2 Control Measures Fire water run-off Controlled burn Containment Recycling Reduction Authorised and safe disposal Operational risk information plan Firefighting with foam Containment Substitution Reduction Disposal Operational Risk Information Plan Controlled Burn Smoke plumes Controlled burn Extinguish Removal or separation Use of Air Quality Cell or appropriate function Protective Review None NOT PROTECTIVELY MARKED Page 8 of 20

9 Operational risk information plan Use of spray/jets/mist to reduce smoke plume. Polluting Materials Access to specialist advice Containment Dilution Absorption Transportation Aeration Treatment Disposal Decontamination Physical damage Defined paths and tracks in protected areas Liaison with conservation bodies Operational risk information plan High pressure oil pipelines (See TOG Pipelines) Containment Diversion Operational risk information plan Wildfires (See TOG Wildfires) Containment Firefighting foam and chemicals Access to specialist advice High volume pumps Operational risk information plan 5 Incident Planning Ensuring the tactical plan delivers the actions required to meet the priorities and objectives of the incident. 5.1 Incident Priorities and Objectives Clearly defined, ensuring incident planning is specific, achievable, realistic and sequential taking resource availability into account ensuring conflicting priorities are appropriately addressed. a) Risks to life and health must always take priority b) Implement local or generic environmental protection plans Protective Review None NOT PROTECTIVELY MARKED Page 9 of 20

10 c) Control the risk of damage to the environment from fire water run-off and spillages of polluting materials based on the containment hierarchy. Hierarchy Activity Description 1 Containment at source 2 Containment close to source 3 Containment on the surface 4 Containment in drainage system 5 Containment on or in watercourse The most effective intervention point is where the source of pollution can be controlled to stop or reduce the volume released. Methods include the use of clay seal putty, leak sealing devices, wedges, and drums. Contaminated fire water will ideally be contained at an incident scene either inside the building or as close to it as possible. The next point of intervention is as close to the source as possible. This may be when it is not possible to contain at source or where there has already been significant loss of pollutant. Methods include the use of grab packs, booms and pop-up pools. The most common way for contaminants to enter the environment is via drainage systems. Methods to prevent this include the use of booms, clay drain mats, pipe blockers, pumps, and flexi-dams. Pollutants may be contained in drainage systems if they have already entered the system. This can be carried out using in-built pollution control devices in the drainage systems such as oil separators, penstocks and valves, which allow predictable volumes of runoff to be stored. Or portable equipment such as pipe blockers can also be used. The deployment of booms downstream of an incident is of significant benefit where a pollutant floats. Damming can be used where pollutants are mixed or do not float but is normally restricted to small ditches and streams with low flows. Booms can also be deployed around drinking water intakes. d) An Environmental Analytical Risk Assessment (EARA) should be carried out prolonged incidents, where full ICS has been implemented, where a predetermined serious risk to the environment has been identified or where a Fire Service procedure requires such an assessment i.e. the use of foam, decontamination or where there is a large volume of firewater runoff. e) Where there is no risk to life or health IC should balance to need to protect the environment against the risk to personnel and the possible escalation of the incident and its impact on the community, road, rail and the local or national infrastructure. f) Small amounts of pollutants may prove to be very toxic i.e pesticides Protective Review None NOT PROTECTIVELY MARKED Page 10 of 20

11 g) For incidents involving all pollutants consider the short and long term possibility of environmental damage this especially applicable to areas of natural conservation including water supplies, SSSI, fisheries, world heritage sites and other important etc. need to be a large spill if substances is very toxic 5.2 Incident Specific Activity How priorities and objectives are achieved through tactical planning that balances risk against benefits. a) Incidents involving pollutants/chemicals which present a significant risk to the environment when spilt directly into a water body, either neat or diluted, i.e. pesticides will require the use of modified tactics which may include a controlled burn b) At Large incidents involving significant or very hazardous plumes, gas releases consider requesting the assistance of the Air Quality in Major Incidents Service via the Environment Agency. c) Large waste fires implement SSRI/pollution control plans see TOG for Waste Fires. 6 Command and Control Command structure and incident ground organisation to control activities. a) Establish and maintain cordons for areas effected by pollution control activities b) Ensure environmental protection is included in tactical plan c) High light measure required to protect the environment when communicating a modifications of the tactical plan d) Water Officers should understand the impact of a water plan on the environment. This is especially applicable whilst abstracting from open water supplies or where there is the possibility of cross contamination of supplies and the bio-security is at risk. e) Foam Officers should monitor and control the qualities, effects containment of foam 7 Safety and Welfare 7.1 Safety considerations a) Safe access/egress b) Safe method of extinguishment c) Consider evacuation d) Correct PPE when dealing with leaks, spills and environmental equipment e) Water safety procedures when performing tasks around open water 7.2 Reliefs/welfare Protective Review None NOT PROTECTIVELY MARKED Page 11 of 20

12 8 Communication Establish reliable, accurate, timely communications 8.1 The IC must notify the respective Environment Agency of incidents where there is a risk to the environment. This communication must include the following details: Whether or not there is a risk to life or health The potential or actual environmental damage that has occurred/could occur The pollutants involved and an estimate of quantity The actions that have been taken, or is planned to protect or reduce environmental damage 8.2 IC must liaise with owner-occupier so that their pollution and waste disposal responsibilities are identified 8.3 Pubic information (Media) for incidents that may impact on the public 9 Liaison Effective liaison with external agencies and interested parties to build shared situational awareness 9.1 Who? a) Environment Agencies b) Natural England c) Local Authority d) Health Protection Agencies (for incidents that may have a direct impact on public health) e) Sewerage Undertakers (for incidents that effect the sewer network 9.2 How? a) National Agency contact centres (via Fire Control initially) b) Environment Agencies may communicate direct with the fire ground. c) Where Environment Agency officers attend the incident they liaise with the IC or HEMPA 9.3 Why? a) Obtain information and location of vulnerable environmental areas b) Advice on environmental procedures c) Establish and communicate aims and issues d) Communication of tactical plan to all relevant parties where alternative environmental tactics are being considered. Protective Review None NOT PROTECTIVELY MARKED Page 12 of 20

