and, yet still, there are a good number of establishments that are ignoring the demands of legislation”
“So much has been written on this topic over recent years
David Mears, Joint Managing Director, Highspeed Group
area where food is consumed. Best practice is to ensure that, whatever tank is used, it is top fill - top offtake. This prevents any chance of pollution, as would be possible if a bottom offtake tank were used. The practice of a tank raised up on blocks and using a gravity hose is definitely frowned upon. Consider the pollution possibility; knock the gate valve off and the whole contents flow out! The use of single skin tanks is gradually being phased out, with many manufacturers reducing or stopping production. A number of companies selling these tanks previously have now delisted them and, so, their days are numbered. We know of a growing number of instances too, where tanker drivers have refused (and rightly so) to deliver fuel to non-compliant or dangerous tanks. A document from DEFRA, which gives guidance, may be worth looking at;
http://www.defra.gov.uk/environment/quality/ water/waterquality/oilstore/documents/oil_store. pdf.
It may also be worth noting that, as the Scottish regulations are more encompassing, it is anticipated that the
England and Wales regulations will be updated to a similar level.
Wash Pads
So much has been written on this topic over recent years and, yet still, there are a good number of establishments that are ignoring the demands of legislation, regarding cleaning machinery and equipment, with wash-off water going to ground. This is illegal. You need to comply with the new Groundwater (England and Wales) Regulations 2009, which came into force on 30th October 2009. Conformance with the EU Water Framework Directive is also applicable. The Regulations, which are law, are very clear and state that you cannot discharge hazardous substances into the ground. Among those listed as hazardous in the regulations are: persistent hydrocarbons (that’s oil, grease, petrol, diesel etc.) and persistent and bioaccumulable organic toxic substances. So, washing down machines into the groundwater, with these substances on them, means that you are breaking the law. To claim ignorance of this is no defence.
The EA is paying particular attention now to water resources offences (see Civil
Sanctions notes later), and the installation of a fully compliant wash-off facility, with a dedicated washpad surrounded by a low kerb, should be a priority. The ideal solution, of course, is to include a water recycling system that, unlike discharge systems, will save many thousands of litres of water. A recycling system is “future-proof ” too. If you choose an officially approved system, on the Water Technology List (WTL), you will have the added advantage of being able to make tax savings under the Enhanced Capital Allowance scheme (ECA). Ask your accountant to check this out.
A word of caution when considering a wash-pad solution; do thoroughly research what is being offered and make an informed decision. Not all so called “systems” are proper biological recycling systems, but glorified separators which discharge. Discharge from separators or discharge systems must go to the foul sewer and cannot go to ground. If you have access to foul, then you can install a separator (subject to your sewage company’s approval), but do consider the regular pump-out costs, water wasted and that it may not be “future-proof ”.
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