Spill Alert - Issue 22

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How prepared are you? The unpredictability of a spill, the impact it can have on the environment, and on the responsible party’s business, calls for a prudent approach to regularly reassess potential risks and their consequences, and to apply commensurate levels of risk mitigation. But navigating through oil spill preparedness and response can be daunting. With over 30 years of experience in oil spill response and preparedness globally, Oil Spill Response Ltd. provides peace of mind and expert support through every phase of preparedness from planning, training and exercising, to identifying oil spill equipment requirements and response services. Managing oil spill risk and meeting regulatory requirements can be left in our expert hands. Strategically positioned in ten locations on six continents, OSRL offers an end-to-end oil spill service and integrated solutions for all of your preparedness and response needs. We’re ready to assist anytime, anywhere. In the event of an incident, OSRL members have access to five oil spill 2

response experts for five days, with one call, ensuring coordination when it’s most crucial.

In good hands OSRL Membership provides expert guidance and support across all tiers of preparedness: • Training of personnel • Range of contingency planning, consultancy and advice • Fully maintained response equipment • Exercises

Contact us Get in touch to speak with one of our representatives about managing your oil spill risk: MyOSRL@oilspillresponse.com






























Cover image: The early days of the Baniyas Refinery spill interpreted and analysed to show oil pollution by Orbital EOS © Orbital EOS

Spill Alert is the official magazine of the UK and Ireland Spill Association. It is published by the Association whose Registered Office is; 39 Chapel Road, West End, Southampton, SO30 3FG. The views in the magazine may not represent the views of the Association if the authors are not employees of it and are therefore individual views. No article may be reproduced without the permission of the Association whose contact details are below © UK and Ireland Spill Association Ltd - 2021 All enquiries for membership of the Association, editorial, advertising or attendance at events should be made to: Mark J Orr, Executive Director, UK and Ireland Spill Association Ltd info@ukirespill.org Tel: 0333 444 1890 Mob: +44 7864 707408 www.ukirespill.org

All enquiries for marine, shoreline and inland accreditation should be made to: Neil Marson, Executive Director, International Spill Accreditation Scheme Ltd neil.marson@isasaccreditation.org Tel: 0333 444 1891 Mob: +44 7889 714828 www.isasaccreditation.org


WELCOME TO SPILL ALERT WELCOME Welcome to this autumn issue of Spill Alert.

Lee Barber, Chair UK and Ireland Spill Association

There seems to be a lot happening in the industry at the moment. Face to face events such as conferences, seminars and exercises are back on. I recently attended a conference which discussed amongst other things the oil industry and the need for growth over the next decade to fund carbon zero initiatives. A lack of investment in exploration following the pandemic means that we could start to see shortfalls in energy supply. A lot of the oil majors realise that they need to fund the energy transition and the only way to do that is through exploration and production activities, so we should expect to see oil and gas activities for quite some time. There was also some scepticism that our carbon neutral goals are realistic for developing nations and that we should instead be considering a balanced energy portfolio rather than an elimination of fossil fuels. That said, there is no doubt that the world’s use of hydrocarbons is going to reduce over the coming decades and this will bring challenges which responders need to prepare for. Few emerging fuels come without risk, and I encourage all members to keep an eye on the future, gain knowledge as opportunities are there in helping customers transition as they will need our advice to do it safely and should involve us in their contingency planning.

As ever with spill response, we expect the unexpected, and talking to many members and colleagues there seems to be plenty to keep us busy. Aged infrastructure that has not had much attention these last 18 months is now back working hard and on occasions failing and a spill is the result. Hurricane Ida has shown that much of it lacks resilience in the face of Mother Nature. I suspect this is not unique to the USA. One of the safeguards getting more visibility is the interpretation of satellite imagery and importantly drones to clarify what the satellite may have picked up. These are such a useful tools and we at OSRL have for some time recognised their importance in the response toolkit. The spill in the Eastern Mediterranean has shown just how useful, yet also low cost their use can be in tracking incidents. As technology gets smarter, I can imagine that routine monitoring using satellites and drones will replace piloted fixed wing operations. Preparedness is so important and I am delighted that so many members were in Portland exercising together in early September. The weather must have made it special, even the BBC ventured out to film the event and the feedback I have had was that it was great to see companies working seamlessly together and the spill stockpile getting wet! I hope that autumn is good for you and I look forward to catching up with you at our virtual AGM.


Best Wishes

E L T More details at



INDUSTRY NEWS including the potential impact of rising sea levels on ports.

“Our Sustainable and Smart Mobility

Strategy makes clear that all transport

modes need to become more sustainable, smarter and more resilient — including

shipping. Although maritime transport has


improved its environmental footprint in

past years, it still faces big challenges when it comes to decarbonising and reducing


pollution. Based on all the latest evidence, our policies aim to help the sector confront these challenges, by making the most of innovative solutions and digital technologies. This way, maritime transport can keep growing and delivering on our citizens’ daily needs, in harmony with the environment, all the while maintaining its competitiveness and continuing to create quality jobs,” said Adina Vălean, EU Commissioner for Transport. “This joint report gives us an excellent overview of the present and future challenges related to maritime transport. The message is clear: maritime transport is expected to increase in the coming years

Maritime transport plays and will continue

% of all greenhouse gas emissions from

and unless we act now, the sector will

to play an essential role in global and

transport in the EU, behind emissions from

produce more and more greenhouse gas

European trade and economy. In recent

road transport (71 %) and aviation (14.4 %).

emissions, air pollutants and underwater

years, the maritime sector has taken

Sulphur dioxide (SO2) emissions from ships

noise. A smooth but rapid transition of the

significant measures to alleviate its

calling in European ports amounted to

sector is crucial to meet the objectives

environmental impacts. Ahead of a

approximately 1.63 million tonnes in 2019,

of the European Green Deal and move

projected increase in global shipping

a figure which is expected to fall further

towards carbon neutrality. This will also

volumes, a new report reveals for the

over the coming decades due to stricter

create new economic opportunities for the

first time the full extent of the impact of

environmental rules and measures.

European transport industry as part of the necessary transition to a sustainable blue

the EU maritime transport sector on the environment and identifies challenges to

Maritime transport is estimated to have

economy. The challenge is immense, but

achieving sustainability.

contributed to the fact that underwater

we have the technologies, the resources

noise levels in EU waters have more

and the will to tackle it,” said Virginijus

With 77 % of European external trade and

than doubled between 2014 and 2019

Sinkevičius, European Commissioner for

35 % of all trade by value between EU

and has been responsible for half of all

Environment, Oceans and Fisheries.

Member States moved by sea, maritime

non-indigenous species introduced into

transport is a key part of the international

European seas since 1949. However, even

“Innovation-driven sustainability is an

supply chain. Despite a drop in shipping

though the volume of oil transported by

opportunity for shipping to complete a

activity in 2020 due to the effects of the

sea has been steadily increasing, only eight

transformation on the same scale as the

COVID-19 pandemic, the sector is expected

accidental medium to large oil tanker spills

replacement of sails by steam. This new

to grow strongly over the coming decades,

out of a worldwide total of 62 occurred in

maritime revolution will depend on ships

fuelled by rising demand for primary

EU waters over the past decade.

developed through advanced technology and digital solutions, but also on a multi-

resources and container shipping. The joint report assesses the current

layered, fully inclusive process at national,

Against this background, the European

state of emerging maritime transport

European and international level that

Maritime Transport Environment Report,

sustainability solutions, including

encompasses safety, security and social

launched today by the European

alternative fuels, batteries and

aspects as well as environmental ones. But

Environment Agency and the European

onshore power supply, and provides a

crucial too is shipping’s role as a link in a

Maritime Safety Agency, marks the first

comprehensive picture of their uptake in

transnational logistics chain. This means

comprehensive health-check of the sector.

the EU. It also outlines future challenges

that every part of that chain — from ports

The report shows that ships produce 13.5

posed by climate change for the industry,

to the shipbuilding sector, from shippers

6 6

to the private and public financial sectors

Oil pollution: out of a total of 18

— must be included in our drive towards

large accidental oil spills in the word

Kostelac, EMSA’s Executive Director. “While Europe’s maritime transport sector

since 2010, only three were located in the EU (17 %); better monitoring,

plays a vital role for our economic well-

enforcement and awareness is helping

being, this report clearly shows that

to reduce oil pollution events even

maritime transport in Europe and the

though the amount of oil transported

entire international shipping community

by sea has been steadily growing for

have an urgent responsibility to step up their efforts to reduce this sector’s environmental footprint. While steps have been taken already based on European and international policies, much more is needed for a fundamental shift towards a sustainable maritime transport sector that contributes to secure the future wellbeing and survival of our most sensitive ecosystems and coastal areas, and the well-being of Europeans,” said Hans Bruyninckx, EEA Executive Director.


the past 30 years. EU maritime transport faces a crucial decade to transition to a more economically, socially and environmentally sustainable sector. Already, most ships calling in the EU have reduced their speed by up to 20 % compared to 2008, thereby also reducing emissions, according to the report. In addition, non-traditional fuels and energy sources, such as biofuels, batteries, hydrogen or ammonia, are emerging as

Greenhouse gas emissions: in total,

possible alternatives for shipping, with

ships calling at EU and European

the potential to decarbonise the sector

Economic Area ports generated 140

and lead to zero emissions. Onshore

million tonnes of CO2 emissions in 2018 (approximately 18 % of all CO2 emissions generated by maritime

power supply (where ships shut down their engines and connect to a power source on land while berthed at port) can also provide a clean source of energy in

transport worldwide that year).

maritime and inland navigation ports.

Air pollution: In 2019, sulphur dioxide

More details and further links to data are

(SO2) emissions from ships calling in European ports amounted to around 1.63 million tonnes, approximately 16 % of the global SO2 emissions from international shipping. Underwater noise: Ships create noise which can affect marine species in different ways. It is estimated that between 2014 and 2019, the total accumulated underwater radiated noise energy more than doubled in EU waters. Container ships, passenger ships and tankers generate the highest noise energy emissions from propeller use. Non-indigenous species: Overall, since 1949, the maritime transport sector has accounted for the largest proportion of non-indigenous species introduced into seas around the EU — close to 50 % of all species, with the largest number found in the Mediterranean. A total of 51 species are all classified as high impact, meaning that they can affect ecosystems and native species. The report also notes the limited data

at: EEA: https://www.eea.europa.eu/ publications/maritime-transport/ EMSA: http://www.emsa.europa.eu/emter

MV WAKASHIO - COAST GUARD OFFICER DELAYED ACTION AS VESSEL APPROACHED COASTLINE A Mauritius Coast Guard watch officer has come under fire in the investigation into last year’s grounding of the Wakashio ore carrier at Pointe-d’Esny, resulting in the island-nation’s worst environmental disaster. The officer, Constable Ujoodha, looked at his screen only once even though he saw that the vessel was 11.5 nautical miles from the coast when it should have been 20 nautical miles away. He did see that the MV Wakashio had deviated from its course, but ignored it and chose instead to concentrate on other administrative work. Constable Ujoodha was the officer in charge of the radar surveillance of Mauritius’ territorial waters at the headquarters of the National Coast Guard (NCG), in Fort-William, Port-Louis, at the time of the accident on July 25, 2020. However when he did ask the radar station at Pointe-du-Diable to contact the vessel. They ignored the calls….


sustainability,” said Maja Markovčić

More details at: https://lnkd.in/dHNmkat

available in assessing the full impact on habitats and species.



He is a Chartered Engineer with an MBA and has held a variety of leadership roles in global management of engineering, shipping & marine activity, and real estate, plus experience in finance, health and safety and HR. Oli worked for the last three years in workplace, human performance,

ITOPF has announced the retirement of its

and culture. He has a particular interest in

Managing Director, Dr Karen Purnell, on

developing talent and understanding the

31st December 2021 after serving some 27

role of purpose and the work environment

years with the company. Having overseen a

on delivering extraordinary outcomes.

recent Modernisation Project, Karen said

Oli responded to say that

science and the marine environment with

Oli Beavon, ITOPF’s Incoming Managing Director

the dynamic world of shipping. I have

loved every moment of my near three decades with ITOPF and I’m proud to

leave it stronger and poised to respond to the evolving needs of the future.


