Why facilities managers must go beyond SFG20 guidelines to keep tertiary containment systems compliant

Insights

Don’t get caught out. Make sure your clients’ assets are compliant with the law, not just guidance

Tertiary containment systems (in particular, separators or interceptors) play a vital role on any storage site in minimising the consequences of a major environmental incident. Correct management of 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 succeed in this function if it is well maintained, which means adhering to current standards and good practice guidance and, most crucially, the correct statutory requirements. This is unfortunately where some management operators and their clients have unwittingly found themselves in hot water.

Most facilities managers will follow the SFG20 guidelines, believing this ‘industry standard’ will have them covered.

However, what many professionals do not realise is that ticking the boxes of the top-line, often loosely worded requirements in SFG20 is not enough. SFG20 guidance does not fully comply with the current BS EN 858-2:2003 standard, leaving unsuspecting facilities managers open to prosecution.

What do the SFG20 guidelines say?

The SFG20 guidelines do, of course, cover the basics 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. All eminently advisable.

What users of the SFG20 guidelines often do not spot, though, is the instruction given within section 48-03 and more clearly still at the beginning of the manual: “It is extremely important that you have read and understood the SFG20 Overarching Introduction which is the first schedule included in this Book of Standards and provides essential guidance concerning: Statutory Compliance; Safety; Points to Consider during Maintenance Works; Maintenance of Systems; Proprietary Equipment; Records; Efficiency and Emissions; Catering.” [SFG20, p.1]

Follow this instruction and you find a line in the Overarching Introduction that reads: “The Specification [i.e. SFG20] is not intended to replace the Manufacturer's guidance but rather supplement it. For the avoidance of doubt, the manufacturer’s guidance will always take precedence over the Specification.” And again, within section 48-03, the instruction is reiterated: “Ensure you have read and understood the manufacturer’s recommendations”.

Why is this crucial? Because any manufacturer’s guidance for interceptor systems will refer you to BS EN 858-2:2003, which must be fulfilled to demonstrate that your client has met their statutory obligations to ensure they manage their assets without harming the environment, and so avoid liability and strict financial penalties. Not just SFG20 guidelines, but the current regulator-recognised standard.

If you fail to follow this signposting from these lines tucked away in the SFG20 guidelines – and it’s all too easily done – you may think you are maintaining your clients’ assets to the relevant standards, while actually remaining dangerously unaware of your full legal responsibilities.

  1. Beyond SFG20 guidelines
  2. Beyond SFG20 guidelines
  3. Beyond SFG20 guidelines
  4. Beyond SFG20 guidelines

What does the law say?

The Water Resources Act 1991 states that "It is an offence to cause or knowingly permit any poisonous, noxious or polluting material, or any solid waste to enter any controlled water."

Environmental Permitting Regulations 2016 state that "It is an offence to cause or knowingly permit a water discharge activity or a groundwater activity without an environmental permit."

The current British Standard for the operation and maintenance of separators (or interceptors) is BS EN 858-2:2003.

Regarding separator systems for light liquids (e.g. oil and petrol), it 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.

Following an increased number of pollution incidents where failed interceptors have been the cause or exacerbating factor, the authorities have been clamping down on poorly maintained and non-compliant operations. Fines can be up to 100% of pre-tax profits and, in certain circumstances, senior officers of offending businesses have been held personally liable.

So, what should you do to ensure full compliance?

Firstly, pay close attention to the small print in the SFG20 guidelines and, more importantly, the manufacturer’s guidance for your client’s specific containment systems.

Do not assume that ‘guidelines’ and ‘advice’ constitute statutory compliance. Find out specifically what current legislation, standards and good practice applies to your client’s setup, ensure you follow it, and keep detailed records.

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, ensuring they are operating correctly and preventing pollutants.

It also requires your client’s interceptors to be 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 five-yearly integrity inspection, which is particularly important as there are several faults that can develop internally that could compromise the system but remain undetected during the six-monthly inspection.

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

Working with an environmental partner who can advise on your statutory obligations will provide a full ‘peace of mind’ service package to keep your client’s tertiary containment maintained and compliant.

A turnkey partner will have the latest technology and keep comprehensive records – as well as innovating to improve system efficiencies and save your client money.

How we can help

Published on 3 August 2022.

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