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Article #117: Will the UK Waste Industry Achieve Safe Compliance with the ATEX Regulations in time?

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Waste Management Operators may have done assessment. The ICoPs recommend the best
all they can to maintain good health and person to carry out these assessments
safety practices in the past, and will will normally be the site manager.
continue to do so; but how many will be (Please include the ATEX sign graphic
compliant after 30th July 2006 when the here.)
EU's ATEX Directive finally comes into This requirement is in addition to the
force? normal practice of writing method
The EU Directive applies to all statements based upon risk assessments,
workplaces where the risk of the presence plus internal H&S checks, and Supervisor
of an Explosible Atmosphere exists, and approvals in place in companies already,
encompasses all installations from waste as has been the case since the
transfer and processing plant (where introduction of various health and safety
explosive dusts, and unused solvents may legislation in the 1980s.
create an explosive atmosphere), to any A major area of concern remains in
landfill - no matter how long since respect of the impact which the DSEAR
closed and made over to other uses - will have on the after-use and
which possesses any wells (for gas or restoration of landfill sites, and such
leachate monitoring or management) in matters need to be taken on-board by the
gassing waste. planners when after-use policy is
Although the large waste operators have established for sites. The directive is
been actively tackling the issues explicit and prescriptive in that each
surrounding ATEX compliance at their zone area must be signed, and it is clear
waste collection, transfer and processing that these zones extend into the general
facilities, and on their (mostly active) airspace around and above chambers,
landfill sites, most landfills are wells, and boreholes etc. Just how this
historical and fall into the "closed" can be squared with public access uses
category. In this area there has been such as golfing, and even dog-walking has
very little activity to review old sites, yet to be resolved - yet the defined
assess which exhibit the potential for an zones apply to workplace activities and
explosive atmosphere to be present, and not the public usage of the site.
compile the necessary risk assessment, Generally, the ICoPs give guidance which
ameliorative, training and record keeping by its specificity will clarify the
actions needed for compliance. interpretation DSEAR requirements and
Similarly, activity would seem to have reduce costs to an affordable level.
been minimal in reviewing and risk Detailed reading of the ICoPs should do
assessing existing leachate treatment and much to allay concerns that wholesale
methane stripping plant for compliance - replacement of equipment which has given
so far. long-term incident free service over many
Even within the big five UK waste sites and for extended periods, would be
operators active sites there are real required just to comply with the
problems in interpreting the requirements directive.
and in achieving compliance, and much of There have however, already reportedly
this arises from the inherent difficulty been substantial costs to some major
in applying regulations which were operators in preparation for DSEAR. SITA
originally perceived for factory and themselves have been reported as finding
industrial workplaces, to a landfill it necessary to spend between £50,000
setting. and £100,000 per flare, on changing 18
However, the industry has been actively of its landfill gas flares on sites
working to solve the matter. For more around the country to comply.
than the past 12 months the waste Such high costs are likely to be the
industry has been endeavoring to tackle exception rather than the rule, and costs
the various issues surrounding ATEX will be best controlled by careful
compliance, as regulated under the UK's reading, and in-depth knowledge, of the
instrument known as the DSEAR (Dangerous ICoPS. Although not all ICoPs have yet
Substances and Explosive Atmosphere been published, reviews can be undertaken
Regulations). A working group has been in full knowledge of the approach being
meeting, and is currently well advanced taken by the ICoP committee. Industry
in its programme to produce six Industry participants will normally also be
Codes of Practice to provide provided with final drafts of ICoPs prior
comprehensive guidance on the application to publication for their comments, on
DSEAR to all waste management activities. request.
The first Code (ICoP1) was published in So the message is that all Site Managers,
Autumn 2005, and establishes general Estate Managers with former landfills as
principles of compliance, provides basic part of their landholding portfolios, and
calculations for establishing ATEX Area the Waste Disposal Officers for Council's
Classification ("Zones") around landfill responsible for closed landfill should be
wells, boreholes etc., and provides aware of this legislation and should be
examples of the most common zoning. making it their duty to familiarise
ICoP 2 is titled, "Area Classification themselves with the ICoPs, and then carry
for Landfill Gas Extraction, Utilisation out their reviews, and all this needs to
& Combustion", and was published in be done by the end of this month (June).
November 2005. By taking this approach DSEAR compliance
ICoP 3; "Area classification for leachate should become both affordable, and reduce
extraction, treatment and disposal", has injuries from these risks. Whether the
now also recently been published, and a rate of injury directly from the risks
further ICoP on Landfill Operation is covered by these regulations was ever
well advanced. sufficiently high for any statistically
All these documents are approved by the relevant Health and Safety gain ever to
Health & Safety Executive, before be seen is doubtful, but we hope we are
publication, and are available for free proved wrong, and that the passage of
download on the ESA web site time will reveal real benefits to the
All operators will find that changes to industries workforce. In any event, the
existing practices will be required in implementation of these regulations will
order to comply with the DSEAR. Previous go ahead on 1 July, so the wise will go
procedures for carrying out risk ahead now and comply as a matter of
assessments and establishing safe working urgency.
methods will need to be re-assessed and Note 1: The article refers to the "ATEX
modified to comply with the new DSEAR Directive", for brevity, however, the
Zoning requirements. Specifications for DSEAR actually implements two EU
equipment will require review and either Directives on the subject, namely: The
ATEX Certified equipment installed, or a ATEX Product Directive, and the ATEX
site specific risk assessment undertaken Worker Protection Directive.
to justify each plant installation is Note 2: The term "ATEX" is derived from a
"appropriately" certified if ATEX shortening of the words ATmosphere and
Certificates are not available for EXplosible.
existing plant, as required under these (Steve Last served on the committee in
regulations. preparation of ICoP 3, and has commented
All staff and operatives will in future on others.)
under these regulations be required to be This article is free for republishing
trained specifically in atmospheric Source:
explosion risk management in general, and Occupation: Environmental Engineer
in the meaning of three ATEX Zones, each Steve Last is an environmental engineer
of which reflect the degree of risk who is also a Chartered Environmentalist
within one of three classified risk (CEnv), and lives in the county of
severity situations. Drawings must be Shropshire, UK. CEnv is a new and growing
retained on site showing the locations academic discipline created in the last
and extent of these ATEX area two years. All Chartered
classification zones, and each zone must Environmentalists further the principles
be marked on site by a sign. These zones of sustainability.
will all need defining individually for UK and World Climate Change: For Better
each site on the basis of a risk or for Worse.






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