Spill Alert Issue 24

A CONSULTATION TO ENCOURAGE RECRUITMENT, FUTURE-PROOF TRAINING AND COMPETENCY ACROSS THE SPILL AND POLLUTION MANAGEMENT INDUSTRY

PRODUCED BY: EMPLOYMENT OPPORTUNITIES WORKING GROUP

SEPTEMBER 2022

INTRODUCTION

Our industry has a problem with recruitment. Most member companies say that they are short of staff and particularly seek experiencedtrained staff.

Following Brexit, the influx of European workers into construction and other artisan trades has almost ceased. There is now competition fortrained staff and our industry must compete hard to retain, let alone recruit, new employees.

Conversely the industry is as busy as it has ever been. With the transition from hydrocarbons, investment in maintaining infrastructure isreducing with the consequence that failures have increased and maintenance of it essential. This high level of activity is likely to continue forthe next decade and beyond.

Those who work in the industry enjoy it. Most will say that, no two days are the same, they travel widely and the work is diverse, generallyrewarding and interesting. Most feel there is opportunity to develop within it. Many have made careers in spill response and have movedfrom responder to senior manager or even to become Directors in the industry having worked for several companies along the way.

The industry tends to reward those who are versatile, have a good safety culture, are quick to learn, show leadership skills, can work wellunder pressure, are willing to travel and work away from home for periods of time.

The industry is likely to grow over the next decade and whilst we will see a slow move from hydrocarbons toward chemicals and alternatiovefuel types. Consequently scopes of work may change however it will grow as the importance of environmental protection becomes evenmore essential.

To discuss these issues in January 2022 we formed the Employment Opportunities Working group with the following objective:

Through collaborative working to generate and evolve career pathways for the industry. To promote them to those within our industry and to those who seek to join it from other industries. The goal is that all in the industry have a clear career pathway and can develop their potential within it. Devise a communication strategy so that a career in our industry is attractive and recognised as worthwhile and rewarding.

A small working group has met 6 times since then to see what can be done. This group members and their relevant experience is as follows:

• Martin Brannock, Managing Director, RSK Response (Inland Response and Consultancy)

• Mark Shephard, Director of Operations, NRC (Marine and Inland Response)

• Neil Marson , Executive Director, International Spill Accreditation Scheme (Marine and Inland Response)

• Steve Guy, Assessor, International Spill Accreditation Scheme (Marine)

• Mark J Orr, Executive Director, UK and Ireland Spill Association (Inland)

THE CHALLENGE

• These are comments made by working group members in one of our earlier meetings

• How do we help our members win the competition for resources.

• We have great career opportunities and need to tell people about them.

• We are often challenged to prove competence particularly on inland events where most training is in house and not independently accredited.

• Whilst marine spill response has an established progression from MCA 1-5, inland response and consultancy lack this.

• This can mean that individuals, thinking of their own careers, do not know how transferable skills are from one part of the spill/ pollution industry to another

It summarises some of the problems to be addressed.

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EXPERIENCE OF OTHER INDUSTRIES

UK and Ireland Spill Association has become quite close to the British Disaster Management Association (BDMA) whose members primarilydeal with fire and flood damage incidents. Speaking to some of their Board members, they faced similar issues a decade ago and undertooka review.

Their clients are primarily insurance companies or larger companies who may self-insure some of their own risk. They were unhappy, as the service provided was inconsistent across the industry as training was provided by member companies to their own syllabi based up-on what they did and not necessarily what the client required. Quality of provision varied significantly from one member company to another and delivery expectations were sometimes different to the industry norm.

They addressed this by undertaking two significant pieces of work:

A team of members met and wrote what eventually became the first draft of BS 12999: A code of practice for the organization andmanagement of the stabilization, mitigation and restoration of properties, contents, facilities and assets following incident damage.

From this document flowed the competency training required to meet the requirements of the standard at all levels of management andservice delivery. It also includes training of client’s staff so they know what to expect when engaging with member companies. This resultedin the formation of the BDMA Academy https://bdma.org.uk/training-and-education/

Through the Insurance Working Group, our Association has become closer to the Chartered Institute of Loss Adjusters (CILA). As the insurance industry evolved ,the performance of loss adjusters failed to evolve with it. CILA council members and executive board were aware of this and undertook a review that resulted in CILA becoming directly involved in setting syllabi and providing support to members through a defined qualification scheme. https://www.cila.co.uk/cila/getting-qualified

The training provision is an important part of CILA and manages the career development of members. The Education committee reviewsthe necessary knowledge, competences and skills required by Loss Adjusters and promotes Institute projects that support our members soensuring we are, ready now and ready for the future.

