Environment Agency expectations: chemical storage guidance, discharge permits, PPGs and GPPs

If you store, handle or use oils, fuels, solvents, detergents, acids, alkalis, dyes, fragrances or other chemicals, the Environment Agency (EA) expects you to prevent pollution before it happens. For UK industrial sites, that usually means: practical controls for chemical storage, robust spill response, and (where relevant) the correct discharge permit or consent in place.

This page answers common compliance questions in a question/solution format, with practical actions you can apply to day to day operations in manufacturing, warehousing, maintenance and facilities management.

Question: What does the Environment Agency expect from chemical storage and spill control?

Solution: Apply a simple hierarchy of control: prevent, contain, protect drains, respond, and document

The EA expectation is not just having a spill kit on a shelf. It is evidence that you have reduced the likelihood of pollution and can control it if it occurs. In practice, that means:

• Prevent leaks and overfills with good housekeeping, compatible containers, clear labelling, and safe transfer procedures.
• Contain foreseeable leaks using bunding, spill pallets, drip trays and secondary containment sized for your stored volumes.
• Protect drains using drain covers, drain blockers or other drain protection before liquids enter surface water or foul sewers.
• Respond quickly with correctly specified spill kits (chemical, oil, maintenance/general purpose) and trained staff.
• Document inspections, maintenance, incident response and training to show your control measures are active, not just installed.

For operational context, many cosmetics and personal care manufacturers handle liquids that can be harmful to aquatic environments (for example, fragrances, solvents, surfactants, oils and dyes). A small spill that reaches a drain can become a reportable pollution incident. Proportionate spill containment and drain protection is therefore a core EA expectation.

Question: Are PPGs still relevant, and what are GPPs?

Solution: Use GPPs as current best practice, and treat older PPGs as supporting reference where applicable

Historically, the EA published Pollution Prevention Guidelines (PPGs). These have largely been replaced by Guidance for Pollution Prevention (GPP) documents which provide practical, sector-relevant measures to prevent pollution, including for storage, handling and spill response.

From a compliance perspective, the key point is not the document label but whether your site follows current best practice to prevent discharges to land, surface water or groundwater. GPPs are commonly referenced by regulators as a benchmark for sensible controls.

Useful references:
Guidance for Pollution Prevention (GPP) collection (GOV.UK)
Environment Agency (GOV.UK)

Question: How do I know if I need a discharge permit or trade effluent consent?

Solution: Identify where liquids can go, then check what authorisation applies

Many pollution events happen because sites assume a drain is safe to use or that wash-down can go to the nearest gully. The EA expectation is that you understand your drainage and have the right permissions for any discharge.

• Surface water drains usually flow to rivers, streams or soakaways. They should never receive chemical contamination.
• Foul drains go to a sewage treatment works. Discharging certain substances may require controls and, for trade effluent, consent from the local water company.
• Direct discharges to surface water may require an environmental permit and strict limits.
• Discharges to ground (including some soakaways) can be highly restricted and may require a permit depending on activity and risk.

If your activities include process wash waters, cleaning chemicals, interceptors, tank cleaning, or any possibility that spilled chemicals could enter drainage, review your authorisations and speak to the relevant regulator or water company. You should also maintain a clear site drainage plan and mark drain types on site.

Useful references:
Environmental permits (GOV.UK)

Question: What does good chemical storage look like in practice?

Solution: Combine bunding, segregation, inspections and spill readiness

Good chemical storage is a mix of physical containment and routine management. The EA will typically expect storage areas to be suitable for the substances present, protected from impact, and able to contain leaks.

Practical checklist:

• Secondary containment: use bunded areas, spill pallets, or bunded cabinets so that leaks are contained at source.
• Segregation: separate incompatible chemicals (for example acids from alkalis, oxidisers from organics) and store flammables correctly.
• Transfer controls: use drip trays and controlled decanting to prevent routine drips becoming drainage contamination.
• Drain protection nearby: keep drain covers or drain blockers close to high-risk storage and transfer points.
• Inspection regime: record checks on containers, valves, hoses, IBC taps, bund condition and housekeeping.
• Spill kit selection: specify spill kits by chemical compatibility and expected spill volume, not just by convenience.

Site example: An IBC of surfactant in a production area may only seep slowly from a faulty tap. Without a bunded pallet or drip tray, that seep can track to a floor drain over several hours. With bunding and a nearby chemical spill kit, the same issue becomes a controlled clean-up rather than a potential pollution incident.

Question: What spill response equipment supports EA expectations?

Solution: Use the right spill kit, add drain protection, and position equipment where spills happen

Regulators expect spill response to be credible. That means spill control products matched to your risks, and deployed fast enough to prevent liquids reaching drains or leaving site.

Spill control essentials:

• Chemical spill kits for acids, alkalis, solvents and aggressive liquids (check compatibility).
• Oil spill kits for hydrocarbons and oils, including outdoor yard risks.
• Maintenance spill kits for mixed, non-aggressive liquids and everyday leaks.
• Spill absorbents such as pads, socks and pillows for fast containment and clean-up.
• Drip trays under pumps, dosing points and decanting areas to stop routine drips becoming incidents.
• Drain covers and drain blockers to stop contaminated liquids entering drainage during a spill.

Positioning matters. Put spill kits and drain protection at chemical storage areas, goods-in, decanting points, process dosing areas, laboratory spaces, engineering workshops, and waste storage areas.

Related Serpro resources:
Spill Control in Cosmetics Manufacturing

Question: How do I demonstrate compliance during an EA visit or audit?

Solution: Keep evidence that controls are maintained, staff are trained, and incidents are managed

EA inspections and customer audits typically focus on whether your systems work in reality. Prepare to show:

• Risk assessment for chemical storage, transfers and foreseeable spill scenarios.
• Site drainage plan identifying surface water and foul drainage routes, interceptors, and outfalls.
• Inspection records for bunds, spill pallets, drums/IBCs, valves and hoses.
• Spill response procedure including escalation, drain protection steps, and waste disposal route.
• Training records and spill drill outcomes so staff can act quickly and safely.
• Waste paperwork for used absorbents and contaminated materials, stored and removed correctly.

Question: What are the most common mistakes that lead to pollution incidents?

Solution: Remove predictable failure points before they become reportable events

• Assuming indoor spills cannot reach drains: many internal drains connect to surface water systems or interceptors that can overflow.
• Under-sizing containment: bunding or drip trays that cannot realistically hold a foreseeable leak.
• Spill kits not matched to chemicals: the wrong absorbent or missing PPE delays response.
• No drain protection on hand: by the time a drain is blocked, contamination may already be in the system.
• Poor container management: damaged drums, unprotected IBC taps, and overstacking increase leak likelihood.

Question: What should we do next to align with EA expectations?

Solution: Run a quick site review and close the biggest gaps first

Start with the highest-risk areas and easiest wins:

1. Map where chemicals are stored and transferred, and identify the nearest drains and routes to surface water.
2. Confirm you have suitable bunding, spill pallets or drip trays at each risk point.
3. Add drain protection and spill kits where response time matters most.
4. Review whether any discharge requires a permit, consent or tighter controls.
5. Implement an inspection and training routine, and keep records.

Important: This page is general guidance only. Your legal duties and permit requirements depend on your site, substances, volumes and drainage arrangements. For definitive regulatory guidance, consult the Environment Agency and the relevant GOV.UK resources listed above.