Environment and Heritage Service Water Pollution Incidents and Enforcement 2004 doc

This report presents statistical information relating to water pollution incidents throughout Northern Ireland investigated by, or on behalf of, the Environment and Heritage Service EHS

Water Pollution Incidents and Enforcement 2004

Annual Report

1 Sewage discharge into a watercourse

2 Milk discharging into a stream

3 Leachate entering a watercourse from illegal dumping

2.

Water Pollution Incidents and Enforcement 2004

Annual Report

This report presents statistical information relating to water pollution

incidents throughout Northern Ireland investigated by, or on behalf of, the

Environment and Heritage Service (EHS) during 2004 EHS responded to

2207 reports of water pollution in 2004, a decrease of 13.2% from 2003 This

equates to almost 6 investigations per day EHS substantiated (confirmed)

55.6% (1227) of the incidents reported as having an impact on water quality

Pollution incidents are classified by Source (where the pollution originates),

Category (the type of pollution identified), Cause (why the incident occurred)

and Severity (the environmental impact of the pollution)

By Source, Industry accounted for the largest number of incidents

investigated by EHS (24.6%), followed by Farming (24.1%) and DRD Water

Service (23.6%) This is illustrated in Figure A

By Category, Sewage (35.0%), Agriculture (24.1%) and Oil (18.5%) continued

the trend from 2003, accounting for the largest proportion of pollutant types

(77.6%) This is illustrated in Figure A

Figure A: Distribution of substantiated pollution incidents by Source and

The main Causes of water pollution during 2004 were Equipment Failure

(20.6%) and Poor Working Practice (18.0%)

A total of 309 High and Medium severity incidents were investigated during

2004 This was a reduction of 9.7% compared to 2003 figures (339) Farming

was responsible for the largest proportion of High and Medium severity

incidents, (40.3%), which is an increase of 4.6% compared to last year’s figure

EHS surpassed their target of responding to 95% of incidents assessed as High

or Medium Severity within 4 hrs, achieving a 95.8% response rate during 2004

To date, for the incidents that occurred during 2004, EHS has issued 193

warning letters, 2 Water (NI) Order Notices and submitted 77 cases to the

Public Prosecution Service (PPS) (formerly the Office of the Director of Public

Prosecutions) with a recommendation for prosecution To date, 25 of these

cases have been heard in the Magistrate’s Courts and all have resulted in a

conviction

For the incidents that occurred during 2003, EHS has issued 176 warning

letters, 2 Water (NI) Order Notices and submitted 122 cases to the PPS with

a recommendation for prosecution To date, 97 cases have been heard in

the Magistrate’s Courts, with 94.8% resulting in a successful conviction Of

the 92 successful convictions to date for pollution incidents and consent

breaches detected during 2003, the total fines so far imposed by the courts

is £71,900.00 These fines ranged from £100.00 to £3,500.00, with an average

fine of £807.87 Of the 122 cases taken by the Department under Articles 7

and 9 of the Water (Northern Ireland) Order 1999, the Category of Agricultural

discharges accounted for 59 (48.3%) with the remaining 63 (51.7%) made

up of Breach of Consent, Chemical, Non Agricultural Waste, Oil and Sewage

discharges

The number of cases referred to the PPS in 2003 was the highest for a number

of years and represents a 23% increase over the number of cases referred to

PPS for incidents that occurred during 2002

The Water Pollution Hotline (0800 80 70 60), continues to be promoted

by EHS The number of incidents reported through this service during 2004

increased by 8.9% to 836, compared to 768 in 2003

Contents

ANNEX A: Pollution incident assessment criteria 54

ANNEX D: Fines imposed under the Water (Northern Ireland) Order 1999, for pollution

incidents that occurred during the period 1/1/03 - 31/12/03 (as at 22/9/05) 61 ANNEX E: The Joint Environment Agencies’ Pollution Prevention Guidelines

