When a pollution incident occurs at a UK industrial site, the response in the first few minutes determines whether the damage is contained — or whether it becomes an Environment Agency prosecution. Having the right equipment is necessary, but it is not sufficient. Without a written Pollution Incident Response Plan (PIRP), your site cannot respond effectively, and the legal consequences of a slow or disorganised response can be severe.
The Environment Agency's Pollution Prevention Guidelines (PPG22) require sites that handle or store hazardous substances to maintain a written PIRP. This document must be more than a laminated poster by the fire exit — it must be a functional, site-specific operational document.
What Is a PIRP and Why Is It Required?
A Pollution Incident Response Plan is a documented set of procedures that enables a site to respond immediately and effectively to any release of a polluting substance. PPG22 (now part of the EA's Regulatory Position Statements and integrated pollution prevention guidance) establishes that regulated sites must have one in place.
For sites operating under an Environmental Permit (EP), the PIRP is typically a permit condition. For non-permitted sites that store above-threshold quantities of oil, chemicals, or hazardous waste, a PIRP is required as part of your duty of care under the Environmental Protection Act 1990 and Water Resources Act 1991.
Failure to Notify the EA — A Separate Offence
Under Section 85 of the Water Resources Act 1991, it is an offence to cause or knowingly permit the entry of a polluting matter into controlled waters. Critically, failure to notify the EA of a pollution incident within a reasonable time is treated as an aggravating factor in any prosecution. Courts have accepted this in sentencing decisions under the Definitive Guideline for Environmental Offences (2014), which explicitly lists "failure to respond promptly" and "deliberate concealment" as culpability-increasing factors.
The EA's 24-hour pollution incident hotline is 0800 80 70 60. This number must appear prominently in your PIRP.
Mandatory Contents of a PIRP
PPG22 and EA enforcement practice identify the following as minimum required contents. Auditors and inspectors will check for each of these elements.
1. Site Drainage Map
A current, accurate drainage plan showing all surface drains, foul drains, interceptors, outfalls, and the location of isolation valves or penstock controls. Must be updated whenever drainage infrastructure changes.
2. Chemicals Inventory and Safety Data Sheets
A current inventory of all hazardous substances stored on site, with the volume stored, storage location, and associated Safety Data Sheets (SDS). The SDS must be Section 14 (Transport) and Section 13 (Disposal) compliant so responders know how to handle the substance and what spill kit media to use.
3. Emergency Contacts
Must include:
- EA Pollution Incident Hotline: 0800 80 70 60 (24/7)
- Local fire service non-emergency line
- Site EHS manager (with out-of-hours mobile)
- Named spill coordinator and deputy
- Contract spill response company (if used)
- Waste carrier for recovered material disposal
4. Spill Response Procedures
Step-by-step response procedures for each category of pollutant stored on site (oil, acids, alkalis, solvents, etc.). Should include: who activates the PIRP, how to isolate drainage, how to deploy spill kits, when to call the fire service, and when to evacuate.
5. Nominated Spill Coordinator
A named individual (with named deputy) who has authority to activate the PIRP, direct the response, and make the EA notification call. This person must have received appropriate spill response training.
6. Training Records
Evidence that all relevant staff have received spill response training. Training must be refreshed at defined intervals (annually is standard EA expectation) and whenever significant changes are made to site operations or the PIRP itself.
Annual Review Requirement
The PIRP must be reviewed at least annually, and following any pollution incident, near miss, or significant change to site operations. The review must be documented — sign, date, and record what was changed and why.
Accessibility — A Critical Compliance Failure
One of the most common PIRP failures identified in EA audits is that the document is held exclusively by the EHS manager or in a locked office. A PIRP that cannot be accessed by operational staff during a night shift or in the EHS manager's absence is not compliant. The plan must be:
- Physically posted in relevant work areas
- Available in the site control room and gatehouse
- Accessible in a format that does not require a computer login under pressure
PIRP Minimum Contents Checklist
| PIRP Element | Required By | Review Frequency | In Place? (Audit Column) |
|---|---|---|---|
| Site drainage map (current) | PPG22 / EP Condition | On change + annual | ☐ |
| Chemicals inventory + SDS | COSHH Reg 6 / PPG22 | On change + annual | ☐ |
| EA hotline (0800 80 70 60) | PPG22 / WRA s.85 | Annual | ☐ |
| Spill response procedures (by substance) | PPG22 / COSHH ACOP | Annual + after incidents | ☐ |
| Named spill coordinator + deputy | PPG22 | Annual / on personnel change | ☐ |
| Training records (all relevant staff) | COSHH Reg 12 / PPG22 | Annual refresh | ☐ |
| Drainage isolation procedure | EP Condition / PPG22 | Annual + after drainage changes | ☐ |
| Spill kit inventory + locations | PPG22 / COSHH | Quarterly check + annual review | ☐ |
| Incident notification log template | PPG22 / WRA | Annual | ☐ |
| PIRP review date and sign-off | PPG22 / EP Condition | Annual minimum | ☐ |
| Copies posted in all work areas | PPG22 | On revision | ☐ |
Starting Your PIRP
If your site does not have a PIRP, start today. Compile your drainage plan, chemicals inventory, and emergency contacts. Nominate your spill coordinator. Book spill response training. Document what you have done. A basic, accessible, accurate PIRP is always better than a comprehensive document locked in a filing cabinet.
If you already have a PIRP, treat this checklist as your annual audit tool. If any row has an empty tick box, you have a compliance gap to address before the next EA visit.
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