14 - Incidental Pollution

This risk factor assesses the adequacy and effectiveness of the control arrangements and management systems for the potential incidental pollution from the sites, facilities and activities or from customer’s products / services. The focus of this risk factor is on third party damage and injuries due to the discharge, dispersal, release or escape of smoke, vapors, soot, fumes, acids, alkalis, toxic chemicals, liquids, solids or gases, waste materials or other irritants, contaminants, or pollutants into or upon land, the atmosphere or any water course or body.

What do we look for?


  • Handling/storage/processing of Hazardous and toxic substances.
  • Processes that are subject to unexpected leaks, upset, discharge, or releases.
  • Proximity/distance to third parties and/or exposes ocean, lakes, river, or streams.


  • No, or limited handling of hazardous materials and processes.
  • Risk assessment and compliance with regulations (ISO/EMAS certification and audit).
  • Employee training and Pollution Prevention Program.
  • Spill control/containment and Emergency Response Plan.
  • Adequate maintenance of equipment to protect bodies of water.

  • Establish  and implement a risk mitigation program

  • Implement a spill control/containment and emergency response plan

  • Provide training and instructions to employees in proper handling and storage  of hazardous materials.