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