Karen hands the reins to Oli Beavon, a seasoned leader with diverse experience

team that I have admired for many years, and that is deeply respected for the

expertise and professionalism it provides.

gained over nearly three decades with BP.

offline this long after Hurricane

Occidental Petroleum Corp. and

Katrina devastated New Orleans

Murphy Oil Corp. were the latest

and its environs in 2005.

to report some platforms could not restart amid a lack of available

HURRICANE IDA which struck the Gulf of Mexico at the end of

While the loss of life and initial

takeaway capacity. Royal Dutch

August caused less direct damage

damage reports from Ida were

Shell Plc also has several platforms

that Hurricane Katrina (2005)

nothing like the monster storm that

out of action and is without power

that devastated the same region.

struck New Orleans 16 years ago to

at its giant Norco refinery and

However its impact is still being felt.

the day, the offshore oil sector is

chemical plant just outside of New

having a tougher time resuming this


A month on weeks on half of the

time. This is due to extensive power

crude oil output from the Gulf of

cuts and damaged infrastructure on

What has also surprise is the

Mexico has yet to resume. Just

land. It’s also a larger industry now,

disruption over such an area with

over 40% of U.S. Gulf of Mexico oil

pumping about 1.8 million barrels a

port operations disrupted across

and natural gas production is back

day before Ida compared with 1.5

the Gulf’s ports, inland waterways

online after Hurricane Ida battered

million ahead of Katrina.

disrupted and closed.

southeast Louisiana, marking an even slower comeback than in the

Refineries and petrochemical plants

wake of Katrina.

along the Mississippi River also are facing slow restarts due to flooding

8 8

I am very excited to become part of a

with a company that has enabled me to realise my dream of combining a love of

I am privileged to have found a career

More than a week after the

and infrastructure damage meaning

Category 4 storm made landfall,

offshore production platforms have

about 77% of the region’s offshore

nowhere to send their oil if they

production remains shut, according

resumed immediately. Getting back

to the Bureau of Safety and

to full output requires crude flowing

Environmental Enforcement. By

freely again through the Gulf

comparison, about 60% of oil

Coast’s vast network of pipelines,

output and 40% of gas was still

storage terminals and refineries.


X-PRESS PEARL UPDATE The X-Press Pearl, departed Hazira, India on May 15 and was heading eastbound on the last leg of a voyage from the Middle East. Whilst sailing a fire started in one of its containers. She requested permission to return to India which was rejected. However, Sri Lankan authorities agreed to respond to a distress call on 20 May as the vessel anchored 9.5nm outside the port of Colombo awaiting terminal space. She was carrying 1486 containers which included 25 tons of Nitric Acid as well as cosmetics and other potentially hazardous chemicals. . Whilst extensive firefighting efforts were undertaken to contain the fire its eventually spread to the whole vessel. SMIT Salvage were appointed to manage the incident and once the fire was thought to be extinguished on several occasions it flared up eventually consuming the whole vessel. With debris from the fire and its container’s contents washing onto Colombo’s pristine beaches on 23 May the Sri Lankan authorities demanded the vessel be towed further from the shore and into deeper

waters. However, with the fire raging this was not possible. With the fires extinguished the salvage and port authority teams were able to get on board on 1 June and agreed that the tow could start. However whilst undertaking a slow tow on 2 June the water flooded vessel’s stern struck bottom and the tow was abandoned.

Since then, the rest of the vessel has sunk. The vessel has appx 300 metric tons of bunker fuel on board and there are fears that as the vessel sinks and maybe starts to break up that this and other chemicals retained on board despite the fire will be released into the local waters. As such the Sri Lankan Navy and Coast Guard remain on the scene. Speaking on CNA in Singapore, Shmuel Yoskovitz, the CEO of X-Press Feeders, the owners of the ship, said he wanted to apologize for what has happened. “I’d like to express my deep regrets and apologies to the Sri

Lankan people for the harm this incident has caused to the livelihood and to the environment of Sri Lanka,” said Yoskovitz. X-Press Feeders brought in representatives of ITOPF and Oil Spill Response to monitor and assist with any clean-up if there is an oil leak. Oil Spill Response have also been contracted by the Sri Lankan Government to assist in the clear up of the debris from the containers and have staff permanently deployed on the task. In July the insurers of X Press Pearl made an initial payment of $3.6 million to the Sri Lankan Government and further claims are likely but all take time to compile and process. At some point the vessel will have to be recovered with the risk of further contamination from container debris in the hold and possible fuel from its bunker tanks. This regrettable incident is likely to remain in the headlines for some time. More details at: https://www.maritimeexecutive.com/article/xpress-pearl-slowlysettles-to-the-bottom


WIDER ISSUE RELATED TO X-PRESS PEARL INCIDENT FOR THE INDUSTRY TO CONSIDER The X Press Pearl was a newly launched feeder vessel collecting containers from smaller ports until full and then discharging them at a major container port. It was modern, well equipped and professionally manned. It has been stated in the media that the fire was caused by a leak, of properly declared, but incorrectly packed nitric acid. This is corrosive, toxic and flammable. X Press Pearl was carrying 25 tonnes of it. It is likely that this was being shipped to manufacture ammonium nitrate, a popular fertiliser. The leak was first identified in Hamad Port, Qatar which refused the ship’s request to discharge the container. The ship made the same request later to Hazira Port in Gujarat, which was also denied. Colombo Port, Sri Lanka also refused entry but agreed that she could anchor offshore where she now rests. All are modern and well equipped ports and claimed they lacked the manpower and equipment to discharge the leaking container. Really…. Or would accepting the vessel, creating an exclusion zone, allocating resources to it just interrupt their commercial operations. 10

Probably. However there are wider issues here and X Press Pearl is an unfortunate victim of this: The International Maritime Dangerous Goods Regulations control handling and storage of hazardous goods at sea. – It needs to be robustly enforced which it is not at the moment. Shippers who accept dangerous goods cargos should ensure correct identification of contents, adequate storage and packing so it is safe to carry at sea. Stronger enforcement and legal action against those states where the cargoes were loaded and the supply chain that permitted There is also a change of attitude. Traditionally ships in distress had ‘freedom of ports’ to seek shelter. However, states may deny this if they pose a risk to the environment or the safety or security of its people. This will probably now be cited as the reason for denial of entry to X Press Pearl in Qatar and India. The IMO recognised this in 2003 and adopted resolutions creating places of refuge for vessels in distress. These are sheltered waters with some support facilities nearby but it does not avert the environmental risk. In X Pres Pearl’s case it did receive support from the

authorities, however there is a difference to support that can be given to a vessel at anchor and that the can be given to a vessel alongside where firefighting, water management, cranage and medical support can more easily be given and any environmental impact contained in the port. These were denied X Press Pearl and the loss occurred and its consequences are been and will be felt for a long time. It is estimated that there are 150,000 annual cases of undeclared or misdeclared dangerous goods capable of causing fires. We all probably suspect that that it may be more as the only ones we generally hear about are drug hauls. With busy shipping routes, time pressures, commercial imperatives etc it seems a lot but when 226 million containers are shipped each year maybe that is reasonable. We have recently seen incidents in ports in Dubai and Chile both with incorrectly declared container loads. Xpress Pearl may have been an exceptional incident but the lessons to be learned should prompt change. Imagine if this has been on board a vessel carrying 20,000 containers in mid Atlantic

BANIYAS REFINERY SPILL AFFECTS A LOT OF EASTERN MEDITERRANEAN After satellite imagery highlighted a fuel spill off the coast of Syria and tracking initially north of it, Syrian officials admitted that a tank filled with 15,000 tons of fuel had been leaking since August 23 at a thermal power plant on the Syrian coastal city of Baniyas. They said they had been able to bring it under control. Baniyas is Syria’s largest refinery. Satellite imagery analysis by Orbital EOS tracked the oil spill from source to its location (23 Sep) slowly dispersing just north of the Turkish Cypriot coast. The oil spill was larger than originally thought, covering around 800 square kilometres (309 square miles) -- an area around the same size as New York City. The company told CNN Tuesday evening that the oil slick was around 7 kilometers (4 miles) from the Cypriot coast. The Cypriot Department of Fisheries and Marine research said that, based on a simulation of the oil spill’s movements and meteorological data, the slick could reach the Apostlos Andreas Cape. It also said it would be willing to assist in tackling the spill. Apostlos Andreas Cape is in the Turkish-controlled north of the divided island and sits just over 130 kilometers (over 80 miles) west of Syria’s Baniyas. Photos circulating on social

media for more than a week have shown the oil slick along the coastal areas of Syria’s Baniyas and Jableh, and locals have warned of a potential threat to marine life. A resident in Baniyas, who spoke to CNN under condition of anonymity, said much of the coast had been polluted. “People did not need this, it is already hard to make a living here and this certainly affected the lives of many families and made them lose their income” the resident said.

the state-run Anadolu news agency. Baniyas refinery is the main source of Syrian fuel products and is essential to keeping the war-torn country powered. This is the second major oil spill in the eastern Mediterranean this year. In February, an oil spill off the coast of Israel devastated the country’s beaches and left tar deposits across the Lebanese coast. in February, Israel bore the brunt of an enormous oil discharge which emanated from a Syrian oil tanker in the Mediterranean. Large amounts of heavy tar began washing up on the Mediterranean coast after a storm. Over the following days, beaches all along Israel’s Mediterranean coast were contaminated and wildlife was severely affected.

“The government only sent teams with sponges and water hoses; they do not have the capacity to deal with this.... you cannot clean the sea with sponges,” the resident added. Turkey, which shares a border and coastline with Syria, has also been drawn in to contain the spill. “We are taking the necessary measures by mobilizing our resources to stop any chances of the spill turning into an environmental disaster,” Turkish Vice President Fuat Oktay told

An investigation launched by the Israeli Environmental Protection Ministry indicated that a leak of “tens of tons of crude oil” had taken place between February 1 and 2. The Syrian-owned tanker “Emerald — which was not insured — had spilled the oil approximately 130 kilometers (80 miles) out at sea, according to the Times. At that time, the London-based International Oil Pollution Compensation Fund agreed to pay damages related to the spill.



European Maritime Safety Agency (EMSA) has quietly been building its drone capacity which enables it to deploy drones in various European states concurrently at the request of its member states. This summer EMSA’s remotely piloted aircraft have been monitoring the level of sulphur oxides released by ships transiting the Strait of Gibraltar, one of the world’s busiest shipping lanes. The operation carried out by the Spanish General Directorate of Merchant Marine – under the direction of the Spanish Ministry of Transport, Mobility and Urban Agenda – marks the first time these emissions have been monitored by drone outside the special designated emission control areas in Northern Europe. The flights have been in operation since mid-July from a base in Tarifa and will continue until the end of October. The project designed to test the effectiveness of drones in measuring pollutant emissions from ships was set up by the Spanish Ministry of Transport, Mobility and Urban Agenda (MITMA), in collaboration with the Algeciras Maritime Captaincy and the General Directorate of Merchant Marine. Using

12 12

EMSA’s remotely piloted aircraft systems (RPAS), the goal is to detect sulphur oxide emissions above a certain level indicating a possible breach of the International Convention on Maritime Pollution (MARPOL – Annex VI). The current limit for sulphur oxide in ship fuels is 0.50% by mass. The aircraft used is a CAMCOPTER® S100 and it is under contract to EMSA from the consortium of Nordic Unmanned, Norce and UMS Skeldar. It has several features making it a useful tool for the service, including the ability to take off and land vertically from an area less than 25 square meters, flight endurance of over six hours and a range of more than 100 km. To help detect the gases generated by fuel combustion and expelled through ship funnels, the aircraft is equipped with gas sensors and cameras that cover both optical and infrared spectral ranges.

