Environment Agency Pollution Prevention Guidelines — Complete Reference

The Environment Agency (EA) Pollution Prevention Guidelines (PPGs) constitute the principal technical guidance series governing pollution prevention practice for industrial, commercial, and agricultural operations in England. Although several PPGs have been withdrawn and replaced by Regulatory Position Statements or Serv1ce guidelines, they retain significant practical and evidential weight in enforcement proceedings. This comprehensive reference covers the complete PPG series, with detailed analysis of the most commercially relevant guidance documents and the enforcement framework applicable to non-compliance.

Complete PPG Series Overview

The PPG series comprised 26 documents numbered PPG1 through PPG26 (note: not all numbers were assigned). The core titles are as follows:

• PPG1 — General guide to prevention of water pollution
• PPG2 — Above ground oil storage tanks
• PPG3 — Use and design of oil separators in surface water drainage systems
• PPG4 — Disposal of sewage where no mains drainage is available
• PPG5 — Works in, near or liable to affect watercourses
• PPG6 — Working at demolition and construction sites
• PPG7 — Refuelling facilities
• PPG8 — Safe storage and disposal of used oils
• PPG9 — Highway depots and transport operators
• PPG10 — Intermittent discharges to sewer
• PPG11 — Preventing pollution at motor vehicle body repair shops
• PPG12 — Sheep dip
• PPG13 — The use and design of oil separators in surface water drainage systems (superseded PPG3)
• PPG14 — Marinas and craft
• PPG15 — Retail premises
• PPG16 — Waste minimisation at fuel filling stations
• PPG17 — Pollution prevention for pig farms
• PPG18 — Control of spillages on highways
• PPG19 — Garages and vehicle service centres
• PPG20 — Dewatering underground constructions
• PPG21 — Pollution from emergency generating sets
• PPG22 — Incident response — dealing with spills
• PPG23 — Poisonous, toxic or polluting matter on vessels
• PPG24 — Stables, kennels, and catteries
• PPG25 — Milk handling and storage
• PPG26 — Safe storage of pesticides

PPG2 — Above Ground Oil Storage: Detailed Requirements

PPG2 remains one of the most widely referenced guidance documents in EA enforcement. It applies to all above-ground bulk oil storage in England (with the Control of Pollution (Oil Storage) (England) Regulations 2001, SI 2001/2954, providing the statutory underpinning for containers over 200 litres). Key requirements include:

Bund Design and Capacity

Secondary containment bunds must have a minimum capacity of 110% of the largest single tank they serve, or 25% of the total maximum storage capacity of all tanks within the bund — whichever is greater. Bund walls must be impermeable to oil and water, constructed from concrete, masonry, or welded steel, and must not incorporate any drainage outlet, valve, or pipe penetration at or below bund floor level without an appropriate closure mechanism (typically a locked-shut valve). Underground drainage connections within the bunded area are expressly prohibited unless there is a pollution prevention device (interceptor) installed.

Inspection and Maintenance Requirements

PPG2 requires that:

• All tanks, pipework, valves, and secondary containment are visually inspected at least weekly
• Formal recorded inspections are conducted at intervals appropriate to the risk
• Any oil found in the bund is removed promptly and disposed of as waste oil (it cannot be returned to the primary storage tank without testing)
• Inspection records are maintained on-site and available for EA inspection
• Fuel delivery procedures specify that a responsible person supervises delivery, with a secondary containment check conducted before and after delivery

Record Keeping

Under the Control of Pollution (Oil Storage) Regulations 2001, operators must maintain records of: tank installation and capacity; date of any inspection, maintenance or repair; any leaks or spills and remedial actions taken; and any EA correspondence or enforcement action. Records should be retained for a minimum of 6 years to align with the Limitation Act 1980 and EA enforcement timelines.

PPG7 — Refuelling Facilities

PPG7 addresses the pollution risks from commercial refuelling operations including fuel filling stations, fleet vehicle depots, and waterside bunkering. Mandatory measures include: impermeable surfacing extending a minimum of 10 metres from the fuelling nozzle (or to the nearest drain, whichever is less); correctly sized oil/water interceptors to Class 1 standard (BS EN 858-1); automatic overfill protection on bulk storage; and a minimum 110% secondary containment bund around bulk storage tanks. Spill response equipment — including appropriate hydrocarbon spill kits and drain blockers — must be available at the point of fuelling at all times.

PPG8 — Safe Storage and Disposal of Used Oils

PPG8 applies to the storage of used or waste oils arising from vehicle maintenance, industrial processes, and other operations. Used oil is classified as controlled waste under the Environmental Protection Act 1990 and must be stored in a manner that prevents pollution: in dedicated labelled containers, within a bunded area, away from drains and watercourses, and with arrangements for collection by a licensed waste carrier. Under the Environmental Permitting Regulations 2016 (Schedule 3, Waste Exemptions T9 and T10), storage of up to 3,000 litres of waste oil may be exempt from permit requirements subject to registration. Above this threshold a formal permit is required.

PPG22 — Incident Response: The 1-Hour Notification Duty

PPG22 establishes best practice for incident response to spills and pollution events. The critical legal obligation is the duty to report any pollution incident to the EA National Incident Hotline (0800 80 70 60) as soon as practicable and within 1 hour of discovery where controlled waters are or may be affected. This notification duty derives from the Water Resources Act 1991 (Section 85) and the Environmental Permitting Regulations 2016 (Regulation 38). The EA's approach to enforcement is materially influenced by whether the operator reported promptly and co-operated fully. Failure to report is treated as an aggravating factor and can trigger prosecution rather than civil enforcement.

PPG22 requires that all sites handling hazardous liquids maintain a written incident response plan covering: identification of responsible persons, emergency contact numbers (including EA), locations of spill response equipment, spill containment procedures for each hazardous substance on site, and post-incident reporting and investigation requirements. Chemical and universal spill kits, portable berms, and drain sealing equipment are core components of a PPG22-compliant incident response kit.

EA Site Inspection: What Inspectors Check

EA inspectors exercising powers under the Environment Act 1995 (Section 108) and the Environmental Permitting Regulations 2016 may enter premises without notice during working hours. During a compliance inspection, inspectors typically assess:

• Physical condition and effective capacity of all bunds and secondary containment structures
• Whether drains connected to controlled waters are protected or sealed
• Adequacy and maintenance records for oil/water interceptors
• Presence, condition, and accessibility of spill response equipment
• Site drainage plan and whether it accurately reflects current drainage layout
• Waste storage, labelling, and disposal documentation (waste transfer notes, carrier licences)
• Environmental permit or exemption documentation
• Emergency response plan and evidence of staff training
• Any history of pollution incidents and EA correspondence

Enforcement Notices and Civil Sanctions

The EA has a tiered enforcement response. For minor non-compliance, it may issue a warning letter or request a remediation plan. For more serious breaches:

• Section 85 Water Resources Act 1991 caution: A formal written caution recorded against the operator, admissible in future proceedings
• Remediation notices: Requiring specific works to remedy pollution or its risk; costs recoverable from the operator under Section 161 WRA 1991
• Enforcement undertakings: Operator proposes remediation and improvement measures in lieu of prosecution
• Variable monetary penalties: Up to £250,000 for specified offences under the Environmental Civil Sanctions (England) Order 2010
• Criminal prosecution: Under Section 85 WRA 1991 or Regulation 38 EPR 2016 — unlimited fines on indictment; imprisonment for certain offences

The prosecution threshold is reached where: the pollution was serious or persistent, the operator failed to co-operate, there is evidence of deliberate acts or gross negligence, or where the operator has a prior history of non-compliance.

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Last reviewed: April 2026