A positive, collaborative airport-wide approach is essential to minimise pollution. Heathrow Pollution Prevention Code of Practice

A positive, collaborative airport-wide approach is essential to minimise pollution. Heathrow Pollution Prevention Code of Practice

Contents EXECUTIVE SUMMARY 03 INTRODUCTION _ 1.0 04 GENERAL REQUIREMENTS _ 2.0 06 PREVENTING _ 3.0 07 MANAGING INCIDENTS _ 4.0 11 COMMUNICATION AND FEEDBACK _ 5.0 13 DEFINITIONS AND TERMS 14 ABOUT THE 15

Executive summary The activities of every company working at Heathrow could impact local rivers and lakes which absorb rainwater runoff from the airport. This Code of Practice (CoP) requires every organisation operating at Heathrow to do the following: > Understand how pollution could be caused in their operational activities > Put in place effective measures to minimise the likelihood of pollution from their operational activities > Implement an effective plan to contain and clean up pollution resulting from incidents > A commitment to continuous improvement in their approach to pollution prevention All organisations operating at Heathrow Airport are expected to adhere to the requirements of the Code of Practice. Members of the Heathrow Sustainability Partnership including Heathrow Airport Ltd (HAL) shall become formal signatories. // 3

01 HEATHROW 1.0 Introduction This Code of Practice outlines a set of principles which aim to protect local land and watercourses from acute and diffuse pollution caused by operational airport activities. Heathrow Airport sits on a principal aquifer and any rainfall that falls on the site is drained into a local river and lake surrounding the airport. Airport related pollution which is released or washed onto unpaved areas and into the drainage system therefore directly affects the quality of the local environment and damages the reputation of Heathrow. It also leads to unnecessary cost and in extreme cases may result in regulatory enforcement action. Many of the requirements in this Code of Practice (CoP) are essential for Heathrow to comply with its statutory obligations and environmental permits. // 4

01 All organisations operating at Heathrow are expected to adhere to the requirements of the Code of Practice. Every organisation operating at Heathrow shall take responsibility, and ensure that their employees take responsibility, for their pollution risks. Effective action is required to prevent, or where that is not possible, minimise pollution sources. All organisations operating at Heathrow are expected to adhere to the requirements of the CoP. Members of the Heathrow Sustainability Partnership including Heathrow Airport Ltd shall become formal signatories. This CoP requires organisations to do the following: > Understand how pollution could be caused in their operational activities. > Put in place effective measures to minimise the likelihood of pollution from their operational activities. > Implement an effective plan to contain and clean up pollution resulting from incidents. > A commitment to continuous improvement in their approach to pollution prevention. // 5

02 2.0 General requirements 2.1. Commitment 2.1.1. All organisations operating at Heathrow are expected to adhere to the requirements of the CoP. 2.1.2. Organisations must conduct all of their activities in a way that prevents or where that is not possible minimises the risk of pollution. 2.1.3. All organisations commit to working openly, constructively and share best practice with each other to deliver effective pollution prevention at Heathrow. 2.1.4. All organisations commit to on-going continual improvement in their approach to pollution prevention. 2.1.5. All organisations must comply with statutory requirements and where applicable all HAL regulations, licences, permits and Operational Safety Instructions (OSIs) in addition to the requirements of this CoP. 2.2. Implementation 2.2.1. All organisations are responsible for communicating and embedding the requirements of the CoP within their respective organisations. 2.2.2. All organisations are responsible for communicating the requirements of the CoP to any companies working at Heathrow under contract to them and check that the contractor s activities comply with those requirements. 2.2.3. All organisations commit to raising awareness of the CoP and promoting its aims and requirements. 2.3. De/Anti-icing operations 2.3.1. Organisations that store or use de-icing or anti-icing products must also be signatories to the Heathrow Airport De/Anti-icing Code of Practice and comply with all its requirements. // 6

03 3.0 Preventing pollution 3.1. Drain and land protection 3.1.1. Organisations must not discharge anything into the airport s surface water drains (outside drains), without permission from HAL. These drains discharge into local rivers and lakes. 3.1.2. Organisations must ensure that their activities will not release any substances that could enter or be washed into the airport s surface water drains. 3.1.3. Organisations must not discharge any liquids onto areas of uncovered ground, such as grass, soil and vegetation. 3.1.4. Any substances released during operational activities must be contained, cleaned up and removed from the airport site as waste by a licenced contractor. The release shall be treated as an environmental incident (see section 4.0). 3.1.5. Any activities that generate effluent or waste water must take place in designated areas or with appropriate written permission from HAL. 3.1.6. Organisations working at Heathrow must prevent damage to conservation sites and understand and meet statutory requirements for managing the spread of invasive non-native plant species encountered at the airport. // 7