Since 12 July, the RPAS has been carrying out daily two flights with an average of ten inspections per day. Current figures show that of 294 vessels controlled some 27 were found in possible breach of the limits of sulphur content in their fuel. The measurements and records are automatically encoded in the information exchange system which triggers an alert in the EMSA THETIS-EU database. While this does not confirm noncompliance directly, it does help port authorities target ships for inspection and proceed with the lab testing necessary for any eventual sanctions. Drones and aerial surveillance will play an increasing role in environmental protection in the future – something that should be welcomed. EMSA has been at the forefront of some of these developments. More information at: www. emsa.europe.eu

NEW TECHNOLOGIES FOR GREENER SHIPPING Somewhat late to the party in our view, however the International Maritime Organisation (IMO) has chosen the above as the World Maritime Theme for 2022, reflecting the need to support a green transition of the maritime sector into a sustainable future, while leaving no one behind. The IMO Council, meeting for its 125th session (28 June-2 July), endorsed the theme following a proposal by IMO Secretary-General Kitack Lim. Mr. Lim said the theme would provide an opportunity to focus on the importance of a sustainable maritime sector and the need to build back better and greener in a post pandemic world. “IMO actively supports a greener transition of the shipping sector into a sustainable future, and showcases maritime innovation, research and development, and the demonstration and deployment of new technologies,” Mr. Lim said. “In order to achieve these objectives, partnerships are key, as they allow all parties involved to share and distribute information on best practices and to access resources and

general know-how in support of the transition of the maritime sector into a greener and more sustainable future. This theme will allow for a coordinated outreach and communications campaign by all stakeholders to highlight IMO initiatives to make shipping greener”, Mr. Lim said. The theme will allow for a range of activities to delve into specific topics related to promotion of inclusive innovation and uptake of new technologies to support the needs for a greener transition of the maritime sector, especially in the context of developing countries, and in particular the small island developing States (SIDS) and least developed countries (LDCs). The theme is linked to the United Nations Sustainable Development Goals (SDGs), particularly SDGs 13 and 14 on climate action and sustainable use of the oceans, seas and marine resources; SDG 9 on industry, innovation and infrastructure; and SDG 17, which highlights the importance of partnerships and implementation to achieve these goals. IMO’s Department

of Partnerships and Projects (DPP) was established in 2020 to serve as the gateway for developing partnership opportunities with a wide range of external partners, including IMO Member States, UN agencies, financial institutions, NGOs, IGOs and the private sector. Decarbonization, marine plastic litter and biofouling are among the topic areas already being addressed by the major projects of IMO, including GMN, GloFouling Partnerships, GreenVoyage2050 and GloLitter Partnerships. All of these projects aim to support and promote innovation and green technologies. More information at: https://www.imo. org/en/MediaCentre/ PressBriefings/Pages/ WMT2022.aspx





ADLER AND ALLAN BOLSTERS SUSTAINABILITY OFFERING Adler and Allan has launched several new services and strategies to reflect its mission to help clients reduce environmental risk and impact. Alongside these initiatives it has appointed a new Sustainability Manager to the business to embed sustainability at the heart of its growth strategy. Dan Ellis joins the business from Delta-Simons where he was Principal Sustainability Consultant. He brings with him a wealth of experience in the sustainability, carbon reduction and ESG sphere, having supported some of the world’s largest manufacturers, retailers, technology companies and investment funds to reduce risk and improve positive impact. Alongside the appointment, Adler and Allan is launching a series of services to help its clients to understand their environmental impact, decarbonise operations and take positive action towards a sustainable future. Net-Zero Strategies and Action Plans Carbon Offsetting Streamlined Energy and Carbon Reporting (SECR) Energy Audits Transport Audits TCFD & Non-Financial Disclosures Environment Social Governance (ESG)

Adler and Allan, has also recently launched a new market leading sustainability tool to estimate the carbon emissions of any project unique to the client’s industry, offering its customers a ‘greener alternative’ when providing proposals. The tool allows full transparency of the CO2 emissions associated with all activities required in a project to allow clients to select from at least two remedial options; one being a reduced carbon alternative. The Environmental Consultancy team has built the tool using DEFRA conversion factors and is the first one of its kind in the industry.

on our carbon footprint via the Carbon Reduce Scheme in accordance with ISO 14064-1:2006, achieving gold certification status.

As businesses look to achieve decarbonisation through greener fuels and new energy sources while managing their existing legacy infrastructure to reduce their environmental impact, supply partners need to evaluate their offering. Adler and Allan understand the importance of its own sustainability strategy as part of the supply chain. Ellis said: “Since 2012, we have measured, managed and reported

For more information about Adler and Allan’s sustainability solutions on its website: https://www.adlerandallan.co.uk/ environmental-consultancy/net-zerosolutions/ For more information contact: Jen Patterson, Marketing Manager, 07843 343816 Jen.Patterson@adlerandallan.co.uk

“Over the past five years, we have cut our carbon intensity by over 14% per full-time equivalent (FTE) and realised a 4% reduction in our absolute emissions, despite significant business growth. We are committed to leading the way on achieving Net-Zero; and using our expertise in energy, fuel, waste, water and ecology help others to make the world a little better than it was yesterday.”



acquisition enables Lehane Environmental

Lehane Environmental started out as a

to avail of the full resources of an

family business back in 1974 and retained

International Waste and Environmental

the strong relationships and commitments

Response PLC.

to deliverables since then which are synonymous with family businesses. It is

Lehane Environmental are delighted to announce that the AMBIPAR Group PLC has acquired Lehane Environmental & Industrial Services Ltd. The operations and people, including Martin Lehane, EHSQ Director, will remain the same so you can be assured of our continued quality service. The


The Lehane Environmental Team are

fitting that Ambipar also started as a family

excited about the opportunities which this

business, and although now a PLC, the

acquisition provides and look forward to

Borlenghi family today still manage it and

presenting some of the benefits of this to

continue to foster these family business

you, our valued Client, over the coming


period. Together we will leverage our combined industry expertise, relationships

More details at: www.lehaneenvironmental.

and infrastructure to create new job

com and www.ambipar-response.com

opportunities and help to position our company as Industry Leaders.


BRITISH STANDARDS REPRESENTATION Over the last year we have managed to sponsor representation of the Association within British Standards Institute.

It was great to have a stand at Contamination Expo and to see many members visit or exhibit at the show. This series of events (Recycling and Waste Management, Flood Expo, Contamination Expo) etc have been a staple in the event diary for many a year and it was great to attend and exhibit at a face to face

Shirley Miles of Darcy Committee responsible for Wastewater Engineering B/505/08 Separators. This covers BS EN 858 Part 1 and 2 oil separators and BS EN 1825 Parts 1 and 2 Grease separators. This is responsible for the UK input to CEN/TC 165/WG

event again. We had a stand adjacent to the Hazardous Materials Theatre where Dr Jon Burton, Oracle Environmental gave a talk on Spill Response to Biofuels and Neil Stothert, MD of RSK-RAW gave a talk on The Future of Unrenewable Spill Response in a Renewable Energy World. Attendance at the show fluctuated but it was great to see members attend both talks and it was encouraging so see so many members visit giving us a chance to catch up and meet face to face – many newer members for the first time! We shared the stand with International Spill Accreditation Scheme so it gave Executive Dirtector, Neil Marson an opportunity to put faces to names and update accredited members on the recent improvements to the scheme. OAMPS, our event sponsor attended on 22 September only.

Overview Under the direction of B/505, is responsible for the development and maintenance of standards in the engineering aspects of wastewater collection, drainage and treatment up to the point of disposal. Subjects covered include pipes and fittings, manhole and other access covers, gullies, separators, pipe laying technology, waste outlets and traps, renovation and repair of drains and sewers, drainage systems inside and outside buildings, sewer and drain cleaning operations, positive and negative pressure systems, wastewater treatment plants and in liaison with B/504. Rob Futcher of Commercial Fuel Solutions represents the Association on RHE/13 - Liquid fuel firing Categories: Burners. Liquid and solid fuel, Containers and tanks. Stationary Central heating, Industrial furnaces. General Energy and heat transfer engineering. Heaters. Gas Burners. Gas fuel. Ergonomics. Water heating. Metal corrosion. Manufacturing engineering. Petroleum products and natural gas handling equipment. Heaters. Liquid fuel. Occupational safety. Industrial hygiene Burners. Boilers Overview: Under the direction of the Standards Policy and Strategy Committee, is responsible for standards for liquid fuel burning equipment and the UK input to the work of CEN/TC 46 Oil stoves, CEN/TC 47 Atomizing oil burners and their components - Function - Safety – Testing and ISO/TC 244 Industrial furnaces and associated processing equipment. Rob is after feedback on BS 5410-3 Code of Practice for liquid fuel firing which is being redrafted at the moment. If you wish to have input please contact Rob on rfutcher@commercialfuelsolutions.co.uk Both will give an update on the work they have been doing in the December issues and every six months thereafter.



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Devitech, part of the Darcy Group, are the ideal partner to help electrify your vehicle fleet and adapt to the changing needs of your workforce and visitors. With grants available for up to 75% of cost (capped at £350 per unit and with businesses allowed to claim up to £14000), installing electric vehicle charging is easier and more Devitech conduct a free site survey and quote You complete and online application form

Grant voucher awarded and passed to Devitech Devitech carry out installation and test report. Devitech have national engineering coverage and installations are compatible with all leading manufacturers and models, Devitech undertake all design work from inception to installation and assistance with your grant application. For more information contact: 0800 0370 899, devitech@ darcy.co.uk

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MV WAKASHIO: THE FALLOUT AND LESSONS TO BE LEARNED. As a spill and pollution response trade association it has been fascinating to follow the MV Wakashio grounding and subsequent loss though social media and in the 4 webinars we have so far run. The media coverage has been reasonably balanced with the exception of one journalist at Forbes who seems never to have seen a spill pad in his life or been to sea in anything other than the Manhattan ferry. We have benefitted hugely from firsthand reports from those in Mauritius which have been honest and insightful. Whilst tinged with some frustration, all have commended the fortitude of the affected population and praised the way they have rallied together to do their bit to ‘save their island’ and the energy with which they approached the remedial works. We hope we have delivered our webinars and coverage in a balanced manner. It is certainly not our position to judge. We would appreciate feedback on that point. There is no doubt that this was one of the most significant incidents in shipping in 2020 as it was so surprising that a 300m bulk carrier should choose to be where she ended up, running aground on a reef with visible surf, in daylight.

So why did it happen? I am not sure we will ever truly know what was happening on the bridge at the time of the grounding. It is down to the inquiry to find this out. To date it has failed to do so. However we have had confirmed some of what the media have reported. The Captain agreed to change the approved route to pass the Cape of Good Hope to allow the vessel to close the island so that the crew could connect to family and friends using their phones. From the inquiry we have had confirmed that there was a birthday party on board and the Captain left the bridge to join that, leaving the First Officer in charge. When he came back to the bridge the First Officer was in charge of navigation and then, with the Chief Engineer also on the bridge, the vessel first struck the reef. The Captain has stated that

the Chief Officer was in charge of maintaining safe navigation and the error was his. Not surprisingly the First Officer says otherwise. The Court of Inquiry has again refused the Captain and First Officer bail as it would appear to believe that both have responsibility for the errors. Ultimately the Captain is the man in charge so should have ensured, knowing that they were entering shallow waters, that the vessel was safely navigated. There is no confirmation that the mapping software in use was inappropriate for the area they were navigating. However, the initial investigation by the Panama authorities indicated that it was not set at the right scale to show the hazards around the vessel and that the charts were not the current version. We have also heard that the Mauritius Coastguard were slow in reacting to the MV Wakashio being off her filed course. Having entered territorial waters one would have expected the vessel to be challenged by the Coastguard, particularly as she was heading straight toward the coast and not tracking south west as would be expected if she was routed to pass south of Cape of Good Hope. Due to a lack of attention to the radar plot by the duty watchkeeper no contact was made until after much delay the deviation was noticed and the Mauritius radar station endeavoured to contact the vessel as it approached the shore but no calls to the vessel were answered. We also know that two helicopters should have been available that could have intercepted the vessel. However, neither were actually available as one was under maintenance and spare parts for the other had not been delivered. We also know that following the grounding the ballast pumps, used to move fuel and liquids around the vessel, were not working. This would have meant that there was no way the vessel could alter the trim of the vessel to lift the bow to enable it to go astern


and free itself. With this not being an option, and no tug available, the fate of the vessel was sealed unless urgent help was provided. The heavy weather, over the subsequent 5 days, saw the vessel move 500m around the reef eventually burying her stern on it and the bow being pushed around by the wind and the surf rebounding off the reef. Either in the original grounding or during this heavy weather the engine room flooded and the stern has never left the reef. Its removal started in November and should have been completed by March. However unusually stormy weather has meant that work has stopped and will not recommence until late September at the earliest.

