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