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LAW


WHAT’S


REQUIRED OF YOU TO COMPLY WITH LEGAL AND HEALTH & SAFETY LEGISLATION


Legislation & Environmental Update


“Does your greenkeeping or grounds maintenance department comply with all the latest legislation?


The differences between what is law and what are recommendations are confusing. The following, covering topical items, may prove of help;


• The Control of Pollution (Oil Storage) (England) Regulations 2001. Require that if you store more than 200 litres of oil above ground you must comply. The deadline for compliance was Sept 1st 2005. ‘Oil’ means not just lubricating and hydraulic oils but diesel fuel and petrol too. To comply you must ‘bund’ all oil storage; bunded diesel tanks; bunded petrol storage, and all barrels and other oils standing on Sump Pallets.


environment/water/quality/oilstore/pdf/oil_st ore.pdf


• The Groundwater Regulations 1998. Came into effect on 2nd December 1998 and demanded immediate compliance. These regulations state that causing pollution with mineral oils and hydrocarbons is an offence punishable with fines up to £20,000. To comply, wash-off areas should be designed to prevent pollution. Washings should leave the pad and enter a suitable treatment / recycling plant or an interceptor. (Interceptors, whilst accepted by most EA inspectors at present, are not deemed ‘future-proof ’). The safest option is to install a biological water recycling system. A number are available with most installed above ground with the exception of the ClearWater underground system from Course Care. Contrary to recent scare mongering, there are no plans to introduce


legislation for above ground effluent tanks. The safest place for all such storage remains firmly underground. It is difficult to imagine all interceptors, foul water and septic tanks, sewage plants and the like being dug up and placed above ground, vulnerable to damage and


See: http://www.defra.gov.uk/


See:http://www.defra.gov.uk/ Environment/waste/special/index.htm)


• The Carriage and Storage of Petrol. It is not permitted to carry more than 2 x 5 litre plastic containers of petrol in a normal vehicle. As there are three pieces of legislation relating to portable petrol containers, dating back to 1928, it is difficult to understand the law and much is left to interpretation by local officials. The HSE, however, in their Carriage of Dangerous Goods Manual, under Small Load Exemptions, states that; a typical case would be the carriage of two or three jerry cans in a van. Many groundsmen and greenkeepers are, often unwittingly, collecting and carrying far more than this either in their own or company vehicles. This, apart from being a dangerous practice, will most probably negate insurance cover flouting Health and Safety rules. (a golf club secretary informed us that his insurance company had confirmed that they would not cover the club and that other arrangements should be made immediately!) An inexpensive solution is to use a Transit Box, specially designed to carry 4 x 20 litre jerrycans. This can be carried on the back of a trailer or a pickup legally and also be used for storage. A better answer, saving frequent visits to a filling station, is to purchase a bunded, fully compliant petrol station, like the one offered by Course Care.


vandalism. Such a preposterous idea can be dismissed, as to implement it would lead to far greater pollution and be totally unworkable! When contacted, senior officials from the Environment Agency told us that they are not aware of any such proposals and to issue statements suggesting such changes to


legislation would be seen as misleading!


• The Hazardous Waste Regulations Already covered in depth in our


• Environment Agency PPG. One of the Pollution Prevention Guidelines issued by the EA and considered best practice. PPG2 covers above ground oil storage tanks and describes how tanks should be bunded. Copies are available from the at: http://www.environment-agency.gov.uk/ business/444251/444731/ppg/ It should be noted that, although gravity dispensing, bottom outlet tanks are ‘legal’, the preferred option is for top fill - top offtake bunded tanks. Bottom offtake tanks are considered a possible cause of pollution. It does seem pointless purchasing a bunded tank with a bottom offtake in the knowledge that simply opening a valve could discharge the whole contents or, as often happens, vandals or thieves actually break the valve off! You have no defence if prosecuted, as it would be deemed that you had not taken reasonable precautions to prevent pollution.


20 www.pitchcare.com/re


April/May issue, the new regulations replaced The Special Waste Regulations and have been subject to recent change affecting everyone in our business.


• Environment Agency PPG26. This covers the storage and handling of drums (see previous weblink). Essentially these guidelines emphasise the need to use Sump Pallets, Drip Trays and Spill Kits. Spill Kits should be placed next to each oil store, i.e. sump pallet, diesel tank, petrol station. All of these items should be available from you fuel tank or oil supplier.


With thanks to David Mears, Joint Managing Director, Course Care Lowcall number: 0845 600 3572 Website: www.course-care.co.uk


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