1 Introduction

This report presents statistical information relating to water pollution

incidents throughout Northern Ireland investigated by, or on behalf of,

Environment & Heritage Service (EHS), during 2004 Comparisons are made

with data from earlier years to allow the description of historical trends The

data has been classified by Source (where the pollution originates), Category

(the type of pollution identified), Cause (why the incident occurred) and

Severity (the environmental impact of the pollution) This report also includes

details of enforcement action taken under the Water (Northern Ireland) Order

1999 for pollution incidents that occurred during 2003 and 2004

1.1 Background

The Environment & Heritage Service (EHS), an Agency within the Department

of the Environment (DOE), takes the lead in advising on, and implementing,

the Government’s environmental policy and strategy in Northern Ireland

The overall aim of EHS is to protect and conserve the natural and built

environment and to promote its appreciation for the benefit of present and

future generations Four directorates accomplish the work of EHS: Natural

Heritage, Built Heritage, Environmental Protection and Corporate Services

Environmental Protection seeks to safeguard the quality of air, water and

land This involves the enforcement of legislation and a range of supporting

activities to monitor and report on discharges and emissions, to establish

the impacts of pollution, to set standards, and issue consent licences and

authorisations Within Environmental Protection there are five discrete units

dealing with:

• Water management,

• Air quality and noise,

• Waste management,

• Industrial pollution, and

• Drinking water for public and private supplies

Under the Water (Northern Ireland) Order 1999, the DOE has a duty to

promote the conservation of the water resources of Northern Ireland and the

cleanliness of water in waterways and underground strata In exercising these

functions, the Department is required to have regard to:

• The needs of industry and agriculture;

• The protection of fisheries;

• The protection of public health;

• The preservation of amenity;

• The conservation of flora and fauna; and

• The conservation of geological or physiological features of special

interest, and any feature of archaeological, historical, architectural or

traditional interest

It is the role of the Water Management Unit (WMU) of EHS to conserve,

protect and where possible improve both the freshwater and marine

aquatic environment in Northern Ireland The WMU consists of scientific and

• Taking action to combat or minimise the effects of pollution;

• Monitoring of water quality;

• Preparing water quality management plans;

• Controlling effluent discharges;

• Supporting environmental research

1.2 Water pollution incident management

In exercising its duties in relation to pollution control, the EHS’s strategic

objectives are as follows:

• To ensure the protection of water quality and abatement of pollution in

the aquatic environment

• To control effluent discharges to waterways and underground strata

through the process of granting consents under Article 9 of the Water

(Northern Ireland) Order 1999

To achieve these objectives, Northern Ireland is divided into nine areas for the

purposes of water pollution incident management, each area being served by

regionalised field staff, as shown in Figure 1

Figure 1: Areas for water pollution

incident management

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1.3 Structure of the WMU Regional Operations section

Under the terms of the Water (Northern Ireland) Order 1999, the EHS Water

Management Unit, Regional Operations section is responsible for taking

action to prevent or minimise the effects of polluting discharges made to

our waterways and for instigating enforcement action against polluters

where appropriate The section operates on a 24hr, 365 days a year basis, to

co-ordinate the Agency’s response to incidents of water pollution affecting

either the freshwater or marine aquatic environment in Northern Ireland

As indicated in Figure 2, the section is divided into five distinct teams The

Operations Management, Pollution Prevention, Enforcement, and Resources

teams are based in our headquarters in Lisburn and the Field Staff are based

in various properties around the province

Principal Scientific Officer

Senior Scientific Officer

Operations Management

Higher Scientific Officer

Regional Field Staff

The Operations Management team co-ordinates and manages the response

to reports of water pollution received by EHS Members of the team gather

relevant information from complainants, assess the potential environmental

impact of an incident and forward incidents to field staff The management

of incidents includes the mobilization of additional staff and resources,

communication with other Government Agencies and dealing with Press

enquiries All Information relating to a pollution incident is logged according

to its geographical position on the Pollution Incident Logging and Tracking,

Geographical Information System (PILoT_GIS) This system records how the

team progresses the investigation and enforcement action to be taken for

each pollution incident and is regularly audited to ensure that the information

held is accurate

SECTION 2 of this report provides information extracted from the PILoT_GIS

Figure 2: Structure of the WMU – Regional Operations Section

Pollution Prevention

The aim of the Pollution Prevention Team is to help achieve a reduction in

the number of water pollution incidents occurring in Northern Ireland The

team carries out the following proactive initiatives to prevent incidents from

occurring or minimise the effect of pollution on the environment;

