Environmental · Mandatory · Pre-Construction

Spill Response and Pollution Prevention Plan

A plan detailing pollution prevention measures and spill response procedures for the construction site.

Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. EA Guidance / PPG1 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.

Legal basis	Environment Agency Guidance / PPG1 + Water Resources Act 1991 + Environmental Permitting Regulations 2016
Status	Mandatory
Prepared by	Principal Contractor
Key offence	s.85 Water Resources Act 1991: it is a criminal offence to cause or knowingly permit polluting matter to enter controlled waters
EA hotline	Environment Agency 24-hour incident hotline: 0800 80 70 60

1. Spill Response Plan — Preventing Water Pollution Before It Happens

Water pollution from construction sites is one of the most frequently prosecuted environmental offences in England and Wales. The Environment Agency investigates hundreds of pollution incidents from construction every year, and the courts have consistently imposed significant fines — often running into tens or hundreds of thousands of pounds — on contractors who allow polluting materials to enter watercourses, groundwater, or surface water drains. Under section 85 of the Water Resources Act 1991, it is a criminal offence to cause or knowingly permit poisonous, noxious, or polluting matter to enter controlled waters, and liability is strict: it is not necessary for the prosecution to prove negligence or intent.

The most common pollutants from construction sites are diesel and hydraulic oil from plant and fuel storage, concrete and cement washwater (which is highly alkaline with a pH of 11–13 and is toxic to aquatic life), and silt from earthworks and dewatering operations. A single litre of diesel can contaminate up to one million litres of water. Concrete washwater entering a watercourse can kill fish and invertebrates for hundreds of metres downstream. Silt runoff smothers river beds, destroys spawning habitats, and blocks fish gills.

A spill response and pollution prevention plan is the contractor's primary tool for identifying pollution risks on site, implementing preventive measures to stop pollution before it occurs, and establishing a clear, rehearsed response procedure for dealing with spills and incidents when they do happen. The plan must be site-specific, based on a thorough assessment of the pollution risks particular to the site, and it must be understood and practised by everyone working on site — not just the environmental manager.

Report immediately — delay is a criminal offence

Report all pollution incidents to the EA's 24-hour hotline immediately — delay is a criminal offence and significantly worsens the environmental damage. The EA takes a much more serious view of incidents where there has been a failure to report promptly, and the courts treat delay in reporting as an aggravating factor when determining the level of fine.

2. What to Record

The spill response and pollution prevention plan must be comprehensive, site-specific, and available to all site personnel. The following table sets out the key sections of the plan and the information that should be included.

Section	What to record
Site description	Site location, layout plan, and surrounding environment. Identify all watercourses, ditches, land drains, surface water drains, soakaways, and groundwater features on or adjacent to the site. Mark drainage outfalls and confirm where surface water from the site ultimately discharges to. Identify any sensitive ecological receptors such as SSSIs, water-dependent habitats, or water abstraction points downstream.
Pollution risk register	A systematic assessment of all pollution risks on site, identifying the source (e.g. fuel storage, concrete operations, earthworks), the pathway (e.g. surface runoff, drain connection, direct discharge), and the receptor (e.g. watercourse, groundwater, public sewer). Assess each risk as high, medium, or low and assign specific preventive measures to each. Review and update the register as the project progresses and activities change.
Fuel and oil storage	Location, type, and capacity of all fuel and oil storage on site. Confirm that all storage complies with the Oil Storage Regulations 2001 — tanks must be within a bund with a capacity of at least 110% of the largest tank or 25% of the total capacity (whichever is greater), with an impermeable base and walls. Record inspection and maintenance schedules for tanks, bunds, pipework, and dispensing equipment. Include refuelling procedures and drip tray requirements for mobile plant.
Concrete washout	Location and design of designated concrete washout areas. Washout areas must be fully contained, impermeable, and located away from any drainage or watercourse. Record the procedure for managing washout water, including neutralisation if necessary and disposal by a licensed waste carrier. Concrete washwater must never be discharged to a drain, watercourse, or onto bare ground.
Drainage controls	Details of all temporary drainage controls on site, including silt fences, settlement lagoons, silt busters, filter drains, cut-off ditches, bunded areas, and drain protection measures (e.g. drain covers, nappy inserts). Include a drainage plan showing the location of each measure and the activities it is designed to protect against. Record inspection and maintenance schedules for all drainage controls.
Spill kits	Location, contents, and type of all spill kits on site. Spill kits must be appropriate to the substances stored and used on site (e.g. oil-only absorbents for hydrocarbon spills, general-purpose absorbents for other liquids). Record the number of spill kits, their locations (which must be clearly marked and easily accessible), and the restocking procedure after use. Ensure spill kits are available at all fuel storage areas, refuelling points, and high-risk work locations.
Spill response procedure	A step-by-step procedure for responding to a spill, covering: stop the source, contain the spill (using absorbents, booms, or drain covers to prevent it reaching drains or watercourses), clean up the contaminated material, dispose of waste via a licensed waste carrier, report the incident internally and to the EA if polluting matter has entered or may enter controlled waters. Include clear decision criteria for when the EA must be notified.
Emergency contacts	A list of emergency contacts displayed prominently in site offices, at fuel storage areas, and in all site vehicles. Include the EA 24-hour incident hotline (0800 80 70 60), local EA officer, water company (for foul sewer pollution), site environmental manager, project manager, and specialist spill response contractor. Contacts must be kept current and checked regularly.
Training	Record of pollution prevention and spill response training provided to all site personnel. Every person working on site must receive a pollution awareness briefing as part of their site induction, covering the site-specific risks, the location of spill kits, and the basic spill response procedure. Designated spill responders must receive more detailed training including practical spill containment exercises. Record training dates, attendees, and content delivered.

