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Quick Guide: SFG20 (schedule 48-03)

Published: 29 March 2023 | Download Quick Guide


This Quick Guide looks at SFG20 (schedule 48-03), the legal implications, why it's important to act, and what you should do to apply this good practice guidance to your organisation.

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Summary

Launched in 1990 by the Building Engineering Services Association (BESA), SFG20 is recognised as the industry standard in facilities management for building maintenance specifications.

It is a web-based service, with a growing library of over 1,200 maintenance schedules (sections) for more than 70 equipment types, which are kept updated by BESA.

This removes the requirements of consulting the manufacturer guidelines for each asset, saving facility manager’s time and hassle while making it easier for an organisation to remain compliant.

The legal perspective

SFG20 (schedule 48-03) covers the basics of responsible separator maintenance.

It used to advise 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.

This has been updated to reflect the maintenance schedule established in the current British Standard for the operation and maintenance of separators, BS EN 858-2:2003 Separator systems for light liquids (e.g. oil and petrol).

The updated schedule 48-03 states that separators 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.

Why you must act

Due to the recent change that now applies for separators, all facility managers should adjust their maintenance schedules to demonstrate their client has met their statutory obligations.

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 the facility manager and their client to demonstrate they have done their utmost to ensure compliance according to SFG20 (schedule 48-03), and BS EN 858-2:2003, and followed best practice guidance established in CIRIA 736.

To this end, comprehensive service logs must be kept as evidence of robust maintenance and servicing.

Penalties and reputational issues

The costs of failing to follow the guidance set out in SFG20 (schedule 48-03) are not just environmental, but could be financial and reputational.

Following an increased number of pollution incidents where failed separators 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. In certain circumstances, senior officers of offending businesses have been held personally liable.

Practical application

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.

We advise that you work with an environmental partner to follow a programme of proactive separator maintenance that complies with the updated guidance in SFG20 (schedule 48-03).

This requires you to:

  • Install alarm systems to monitor oil, silt and liquid levels in your client’s underground separators.
  • Every six months, service and maintain your client’s separators and conduct a non-intrusive inspection to check levels and functionality of key components. Ideally, engage an environmental partner who can work according to the specific type and setting of your client’s separators using the latest technology and methodologies.
  • Every five years, conduct a more detailed integrity inspection of your client’s separators.
  • Keep full records of maintenance, servicing, inspection, and testing.

What you should do

  1. Install alarm systems to monitor levels in underground separators.
  2. Service and maintain separators every six months.
  3. Conduct a more detailed integrity inspection every five years.
  4. Keep full records of all maintenance and servicing.
  5. Work with an environmental partner who can guide you through the required inspection and maintenance regimes to ensure your sites remain compliant.
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