• Education of the public and industry about the effects and consequences

of pollution

• Distribution of advisory publications to the public and industry

• Offering advice at site meetings

• Promotion of good environmental practices in response to planning

consultations

• Initiating pollution prevention programmes

• Involvement in relevant working parties

SECTION 3 of this report further details the work of the Pollution Prevention

Team during 2004

Enforcement

Where pollution occurs it is the policy of the EHS to take formal enforcement

action, if this is warranted by the severity of the pollution and the

circumstances which led to it occurring Water Pollution incidents are

investigated and then submitted to the Enforcement team for a decision

on the appropriate course of action to take This can be the issuing of an

enforcement warning letter, an enforcement notice or the instigation of

prosecution proceedings In cases where it is decided that prosecution is

appropriate, EHS staff collect the necessary evidence and prepare a file which

is submitted to the Public Prosecution Service (formerly the Office of the

Director of Public Prosecutions) with a recommendation for prosecution

SECTION 4 of this report further details the work of the Enforcement Team

during 2004

Resources

The Resources team maintains a stockpile of specialist equipment that can be

deployed to carry out clean up operations following water pollution incidents

occuring in either the freshwater or marine aquatic environment The team

co-ordinates the training programmes for all staff in the Regional Operations

Section It also co-ordinates the assessments, by field staff, of pesticide stores

under the British Agrochemical Store Inspection Scheme (BASIS)

Field Staff

At present EHS, WMU relies on the purchase of external services to fulfil

its statutory responsibilities under UK and EU legislation The field service

is composed of approximately 49 field staff from six service providers (4

Group Environmental Health Committees, Fisheries Conservancy Board and

Loughs Agency (until May 2004)) who undertake a wide range of duties from

pollution investigation to sampling

Group Environmental Health Staff

Each of the nine water pollution management areas has an Environmental

Health (Rivers) Officer (EHRO) or Senior Water Quality Inspector (SWQI) and

a number of Water Quality Inspectors (WQIs) The EHROs, SWQIs and WQIs

act as field agents on behalf of EHS A number of sampling staff are also

employed over the summer period to sample and monitor the bathing waters

around Northern Ireland

There are currently 37 staff employed in this section of the field staff

The main activities of Group Staff are:

• Pollution investigation;

• Collating evidence of pollution offences and preparation of prosecution

files under the Water (Northern Ireland) Order 1999;

• Initiation and supervision of clean-up work following certain pollution

incidents;

• Carrying out pollution prevention advisory visits to industry;

• Sampling effluents from consented Industrial sites;

• Making recommendations on applications for discharge consents in

respect of domestic and trade premises

The Fisheries Conservancy Board (FCB) and the Loughs Agency (LA) also

undertake pollution operations (mainly from agricultural sources) on behalf of

EHS, in the areas shown in Figure 3

Fisheries Conservancy Board (FCB)

FCB was established in 1966 as a Non Departmental Public Body (NDPB)

responsible for the application of the Fisheries Act (Northern Ireland)

1966 FCB’s role is primarily the enforcement of statutory provisions in

respect of salmon and inland fisheries, and also pollution control FCB’s

parent Department, the Department of Culture, Arts and Leisure (DCAL), is

responsible for fisheries policy and legislation

FCB has a permanent staff of approximately 29 with about 7 full time

equivalents (FTE’s) being involved in work on behalf of EHS

The main activities of FCB are:

• River quality sampling on behalf of EHS;

• Pollution investigation and prevention on behalf of EHS; and

• Preparation of prosecution files under the Water (Northern Ireland)

Order 1999 on behalf of EHS;

• Patrolling rivers and freshwater fisheries to enforce legislation, including

angling and commercial fishing licensing provisions;

• Providing a bailiffing service on the DCAL public angling estate;

• Providing an assessment for authorities on developments, such as water

abstraction, drainage schemes etc which may have an impact on fishery

interests;

• Prosecuting persons in relation to offences under the Fisheries Act and

subsequent amendments;

Loughs Agency (LA)