The result With the stern flooded and sat on the reef and the rest of the vessel buoyant the continual movement of the vessel started to pull it apart. The first leak of oil started to appear around the vessel on 6 August and was rapidly blown into the shore during subsequent days. In all 800-1000 tonnes of Very Low Sulphur Fuel Oil was lost off the vessel at this stage from the starboard side bunker tank. Tankers were alongside the vessel on 8 – 10 August pumping off the remaining fuel oil on board and also offloading the IBCs that were on the deck full of previously transferred fuel oil. Cracks started to appear around Cargo Hold No. 8 on 9 August and on the 10 August the Prime Minister told the nation that the: ‘Wakashio is likely to break up and the worst case scenario is likely to happen as the boat will fall apart’ . On 12 August the salvors stated that they had recovered as much bunker fuel as they could. On 15 August the Mauritius National Crisis Committee, announced a crack in cargo hold No. 8 to the starboard side of the vessel worsened at 2 pm local time on 15 August 2020. “At around 4:30 pm, a major detachment of the vessel’s forward section was observed,” the committee said in a statement. It estimated that 90 tonnes of fuel were still on board at the time of the separation. The bow section was taken under tow.


With the separation of the bow from the stern section there was a further loss of oil and liquids.

The bow section was deliberately sunk at sea on 24 August in an area agreed by the Mauritius authorities. This left the stern stuck on the reef and its presence further damaging it by the movement of the vessel against the reef. Oil slowly spread up to 30km from the point of loss along the southeast coast of Mauritius across protected areas, RAMSAR areas, and site of special scientific interest. The Government closed off all fishing and sea based recreational areas; closed, albeit most temporarily, all aquaculture sites; threatened countless rare species and threatened the mangrove swamps.

The response The Mauritius POLMAR plan was rigidly applied and was only initiated when product was lost from the vessel. This decision was no doubt based on the expectation that the vessel could be refloated off the reef with the assistance of SMIT Salvage who were appointed by the ship owners to recover the vessel. We do not know what discussions took place in Government. Apart from protection of the Blue Bay Marine Park which utilised just about 45% of the national stockpile little concurrent action appears to have been taken prior to the breach of the vessel and the loss of fuel from it. However, this site was not downwind or down current from the Wakashio. The rest of the stockpile was deployed to protect the Ile aux Aigrettes, Mahebourg Waterfront, Riviere des Creoles, Pointe d’Esny and directly astern of the Wakashio as show in this breakdown and the date by which they were deployed:

The stockpile of 3200m was surprisingly small. However once the POLMAR plan was initiated it was supplemented by spill equipment from the French stockpile in Reunion that arrived on 10 Aug, somewhat later than ideal. However it must be borne in mind that on 31 July SMIT salvage stated publicly that they were confident of the vessel’s recovery. A week later the first fuel was lost and little was in its way to contain it so recovery could be undertaken. Once the POLMAR Plan was initiated the stock held in Reunion, just 200 nm from Mauritius, was accessed there was a plentiful supply of booms and absorbents supplemented by supplies from Japan and India. It is surprising that, as a preventive measure, that this was not accessed earlier event if it was not eventually used! In the apparent absence of any government leadership the members of the public, with encouragement from NGOs and environmental groups on the island, mobilised in their tens of thousand to use local resources to build booms. Bagasse booms, made of organic materials like leaves from sugar cane, straw, by products from other crops, wrapped in plastic sheeting and kept buoyant with plastic drums and marine floats, we produced in huge number over several days in early August. These booms, a recommendation in many POLMAR Plans, were deployed by fishing boats to catch pollution from the Wakashio at sea and prevent it from reaching the shore. In all 50km, yes, FIFTY kilometres, of boom were manufactured and deployed by local people. This compares with 3200m deployed by the Government. There is no doubt that these booms protected much of the Mauritius coast from the fuel oil lost from the Wakashio and importantly held the product at seas as opposed to it washing on the shore where it is much harder to recover. At this stage the response was being undertaken by Le Floch Pollution appointed by the ship owner and Polyeco appointed by the Government with separate areas of responsibility.

The clean up We have covered the response and clear up in detail through webinars that may be viewed at: However much of the shioreline clean up was undertaken by Polyeco employing nearly 300 local people, many being fishermen who could no longer fish as access to their waters was closed.


How it is now packaged


Oily Sludge Contaminated Absorbents Empty Containers and IBCs Contaminated soils and sand Other contaminated materials (booms, PPE, plastics, debris, vegetation, plastic bottles, hair used in the bagasse booms) Hazardous materials

2714 tonnes of waste. 4045 big bags of waste. 241 IBCs containing waste. 5108 sealed 205 litre drums of waste.

By sea to Polyeco Greece

The clean up proceeded under the supervision of the Ministry of the Environment and proceeded smoothly with Not surprisingly, there was a lot of waste comprising the following waste streams

Booms Used


Conventional oil spill booms from stockpile


Bagasse booms made by local volunteer population with NGO support


This continues to employ the following resource: 2 hazardous waste experts 4 waste management supervisors 6 foremen and 55 staff

Preparation and Planning POLMAR plans should not be so rigid as to exclude preventive action. Had more extensive booming and deployment of skimmers and recovery vessel prior to the loss of product from the vessel, the impact on the shoreline may have been reduced. POLMAR Plans need to be regularly practised, was the Mauritius plan exercised in anticipation of an incident like MV Wakashio and if so, why was the response delivered in such an unstructured manner until external agencies got involved. Stock of in situ equipment need to be examined. Some 3500m of conventional boom were deployed, yet over 50km of citizen made bagasse booms were deployed. Whilst difficult to recover and dispose of bagasse booms did prevent a larger incident. Any MARPOL incident should have a communication plan which should cover social media, press, TV to ensure local people are well informed. This incident demonstrates that when a vacuum of information exists its will be filled. In a major incident, which this became, the international reputation of a nation is under the spotlight. The lack of clear and regular government communication throughout has unified political dissent

making it harder for them to manage the island’s recovery from COVID and Wakashio.

Effectiveness of external funding? Two of the funding support packages that the Mauritius Government received was the creation and participation in MASE (Mauritius, Seychelles, Madagascar, Comoros, Djibouti) €37.5M and Marine Highway Development and Prevention Project $11M. What benefit did they have to the management and execution of this incident?

Regional capability On such a busy shipping route (which is forecast to increase by 20% over the next decade) why is there not a regional stand by tug(s) able to handle very large vessels when they get into difficulty. Waiting a week is surely too long and contributed to the loss of the vessel.

Design What secondary containment is there for fuel tanks inside the hulls of vessels other than tankers, like MV Wakashio.

Legal Authority MV Wakashio is alleged to have ignored coastguard calls to confirm her intentions. How are nations to respond to ‘rogue vessels’ and can military intervention be taken in such incidents to prevent damage which ultimately resulted in loss of life (the crew of the tug MV Sir Gaetan Duval on 31 Aug 20).

International Support The international support the island received was key to organising a coordinated response. However, it took weeks of valuable time to organise and deploy and with COVID restrictions over a month to be effective. With shipping posing a consistent risk why is there not a regional task force ready to go?

Insurance Owner and charterer insurance seems to dictate the scale of response. Is this not an outdated tradition which slows effective and comprehensive response that need to be reviewed?


MARITIME AND COASTGUARD AGENCY EXERCISE SEPTEMBER 2021 The Maritime and Coastguard Agency (MCA) conducted a week of training and exercises over the week of 13th to 17th September from Portland Port, Dorset. The week-long event was to exercise containment and recovery equipment from the UK national counter pollution stockpile. The exercise provided an opportunity for many response organisations to work together. Participants included the MCA, MOD, MMO, Portland Harbour Authority, Ambipar Response, Adler & Allen, Oil Spill Response Limited (OSRL), Dorset Adventure Cafe, EagleVista Aerial Imaging, Prolectric Services and Northern Rib Hire.

On Tuesday the NOFI Current Buster 6 was deployed, demonstrating an at-sea response capable of operating at an effective speed up to five knots. The system was the focus of BBC News and became the subject of a Cbeebies educational programme for young children.

Numerous agencies and government departments sent observers to gain a better understanding of the UK national response capability and the counter pollution function of the MCA.


Under close supervision by MCA and Ambipar personnel, the children’s television personality, Grace Webb operated the Current Buster 6 boom reel as part of her documentary series “Grace’s Amazing Machines”. Portland Port were great hosts for the event and became involved from the

first reconnaissance visit through to the closing debrief. Use of the sheltered Port allowed for equipment to be deployed in a calm working environment before participants re-deployed equipment in open water. In addition to exercising response strategies, the event was used for training and coaching. Having many organisations together for the exercise added to the positive experience and demonstrated the UK ability to mount a safe and successful response. As the first major exercise event since the start of the pandemic, spirits were high and even the weather helped make it a successful week.


Glimpse of part of the new ISAS website COMING SOON!

ISAS - DRIVING STANDARDS FORWARD Now that we have seen the lifting of the COVID restrictions, the International Spill Accreditation Scheme (ISAS) Team are now back into action and able to resume the essential work of promoting and accrediting both marine and inland Oil Spill Response Operators (OSRO’s) to meet growing demands of standards within the industry. ISAS are seeing a steady flow of companies now joining the scheme who recognising the importance of being accredited to demonstrate to their clients that they are working to a set standard. Working closely with companies ISAS undertake a standardised audit of their capabilities within the category/s applied for by the company, the Scheme is made up of eight different categories covering both on land and marine response, all successful companies are accredited for a three-year period, subject to an annual review. With more Stakeholders seeking to work only with 22

accredited contractors, the Scheme is an essential part of a company’s toolbox and demonstrates to prospective clients that the company has achieved a pre-described standard within their field of operations. ISAS was able to, recently, join forces with UK and Ireland Spill Association at the first live Contamination and Geotech Expo at the NEC Birmingham since COVID shutdown ended. Whilst the number of visitors was not as high as previous years there was a steady flow of good quality enquiries from those attending the exhibition, with strong positive interest being shown in the ISAS Accreditation Scheme, all these enquiries are now the subject of follow-up action, and we are looking forward in welcoming those companies into the Scheme in due course. In addition, our web-designers have been busy building the new ISAS website which we hope to launch within the

next month, a key change to the site is that accredited companies can be searched more specifically with their details and location linked into google maps, this should assist prospective clients in identifying the nearest and most appropriate company relevant to their needs. Meanwhile our Assessors are busy preparing for their next run of field work which will involve visiting companies and undertaking new audits or carrying out the annual re-assessments of current members, they will soon be contacting those companies who are becoming due to be assessed, to arrange dates for their visits. Further information on the work of ISAS and the Scheme can be found on the ISAS website (www.isasaccreditation.org ) or contact Neil Marson, Executive Director on neil.marson@ isasaccreditation.org or Mobile 07889714828.


