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NATIONAL CONTINGENCY PLAN FOR MARINE POLLUTION FROM SHIPPING AND OFFSHORE INSTALLATIONS

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APPENDIX K

ENVIRONMENT GROUP
Introduction
K.1    The aim of this appendix is to provide outline operational guidance to section 9 of the NCP on how to address the environmental and public health aspects of the response to a maritime incident.  It describes the likely composition of the Environment Group, the procedures for establishing such a Group, and the key tasks that the Group would carry out during and after an incident.

Terms of reference
K.2    The Environment Group has a vital role in the response to any maritime incident, particularly where there might be a threat of land, air or sea pollution involving oil and/or hazardous and noxious substances.  The purpose of advice from the Group is to minimise the impact of the incident on the environment and public health in the widest sense.  This type of event falls under the scope of an “emergency” under the Civil Contingencies Act Part 1 (Local Arrangements for Civil Protection) and is therefore subject to the Regulations of the Act.  The Act defines “emergency” in the following manner:

“an event or situation that threatens damage to the environment only if it involves, causes or may cause:

a.contamination of land, water or air with:

(i) harmful biological, chemical or radio-active matter, or

(ii) oil,

b.flooding, or

c.disruption or destruction of plant life or animal life.

K.3    Public health issues are addressed initially by the Environment Group.  However, should a threat to public health be deemed significant and specialist knowledge and advice be needed then a public health officer shall be available to determine the appropriate level of response.  Other agencies such as HPA may need to be involved to provide specialist public health advice.

K.4    The main function of the Group is to provide advice and guidance to the SOSREP, the Salvage Control Unit (SCU), the Marine Response Centre (MRC), the Shoreline Response Centre (SRC), and the command and control centre for response in a harbour (when established) and to the Operations Control Unit (OCU) (if and when established by the SOSREP) for incidents involving the offshore oil and gas industry, on all environmental and public health aspects of a pollution incident.  This includes the assessment of environmental risks and potential impacts arising from an incident, as well as the implications of any clean up or salvage operations.  It achieves this through:

  • the appointment of an Environment Liaison Officer (ELO) for each of the response units established to deal with the incident ;
  • providing advice and guidance to minimise the impact of the incident and clean up response on the environment and public health, informed by local knowledge and specific information collected;
  • using all relevant environmental information and local knowledge available;
  • monitoring the environment and assessing the impact of the incident and clean up response in both the short and long terms (that is, by fulfilling the role of an impact assessment group unless the extent or complexity of an incident results in a separate group being formed specifically with this task); and
  • facilitating the welfare, rehabilitation or humane disposal of impacted wildlife by the RSPCA, SSPCA and the USPCA, or other agreed recognised animal welfare organisations.  In the case of significant wildlife casualties there is a requirement to set up a dedicated wildlife treatment centre staffed by suitably qualified personnel.  All aspects of wildlife welfare and rehabilitation from search and collection to release should follow established guidelines and procedures under the management of the recognised animal welfare body.

The mechanism for advice provision by the Environment Group
K.5    Due to the need for prompt provision of environmental advice, it is recognised that much or most of the advice stemming from the Environment Group is  given to the response centres verbally or by telephone.  The Group provides its advice to response units through ELOs.  The Group should provide its advice in a timely manner, record its advice and the rationale for it in writing.  Where the response units do not accept the advice given by the Environment Group they should similarly record the reasons in writing and pass this to the Group and the heads of all other response units formed.

Key tasks
K.6    The Environment Group:

  • provides operational advice, including:
    • advising on potential and real impacts on public health;
    • advising on the relative importance of environmental features and wildlife at risk and their sensitivity/vulnerability to oil or other hazardous substances and related clean-up activities;
    • agreeing and prioritising environmentally sensitive sites and wildlife in need of protection;
    • ensuring that priorities of clean-up adequately reflect environmental concerns;
    • advising on the environmental implications of operational response measures and their effectiveness when implemented;
    • taking account of and seeking to resolve conflicting environmental issues and priorities within the group’s remit; and
    • contributing EG-appointed members to the SRC-controlled Shoreline Clean-up Assessment Teams (SCAT).
  • requires a range of data, information and operational advice including:
    • human population at risk;
    • information on the distribution and seasonal status of all wildlife;
    • information on fishing grounds, spawning and nursery areas, shellfish beds and mariculture generally;
    • information on abstractions from, discharges to and uses of all waters likely to be affected;
    • real time information on wildlife, fishing activity and ecosystems in affected areas;
    • collated records of all wildlife affected by pollution (including wildlife welfare co-ordination); and
    • details of the progress and success of clean-up operations.
  • advises on monitoring, including:
    • risks and acute effects to public health;
    • preparation or identification of environmental baselines against which later environmental evaluations can be compared;
    • monitoring the environmental effects of clean up operations in sensitive areas, ensuring that such activities match the strategy of the Environment Group as agreed in the relevant response centre; and
    • baseline monitoring of impact on wildlife, fisheries and sensitive sites/habitats threatened by pollution.
  • initiates long-term impact assessment, including:
    • impact on human health;
    • impact on fisheries (including shell fish beds and salmon farms etc.); and
    • impact on all aspects of the natural environment.

K.7    If a situation develops where there is potential for conflict for resources between members of the SRC and the Environment Group, then efforts should be made to co-ordinate requirements thereby avoiding duplication.  The Environment Group should bear in mind that under international conventions, response measures and their associated costs need to be reasonable.

Establishing the Environment Group
K.8    Establishing an effective Environment Group for an incident will be best facilitated by sound contingency planning.  For most of the UK coastline, Standing Environment Groups have been established in order to undertake these preparations.  As a minimum, the Chair and the potential pool of ELOs should be nominated in advance, and suitable accommodation and support facilities identified.  These standing groups should have links to the Local Resilience Fora (LRF) to ensure an integrated approach to the planning and response phases of such incidents.

Environmental Liaison Officers
K.9    The chair nominates an Environment Liaison Officer for each of the established response centres.  The chair establishes lines of communication to allow the provision of timely advice to these units.  It is important that the individual ELOs appointed are fit for the task in hand.  The expertise required varies with each incident and a pool of suitable nominees with a range of relevant experience, knowledge and specialism should be identified.  In all incidents, the common requirement for ELOs is broad familiarity and understanding of the responsibilities and issues relating to the response centre to which they may be appointed.  To ensure clarity for communication between response units and the Group, only one ELO is appointed to each response unit, though the ELOs may require relief or support by one or more deputies.

Membership of the Environment Group
Core membership
K.10    The composition of the Environment Group depends on the nature (magnitude and complexity) and location of the incident.  The core membership may include representatives of the following:

  • the relevant statutory nature conservation bodies: (EN, SNH, CCW or EHS, plus JNCC);
  • the relevant government department with respect to fisheries and other wider maritime environmental interests (SEERAD or FRS, Defra, DARD);
  • the relevant environmental regulator (EA, SEPA, or EHS);
  • the local public or port health body (public health interests are represented by specialists from either the Health Protection Agency in England, the National Public Health Service in Wales, Health Protection Scotland and the Health and Social Services Boards in Northern Ireland);
  • the Food Standards Agency may contribute to the process either directly or in partnership with other agencies as appropriate;
  • the affected, or threatened, local authorities; and
  • MCA may join the core group if deemed necessary by the Chair.  The MCA, in any case, maintains close liaison with the Group in the context of overall incident management and continuity.

K.11    In addition, the core membership of the EG may include Sea Fisheries Committees, and National Park Authorities with coastlines as appropriate.

K.12    The Chair and core members decide whether to expand the Group's membership to include representatives of other organisations.  The Chair and core members also decide when it is necessary to convene the Environment Group close to the scene of the incident.

Animal welfare bodies
K.13    The Environment Group may draw members from the RSPCA, the SSPCA, or the USPCA.  They take the lead in wildlife welfare and rehabilitation and co-ordinate that work thereby avoiding any possible duplication of effort and unreasonable actions.  The statutory nature conservation body alerts these bodies when live wildlife casualties are involved.

Other bodies
K.14    Depending on how the incident develops, the members may recommend that further environmental organisations become involved.  Representatives of Non-Governmental Organisations (NGOs) may also have relevant expertise to offer the group.

