Oil Storage: The Key Considerations

In the UK oil is still one of the biggest pollutants. Country specific regulations governing its storage are:

ENGLAND

The Control of Pollution (Oil Storage) (England) Regulations 2001: Which define “oil” as any kind of oil including petrol.

SCOTLAND

The Water Environment (Controlled Activities) Scotland Regulations 2011 (As Amended) and The Water Environment (Misc.) Scotland Regulations 2017: Which define “oil” as any kind of oil other than solid products such as uncut bitumen and includes fuel oil, waste oil, biofuel mixtures, vegetable oil, plant oil, lubricant oil and hydraulic oil.

NORTHERN IRELAND

Control of Pollution (Oil Storage) Regulations (Northern Ireland) 2010: Which define “oil” as any kind of oil and includes petrol, diesel, waste, vegetable and plant oil, but does not include uncut bitumen.

WALES

The Water Resources (Control of Pollution) (Oil Storage) (Wales) Regulations 2016: Which define “oil” as any kind of oil except uncut bitumen.

The incorrect storage and or poor management of oil can have far-reaching consequences for your business and the environment; and although the various country-specific regulations are amongst some of the most highly publicised it’s all too easy to forget that oil still poses one of the biggest threats to the environment and the health and safety of personnel if not handled and stored correctly.

By using products specifically designed for the task, such as rotationally moulded polyethylene spill pallets for indoor applications, bunded drum & IBC stores with fully seam welded sumps for secure outdoor use and double skinned storage tanks for bulk liquids, it’s relatively straight forward to ensure that your site is protected and fully compliant.

The following questions will help you determine the correct storage method to suit your specific requirements and when used in conjunction with other measures including good housekeeping, spill kits and other spill response products, will substantially reduce the risk of an incident.

1. How many containers do you need to store?
2. What size(s) are the containers (i.e. 25ltr – 205ltr – 1000ltr)?
3. Will the containers be stored indoors?

If yes; are there access limitations (door widths, ceiling heights etc.) and what space is available in the area the unit will be located.

4. Will the oil be stored outdoors?

If yes are there surface water drains or a watercourse in the vicinity, what is the condition of the ground, it should be firm-level ground such as concrete. Also, check if the unit can be sited close to existing buildings. We strongly recommend that you take advice from your insurers and even the local authority fire brigade before locating one next to an existing structure.

5. How will the containers be delivered to site?
6. How will they be moved around the site?
7. Is there a fire, explosion or vapour release risk associated with any of the containers?
8. If you are storing different types of oil is there a requirement to store any of them separately?

The SDS (Safety Data Sheet) for the oils you are storing will provide you with a wealth of information, but if you are unsure about any aspect you should talk to the manufacturer for more detailed information.

Determining the amounts (litres) of oil you have on-site and in what types of container (205ltr drums, 1000ltr IBC, bulk tanks etc.) is fundamental to ensuring you don’t end up with oil stored in a way that will lead to an incident. Don’t forget to include used, empty containers which are likely to have residues in them and therefore be classed as a risk and need to be stored within a bunded area too.

You must consider the location of the storage area with great care to minimise the risks of damage to the environment, the health and safety of your employees and the public. It must be located somewhere that if oil leaks or spills, it won’t pollute the local and wider environment. It should also; if possible be away from vehicle routes to eliminate the risk of the oil store being “run into” and damaged/compromised. If this is not possible you should consider the addition of “crash barriers” to protect the storage area.

It goes without saying that your storage containers (bunded stores, spill pallets etc.) must be designed with environmental protection in mind. This means that the bund and any storage units or spill pallets must be able to contain at least 110% of the volume of the single largest container or 25% of the combined volume stored, whichever is greater. Don’t forget to consider how you protect the drums or IBCs when they are being moved around the site. Bunded trolleys or mobile spill pallets are ideal, but remember to properly secure the load before moving it.

If your bunded area isn’t protected against the elements, rainwater will collect in it and reduce its capacity, you must always check the contents of the bund before disposal to ensure you don’t cause a pollution incident by discharging contaminated water. It is against the law to discharge anything into the sewer that could harm or interfere with the treatment or disposal of the sewer contents. If you allow rainwater from bunds to enter surface waters or groundwaters you must have an Environmental Permit or registered exemption in England and Wales, a discharge consent or groundwater authorisation in Northern Ireland or authorisation under the Controlled Activity Regulations (CAR) in Scotland.

Don’t forget areas where you have smaller amounts of oil such as laboratories, test rigs, workshops etc. The same rules apply but you may only require a small “laboratory cabinet”, which should be secured to the floor and/or wall to prevent it toppling over, avoid the temptation to store anything directly on the floor, even on a temporary basis, and always avoid storing above eye-height, or on top of cupboards or cabinets. Wear/use PPE (Personal Protective Equipment) as appropriate at all times.

Keep an inventory of the oil you have on-site along with copies of the SDS and ensure they are readily available to staff; and that the information can be accessed easily out of hours for use by spill responders or outside agencies.

It’s important that your staff is trained and know how to deal with any spills that may occur, and that you have a pollution incident response procedure in place.

Ensure that you have spill kits, containment equipment and drain sealing products suitable for the quantities of oil you are storing and using. Remember it’s always better to try and keep any spill above ground and deal with it there.

Locate your spill response equipment close too and remote from any area that poses a risk and remember to ensure locations are marked on your site plan (again available to staff or outside agencies) and that the equipment is highly visible and not hidden behind anything that will restrict access.

An outside pair of eyes will often see things that have become commonplace to you, so you might want to consider using the services of an outside company to assess/review your site.

If you pollute, you could get an unlimited fine, go to prison for up to 5 years, or both. You may also have to pay for the whole cost of the clean-up and there could be further costs such as paying compensation to third parties, higher insurance premiums or loss of contracts.

Emtez is an ISO 9001, ISO 14001 & ISO 45001 accredited company with more than 35 years’ experience of manufacturing spill containment and spill response products and we are happy to offer a free of charge and without onus site assessment to anyone responding to this article quoting OIL2020.

Features and benefits of Emtez oil storage units:

*Unless certain options such as electrics have been specified