OIL SPILL RESPONSE LTD Wherever you go in the marine spill industry you meet people whose CVs seem to have Oil Spill Response Ltd (OSRL) on it somewhere. Their imprint on the industry is significant and its culture of quiet professionalism weaves its thread throughout the industry and in many areas they set the benchmark for the industry which all seek to follow.

Members receive; support in risk

The oil companies, whose oil it was

management, staff and management

that spilled, were heavily fined and

training, OSRL incident management

their reputations adversely affected. To

support and deployment of OSRL resource

mitigate further losses, they started to

in support of exercises and, importantly,

play a more active role in developing

incidents wherever they occur in the world.

their own response organisations. In the UK, British Petroleum (BP) set up a large

For members it is a fixed price contract

oil spill response base in Southampton

with some variables related to deployment.

and established, what is now Vikoma, a company manufacturing oil skimmers and

For OSRL it means they know their income

retention booms on the Isle of Wight.

but do not necessarily how much they are With oil companies becoming energy

going to need to spend to support their

companies and the necessary reduction

members. Consequently, it is not a blank

in the use of hydrocarbons as the


Enroute to a wireline logging job in Bu Hasa field in Abu Dhabi, UAE

world pushes to net zero, I was keen to understand how OSRL are preparing for

However, they have more experience than

this. So, it was a pleasure to sit down, face

any business in the industry in the number

to face, for a couple of hours with Robert

of unplanned events and incidents they are

Limb, its CEO, to discuss OSRL and his

going to have to deal with in an average

thoughts on the future of his business and


amongst various oil companies and in

the industry in general. There is a myth that runs through the

Subsequently the BP base was syndicated

This unusual ownership and membership

1985 Oil Spill Response Ltd (OSRL) was

structure is a legacy of OSRL’s formation.

formed to continue this pioneering work with funding support from four other

industry that OSRL is different to every other business in the industry in that they

A succession of oil tanker losses in

international oil companies. This is the

have a pot of gold, the oil companies, who

the late 1960s and through the 1970s,

basis of the existing member/shareholder

pay for everything they do.

caused considerable environmental


harm and negative publicity for the oil They do not. OSRL has 162 members

companies who owned the vessels. It also

Consequently, in March 1989 when the SS

divided into three categories of

demonstrated that governments in general

Exxon Valdez struck Bligh Reef in Prince

membership https://www.oilspillresponse.

had little defence against large spills.

William Sound in Alaska spilling 10.8 million gallons of crude oil, OSRL staff were

com/membership/our-members/ :


These significant pollution incidents,

amongst the first response organisations to

occurring in relatively close succession,

arrive at the incident from outside Alaska.

– they are shareholders and are primarily

caused Europe to wake up to the risk it

companies involved in oil exploration and

carried in allowing lightly regulated vessels

(For keen followers of oil spill response

production. These members are generally

to navigate their waters with inadequate

history you can read a more in depth

oil companies or are working directly

maritime pollution incident plans as

article here in Spill Alert Issue 20 https://

providing services for them; e.g. Trafigura.

demonstrated by the response to each of


This is where the majority of OSRL income

these incidents. Government responded


comes from.

with tighter legislation.

ASSOCIATE MEMBERS – they pay a membership fee based on the level of risk eg a tariff per platform, per refinery, per vessel etc; A good example of membership here is: Associated British Ports Southampton or Prax Lindsay Terminal Limited.

NATIONAL AUTHORITY MEMBERS – these are governmental organisations or agencies, like the UK Maritime and Coastguard Agency, Irish Coast Guard, Rijkswaterstaat Zee En Delta, The Commonwealth of Australia -

SS Torrey Canyon (25-36 million gallons crude oil) off the Isle of Scilly on 18 March 1967. SS Walfra, (14 million gallons) off Cape Aghulas, South Africa in February 1971. SS Amoco Cadiz on the Portsall Rocks, Brittany, Bay of Biscay (220,800 tons of crude oil) March 1978.

Since then, OSRL has responded globally with trained staff, with its contracted and/ or directly owned dispersant platform. The training department, first established in 1991, shares knowledge and experience from subject matter experts and responders within the industry and OSRL has built a global network of 16 bases manned with centrally employed and local employees.


Department of Industry, Science, Energy and Resources.



Flying the Atlantic – refuelling stopover in Narsarsuaq, Greenland on the way to Canada

This area responds to its members incidents when called upon to do so. It spends a lot of time preventing incidents by helping its clients manage risk and put in place procedures, equipment, and training so that they can contain it should one occur. This buys time for OSRL to deploy to manage the response and to deal with larger incidents should they occur. In addition, members have access to Technical Advisors with free in country assistance provided in the event of an incident. OSRL conducts frequent exercises as part of member training. On the day I visited staff were debriefing and wrapping up an

response services to meet increasing regulatory and public scrutiny.

SUBSEA WELL INCIDENT SERVICES In the unlikely event of a subsea well control incident, the Capping Stack is a temporary solution in order to stop an uncontrolled release of hydrocarbons to the environment while a relief well drilling operation with well kill is considered to be a permanent solution OSRL is the custodian of the equipment, storing and maintaining the capping stack systems in four international locations. 15KPSI capping stacks are located in Brazil and Norway, and 10KPSI capping stacks are located in Singapore (this cap is currently being upgrade to 15KPSI) and South Africa. The units can be configured for a variety of subsea interface requirements, and can be transported by land, sea or air. Maximum operating depths are 12,500ft/3800 m and they all include chemical injection points to mitigate the formation of hydrates. It is suitable for both exploration and production wells, and can safely contain, choke and cap up to 100,000 bpd flow in a controlled manner.

operations Technical support and development Consultancy and Secondments for both offshore and onshore risks Membership support and stakeholder engagement OSRL is a busy global international operation that is often quite different to the calm one sees when one visits it waterside HQ base at Southampton. This base also provides administration and management for a complex and geographically diverse business. In February 2013 Robert Limb, took over the helm of this global operation. Unusually his roots were in the international oil and gas business and not in the Royal or Merchant Navy like many of his predecessors. This marked a change that many noted at the time. However others suggested that a strong international commercial background was just what OSRL needed in changing times and in the years since, it seems they were right. After graduating in Chemical Engineering from the University of Exeter on a scholarship from the Atomic Energy Authority, Robert found himself graduating to join an industry which the Conservative Government of Margaret Thatcher had just torpedoed by terminating all of its major projects.

oil spill exercise in the English Channel that involved simulated dispersant application using their Boeing 727 Tersus system supported by the UKCS surveillance aircraft, Unmanned Aerial Systems (UAS) and vessels. It is also brought in to assist other organisations dealing with incidents. A good example of this is their involvement in the MV Xpress Pearl, where OSRL was initially mobilised by ITOPF in response to the loss of this vessel off the coast of Sri Lanka. Since then, it services have been retained by London P&I Club to assist them in the clean-up from the loss of the ships container load which includes a significant quantity of plastic nurdles. OSRL will likely provide further assistance when the wreck of the vessel is finally removed from the seabed by the salvors. Here competence, capability and speed of response rather than contractual relationship has won OSRL this valuable piece of work. This division also manages the global dispersant stockpile which consists of

The subsea group are responsible for the management, maintenance and mobilisation of these capping stacks and other subsea systems. When an incident occurs OSRL are ready to assist the incident owner with the installation of these devices over a well. It is fair to say that OSRL are now world leaders in this technology and considerable experience is now vested in the company who have worked with its members to help design, manage the build and practice the deployment of these devices. The company continues to evolve the service providing additional equipment and capabilities to meet this rapidly evolving part of the Oil and Gas industry.

PREPAREDNESS SERVICES This group provides a wide range of services and support including:

5000m3 of three types of dispersant stored in six locations around the globe. Another area of current focus is growing the wildlife emergency preparedness and


Preparedness training and support Exercises including Crisis and Incident management Equipment hire to support specific

Visit to the OSRL base in Bahrain.

So after just 6 months in the nuclear industry, he joined oil services company, Dresser Atlas in 1980 and spent a year as a field engineer working in the US and Canada learning the basics of the job. He was then deployed to the Middle East for just over five years, initially in Saudi Arabia. Field Engineers worked all over the country at exploration and production facilities. With a rotation of 60 days on and 16 days off they were rapidly exposed to full range of production activities. In the same role he then transferred to Abu Dhabi to a new start up business helping develop a footprint in an area with considerable business potential. His next role was in the UK North Sea operations as a General Field Engineer based in Aberdeen, working in Norway, UK and Holland. After 8 years in field operations, he moved into management

as an Operations Manager initially in Aberdeen and then in Great Yarmouth to run a project for Conoco and subsequently the Southern North Sea activities. Once this was established, he moved back to Aberdeen to manage the UK operations. In 1990 he was appointed Country Manager in Norway managing Scandinavian and Russia operations at a time of change following the fall of the Berlin Wall in 1989. In 1994 he moved to Singapore as Vice President, Asia Pacific to turnaround a loss-making division. This involved creating a new team, a strong ethos, giving people clear direction and allowing them the scope to do their job properly. The business expanded significantly opening new operations in Australia, Bangladesh, India and Vietnam. After four years and following the acquisition of Western Atlas by Baker Hughes in 1998 Robert was asked to move to Houston as Vice President, Global Operations. In an oil price downturn and after 6 months in post, he persuaded the Board to split the business into Western and Eastern Hemisphere Operations. He and a colleague then each took responsibility for Global Operations and Sales in their respective hemispheres. By then the business employed 18000 people worldwide, with sales of $35 billion and some of this growth was coming from the move into integrated services where the oil companies were starting to contract out support services which might include drilling wells, managing infrastructure etc. After 30 months in this role, Robert was approached by a friend and former colleague who worked in private equity and was asked to join Vetco, an oil and gas business that had been bought from ABB in mid-2004. Robert joined in 2006 and in 2007 the subsea business was sold to GE and subsequently in 2008 the Aibel engineering and construction business was sold to a Norwegian Group by which time he had become the President of the holding company. Whilst not Roberts’ first introduction to private equity, his positive influence in funding business growth and restructure, was clearly demonstrated at Vetco Aibel. With new owners finding their feet, Robert was then invited by Credit Suisse to join Total Safety Inc. as Senior Vice President International Operations to improve global sales in the oil and gas sector. This was at the time of the Macondo incident in the Gulf of Mexico which accelerated their growth. A number of acquisitions were achieved including Z-Safety in Belgium, France, Germany and Netherlands. This was significant for Total Safety and gave them the direction they needed and once business had settled, Credit Suisse sold out in late 2011, which saw Robert take some

time out. Robert, a keen pilot, had some time to enjoy his passion for flying, making a trip around Africa and undertaking other memorable journeys.

for the subsea injection of dispersant; and to further assess the need for and feasibility of global containment solutions.

After a few months back at home, in late 2012, he was then approached about and subsequently joined as CEO of Oil Spill Response Limited in Feb 2013. This was a familiar name to him as when at Vetco Aibel his VP HSEQ had previously served on the Board of EARL (East Asia Response Limited) which subsequently merged with OSRL and by coincidence met his predecessor over dinner through a mutual friend. After a smooth handover he took the reins and it was apparent that Robert would be helping to navigate OSRL through considerable organisational and operational change.

The Oil Spill Response Joint Industry Project: to manage the recommendations on oil spill response – develop new recommended practices, improve understanding of oil spill response tools and methodologies and to enhance coordination between key stakeholders internationally.

