Feature


Tertiary Containment: Going Beyond SFG20


Don’t get caught out: make sure your clients’ assets are compliant with law, not just guidance


Tertiary containment systems play a vital role in minimising the consequences of a major environmental incident. Correct management of separators and interceptors for your client should ensure that if secondary containment systems fail or exceed capacity you have a ‘final frontier’ to trap harmful light liquids before they enter the surrounding area.


But tertiary containment will only be effective if it is well- maintained. Shirley Miles, Head of Environmental Protection at Adler and Allan, explains that most Facilities Managers following the guidelines in SFG20, believing that this ‘industry standard’ will have them covered not realising that it does not fully comply with the current standard BSEN 858-2:2003.


SFG20 does of course cover


What Does SFG20 Say? the basics


Your Responsibility of responsible


interceptor maintenance. In Section 48-03 it advises that every 12 months you check and report any significant deterioration, clean any contamination, check for obstructions in chamber interconnectors and vent pipes, and comply with safety regulations regarding working in confined spaces.


However… what users of SFG20 often do not spot is the line in the Overarching Introduction which reads: “The Specification [i.e. SFG20] is not intended to replace the Manufacturers guidance but rather supplement it. For the avoidance of doubt, the manufacturer’s guidance will always take precedence over the Specification.”


And why is this crucial? Because any Manufacturer’s guidance for interceptor systems will refer you to BSEN 858-2:2003, which must be fulfilled to demonstrate your client has met their statutory obligations.


So you may think you are maintaining your clients’ assets to the relevant standards while actually remaining dangerously unaware of your full legal responsibilities.


What Does The Law Say?


The current British Standard for the operation and maintenance of separators (or interceptors) BS EN 858-2:2003 regarding separator systems for light liquids (e.g. oil and petrol), states that they must:


• Be fitted with an automatic warning device/high level alarm • Be serviced and maintained as a minimum on a 6-monthly basis • Be subject to a maximum interval of a 5-yearly integrity test • Have full service and maintenance records available for inspection


A pollution incident caused by poorly maintained or inadequate containment is a strict liability offence and failure to adhere to current standards is a key factor in prosecution.


The onus is on you and your client to demonstrate that you have done your utmost to ensure compliance according to BS EN 858-2:2003, as well as best practice guidance in SFG20 and CIRIA 736. To this end, you need to keep comprehensive service logs as evidence of your robust maintenance and servicing.


The costs of failing to do this are not just environmental, but legal, financial, and reputational with fines up to 100% of pre- tax profits.


So What Should You Do To Ensure Full Compliance?


Firstly, pay close attention to the small print in SFG20, and more importantly the manufacturer’s guidance for your client’s specific containment systems. Do not assume that ‘guidelines’ and ‘advice’ constitute statutory compliance.


Follow a programme of proactive interceptor maintenance, in line with BS EN 858-2:2003, which requires you install an interceptor alarm system to monitor oil, silt, and liquid levels within underground interceptors.


It also requires your client’s interceptors are serviced and maintained as a minimum, every six months and integrity tested every five years.


Ideally, work with an environmental partner who can service and test your client’s interceptors according to their specific type and setting, using the latest technology and methodologies. They can conduct a non-intrusive six-monthly inspection to check levels and functionality of key components, and a more detailed five-yearly integrity inspection.


Finally make sure you – and any partner you use - keep full records of maintenance, servicing, inspection, and testing.


Find out more about Adler and Allan here: https://www.adlerandallan.co.uk/sectors/facilities-management/ fmuk 33


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