13 10 Closing Stages and Post Incident Considerations 10.1 Considerations a) Decontamination of equipment b) Establish responsibilities for disposal of wastes c) Criminal investigation / litigation d) Financial loss / cost recovery e) Identifying Lessons learnt?? 10.2 Possible actions a) Disposal of wastes b) Completion of recharge forms c) Recording evidence d) Hot or formal incident debrief (include other agencies as appropriate) e) Hand over to responsible person / authority Protective Review None NOT PROTECTIVELY MARKED Page 13 of 20

14 Part Three Incident Review TOG Environmental Protection Incident Review Considerations Incident Specific User notes 1 Initial Actions Was there a priority to protect the environment? Was there a risk to life or health Identify the pollution? Has an environment risk assessment carried out as part of a DRA? Was a responsible authority i.e. Environment Agency, Natural England, Local Authority etc. informed/consulted? Did/ are they provide advice? Did/ are they attending the incident? 2 Incident Information What has happened What is happening now What is likely to happen Are local factors understood and being addressed (weather, time of day, slope of ground etc.) Are the wider impacts understood and being addressed Has SSRP, SSRI, Operational guidance been consulted Are actions in line with Operational Guidance 3 Resources Information Confirm resource requirements, consider: o FRS o Other Agencies o Contingencies Are resources appropriate to tactical plan Is resource management adequate 4 Hazard and Safety Information Protective Review None NOT PROTECTIVELY MARKED Page 14 of 20

15 Incident Specific User notes Were/are any of the following hazards present? Firewater run-off Fire Fighting with Foam Smoke Plumes Polluting Materials Physical Damage High pressure oil pipelines 5 Incident Planning 5.1 Priorities and Objectives Objectives identified and priorities appropriate Have the risks to the environment been identified Were/are the risks to the environment adequately reduced/controlled 5.2 Tactical Plan Is there a plan and is it working Will it deliver the actions required to meet the priorities and objectives of the incident and: Is it appropriate to the incident type Is it based on relevant information Does it follows a logical sequence Is it appropriately delegated Does it balance risk and benefit Does it reflect the Tactical Mode Is it correctly resourced Is it communicated and understood Is it flexible Is it resilient e.g. Plan B / contingencies Is it monitored, reviewed, evaluated, maintained, if amended, communicated 6 Command and Control Protective Review None NOT PROTECTIVELY MARKED Page 15 of 20

16 Incident Specific User notes Sectorisation (operational and support) Roles and responsibilities, (clearly defined and understood) Spans of control Clear communication routes Continuity - initial IC / Command team Resources Shared situational awareness FRS / others Command support / command post Changes communicated to all 7 Safety and Welfare Confirm adequate Safety arrangements: o DRA / ARA conducted and reviewed o Safety briefings o Safety observers / Safety Officer(s) o Cordons established, controlled o Holding areas Evacuation systems / routes Operating practices appropriately balance risk and benefits First aid / Ambulance service Safety events recorded / investigation Welfare of personnel and others Protracted incident o Crew rotation and reliefs o Rest, feeding, hydration o Toilet facilities o Shelter o Friends and relatives concerns Stress, initial support Medical aftercare / OHU referral Evacuation shelter local authority Voluntary services support (WRVS etc.) 8 Communications Protective Review None NOT PROTECTIVELY MARKED Page 16 of 20

17 Incident Specific User notes Was a responsible authority i.e. Environment Agency, Natural England, Local Authority etc. informed/consulted? Did they provide advice? Did they attend the incident? Briefings and information exchange / cascade FRS to FRS and FRS to others Briefings and information exchange / cascade FRS to FRS and FRS to others Briefings and information exchange / cascade FRS to FRS and FRS to others 9 Liaison with other agencies and interested parties Consider and confirm: Who How Why 10 Closing stages and post incident considerations Protective Review None NOT PROTECTIVELY MARKED Page 17 of 20

18 Incident Specific User notes Investigations / actions supported o o o o o o o Coroner s hearing Criminal investigation Public or Judicial Inquiry Fire investigation Accident investigation Litigation Safeguarding passed to authority o Breach of fire safety legislation / identification of trend o Financial loss / cost recovery o Scene preservation / securing evidence / records Returning to new normality o Equipment decontamination / recovery plan o Re-inspection organised o Local prevention activities o Scaling back of operations Incident closure preparation o Completion and securing of records o Gather information for IRS etc o Incident debriefing and evaluation, sharing lessons learnt o Site clearance Handover - Site safety and security briefing, responsibility record Protective Review None NOT PROTECTIVELY MARKED Page 18 of 20

19 Part Four Document References TOG Environmental Protection 1. Relevant References This incident type is potentially linked to the following other operational guidance documents: Document Name Link to Document Environmental Risk Assessment Ops Article Waste Disposal Responsibilities Pesticides AHIS Controlled Burn Ops Article 2. Additional Information Training issues. This section to be deleted when addressed by development of training package 3. Technical References Final Draft Draft Environmental Protection Handbook Environment Agency PPG28 4. Document Control Document Control Document No. Document Title Version Date Author Role Status Changes V0.1 19/12/13 C. Caswell SM Initial draft Protective Review None NOT PROTECTIVELY MARKED Page 19 of 20

20 Protective Review None NOT PROTECTIVELY MARKED Page 20 of 20

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