Environment PPG Guide
Pollution Prevention Guidelines (PPGs) are best-practice guidance notes published by the UK environment regulators on preventing pollution from industrial sites. They are advisory rather than statutory, but regulators routinely treat them as the benchmark for what compliant containment of pollution looks like.
Overview of the PPG Series
The Pollution Prevention Guidelines (PPGs) were developed by the Environment Agency, NIEA and SEPA to cover pollution risks ranging from oil storage to incident response. Although many were replaced by Guidance for Pollution Prevention (GPPs) in 2015, they remain widely referenced in permits, planning conditions and enforcement actions. The most relevant to bund lining are PPG 2 (oil storage), PPG 18 (fire water management), PPG 21 (incident response planning) and PPG 26 (drums and IBCs). Regulators may request evidence of compliance during inspections, so our specifications ensure that documentation is in place from day one.
How PPG Guides Relate to Bund Design
The PPG framework drives several of the design rules every bund engineer in the UK works to. We align every specification with these requirements:
110% Capacity Rule
The bund must hold at least 110% of the largest primary vessel within it. Where multiple vessels share a bund, the requirement is the larger of 110% of the largest vessel or 25% of the total volume of all vessels.
Freeboard
The bund must have sufficient freeboard above the contained liquid level to accommodate rainfall, firefighting water (per PPG 18) and any wave action during a release.
Impermeable Construction
The bund walls and floor must form a continuous, impermeable barrier, which is where the lining specification sits within the PPG framework.
Drainage Controls
Drainage outlets are normally not permitted, or must be valved closed and only opened under controlled conditions (typically with confirmation that no oil or chemical is present).
Construction Integrity
The structure must be capable of withstanding the hydrostatic load of the contained volume without failing across its design life.
Detail Treatment
Every joint, penetration, corner and termination must be detailed to maintain the impermeable barrier — this is where many older bunds fall short of current PPG expectations.
Inspection Regime
The bund must be inspected regularly enough to evidence ongoing integrity, with the frequency set by the duty and the operator’s environmental permit.
PPG Guides by Industry Sector
Different PPG notes apply more strongly to different sectors. We work to the relevant combination on every project:
Oil, Gas and Petrochemical
PPG 2 dominates, with PPG 7 for refuelling areas, PPG 8 for used oil and PPG 26 for drum and IBC storage on mixed sites.
Chemical Processing
PPG 18 (fire water), PPG 22 (spill response) and PPG 26 (drums and IBCs), with PPG 2 still relevant where oil is also stored.
Food & Beverage
PPG 18 and PPG 26 for chemical and ingredient storage, plus PPG 2 for boiler oil and standby fuel compounds.
Agriculture & Aquaculture
PPG 2 for fuel oil compounds, with the SSAFO Regulations supplementing the PPG framework for slurry, silage and agricultural fuel oil.
Sewage and Waste Water Treatment
PPG 18 (fire water and pollution) and PPG 22 (spill response), alongside the wider Environment Agency framework for waste water assets.
Power Generation and Transmission
PPG 2 for transformer oil, standby diesel and HVO compounds, with PPG 26 for drum and IBC storage.
Nuclear Facilities
PPGs supplement the ONR Licence Condition framework, with PPG 2 and PPG 26 typically referenced for non-radiological oil and chemical containment.
Limitations of PPG Guidance
Operators sometimes assume that compliance with PPG guidance is sufficient by itself. It is not. The framework has specific limitations that need to be understood:
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PPGs are guidance, not law — they are not directly enforceable in the way the Oil Storage Regulations or COMAH are. -
Regulators use them as benchmarks — although advisory, PPGs are routinely cited in enforcement notices, prosecution evidence and permit conditions, and demonstrating non-conformity is treated as evidence of inadequate pollution containment.
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Some PPGs have been formally withdrawn — particularly after 2015, with parts replaced by GPP equivalents. Operators should not assume a withdrawn PPG carries no weight; they typically still represent regulator-accepted best practice.
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PPGs do not displace statutory regulation — the Oil Storage Regulations, the Water Resources Act, COMAH, COSHH, DSEAR and sector-specific frameworks all sit above PPG guidance and apply regardless.
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Sector-specific guidance often applies on top — SSAFO, BS 4247, ENA Technical Specifications, APEA/EI Blue Book and CIRIA C736 all extend or supplement the PPG framework in particular sectors.
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Updates are sporadic — PPGs are not on a regular review cycle, and what was current guidance ten years ago may not represent current regulator expectation today.
Frequently Asked Questions
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We design every bund to hold 110% of the largest primary vessel (or 25% of total volume across multiple vessels, whichever is greater), with impermeable construction, valved drainage normally closed, and a chemical-resistant lining matched to the stored substances. Each design decision is recorded in the specification so the PPG conformity can be evidenced when the regulator asks.
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No, PPG guidance has to sit alongside statutory obligations including the Oil Storage Regulations, the Water Resources Act, COMAH, COSHH and any sector-specific framework. Conforming to PPG is a strong starting point and a regulator-accepted benchmark, but compliance is judged against the full legal framework rather than the PPG notes alone.
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Modern resin lining systems, such as epoxy, polyurethane, polyurea, vinyl ester and novolac, meet and exceed the impermeability and chemical-resistance expectations set out in the PPG framework when correctly specified and applied. The PPGs predate many current technologies but remain relevant because the underlying performance principles (impermeable, durable, chemically compatible) are unchanged.
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PPG notes are not on a regular review cycle, and the most significant change in recent years was the formal withdrawal of several notes by the Environment Agency in 2015. Operators should treat the PPG framework as a stable but ageing document, supplemented by current GPP equivalents, sector codes and CIRIA guidance where the underlying technology has moved on.
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Yes, CIRIA C736 is the principal modern reference for bund design and detailing, alongside BS EN 1992-3 for liquid-retaining concrete, sector codes such as the APEA/EI Blue Book and ENA Technical Specifications, and operator-specific quality standards. We work to whichever combination applies to the site.
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Specialist advice is worth seeking on any new build, refurbishment of an older asset, multi-substance bund, change of use, or any site where the operator is uncertain whether existing capacity, integrity or detailing meets current expectation. We also recommend it whenever the regulator has flagged a concern, since interpreting that concern correctly is what determines the scope of the remedial work.
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The fundamental rules, capacity, impermeability, drainage control, inspection, apply across both small and large sites, scaled to the volume and risk of the substances stored. Larger and higher-risk sites typically have additional obligations under COMAH, environmental permits and sector-specific frameworks on top of the PPG baseline.
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A bund exists to capture any liquid escaping from primary containment before it reaches soil, drains or watercourses, protecting people, property, ecosystems and the operator’s licence to operate. A poorly maintained or unlined bund cannot perform that role reliably, and a release from an unprotected bund typically becomes the operator’s liability under “polluter pays” rather than an externalised cost.
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A fit-for-purpose bund is evidenced through a documented design (capacity, freeboard, detailing), a written lining specification matched to the chemistry, application records confirming installation followed that specification, integrity test results and an ongoing inspection log. We supply each of those as part of every project so the evidence pack is available on demand to a regulator, insurer or auditor.
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