LA is part of the Foyle, Carlingford and Irish Lights Commission (FCILC) which

was set up in 1999 with the enactment of the North / South Co-operation

(Implementation Bodies) (Northern Ireland) Order 1999 The Agency’s

predecessor, the Foyle Fisheries Commission (FFC), was established in 1952

with the enactment of the Foyle Fisheries Act (Northern Ireland) 1952 FCILC

has cross border jurisdiction made possible by parallel legislation in the

Republic of Ireland (ROI) As a result, FCILC has two parent Departments,

DARD and the Department of the Marine (ROI) Each Department is required

under its respective Act to appoint Commissioners from within the parent

Department to jointly oversee the management of FCILC

LA has a staff of approximately 43 with around 5 full time equivalents (FTE’s)

undertaking work on behalf of EHS

The main activities of LA are:

• River quality sampling on behalf of EHS;

• Pollution investigation and prevention on behalf of EHS; and

• Preparation of prosecution files under the Water (Northern Ireland)

Order 1999 on behalf of EHS;

• Patrolling rivers, Lough Foyle and sea areas of the Foyle system to enforce

fishery regulations and to prevent illegal or unlicensed fishing (Under the

new administration these powers have been extended to the Carlingford

Lough system);

• Monitoring salmon numbers and regulating fishing to generate the

maximum sustainable yield;

• Issuing licences for angling and commercial fishing, receiving catch

returns and monitoring salmon purchases;

• Providing an assessment for authorities on developments, such as water

abstraction, drainage schemes etc which may have an impact on the

Foyle and Carlingford Lough fisheries;

• Prosecuting persons in relation to offences under the Foyle Fisheries Act

of 1952 and subsequent amendments;

Figure 3: Operational areas for Fisheries Conservancy Board (FCB) and Loughs

Following recommendations by the Northern Ireland Audit Office and the

NI Public Accounts Committee with respect to the provision of field staff

it was agreed that the service should be brought ‘in-house’ As part of this

process WMU withdrew from using the services of the Loughs Agency on

31 May 2004 Additional funding was made available to the Western Group

Environmental Health Committee to undertake the work formerly undertaken

by the Loughs Agency on behalf of WMU

1.4 Responding to water pollution reports

Pollution incident investigations are initiated following a report of pollution,

which may come from a number of sources In most cases reports are either

made by members of the public or are discovered by field staff working

on behalf of EHS During 2004, as in previous years, EHS used the pollution

incident assessment criteria as described in ANNEX A, where incidents are

classified by Severity (High, Medium and Low) This assessment is used in

order to standardise the classification, recording, and analysis of pollution

incidents across Northern Ireland

EHS has set targets for responding to pollution incidents based on their

assessed Severity, and these are routinely monitored as a performance

measure When a report of pollution is received, WMU aims to assess and

estimate the incident Severity, (based on the information contained with the

pollution report) and forward the incident to field staff within 30 mins The

field staff aim to respond to incidents initially assessed as High or Medium

Severity within 4 hrs and Low Severity incidents within 1 working day Table

16 and Figure 23 detail the rate of response to High and Medium Severity

incidents during 2004

Once a pollution incident has been forwarded to Field Staff, they aim to:

• Confirm that pollution is occurring (substantiate)

• Locate the Source, Category, Severity and Cause of pollution

• Identify the polluter and, if appropriate, collect sufficient evidence to

secure a prosecution;

• Secure from a polluter the necessary remedial action to prevent the

continuation or the repetition of pollution;

• Recover costs, where possible, from the polluter

The rate of substantiation can be affected by any delay in reporting by the

public, the quality of information contained in a report, the diverse and

intermittent nature of some discharges, and the response time by our staff

Although each report of water pollution is investigated and every effort is

made to substantiate the incident (confirm that pollution has occurred), in

many cases reports remain unsubstantiated In order to increase the rate of

substantiation, a number of points have been highlighted in ANNEX B, which

should be referred before making a report of pollution

1.5 Legislation

As previously stated, EHS has a duty to conserve, protect and where possible

improve both the freshwater and marine aquatic environment in Northern

Ireland.Under the terms of the Water (Northern Ireland) Order 1999, it is an

offence to cause pollution of a waterway or groundwater In particular:

Article 7 (1) of the Order deals with the main pollution offence and states

that;

‘a person commits an offence if, whether knowingly or otherwise he

discharges or deposits any poisonous, noxious or polluting matter so that

it enters a waterway or water contained in an underground strata’

Article 9 (1) states that;

‘no person shall, without the consent of the Department, make any

discharge into a waterway or underground stratum: (a) of any trade or

sewage effluent; or (b) of any poisonous, noxious or polluting matter’

Article 9 (4);

Under this Article it is an offence for any person to contravene the

conditions of any discharge consent

Anyone who contravenes any of these Articles can, if convicted in a

Magistrate’s Court, be imprisoned for up to 3 months and / or be fined up to

£20,000

Enforcement Policy

Where pollution occurs it is the policy of the EHS, to take formal enforcement

action, if this is warranted by the severity of the pollution and the

circumstances which led to it occurring In deciding what, if any, enforcement

action to take in each case, EHS aims to ensure that that enforcement action

is:

• Consistent with the enforcement action taken in other cases;

• Proportionate to the risks the incident has posed to the environment and

the seriousness of the breach of the law; and

• Transparent, in that those being regulated know what is expected of

them and the public have confidence in the enforcement process

The formal enforcement options available to EHS in pollution cases are:

• the issuing of an enforcement warning letter, and/or;

• the issuing of a Water Order Notice, or;

• the instigation of prosecution proceedings

Enforcement Procedure

In cases where it is believed by EHS that prosecution is appropriate, EHS

staff prepare a file of evidence, which is submitted to the Public Prosecution

Service (formerly the Office of the Director of Public Prosecutions) with a

the final decision on whether to proceed with each prosecution, taking into

account whether they believe there is sufficient evidence that an offence has

been committed and whether a prosecution is in the public interest EHS

has an excellent record with the PPS; in that of the 122 draft prosecution files

submitted to PPS for pollution incidents which occurred during 2003, PPS

concurred with EHS’s assessment and proceeded with a prosecution in every

case

Where a prosecution results in a successful conviction in court, the court

will normally award costs against the offender for the expenses incurred in

serving the summons, and in the taking and analysis of samples A court

may also order that compensation be paid if the pollution has caused a fish

kill, or if other costs have been incurred in making good the environmental

damage caused by the incident In line with the “polluter pays” principle, it is

EHS policy that, where possible, such costs will always be recovered from the

polluter

SECTION 4 and ANNEX D of this report provide further details of the

enforcement action carried out by EHS during 2004

1.6 Water Pollution Hotline

To encourage the reporting of incidents, EHS operates a freefone pollution

response system that is available to the public at all times During office

hours, all calls made to the WATER POLLUTION HOTLINE, (0800 80 70 60) are

directed to an operations room in Lisburn, where the incident is assessed and

passed to the relevant field staff Out of office hours, all calls are directed to

an Environment Agency (EA) Communications Centre in Reading, who task

the On-Call Duty Emergency Pollution Officer (DEPO) in Northern Ireland to

respond

There have been difficulties receiving calls to the hotline number made

from mobile phones, where in some cases the calls have been diverted to

Scottish Environmental Protection Agency (SEPA), or EA offices other than

Reading EHS is actively addressing the problems associated with calls made

to the Water Pollution Hotline from mobile phones This has been identified

as a network problem associated with directing calls to a number used

throughout the UK and although BT has been contacted regarding this issue,

there is no short term solution As an interim measure all staff in SEPA and

EA offices have been provided with procedures for contacting EHS staff in NI

Until this issue can be resolved, EHS suggest that, where possible, a landline

is used to call the Water Pollution Hotline, as it is free and will ensure calls are

received by the DEPO

Table 1 details the number of reports of water pollution received by EHS

during the period 1999 - 2004 This indicates that the total number of reports

made has decreased since 1999, however there has been a steady increase in

the number of reports made to the freefone Water Pollution Hotline (WPH)

since its inception in 1998 This is balanced by the decreased number of

reports made directly to EHS, regional field staff, FCB and LA offices and is

likely to be due to the promotion of the freefone WPH

The Water Pollution Hotline is promoted through advertisement in telephone

directories and on websites, and by business cards, posters and key fobs that

are distributed at public events Figure 4 illustrates the Water Pollution Hotline

business cards, posters and key fobs that are available on request from the

Regional Operations Section by:

Total WPH

EHS direct (Normal Hours)

Regional Offices direct (Normal Hours)

FCB / LA direct (Normal Hours)

Total reports received

*EHS provided a service for reporting pollution incidents prior to the launch of the Freefone Water Pollution Hotline in 1998

Figure 4: Water Pollution Hotline

2 Analysis Of Incidents

This report presents statistical information relating to water pollution

incidents throughout Northern Ireland investigated by, or on behalf of, EHS,

during 2004 Comparisons are made with data from earlier years to allow the

description of historical trends The data has been classified by Source (where

the pollution originates), Category (the type of pollution identified), Severity

(the environmental impact of the pollution) and Cause (why the incident

occurred)

2.1 Reported Incidents

During 2004 a total of 2207 pollution incidents were reported to EHS, a

decrease of 13.2% from 2003 Of these, 1227 (55.6%) were substantiated

Table 2 details the breakdown of total, substantiated and unsubstantiated

incidents from 1999 to 2004 (Figure 5 illustrates this graphically)

Unless otherwise stated the remainder of this report is based on

substantiated incidents only.

2.2 Regional Distribution

Northern Ireland is divided into nine areas for the purposes of water pollution

incident management (Figure 1) Figure 6 illustrates the regional distribution

of pollution incidents during 2004 The greatest number of pollution incidents

were recorded in Area 6 and lowest number in Area 8 This is a change from

the previous year when the majority of incidents were recorded in Area 1

The number of substantiated incidents recorded for each region from 1999 to

2004, are detailed in ANNEX C, Table 1.

2.3 Distribution by pollution Source

EHS aims to identify the Source of any pollution reported The Source of

pollution is recorded using six descriptors: Farm, Industry, Water Service,

Domestic, Transport and Other “Other” Sources include incidents where

the Source was not determined Table 3 details the distribution of pollution

incidents by Source for 2004 and this is illustrated in Figure 7

By Source, Industry (24.6%) accounted for the largest number of substantiated

incidents investigated by EHS during 2004, followed by Farming (24.1%) and

Table 4 details the regional distribution of pollution incidents by Source

for 2004 Figure 8 illustrates how pollution Sources vary across NI due to

population density and the type of industry present In highly populated

regions, i.e Areas 5 and 6, DRD Water Service account for the largest

proportion of incidents, however in more rural regions, i.e Areas 1 and 2 there

are a greater proportion of Farming incidents

2.4 Trend in pollution Source

Table 5 details the percentage change in pollution Source from 2003 – 2004

and this is illustrated graphically in Figure 9 It is encouraging to note a

decrease in pollution from Domestic (-3.1%) and Farm (-0.4%) Sources during

2004, however Farming remains a major source of pollution Unfortunately

there has been a 2.9% increase in pollution attributed to Industrial Sources

during 2004

There was no change noted in percentage of incidents attributed to DRD

Water Service during 2004 Reports of pollution attributable to DRD Water

Service are initially assessed by EHS and then forwarded to DRD Water Service

for action and to the EHS Water Service Regulation Team who monitor the

situation and progress This team also monitors and regulates DRD Water

Service discharges by reporting compliance with registered standards and

issuing advisory letters that formally identify unsatisfactory performance and

The number of substantiated incidents attributed to each Source for the

period 1999 - 2004, is shown in Figure 10 (ANNEX C, Table 2) Industry,

Farming and DRD Water Service have continued to be the major Sources of

pollution, however incidents from these sectors have reduced over the 6

year period In order to further reduce pollution from Farm Sources, EHS will

work constructively with farmers to implement the SSAFO (Silage, Slurry and

Agricultural Fuel Oil) Regulations In addition to this, the whole of Northern

Ireland will be designated a Nitrate Vulnerable Zone early in 2006 It is

expected that EHS, DARD and relevant agricultural organisations will work

together to develop a Nutrient Management Action Plan which will control

the amount of nutrients that are discharged into the aquatic environment

2.5 Distribution by pollutant Category

EHS aims to identify the Category (type) of any pollution reported Pollutant

Categories are recorded using 7 descriptors: Chemical, Agriculture, Sewage,

Oil, Non Agricultural Waste Discharge, Breach of Consent, and Other “Other”