3. Common Mistakes

Fuel tanks without bunding

Storing diesel, hydraulic oil, or any other polluting liquid on a construction site without adequate secondary containment (bunding) is one of the most common and most easily preventable causes of water pollution. The Oil Storage Regulations 2001 require that all oil storage containers with a capacity of more than 200 litres must be stored within a bund that has an impermeable base and walls and a capacity of at least 110% of the largest container. Despite this clear legal requirement, unbunded fuel tanks remain a depressingly frequent finding on construction site inspections. A leak from an unbunded tank can contaminate soil and groundwater, reach watercourses through surface runoff, and result in prosecution, a significant fine, and the cost of remediation.

Concrete washout draining to surface water

Concrete washwater is one of the most harmful pollutants that can enter a watercourse from a construction site. It has a pH of 11–13, which is highly alkaline and toxic to aquatic life. Even a small quantity of concrete washwater entering a stream can kill fish and invertebrates for a considerable distance downstream. Despite this, concrete wagon washout into open ground, ditches, or near drains remains a common occurrence on construction sites. All concrete washout must take place in a designated, fully contained, impermeable washout area that is located away from any drain or watercourse. Washout water must be collected, treated if necessary, and disposed of by a licensed waste carrier. The washout area must be inspected daily and maintained to prevent overflow.

Not knowing the EA hotline number

The Environment Agency's 24-hour incident hotline number is 0800 80 70 60. Every person on a construction site should know this number. In the event of a pollution incident, the speed of reporting directly affects the severity of the environmental damage and the regulatory response. The EA expects immediate notification of any incident where polluting matter has entered or may enter controlled waters. Failure to report, or delay in reporting, is itself an offence and is treated as a serious aggravating factor by the courts. The hotline number should be displayed prominently in the site office, at all fuel storage areas, and on the spill response procedure card that should be carried by all designated spill responders.

4. Frequently Asked Questions

What do the Oil Storage Regulations 2001 require?▾

The Control of Pollution (Oil Storage) (England) Regulations 2001 apply to all oil storage containers with a capacity of more than 200 litres, including drums, intermediate bulk containers (IBCs), mobile bowsers, and fixed tanks. The regulations require that containers must be stored within a secondary containment system (bund) with an impermeable base and walls, a capacity of at least 110% of the largest single container or 25% of the total storage capacity (whichever is greater), and no drainage valve or outlet that could allow oil to escape. All associated pipework, valves, and dispensing equipment must also be within the bunded area or otherwise protected. The regulations apply to diesel, hydraulic oil, waste oil, vegetable oil, and any other oil product. Non-compliance is a criminal offence enforced by the Environment Agency.

How does the EA classify pollution incidents?▾

The Environment Agency classifies pollution incidents into four categories based on their severity. Category 1 (Major) involves a persistent and extensive impact on water quality, air quality, or land, or serious damage to the environment, including major fish kills or contamination of a drinking water supply. Category 2 (Significant) involves a significant impact on the environment or human health, including localised fish kills or impacts on a sensitive area. Category 3 (Minor) involves a minor or localised impact with minimal environmental effect. Category 4 (Substantiated but no impact) involves a confirmed incident that did not result in any measurable environmental impact. Categories 1 and 2 incidents are most likely to result in prosecution. However, even Category 3 incidents can lead to enforcement action if they reveal systemic failures, repeat offending, or a failure to follow the site's own pollution prevention plan.

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