03 Polluting substances shall be stored in a manner that reduces the risk of pollution HEATHROW 3.2. Storage of polluting substances 3.2.1. Oil storage must be agreed with the airport operator and comply with the Oil Storage Regulations (England & Wales) 2001 as a minimum. 3.2.2. Polluting substances (except oil) shall be stored in a manner that reduces the risk of pollution and in an appropriate location agreed with the airport operator. It must: > 3.2.2.1. Be stored in fit for purpose containers or tanks and include effective measures to prevent spillages or releases caused by a failure of the container or tank, associated pipework and equipment connected to the container or tank, or from operational use of the asset. > 3.2.2.2. Include fit for purpose secondary containment (bunding) that can hold 110% of the largest container in the system or 25% of the aggregate total capacity. The total available capacity of the bund must be maintained at all times. > 3.2.2.3. Be sited to minimise any impact on the environment and at least 10m from a surface water drain or uncovered ground. > 3.2.2.4. Include an effective level of protection against collisions. > 3.2.2.5. Comply with any other applicable Environment Agency Pollution Prevention Guidance as a minimum. 3.2.3. Storage of de-icing/anti-icing products must also meet all applicable requirements of the Heathrow Airport De/Anti-icing Code of Practice. 3.2.4. Storage containers and tanks, secondary containment and any ancillary equipment connected to the container or tank must be inspected regularly to ensure it is being operated and maintained to the standards set out in the Environment Agency Pollution Prevention Guidance as a minimum. // 8

03 All organisations shall ensure that their employees are aware of the importance of preventing pollution 3.2.5. Storage containers and tanks must have permanent legible signs that state the following: a description of the contents, the capacity of the tank, the organisation responsible for the asset and a phone contact that can be reached at any time and able to respond in the event of an incident. 3.2.6. Storage areas must be provided with materials to contain leaks or spillages that are suitable for the type and volume of substances stored. Provision of these materials must be maintained. 3.3. Planning and management 3.3.1. Standard operating procedures of organisations operating at Heathrow shall make effective provision for preventing pollution and minimising the risk of incidents that may give rise to pollution. 3.4. Positive environmental behaviours 3.4.1. All organisations shall ensure that their employees are aware of the importance of preventing pollution and environmental protection in their day to day work and given the knowledge to effectively minimise pollution risks. This shall include: > 3.4.1.1. The importance of working with due care and attention to avoid accidental spillages or other sources of pollution. > 3.4.1.2. Adherence to any procedures relevant to pollution prevention, including responding to environmental incidents. > 3.4.1.3. The responsibilities of individuals in protecting the airport from pollution. // 9

03 Aircraft, vehicles, equipment and other assets must be maintained and operated to a sufficient standard to minimise releases or spills of polluting substances 3.5. Condition, maintenance and operation of vehicles and equipment 3.5.1. Aircraft, vehicles, equipment and other assets must be maintained and operated to a sufficient standard to minimise releases or spills of polluting substances. 3.5.2. All organisations shall ensure any recurrent incidence of spillages from aircraft, vehicles, equipment or other assets are investigated and resolutions implemented promptly. 3.5.3. All organisations must consider likely pollution risks and include suitable mitigation when procuring new equipment for use at Heathrow. 3.6. Waste disposal 3.6.1. Any waste or unwanted items must be placed in the correct airport bin, compactor or other designated waste container for disposal by the airport waste contractor. The bin, compactor or container must be appropriate for the type of waste being discarded. 3.6.2. Where appropriate facilities are not provided or arranged through HAL, the waste or unwanted items must be removed from the airport by an alternative licenced waste contractor. 3.6.3. Fly tipping or incorrect waste disposal shall be treated as an environmental incident (see Section 4.0). 3.6.4. It is the responsibility of all organisations to ensure their employees are aware of the correct disposal routes for waste generated by their activities and recycling opportunities. // 10