categories include incidents where the Category was not determined The

distribution of pollution incidents by Category for 2004 is detailed in Table 6

and illustrated in Figure 11

During 2004, Sewage (35.0%), Agriculture (24.1%) and Oil (18.5%) continued

the trend from 2003, accounting for the largest proportion of pollutant types,

(77.6%) It is expected that through implementation of the Nitrates Directive

and Urban Waste Water Treatment Regulations (Northern Ireland) 1995, that

these figures will be reduced over coming years

Table 6 & Figure 11: Categories of water pollution, 2004

Table 7 and Figure 12 detail the regional distribution of pollution incidents

by Category for 2004 Population density and industry type are major factors

influencing the pollutant Categories identified across NI In highly populated

regions, i.e Areas 5 and 4, Sewage accounts for the largest proportion of

incidents however in more rural regions, i.e Areas 1 and 9 there are a greater

proportion of agricultural incidents

Category Area Chemical Agriculture Sewage Oil Non Agric Waste Dis. Breach of consent Other Total

2.6 Trend in pollutant Category

Table 8 and Figure 13 detail the percentage change in pollutant Category from

2003 – 2004

These indicate a substantial decrease in the percentage of Sewage related

incidents (-2.6%) from 2003 Slight decreases in Chemical (-1.6%) and Non

Agricultural Waste Discharge (-1.6%) incidents have been noted, however

there were increases in Other (3.3%) and Oil (3.1%) incidents during this

The number of substantiated incidents attributed to each Category for the

period 1999 - 2004, is shown in Figure 14 (ANNEX C, Table 3) During the 6

year period there has been little change in the Category of pollution incident,

however it was encouraging to note that EHS investigated 154 less Sewage

related incidents in 2004 (429) compared to 2003 (583)

2.7 Cause of Incidents

EHS aims to identify the Cause of all reported pollution incidents The

Cause of pollution is recorded using ten descriptors; Poor working practice,

Equipment failure, Accident / Emergency, Inadequate equipment, Negligence,

Deliberate dumping, Weather, Breach of Consent, Other and Unknown Table

9 details the distribution of pollution incidents by Cause for 2004 and this is

illustrated in Figure 15

In 2004 the main Cause of incidents was Equipment Failure The most effective

and practical means of reducing these incidents is by adhering to pollution

prevention advice SECTION 3 of this report details the specific pollution

prevention advice offered by EHS

Table 10 and Figure 16 detail the regional distribution of pollution incidents by

Cause for 2004

Cause Area Deliberate Dumping Breach of Consent Accident / Emergency Equipment Failure Inadequate Equipment Negligence Working Poor

Practice Weather Unknown Other Total

2.8 Trend in incident Cause

Figure 17 , (ANNEX C, Table 4) illustrates the trend in incident Cause for the

period 1999 – 2004 During the 6 year period Equipment Failure (20.6%) and

Poor Working Practice (18%) have remained the main Causes of incidents

2.9 Analysis of Incidents by Severity

EHS estimates the environmental impact that a pollutant has on a

watercourse using the pollution incident assessment criteria as described in

ANNEX A, where incidents are classified by Severity (High, Medium and Low)

This assessment is used in order to standardise the classification, recording,

and analysis of pollution incidents across Northern Ireland Table 11 details the

number of incidents in each Severity class for 2004 and this is illustrated

Table 12 and Figure 19 detail the regional distribution and Severity of pollution

The severity of incidents investigated by each region for the period 1999 to

2004 is detailed in ANNEX C, Tables 5.1 – 5.3.

Table 13 details the Source and Severity of incidents investigated by EHS

during 2004 Figure 20 illustrates that the majority of High and Medium

Severity incidents occurring during 2004 arose from Farm (125) and Industrial

(86) Sources, whereas the majority of Low severity incidents were attributable