The working group felt there were lessons to be learned from these examples.

OPINION OF THE WORKING GROUP

The members of the working group believe that, in general, the industry is well trained for current risks that manage the consequences ofthe unplanned release of hydrocarbons into the environment on land and at sea.

In general, most response companies have the confidence of their clients.

The marine sector learned a lot from the many reviews that followed the Deepwater Horizon incident in April 2010. It has since modernisedits training and delivery of response. Consequently the incidents that have tested the industry since 2010 have been well managed and thereis greater interoperability between companies that provide industry resilience and competence.

Fortunately, the inland sector has not had such a large incident to deal with. However, the largest incident in a decade was the derailmentat Llangennech in August 2020. This incident is still early in its review stage but, through collaborative working across the industry, was wellmanaged and involved no loss of life and long term damage to the environment was minimised by appropriate action.

However, the industry must not be complacent. The drive toward net zero means that, over time, hydrocarbon use will reduce, to be replaced by other forms of fuel whose risks to the environment must be understood and managed by responders. It may be that the risks being managed are similar to those from chemical products. However, for each there must be agreed response plans that are reflected in the training provision.

A useful role for the Association is to collaborate with industry and members to design appropriate training provision and liaise with regulators on production of guidance in how the risk of unplanned release may be managed. Part of this work has started in conjunction with the Environment Agency with the new Emerging and Future Risks Working Group.

THE EXISTING TRAINING PROVISION

It is important to say existing training is effective.

In general response companies provide their staff with considerable health, safety, environment and hazard awareness training (fire, asbestos, first aid, working at heights, driving skills, noise and vibration etc), basic specialist training related to working on forecourts or/and oil terminals (fuel and explosion risk, use of gas detector), confined space training that is provided in house or through approved training providers. However there is a division between the specialist response training provision of the three sections of our membership: marine, inland and consultancy which are outlined below:

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MARINE

For marine responders the training structure is the Maritime and Coastguard Agency scheme which is internationally recognised. Its outlinestructure with indicative time periods between qualifiactions in brackets, is as follows:

This scheme involves passing a series of practical and theoretical courses that progress in difficulty and scope as one moves up the chainwith both experience and age, with Level 3 and above being aimed at Incident Command. The courses vary in duration from 24hrs to 5 daysand are generally delivered in person though some parts and some refresher courses can be undertaken online.

Training is provided by accredited providers, which may be larger companies, Nautical Institute and other major training companies.

INLAND

The International Spill Accreditation Scheme (ISAS) has registered 6 companies as accredited training providers who provide a mix ofgeneral courses related to spill response. All were invited to a conference call. Those that attended agreed that their primary focus was onbasic spill response courses to industry and organisations other than spill response companies.

However there are three accredited training companies that provide specific training to spill responders (though course names and contentmay differ slightly). The courses may be described as:

• Basic Spill response course for responders – half or one day practical course

• Advanced spill response course, involving spills in water, maybe introduction to chemicals - one day course

• Tactical Spill Responder, dealing with complex and challenging spills – one day course

CONSULTANCY

As consultants are not generally responders, their training is more related to hazard awareness but spill awareness training, often providedby accredited training providers is undertaken. Their role is more managerial than practical but understanding of what is involved in spillresponses is essential to their work.

Consultants have a mix of theoretical and practical training.

Most training is provided in-house but some specialist training is externally provided.

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DETAILED PROPOSAL

A. The Group felt that if we are to develop a structure for a career in spill response the possibility of migration between marine and inland response and from related environmental sectors should not be ignored. The clear structure of marine training, which is a familiar model career pathway, should be emulated for inland response and consultancy training and prompt the development of more technically challenging courses that reflect emerging and future risks aimed at incident management.