04 4.0 Managing incidents 4.1. Preparedness 4.1.1. All organisations must have effective and wellcommunicated procedures for identifying environmental incidents, responding promptly to incidents, and effective containment and clean up of incidents related to their operational activities to minimise any risk of pollution. The procedures must align with the HAL environmental incident procedures to ensure there is a coordinated and effective response to any incident. 4.1.2. All organisations are required to maintain materials to contain any spills or releases from their activities. Materials must be carried or stored close to where they may be needed, accessible, and proportionate to the scale and likelihood of occurrence. 4.2. Incident response 4.2.1. It is the responsibility of all organisations to take immediate steps to contain incidents where it is safe and practicable to do so. 4.2.2. Any company that is in control of a process or asset that has resulted in the release a polluting substance is responsible for cleaning up to remove the substance. 4.2.3. Pollution clean-up must restore the area to its original condition prior to the incident. 4.2.4. Where the deployed resources are ineffective or there is a risk to the operation of the airport, HAL will provide a supplementary response. 4.2.5. Where the incident has not been adequately contained and may lead to an impact on airport infrastructure, the environment or a breach of statutory requirements, HAL will also provide a supplementary response. // 11

04 All incidents must be reported to HAL regardless of size or scale 4.3. Reporting and notification 4.3.1. All incidents must be reported to HAL regardless of size or scale (i.e. there is no lower size or volume threshold for reporting spills etc). 4.3.2. Incidents must be reported in accordance with the current published HAL environmental incident procedures. 4.4. Incident investigation 4.4.1. Organisations shall have effective processes in place to investigate incidents in order to understand the causes and put in place effective measures to prevent reoccurrence in response to reported incidents. 4.4.2. Organisations shall share Lessons Learnt following any incident investigation where that could assist others in avoiding a similar incident. 4.5. Incident response charges 4.5.1. To align with environmental legislation and the spirit of fairness, all organisations shall work to the principle of the Polluter Pays. Only those parties responsible for incidents should bear the cost of containing the incident, cleaning up and protecting the airport and the local environment. 4.5.2. HAL will itemise any costs incurred in responding to incidents to contain and clean up or to protect, mitigate or remediate any resulting impact on airport infrastructure or the environment. 4.5.3. Costs will be charged to the responsible parties for the given incident and HAL will send a Notice in writing to confirm those charges. 4.5.4. Deliberate or repeated fly-tipping will be treated as a serious breach of this CoP and of environmental requirements imposed on organisations generally. Organisations risk having their right to access the airport withdrawn if they knowingly participate in or condone such activity. Such activities may also be reported to the Regulator. // 12

05 5.0 Communication and feedback 5.1. HAL will publicise organisations performance in implementing this CoP to members of the airport community and the Sustainability Partnership, to highlight areas of good practice and suggest where improvement is required. 5.2. Where best practice is identified HAL will seek to share this with the wider airport community to promote continuous improvement with appropriate permissions. Where best practice is identified HAL will seek to share this with the wider airport community // 13

Definitions and terms Code of Practice (CoP) A Code of Practice is a written set of guidelines issued by an official body to provide guidance in order to comply with a standard. Environment Agency The regulator appointed by the UK government to protect and improve the environment and to promote sustainable development. Environmental incident ( Incidents ) An unplanned event or malicious act that has occurred on the Heathrow Airport site and has the potential to negatively affect the environment or breach an environmental permit emission limit. Examples of incidents include: Spillage or release of polluting substances Fly-tipping of waste or redundant equipment Incorrect segregation of waste Emissions that prompt complaints from others. Fly tipping Depositing waste in areas other than defined waste bins, compactors or other waste containers appropriate for the type of waste. HAL Heathrow Airport Limited the operator of Heathrow Airport. Heathrow /Heathrow Airport The landholdings of Heathrow Airport Ltd which includes the main airport site and off airport sites. Polluter Pays principle The principle that those who cause pollution should bear the costs of responding to prevent damage to human health or the environment. Polluting substances Substances that may have a negative impact on the quality of water, land and air when released into the environment. Pollution The contamination of land, water or air by harmful or potentially harmful substances. Procedure(s) A fixed, step-by-step sequence of activities or course of action (with definite start and end points) that must be followed in the same order to correctly perform a task. Responsible party A company or companies that acknowledge or have been shown through evidence to be responsible for an incident. // 14

About the Pollution Prevention Code of Practice The Pollution Prevention Code of Practice has been developed by the Heathrow Sustainability Partnership, a group of organisations jointly committed to improving the sustainability of their business at Heathrow. For more information on the Sustainability Partnership please visit www.heathrowairport.com/sustainability // 15