Following the Macondo blowout in the Gulf of Mexico in April 2010, the International Association of Oil and Gas Producers (IOGP) created the “Global Industry Response Group (GIRG)”, to learn the lessons from the Macondo blowout and other similar events. Its work was divided

$700M in Capex to create well Capping

into three core areas:

PREVENTION: to improve drilling safety and reduce likelihood of a well control incident INTERVENTION: to decrease the time it takes to stop the flow from an uncontrolled well RESPONSE: to deliver effective oil spill response preparedness and capability

Robert working as a field engineer in the Middle East

OSRL have been heavily involved in all three groups. SWRP spawned OSRL’s Subsea Well Intervention Service (SWIS) which is in operation 24/7. Its members have invested stacks, Containment and Offset Installation Equipment and to provide infrastructure to support a robust response capability to ensure that in the unlikely event of a Macondo type incident, industry will be better prepared to respond. To ensure that industry has a broader more integrated capability the Global Subsea Response Network (GSRN) has been set up by OSRL to provide a more comprehensive group of companies that can provide the full gambit of services that maybe required during a subsea well incident. Naturally the Oil Spill Response Joint Industry Project has involved OSRL in considerable work with all of the major oil spill response organisation, this includes the Global Response Network which Robert chaired for three years. Large responses do not generally rely on one company responding to and dealing with the whole incident. To achieve a successful response requires a network of local and regionally based competent responders together with global resources to combine resources to quickly and efficiently deal with major incidents.

In May 2011, IOGP published GIRG’s comprehensive set of recommendations and proposed that three entities be created to manage and implement them.

The Wells Expert Committee (WEC): to analyse well incident report data and share lessons learned, advocate harmonized risk-based standards, communicate good practice, provide permanent improvement in well control teams’ competence and behaviours and promote continued improvement in BOP reliability and efficiency. The Subsea Well Response Project (SWRP): a consortium of operators to investigate, design and deliver improved capping response with a range of equipment for shutting down wells; to design additional hardware

OSRL has also spent much time working closely with IPIECA as part of the joint industry project updating IPIECA excellent and comprehensive good practice guides. Concurrent with this activity has been the introduction of a jet powered dispersant delivery system using 2 x Boeing 727 aircraft. Ambitious in concept it took time to deliver when the Civil Aviation Authority (CAA) ruled that dispersants should be treated as flammable liquids. Being a pilot, Robert understood how the CAA have to ensure safety but found the delay to the project frustrating. The resolution came through a series of lengthy and costly engineering and safety studies which resulted in the certifying bodies recommending approval. This gives OSRL a tremendous aerial wide area dispersant capability with the previously contracted


Hercules located in Malaysia and the two B727 jets based at Doncaster airport with a minimum of one available at all times. Other air assets that OSRL provide are a PA31 Navajo based at Doncaster and two Cessna 337 in West Africa. All aircraft are equipped with dedicated surveillance sensors and communications systems for oil spill detection and response. Many of OSRL Members now give strategic direction but require their operating companies to be in constant dialogue with OSRL so that prevention and preparedness is maintained. Consequently, a lot of time is spent supporting members in maintaining their ‘licences to operate’ which are always under scrutiny from Government’s and environmental organisations.

New Singapore base opening in Loyang Supply base

As oil companies lose experience, through retirement or the desire to outsource, OSRL is providing the ‘integrated services’ solution, familiar to Robert’s days at Baker Hughes. This generates stronger relationships between its members and OSRL. One of mutual dependency. As the energy transition evolves OSRL will likely grow the integrated solutions business to ensure that oil spill risk resulting from operations continues to be well managed and assured. This will be particularly pertinent for the smaller oil companies taking over larger oil company assets as we are seeing occurring in more mature fields. To assist in this, OSRL has been working closely with the UK Oil and Gas Association which was formed to support the activities of its members across many different aspects of the industry. One specific concept of current interested is the application of mutual aid to increase the available resources while ensuring resilience for any future incidents. OSRL is also broadening its footprint of members with the breadth surprising from Government Agencies all over the world, to shipping companies, to river authorities and national coastguards including the UK Maritime and Coastguard Agency who also have access to the second Boeing 727 whenever it is available. Roberts’ job is not only managing a £129M turnover business that is globally deployed with 280 employees but considerable stakeholder management. Its 162 members


all have unique issues and whilst he is well supported, he is the CEO and in effect they buy a chunk of his time. Having weathered the COVID pandemic whilst maintain response capability worldwide, there are strategic issues that affect the business for the long term and a read of the excellent and informative company accounts publicly available at Companies House gives an insight to those I have not covered in this insight. Robert’ prior commercial experience at senior level at ‘best in class’ oil and gas service companies brought commercial vigour and insight to OSRL at a time, post Macondo, that it needed. He has helped his senior team navigate the challenges that these reviews and new opportunities have presented. Subsea incident services is now the largest activity and home to unique capability and knowledge. The traditional response network is busy and being seen by many as best in class. OSRL is close to Government and its many agencies, particularly the MCA and this is as it should be. Consequently, the OSRL brand is highly

ROBERT LIMB CEO INSIGHTS Diversity in all shapes is a strength and is powerful particularly as it avoids groupthink. Encouraging diversity avoids organisations looking at the world through stereotypes. Encourage people to say what they think and encourage inputs from all. Think outside the box, there are so many opportunities in this changing world. Look locally as partners as well as nationally particularly as the energy mix changes but stay on top of technology. Be careful how you treat people and always do so fairly. You get more back if you invest in them. The days of the dark satanic mills are long gone! Educate and Train staff as broadly as you can afford to: e.g. leadership, people skills, the wider business, special to role training, as they are the company’s ambassadors. Yes, some may leave once better trained but they are also ambassadors for your business and bring with it goodwill and sometimes further opportunities.

respected worldwide and is one of the UK’s great exports. Robert has a hand off approach to management. He sets the tone, gives strategic direction, reviews progress, engages with staff, encouraging openness in the organisation and listening to what people say. He has frequent townhall meetings where staff hear what is happening and is planned and seeks feedback from them. In a diverse and multicultural organisation this openness is welcome and has been one of the strengths that has helped OSRL manage through COVID and the changes in response this has necessitated. Robert has been in post 8 years and whilst he did not mention retirement he no doubt feels that thoughts must turn to succession in such a stakeholder management business where change needs consultation. Also his plane sits on the runway waiting to travel afar!

Seek and encourage co-operation across industry – when large incidents occur we all have to work together and the better we know each other the more seamless and trusting this will be.

Lessons from COVID: People learn from people and need that interaction to gain knowledge, learn new skills and bond as a team. Working remotely has generally been good and made possible by investment in technology that enables it. If this improves work/ life balance and mental resilience, then that is good as we now know productivity can be maintained. It has possibly broken the ‘competitiveness at all costs’ that has existed in busines for many years and that is a positive.

Testing the Subsea Well Intervention Service (SWIS) Offset Installation Equipment offshore Rijeka, Croatia

CEMENT LORRY ROLLOVER ADDS TO A CHALLENGING DAY AT LEHANE ENVIRONMENTAL My mobile rings, with the Regulatory Authority flashing up on the screen. I am informed that a truck has gone in over a bridge in a town. The information is sparse as the Inspector himself is only on route to the scene but he is expecting photos from the Fire Service who are already on the scene. Whilst I’m on the mobile phone an email pops through on my screen – URGENT CHEMICAL TANKER LEAK ON NATIONAL PRIMARY ROUTE – SULPHURIC ACID. Our Operations Manager has already identified resources that can be mobilised for the Chemical Spill. We added the RTA to the incident list and put more resources on standby. As most emergency service providers know, the information and the accuracy of it, on any initial call for an incident, can be totally misleading. Products/ UN Numbers/Volumes/Locations etc can all be incorrect. Until we have confirmation, we do not know what we are dealing with. This is why we request photos of markings and of the site if possible and also copies of other relevant documentation such as SDS/DG Notes etc. Ideally, we want to speak to someone on the scene but this is not always possible. We dispatch an Advance Response Unit to the Acid Tanker Spill. The acid spill appeared to come from a top manhole on an acid tanker and the spill on the road extended for about ~50m. The driver was turning off on a slip road just after roadworks and it appears the breaking action caused the acid to spill out through the manhole. The acid was mainly on the slip road and the hard shoulder and was visibly fuming. We requested the attendance of the Road Maintenance Contractor to close the slip road and divert the traffic.

In the interim the photos started coming through from the RTA. The truck had indeed gone over the bridge, the photos looked very bad and the first instinct was tragedy - that there was possibly a loss of life. This would also require us to deploy a Trauma Cleanup Team. A follow up call from the regulatory authority however confirmed that the driver was in fact in hospital and in a stable condition. This is the most important part of any incident – protection of life – whether it is people involved in the incident or our teams responding. Our Biohazard Teams do Trauma and Crime Scene Cleanup and we are all too aware of the tragedy that people meet with. The report from the RTA was that fuel was leaking from the Truck. It was identified from the photos as a Cement Mixer. This meant that there was potentially 400 litres of fuel to leak, plus Lube Oils and more seriously was the concrete in the barrel. This combination could have a devastating effect on the river which was a prime fishing location.


A Spill Team were just leaving another site following an oil spill on a construction site and these were now allocated to the Acid Spill. Acid Spill Equipment was loaded into a Spill Response Unit to have it ready in our depot for the team returning from the Oil Spill. Our Glass Lined Acid Vacuum Tanker was also placed on standby. When the team arrived on site, the Road Maintenance Team had successfully closed off the Slip Road. This enabled our team to safely work on the road. A special Acid Encapsulant Absorbent/Neutraliser was ap-plied to the free acid. The tanker was cleaned down and also neutralised. The manlid was inspected and sealed securely. After all the acid had been neutralised and drummed, the road was then washed with the washings collected by suction. One of our Tail lift ADR Transport Units loaded the drums of acid waste on board for consignment to an EPA Licensed Hazardous Waste Transfer Station.

The RTA was certainly challenging. It occurred on a 6 Arch Bridge in a town with a sharp corner before and after it. The advance Incident Response Unit was deployed which enables direction to follow up resources for the best access road etc. In cases such as this, road closures and diversions are involved and this could add an hour to a response time if they don’t access the incident via the correct road.

The Cement Mixer had gone completely off the road and was laying on its side in the river. Fortunately, the dry spell had caused water levels in the river to be low – circa 30cm. However this river can reach depths of 1.5m and as with all water incidents one needs to be aware of the potential for sharp rising levels which may not be caused by local rainfall but weather conditions in upstream areas or for example Hydro Dam Water Releases. This is where the Risk Assessment comes into play. Check weather forecasts for the region, ensure no other potentials for water level increases, check stability of bridge or for further falling debris, stability of vehicle in river, potential for fire or explosion – the list can be endless. A Response Team cannot be put at risk as being the next casualty/tragedy. We are there to bring a positive out-come to the incident – to take it from the abnormal/emergency state to normal.