B. As the industry is trying to encourage career development, having a clear pathway is important to provide structure and aspiration. The new pathways for marine, inland and consultancy should meet at stages to enable migration between them. Consequently, the Group believe that providing an element of independent certification, by a recognised Institute, would add authority to the training scheme. This would provide independent certification applicable to achievement of career stages in marine, inland and consultancy career pathways. We have held discussions with Institute of Environmental Science about incorporating the awards at specified career stages as outlined below:

REnvTech, RegisteredEnvironmental Technician

REnvP, RegisteredEnvironmental Practitioner

CEnv, Chartered Environmentalist orCSci, Chartered Scientist

Senior Spill Operator orequivalent

Spill Supervisor or equivalent

On Scene Commander or equivalent

+/- 5 years experience +/- 7 years experience +/-10 yrs experience

The Group recognise that people migrating to our industry from another may come with different qualifications, experiences, vocationaland formal training eg NVQs, Diplomas and Degrees which all contriovbute to competence by knowledge. These need to be accepted in ourcareer pathways and not inhbit individual progress and personal development.

Indeed the Group believed that there should be greater focus on individual achievement and individuals taking some responsibility for themanagement of their career. This would be by maintaining competency training records, compiling CPD records and recording the on-siteexperience they build. These would therefore be essential to independent award of certification.

The career pathways for each section of our membership are outlined in the table.

PROPOSED OUTLINE CAREER PATHWAYS:

Marine

MCA 1 Basic Responder

MCA 2 Senior Spill Operator

MCA 3 Spill Supervisor

MCA 4 On scene Commander

Inland

Basic Spill

Spill

Advanced Tactical Course

On Scene

Responder eg

Operator

with HNS Element

Commander

Compass

Course

Consultancy

Y

Y

MCA 5 Incident Commander Incident Commander Course

Relevant External Training as an exampleSiteManagement

SSSTS*SMSTS*

H&S Training

NEBOSH/ManagingSafety*

Tech IOSH*

ExternalAward

REnvTech REnvP CEnv

*Or industry equivalent

An expanded version of this is at Annex A with a full breakdown of the possible content of a future training structure. It is important thatas an individual’s career develops there is a mix of independently provided training, in-company training combined with building practicalexperience.

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The criteria for the independently awarded qualification is at:

REnvTech,

Registered Environmental Technician - https://www.the-ies.org/technician

REnvP,

Registered Environmental Practitioner - https://www.the-ies.org/registered_practitioner

CEnv,

Chartered Environmentalist https://www.the-ies.org/chartered_environmentalist

CSci,

Chartered Scientist

https://www.the-ies.org/chartered_scientist

It is important to note that the awarding of these qualifications is independent of the Association. Whilst the Association will haverepresentation on the awarding committee they will never be in the majority to ensure the independence of the award.

C.

The Group believe that dealing with and managing spill incidents is paramount in development of management experience. Asthis takes time to earn it is therefore likely that there will be a gap of several years between qualification. A documentary or ‘logbook’ of relevant experience is therefore essential to the award of qualifications

D.

For the award of the RenvP and CEnv candidates will be interviewed in person or online by an awarding panel who will intervieweach candidate. UK and Ireland Spill Association will be represented on this panel.

E.

Cost is always a necessary consideration and indicative costs of the independently awarded certitication are as follows:

Membership of the Insititute of Environmental Sciences:Associate - £101 per yearMember - £125 per year

REnvTech costsOne off Application fee £44Annual Fee £32

REnvPOne off Application fee £88Annual Fee £40

CEnv

One off Application fee

£135

Interview stage

£190

Annual Fee

£125

Note – In general these fees are tax deductible from your personal tax. (This may depend on personal circumstances)

MARKETING OF A CAREER IN SPILL RESPONSE

Oen of the Working Group’s tasks is to develop a marketing plan for the new Career Pathways.

This will involve marketing the career pathways internally to the industry so that those within them understand how it affects them.

This will involve marketing them to relevant career groups eg:

Armed Force leavers Construction Industry Maritime Industry University, Technical College Career Fairs Environmentasl Services Industry Demolition Industry Forecourt Services Industry Oil and Gas Industry (offshore and onbshore)

NEXT STEPS

This is a consultation document which now needs your feedback, written or verbal.

A lot of thought, albeit from a small group, has gone into its production. We want to develop clear and logical pathways for those currentlyin the industry, those who may join it in the future, those who we can attract into it from other industries so that joining the industry willbenefit them and their employers.