Assessment of Long Term Environmental Impact
K.15    If a marine pollution incident is expected to have a significant environmental or public health impact, arrangements should be made to begin to monitor and assess the long-term impact, as well as the short to medium-term environmental impact.  Therefore, in addition to providing operational advice to the response centres, the Group needs to initiate and encourage provision for the collection and evaluation of data on the environmental effects of the incident.  One of the roles of the Standing Environment Groups is to record data on the pre-existing baseline conditions within their area, for use as reference points during an incident.  The Environment Group needs to include a public health risk assessment.

K.16    It is recognised that some incidents result in extensive pollution of the sea and coastlines.  Other incidents may result in the loss of a chemical into the sea that may not have an immediate impact but might be significantly bioaccumulated over the years, or maybe in an irrecoverable package which has the potential for bursting open.  Either type of incident may require a significant monitoring and assessment programme or a long term monitoring commitment.  The EG membership plays an important part in monitoring and assessment work but the process overall may be managed by an independent body set up specifically for that task at that time.

K.17    In such major or long-term incidents impact assessment projects may need to be commissioned.  The appropriate Government Department or Devolved Administration responsible for environmental issues for the waters where the incident occurs take the lead in coordinating the commissioning of such work.  It is necessary to link such new work with the monitoring and assessment activities, particularly so that any monitoring data required for the impact assessment projects is collected as early as possible rather than waiting for two or three months for contractors to be appointed.  This data collected in the early phases of an incident, and the manner in which it was collected, is crucial to any subsequent medium and long term evaluation reports.

K.18    Therefore it may be necessary to transfer the responsibility for coordinating, monitoring and assessment work from the EG to a new separate group concentrating on coordinating Environmental Impact Assessment at an early stage.

K.19    The Environmental Impact Assessment group is charged with obtaining funding for the impact assessment, including public health, and long-term monitoring programmes.  They also consider whether any existing research and development projects or monitoring work should be delayed to release scientific expertise to the impact assessment project.  In a major oil cargo spill incident there is a need to involve the IOPC Fund at an early stage if any costs for this work are to be reimbursed.

The Environment Group links with the MRC, SCU, OCU and the SRC
K.20    The relative length of time that individual response centres are operational varies according to the nature and scale of the incident.  A major incident could involve the establishment of response centres for several months.

K.21    The Environment Group and ELOs expertise requirements vary with each incident and a pool of suitable nominees with a range of relevant experience, knowledge and specialism are identified.  Appendix G describes the role of  the SOSREP and the SCU for shipping casualties and offshore installations.  Appendix H describes the at-sea response and the MRC.

K.22    Appendix J describes the establishment and operation of an SRC.  It is important to co-locate the Environment Group and the SRC, where established.  This enables the Environment Group to provide timely, appropriate advice to the SRC in consideration of the complexity of the situation and length of operation.  To facilitate effective liaison between the Environment Group and teams within the SRC, the ELO appointed to the SRC is a member of the SRC Management Team.

K.23    The specific tasks for the Environment Group in a protracted SRC are likely to includes:

  • an evaluation of the relative importance of nature conservation and other environmental features at risk during an incident.  This includes their sensitivity/vulnerability to oil or hazardous substances and clean up;
  • establishment of agreed priorities for protection and clean up;
  • provision of advice and appointment of Environment Group-appointed members to the SRC controlled multi-disciplinary Shoreline Clean up Assessment Teams (SCAT), as required;
  • provision of advice on the suitability of pre-identified locations for the natural degradation of oil;
  • provision of advice on whether proposed clean-up techniques are likely to cause more damage than leaving the pollution to degrade naturally.  This may involve the preparation of advice for use or non-use of dispersants in specific scenarios to pass on to MCA or other responders before they formally request approval from Defra or others for the required statutory approval.  The formal dispersant approval process is outside the Group’s remit, those decisions are made centrally by Defra/FRS/EHS after consultation with the appropriate statutory nature conservation body;
  • monitoring clean up operations in sensitive areas to ensure that clean-up operations match the strategy agreed in the SRC, and
  • ensuring the thorough documentation of all decisions and actions taken by, or on behalf of, the Environment Group.

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