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A Site Risk Assessment was carried out and following a toolbox talk operatives commenced doing a recce on the site to determine the most suitable location for deployment of booms. Fortunately, we were able to drive to the riverbank via a narrow laneway. It wasn’t suitable for our larger response units however it enabled the booms and equipment to be transferred into our 4x4 Response Unit to be brought to the deployment location thereby limiting manual handling. The oil was leaking from a number of locations on the vehicle. We tie-wrapped absorbent pads to stop the leaks at a number of points. The hydraulic oil tank was underwater and this was leaking a small amount of oil via its cap. Despite efforts it was not possible to stem the leak. Absorbent booms were deployed at the source with fibre absorbent. 3 further boom barriers were deployed down-stream from the source. Following a full assessment of the Truck, a recovery strategy was formulated. Due to the unstable nature of the barrel, it was determined that the barrel would be disconnected from the truck and lifted separately. This would involve separation of hydraulic connections with resultant potential for contamination. Localised containment was provided whilst the mechanical team set about the separation of the barrel from the truck. Meanwhile the 300 ton crane was setting up getting the load ready for lifting. The weather was starting to change which could provide additional risk to teams working in the river. There was also the added new risk in relation to stability of the truck and the barrel during the recovery phase. The removal of the truck went effortlessly and the crane placed it on the road where it was up-righted. Next the barrel was lifted and again this was recovered without any issue. The barrel was placed on a low loader trailer and secured in place. Some minor leaks of oil started appearing however our teams were on hand to contain and cleanup the oil. Once the truck and its barrel were secured and all leaks were stopped, the recovery team took away the vehicle. Whilst the crane was de-mobilsiing, our teams completed the cleanup of the bridge area to remove any remaining traces of oil to enable the road to be reopened. The river was inspected and remaining debris removed and bagged. As there was no evidence of oil in the river and the source had been removed, the absorbent booms and fibre absorbent were then removed and packed into UN Approved Drums for licensed disposal. Night was closing in when the team were drumming the absorbents and the rain came down heavily. The water level and velocity was evidently increasing. Just in time as our team departed the site. Another successful response, completed safely

More details from: Lehane Environmental Ltd - Cork 021 4351020; Dublin 01 525 2806


T Cork 021 4351020 Dublin 01 525 2806 W www.lehaneenvironmental.com 29

WORKING GROUPS REPORT The Working Groups we have formed are proving a method for members to direct the activity of the Association to their benefit/interest. We have established three to date:

Marine and Manufacturers Working Group Next meeting is in October. The next task is to produce a standard on skimmers and then temporary storage tanks for use in spill response. We are also looking toward

Interspill in June 2022. Insurance Working Group (6 member companies) The group has met several times recently specifically to discuss methods of building mutual links with Chartered Institute of Loss Adjusters (CILA) and Insurance Industry Association. The goal with Insurance industry is to educate loss adjusters and underwriters to advise only use of ISAS accredited companies when undertaking remediation work following an oil spill. In doing this we have been discussing Land Contamination in Risk Management (LCRM) which was written by the Environment Agency and first published in October 2020. It replaces CLR 11 and proposes a more intuitive approach to the management of land contamination. In the working group’s discussion two phrases have caused issues with its implementation. It refers to returning contaminated land to its ‘original’ condition without further definition. So is ‘original’ – pre build or preincident and how is this applied and measured as part of a site environmental risk assessment. The other is the definition that requires more detail is what defines a competent person. We believe this should be an accredited contractor.


So we had a useful meeting with them on 20 September and await their feedback. The beauty with LCRM is that it is online so relatively easy to update. We await their comments. We have prepared an article which follows this section to submit to on the implications of Land Contamination in Risk Management guidance for loss adjusters. This will go into Claims Focus and maybe followed by other articles eg biofuels We are in the process of joining CILA and will place accredited members in the Property and Liability Special Interests Group We have agreed a talk at CILA conference on ‘What to expect of a ISAS accredited contractor’ eg code of conduct, accredited standards, clear pricing, contract resolution etc The group has had an effect and we look for further activity with BDMA and CILA.

agreement on deployment. Our work is having impact outside of DEFRA/EA world and we are in touch with British Plastic Federation, Rivers Trust, Seas-at-Risk, Ocean Generation and to NE P&I club and are looking to extend our reach, through our members, further. We have joined Operation Clean Sweep (managed by British Plastic Federation) – supporting better management of plastic products by those who handle it in the supply chain. We have applied to join Seas at Risk which is an association of environmental organisations from across Europe, working together to ensure that life in our seas and oceans is abundant, diverse, climate resilient, and not threatened by human activities. Its mission is to promote ambitious policies for marine protection at European and international level. With over 30 members representing the majority of European countries, Seas At Risk speaks for millions of citizens that care deeply about the health and well-being of seas and oceans. We are considering appointing representatives from ISAS/ UKEireSpill at all Local Resilience Forums and may send ‘ambassadors’ to work with other organisations eg Surfers against Sewage who have a large drive on plastic pollution at the moment.

Plastic Pollution Working Group (8 member companies) was formed to respond to a request from DEFRA/EA to organise a response process for incidents involving plastic pollution. This has involved equipment trials, safe system of work, triage and then field trials with EA and a council in Lancashire. We now have a deployable solution and await ISAS to approve the submitted suggestion for accreditation so the accreditation process can start. We also await the EA


HAVE THE GOALPOSTS CHANGED AS WE MOVE FROM CLR 11 TO LCRM? This article is written by the Insurance Working Group to provide more visibility of LCRM but also to highlight certain concerns it has that are currently being reviewed by the Environment Agency

To members of UK and Ireland Spill Association and the accredited members of International Spill Accreditation Scheme (ISAS) these are familiar pieces of guidance to be followed when dealing with the remediation of contaminated land! The prompt for this article is the best practice guidance has changed! So without boring you too much with stodgy terminology, let alone muddy boots, the key point is this change is relevant to all involved in environmental incidents which can pollute land and water, which therefore includes loss adjusters and the new guidance has made some significant changes to best practice. In October 2020, the Environment Agency (EA) published a new set of guidance documents on the management of land contamination. Land Contamination Risk Management (LCRM) replaces the long-standing guidance known as the Model Procedures for the Management of Land Contamination (CLR11) which has now been formally withdrawn. Although the purpose and principles of the framework remain the same, the new guidance has simplified terminology to try and make it clearer, more concise and current. It is aimed at anyone that may need to manage or deal with land contamination, including landowners, developers, planners and regulators. The EA hope that the guidance is a more intuitive approach to the management of land contamination and includes up-to-date terminology to advise users on “how to assess if there is an unacceptable risk, decide which options are the most suitable to manage the risk, plan and implement remediation if needed and verify the work completed”. While LCRM is relevant to all those involved in or responsible for managing land contamination, the EA has stressed that the person responsible for applying LCRM is appropriately competent in the tasks they are doing for each stage. As with CLR 11, LCRM sets up a phased approach for dealing with land contamination as follows:

STAGE 1: RISK ASSESSMENT You will use a tiered approach to risk assessment. The 3 tiers are:

Preliminary risk assessment. Generic quantitative risk assessment. Detailed quantitative risk assessment. STAGE 2: OPTIONS APPRAISAL There are 3 steps to follow.

Identify feasible remediation options. Do a detailed evaluation of options. Select the final remediation option. STAGE 3: REMEDIATION AND VERIFICATION There are 4 steps to follow.

Develop a remediation strategy. Remediate. Produce a verification report.

Undertake long 4. term monitoring and maintenance, if required

Many of the members of UK and Ireland Spill Association deal with land contamination following a pollution incident that has occurred. This is

covered in LCRM under new pollution. LCRM states that new pollution could result from a pollution incident or from a breach in a permit condition. When dealing with new pollution, LCRM is different to the previous CLR11 in that it states that the site must be returned to its ‘original state’ and not assessed or remediated based on environmental risk. This is a fundamental change in the approach to dealing with the pollution and has caused some variability in both enforcement (between regulators), and application. The guidance also provides links to pollution prevention guidelines for businesses published on GOV.UK and to section J of the Environment Agency’s approach to groundwater protection which states that: “The Environment Agency requires those who cause new land or water contamination (for example, contamination from an accident or incident) to manage it promptly and effectively. They should identify and secure the source and remediate the contamination and any effects it has caused, to ensure groundwater quality is protected and where necessary restored.” With the guidance now almost 12 months old our Insurance Working Group has met to discuss how LCRM is being applied and how workable the guidance is: A number of concerns exist: There is a lack of understanding as to the catalyst for LCRM being introduced as it has created confusion rather than clarity in an environment where CLR 11 was working and was widely understood so why change? LCRM requires a return to the ‘original‘ condition. More direction and wide dissemination of it is necessary as regulators and authorities are interpreting this differently. Does ‘original’ mean pre-development, or prior to the incident? There can be a lot of work and cost between one and the other. If the client is an insurance company they set the remediation standard by what they assess as being necessary to pay, often based on the limitations of the policy. In these circumstances the remediation will be what can be afforded with the priorities risk assessed by the contractor in line


In the spirit of the guidance being a dynamic document the Insurance Working Group met with the Environment Agency on 20 September to discuss this with them. The feedback is being reviewed along with seeing how the guidance document is being used across the regions, and more information on next steps will follow in due course. A benefit to using Accredited Members is the Code of Conduct that assures considerable protection for any client and assurance about how work will be planned, executed and reported in a completion report.


Provide the client with a Contract for the scope of spill works undertaken – the contract may comprise an outline quotation with a schedule of rates for further charges.


Ensure all work is risk assessed and is conducted in accordance with current health, safety and environmental legislation and staff wear appropriate respiratory and personal protective equipment.


Ensure all reasonable methods to mitigate environmental damage are undertaken. Make every effort to minimise waste generated and disposal complies with duty of care under current waste regulations and is recorded on company waste register.

4. 5. 6. 32


Promptly invoice clients with clear breakdown of work done and charges made.


Reply to customer, regulator, authority or agencies in an efficient and timely manner.

9. 10. 11.

Conduct only works for which they are accredited, qualified and experienced. Liaise courteously with all stakeholders and co-operate with any investigation conducted by with Regulators of the International Spill Accreditation Scheme. Conduct themselves in a suitably professional manner.


The LCRM guidance will ONLY be online and will be periodically updated so that the information is current policy. This means it is no longer a static PDF that is difficult to update but it is a live suite of documents that can be managed and updated easily. The EA have stated that:

This is not just our guidance, we want the industry to embrace it, help us to improve it and keep it up to date. It had a big act to follow.

Further detailed information on the LCRM is available at: https://www.gov. uk/government/publications/landcontamination-risk-management-lcrm

Provide the client with regular progress reports.

A fill list of accredited contractors is avvailable from: www.isas-accreditation.org

Report all spills as per the Spill Reporting Schedule (monthly and annually).

We are quite happy to run a webinar on this topic to provide further information on this important topic.



Remediation of a site often uncovers underlying contamination that preexists the incident. It would normally be removed in a risk assessed manner under CLR 11. How is this managed under LCRM?

Ensure all employees attending spill carry identity cards bearing the company name and logo of the International Spill Accreditation Scheme.

with the limitations of the insurance policy rather than returning to original condition. We need a level playing field to ensure best practice is applied if it is going to gain support.



Rob James, Commercial Director, Oil Spill Response Ltd

From the first synthetic plastic, Bakelite, produced in 1907, the world has developed an insatiable appetite for plastic products. Currently, globally we produce some 380 million metric tonnes of plastics every year. (source: https://www.statista.com/statistics/282732/ global-production-of-plastics-since-1950/ ).

Over the last ten years efforts have been made to reduce plastics use, with plastic bags no longer available, or charged for, in supermarkets, plastic drinking straws replaced with paper equivalents and a drive to remove single use plastics from the supply chain. To date this has resulted in plastic use plateauing but not, as yet, reducing. These plastic products start life as pellets (known as nurdles), flakes and powder. The feedstock arrives at the plastics production facilities primarily by sea but also by road or rail. By sea, container losses from vessels in poor weather and vessel collisions, fires and sinkings, such as the X-Press Pearl cause spills of the nurdles and flakes. Once made into products, the plastics set out on more road, rail and sea

journeys to wholesalers for onward distribution. Once again there can be container losses from vessels in poor weather and vessel collisions, fires and sinkings. The 28,000 plastic ducks lost overboard from the APL China in 1998 is one of the more comically bizarre examples of what happens when a container is lost overboard.

infrastructure, and find their way into watercourses and, eventually, the oceans. Almost three million Metric Tonnes of waste each year are estimated to enter the oceans from 1,000 or more rivers by this route, with often disastrous consequences for marine life and fragile marine ecosystems. (Source: https://advances. sciencemag.org/content/7/18/eaaz5803).