We are also tryng to develop a dynamic career pathway that by review will ensure rlevant training and qualification provision for the workthe industry undertakes and the risks its staff face.

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WHAT DO WE WANT TO KNOW

As a company:

Will you adopt this for your spill response staff?If no what needs to change to do so?How can this be improved?

As an individual:

Is this range of external qualifications attractive to you?Will yiou be prepared to invest time and some money in yiour career development?

So please deliver feedback!

Comments directly in writing to info@ukeirespill.org

ANNEXES:

A. Possible Spill Industry Training Structure

Annex A: Possible Spill Industry Training Structure

For the three career pathways there are different training requirements but many elements will be common to all eg Health, safety, fire, confined space, water awareness, management of risk, etc will be common to all and grow in importance as individuals move into a incident management and command role. This is therefore the Group’s proposal and will evolve by consultation. However it must be credible and prepare people for the risk they face when planning exercises and in real incidents.

Across Industry and Pathway Role

In Industry Experience* Marine Training for pathway Additional Training

Spill Responder

Small incident /works supervisor

Site/Incident supervisor

Incident Manager (single location complex incident)

Major Incident Commander (multiple location complex incident)

Nil

2-4 year

5 -7 year

8 -10 yr

Over 12 yr

MCA 1

MCA 2

MCA 3

MCA 4

MCA 5

Equivalent

Equivalent to

Equivalent to

Equivalent to below

Equivalent to

to below

below

below

below

Consultancy Pathway (brownfield, contaminated land or geotechinical)

Junior Environmental Consultant

Environmental Consultant

Senior Environmental Consultant

Training

As Spill Responder

As Small incident

/works supervisor

Partner

SeniorPartner

Inland

Spill ResponderSmall incident

Site/IncidentIncident Manager

Major IncidentPathway

/works supervisorsupervisor

(single locationCommander

complex

(multiple locationincident)

complex

incident)As below or

As below orAs below or

As below orAs below or

equivalent level

equivalent levelequivalent level of

equivalent levelequivalent level

of independent

of independentindependent

of independentof independent

accredited

accreditedaccredited

accreditedaccredited

training

trainingtraining

trainingtraining

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Training for

Title: SpillTitle:

Title: RespondingTitle:

Title:Pathway for

ResponderResponding to

to and ManagingResponding to

Complex IncidentInland

and Managinglarge spill (incl

and ManagingCommander

responders and

1 dayoil and biofuel

biofuels and noncomplex spill

some course for

classroomspill incidents

complexincidents

5 day courseconsultants

and practicalchemical)

including HNSclassroom and

2 day classroom

incidentspractical

and practical

3 day classroom5 day course

and practical

classroom and

practicalEvidence of

IncidentICS 300 (2 days

ICS 400 (2 daysICS 402 (4 hrs

successful

Commandonline)

online)online)

training

Systemachievement

(ICS)100/200

(online 2 hrs)Water

As SpillAs Small incident

As Site/IncidentAs Incident

awareness*

responder/works supervisor

supervisorManager

Small Boats

Operator*(RYA)Working atIncident

Incidentheight

CommandCommand course

training

course Level 1Level 2

Confined

BA & ConfinedChemical hazards

Incident & Crisisspace

space trainingawareness and

Responseawareness

spill responseCommunication

training

Skills – 5 dayGas detector

PID trainingHAZWOPER

training

AsbestosSoil Sampling

and

and custodyHazardous

training

Materials

trainingCITB H&SWaste

Site managementAwareness

managementenvironmental

awareness

training schemecourse

(SMETS) eCourse -1eCourse

daySite Supervision

Site ManagementNEBOSH

Tech IOSHSafety Training

Safety TrainingManaging

Directing SafelyScheme (SSSTS)

Scheme (SMSTS) –Safely

– 2 day

5 daySuccessful

External Award applicable to all pathways REnvTech REnvP

CEnv

*Notes:Qualification does not always mean competence and the gulf between the two is usually filled with experience. This has to be recognised bycompeletion of the elements of training outlined above (or their accredited) equivalent and the completion of training logs and CPD.

At this stage we are not stating that training must be by CITB/NEBOSH etc but the consultation will reveal the common source of thistraining.

Some courses will be applicable to company accreditation eg water awareness and small boats training.25