Environmentally-conscious communities work hard to recycle their plastics, but recycling facilities are often on the other side of the world to where we use plastics, so another voyage ensues. The same tonne of plastic could now be making the third ocean crossing of its short life; first as nurdles, then as product and finally as recyclate. Although the shipping industry is one of the safest and most reliable means of transportation, accidents still happen. Baled plastic waste destined for recycling was one of the most difficult losses to deal with from the MSC Chitra incident in 2010 for instance. Sadly, these plastic products are often discarded rather than recycled, particularly in nations with a less developed waste management

THE POLLUTER PAYS – BUT WHO IS THE POLLUTER? The world shipping council estimate that an average of 1,382 containers is lost overboard per annum. This amount is a tiny fraction of the 226 million containers transported each year globally. Equally, container vessel sinkings are a mercifully rare event but when incidents like the Rena or MSC Napoli occur they hit the news headlines. However, in the case of a vessel casualty, it may be more than just the plastics carried that cause concern. Notwithstanding the widevariety of products carried on a modern container vessel, the fuel oil that powers the ship’s engines may spill


in the incident and become co-mixed with the cargo. Baled plasticsdestined for recycling coated in Heavy Fuel Oil, as was the case in MSC Chitra, provide a real challenge for the incident response teams.

“The Polluter Pays” is a principle enshrined in just about all waste management legislation, however identifying a polluter in such scenarios is not always straightforward. Where there is a clear, proximate source of the plastics pollution, those responsible for the costs of clean-up are clear. For instance, in the cases of the X-Press Pearl and MSC Chitra, the ships’ insurers (the P and I Clubs) have been quick to stand up, engage experts and deliver a good response. For containers lost overboard, in a storm, for example, the ownership trail is less clear, not least because these losses tend to be far offshore and the fate of the container and its contents is difficult to prove. Where general marine litter is concerned the link back to a polluter who can pay is lost altogether.

SILVER BULLET OR RUBBER BULLET? Whilst a Silver Bullet will magically solve the problem, a Rubber Bullet bounces around causing pain to many. Can we find a solution that works? Finding someone to pay for the clean-up of plastic pollution, then, is not always straightforward. What is more, once someone is willing and able to pay, there are no international standards or established Good Practice in managing plastic pollution. In the vessel-source oil-spill world we have the P&I Clubs and then the 1992 Fund and Supplementary Fund, which the IOPC Funds manage, underpinned with international conventions developed through IMO. Exploration & Production companies are liable for spills from their installations but so-called ‘mystery spills’ do still occur, maybe from illegal bunkers discharge or from abandoned wells that no longer have an owner to chase. Where these occur, often it is the Member State who pays from public funds. Even if we can identify a polluter who can pay, there is still the question of how to clean up the plastics we encounter at sea on the shoreline and inland on our lakes and rivers. Plastic


pollution varies from microscopic particles, through the lentil-sized nurdles of the X-Press Pearl to the “Great Pacific Garbage Patch” contents of plastic bags, drinks bottles, footballs and flip-flops. Each different type of plastic in each different environment with a different combination of environmental and socio-economic drivers will require various clean-up tools and techniques.

A PET PROJECT IS NEEDED All this sounds somewhat familiar to anyone who works in oil spill response: Firstly, we need an explicit Claims & Compensation regime; Secondly, we need to agree on some Good Practice in plastic pollution cleanup. How can we build funds to delivery clean-up for the plastic pollution not directly attributable to a vessel or some other facility? Funding models for oil spill compensation offer one option, driven by a per-tonne level imposed on ships entering or leaving the ports of those states who have signed up to the scheme. However, we should note that after the very successful establishment of the IOPC Funds, progress to gaining sufficient signatories to the HNS Convention has been slow, so trying to get an additional convention agreed upon may not be straightforward. Taxing plastics producers at source is another option. However the challenges of gaining international consistency in the taxation regime and distribution of the monies collected to agreed clean-up locations may mean that this option would only work on a nation-by-nation level. This option may also not address issues like the Great Pacific Garbage Patch which sits in international waters. Funding via the IMO or UNEP making appeals to Member States may be a good solution here.

So what would define “good” in terms of good practice? First, we would need situational awareness from aerial/ satellite surveillance and modelling; both perfectly achievable with current technologies. The Great Ocean Clean-Up project demonstrates that larger fractions are amenable to collection using

standard offshore boom configurations which are familiar to the oil spill community. Surface trawl nets are also effective. However, there needs to be more work carried out to evaluate options for collecting the smaller fractions, such as nurdles, offshore. Booms may work but the potential for under- and overcut is high. Once collected, recovery may be via nets or some version of weir skimming. Where plastics hit the shoreline, the X-Press Pearl incident has shown us that all the principles of oiled shoreline response apply with little modification to this new challenge. Response activities such as agreeing on endpoints, segmenting beaches, developing plans, segregating/ minimising waste streams, utilising SCAT and so onare all familiar skills to oil spill professionals and can be employed here. The actual clean up tools brought into action other than traditional manual labour include use of trommels, floatation separation and beach cleaning machinery (albeit with carefully selected screen sizes).

It all looks rather like Net Environmental Benefit Analysis utilising Spill Impact Mitigation Assessment techniques to evaluate the best options; once more, some minor amendments to these Good Practices will deliver well-managed interventions for plastics pollution. The issues of plastic pollution in our seas and oceans may seem like a relatively new problem, but that may in part be the raised profile of the situation in the public consciousness. The oil spill response community is a resourceful and an adaptable church that can apply a broad range of tools and techniques to new challenges. Many models, conventions, good practices and institutions exist, developed over 50 years of building preparedness for effective response to oil spills. This wealth of knowledge and expertise should be our first portof-call for pragmatic and effective solutions to a very real and present problem.


DESMI is one of the world’s most experienced manufacturers of oil spill response systems and have helped to clean most of the world’s oil catastrophes to date. Proven Oil Spill Technology is our promise as a complete oil spill response supplier of:

DESMI has a heritage based on knowhow and technological excellence. We have more than 185 years of operational experience and our international teams are well placed to advise on all aspects of environmental solutions for oil spill, seaweed and marine debris clean-up. Our skilled and dedicated specialists have one goal in mind: to deliver to your needs with no compromise to quality, reliability and after sales service. Whatever your requirements for the offshore, coastal & near-shore, beach & shoreline, ports, harbours & terminals, fast


water, rivers & lakes, sea water intakes & outfalls, arctic or industrial environment, DESMI can advise, supply, and train on the widest range of proven solutions available in the industry today.

More details from: Karina Poulsen, Marketing Manager E-mail kpo@desmi.com Web www.desmi.com

Oil Containment Booms Oil Skimmers Sweep Systems Launch and Recovery Systems Original DOP Screw Pumps Multi-Purpose Power Packs Storage Tanks Work Boats Marine Debris Clean-Up Training and Commissioning …Much More


Rake Remediation can act as a standalone Main Contractor or be involved in more specialist aspects of remediation of other sites, offering remediation equipment either operated by our trained personnel or on a hire basis with back up training if needed.

Mark Swanston, who started Rake Remediation 8 years ago, has worked in the contaminated land and remediation

For larger and longer term projects we can build bespoke equipment for sale to other Remediation companies. Rake Remediation is a specialist remediation contractor dealing with a range of organic and inorganic contamination in both soil and groundwater. Any project from domestic oil spills and emergency fuel transfer to clean up of former filling stations and industrial sites – normally driven by the need to fulfil environmental planning conditions. From their rural base at Rake, near Petersfield, Hampshire, Rake Remediation has teams that undertake all types of contaminated land remediation and specialises in the design, installation and maintenance of in-situ remediation systems. We primarily work in the south and south-east of England but do stray to the Midlands if encouraged! Services include remediation of sites, from complete remediation packages of larger sites, invariably destined for development to relatively small scale domestic oil spills.

Techniques may involve but are not confined to: Excavation and on or off site treatment of soil. Rotary screening bucket for 20 tonne excavator. Pump and treat of groundwater – containing hydrocarbons and or heavy metals. Chemical dosing to adjust pH. Flocculation In situ treatment of groundwater by Chemox, enhanced desorption and oxygen release compounds. Direct push and borehole installation of treatment chemicals. Vapour extraction. Thermally enhanced vapour extraction using Gas thermal treatment technology. We have spill response teams who undertake 24/7 response to domestic or commercial oil spills, some chemical spills and we deal with incident on or in water.

sector for over 40 years and has built around him a small team of professional remediation experts and works as a sub contractor to many major environmental and re-generation consultancies. Spill and incident response has always been a specialisation and interest. For more details please contact: Mark Swanston – info@rake-rem.co.uk Tel: 01730 892224 T 01730 892224 E Enquiries@rake-rem.co.uk



When faced with a spillage it’s important to act fast, prevent any further spread and begin a clean-up operation. When an incident occurs, it’s critical that you act fast to keep your operations flowing. With experience in working across a range of sectors from industrial depots to highways, ensuring the nearby environment and any individuals are protected is a priority. At Quest our teams work around the clock delivering contamination prevention, spread prevention and clean up services. Quest’s recent investments in Spill Response means that each of our vehicles are equipped with the equipment

and knowledge to deal with emergency spillages of all types and sizes. Our vehicles carry on-board spill kits, absorbents, and specialist equipment to quickly contain and clean up the spillage whilst preventing any contamination to the surrounding environment. Emergency Spill Response is carefully planned to minimise the impact of any incidents such as fuel, oil or chemical on both water or land. From the initial call our advisor will provide over the phone advice whilst producing a plan to prevent further spread/ contamination.

Upon arrival we will work with our customer to carry out an action plan, preventing any spread and beginning a clean up. Operating from depots in Yorkshire and the Midlands we provide a 24/7 emergency spill response service for both commercial and residential clients. For more information or book an emergency call out, Contact our Operations desk on 0333 358 8222 More details from: Rob Butler - robert.butler@ questwaste.co.uk www.questwaste.co.uk

EMPLOYMENT OPPORTUNITIES WORKING GROUP On many occasions, when I talk to members and ask what is holding you back at the moment, they say recruiting good people. Conversely in our CEO Insights both the CEOs of Ambipar and Oil Spill Response Ltd reflect on the businesses and say that their businesses are successful as a result of their staff and they both say that there is now a career to be had in spill response. So, my thoughts turn to how we can help members recruit better staff and build a career path for employees in the spill response industry. As a start let’s look at this and form an Employment Opportunities Working Group to: 36


If you want to contribute please contact me! info@ukeirespill.org 07864 707408


Providing expert advice and support on the assessment and mitigation of environmental impacts, risks and liabilities.


To find out more t: 01684 252858 e: info@oracle-environmental.com




16 NOV - details on www.ukeirespill.org - members only WEBINARS WE HAVE SCHEDULED THE FOLLOWING WEBINARS TO XMAS: 17 Nov 21

UKEireSpill Knowledge Base: Inland – Drill rig selection and safety


24 Nov 21

UKEireSpill Knowledge Base: Spill Response to Biofuels

Oracle and UKEireSpill

8 Dec 21

Inland – Soil sampling and analysis

Seed Environmental


MV Wakashio Part 6. As this event closes, 1 year on from it what are the lesson we can learn from it



Marine Debris and Plastic Pollution: some thoughts on collection, recovery and disposal

UKEireSpill, Oracle,

SPILL RESPONSE INDUSTRY INSURANCE SPECIALISTS Our policies have been evolving since 1986 and can provide cover for: • Bespoke tanker/vacuum units with values up to £500,000 and beyond • Business Interruption losses if your vehicles are unusable after being damaged at your premises • Pollution both on and off the highway arising from your own vehicles • Defence Costs for Directors in respect of Pollution claims against them


OAMPS is part of Pen Underwriting Limited which is authorised and regulated by the Financial Conduct Authority (FCA number 314493). Registered Office: The Walbrook Building, 25 Walbrook, London EC4N 8AW. Registered in England and Wales. Company Number: 5172311

Insurance Managers for UK and Ireland Spill Association Ltd & International Spill Accreditation Scheme Ltd

CONTACT US 01372 869 700 team@oamps.co.uk www.oamps.co.uk



SETTING THE SCENE IN THIS ISSUE... Welcome and Introduction Introducing Interspill 2022 Interspill Themes and Call for Papers Interspill Exhibition in 2022 Industry conference and our sector day themes Introducing iConex The venue and Amsterdam – Edwin Stolk - SRGH