Environmental, climate change and workshop waste
Environmental, climate change and workshop waste
Environment Policy and Management Systems
The Fire and Rescue Service/Authority should have an Environment Policy which includes Engineering and Transport and demonstrates a commitment to reducing the environmental impact of its operations and be working towards sustainable development.
The policy should be supported by an Environmental Management System that monitors and reviews the environmental impact of the operations and sets objectives and targets to meet environmental responsibilities.
The Service/Authority may decide to implement the system in conformance with the recognised standard ISO 14001 and further consider BS EN 16001 which is a specific energy management system.
As with other management system standards you may choose to implement the structure and processes without ever going for full certification. However third party verification can have significant benefits in terms of legitimising the work done, confirming your actions are correct.
There is an almost universal agreement amongst independent scientists that climate change is real, is the great environmental challenge facing the world today, and that the only real debate should be what to do about it.
The gases which have the largest impact on climate change are water vapour and carbon dioxide. As humans emit more carbon dioxide and other greenhouse gases into the atmosphere, the Greenhouse Effect becomes stronger causing the global climate to change unnaturally. Amounts of carbon dioxide and other greenhouse gases emitted by human activity has increased significantly as we have become more and more dependent on fossil fuels. The Greenhouse Effect will change the climate in many ways, including warmer temperatures, wetter winters and drier summers. Adapting to climate change and reducing emissions poses a huge challenge for all operators of vehicle fleets.
To illustrate the point, DAF, the vehicle manufacturer, said in 2010 that “22% of the UK’s CO2 emissions come from transport, one-third of which is from truck exhausts”.
In 2008 the UK was the first country in the world to introduce a Climate Change Act. It has also set major targets to reduce emissions by 34% by 2020 on 1990 levels and 80% by 2050. The Committee on Climate Change has also been formed to direct Government on how to move the UK to a low carbon economy. All the above initiatives show that climate change is moving up the political agenda and the FTA have said that the UK is likely to see increasing carbon policy measures which could affect fleet operations.
Alternative fuels, storage issues and their effects on heavy and light vehicles require careful consideration and information from the FTA and SOE/IRTE, in addition to vehicle manufacturers, provide a valuable source of information. (e.g. IRTE “Transport Engineer” conference report on Bio Fuels – October 2010 edition).
The Government and transport industry generally have stressed the importance of not overlooking driver education and training and their role in reducing fuel consumption. There is considerable guidance available to those responsible for driver training and vehicle operation from the links below.
- Society of Operations Engineers – See the “Guide to improving fuel efficiency”
- The Environment Agency – Business and Industry
- The Department of Energy and Climate Change
Management of Workshop Waste
The Environmental Protection Act 1990 Section 34 imposes a ‘Duty of Care’ on all persons concerned with the production, importation, keeping of, treating or disposal of Controlled (Directive) waste. Note: see Defra statutory guidance, “Waste Management – The Duty of Care – A Code of Practice”.
It should be noted that Waste Regulations are subject to EU Directives therefore there are differences in the legislation applying in Scotland and to a lesser degree Wales and Northern Ireland from England. The attached links clarify the differences. Furthermore this legislation has been the subject of significant changes in recent times therefore readers are urged to use the attached links in order to establish the current situation.
Controlled or Directive waste is defined as any household, commercial or industrial waste, such as waste from a house, shop, factory, building site or any other business premises. Waste is further defined as scrap material, effluent or other unwanted surplus substance, anything that is broken, worn out, contaminated or otherwise spoiled that is being discarded. Certain difficult or hazardous wastes, some of which are common in the workshop, are further classified as Special/Hazardous Waste and are subject to additional requirements.
Clearly any Fire and Rescue Service premises where vehicles and equipment are stored, repaired or maintained is probably going to produce both controlled and hazardous waste. Any such site will also need careful management with regard to environmental contamination.
3.1 Transportation and Storage of Waste
In some cases, it may be that a Fire and Rescue Service can be licensed as a Waste Carrier simply by being a Department of the County Council, most of which hold the required registration issued by the Environment Agency. This may also be of benefit operationally in regard to scrap cars for RTC training and the recovery of contaminated items from incidents.
There are reputable companies who will provide assistance and advice or a total service, including the provision of suitable containers for the storage and transport of vehicle related waste. An example of an Automotive Total Waste Management Programme can be viewed by following this link. See their Automotive Hazardous Waste pdf for “wastes and containment matrix” relative to workshops.
The local manager needs to be in control of the situation at all times, and it is worth remembering that it is the individual not necessarily the Organisation that is responsible in law. The following are some examples, but not a definitive list of areas to consider when planning your waste control and disposal operation.
3.2 Contamination of a Site
It is necessary to hold and keep updated a full set of plans and drawings of your whole site, not just the workshop facilities.
This should contain details of both, foul and storm water drains, water courses interceptors well as other services. The direction of flow and the eventual destination, particularly with shared services, will always be important if damage limitation should be required.
3.3 Ground Contamination Risks
The greatest risk in any workshop will be the possibility of a liquid spillage, e.g. hydraulic oil from ruptured tanks or spilt hydraulic pipes fuel spillage. Where this risk exists, all work should be carried out in areas where drainage will be via an interceptor before it can reach the storm water drainage system or natural water courses.
Steam or pressure vehicle washing systems also fall into this category. If this is not possible, due to costs or site layout, then some method of containment will be required.
The storage of all bulk liquids such as vehicle fuels, central heating oils, lubricants and waste oil storage, should of course be fully bunded with particular attention to ensuring that contamination of the ground in the fill/drain pipe area is avoided.
Serious consideration should be given to the specification and use of bio- degradable hydraulic oils (where the manufacturer approves their use).
Mobile service vehicles operated away from the workshop by the FRS or contactors present a significant risk and they should be required to carry containment systems and materials to deal with any spillages.
The storage of smaller quantities of any liquids will need to be considered, not only for containment, but with, for example, Health and Safety and COSHH, in mind.
Finally, a good manager will always look around their site on a regular basis looking for the risk of ground contamination. Waste holding areas are always the biggest risk. Always remember it does not need a spillage to happen, it is just the potential for a spillage to happen that can bring a prosecution.
3.4 Financial Considerations
The cost of waste disposal is now reaching a point where it can occupy its own budget heading, therefore becoming an overhead on the workshop hourly rate. Many organisations now find it worthwhile to segregate waste with a view to turning expenditure into an income.
Listed below are a few examples:
- Waste paper
- Waste oil
- Non ferrous scrap metal
- Ferrous scrap metal
- Lead acid batteries
The quantities needed to encourage a registered waste dealer to collect from site will vary according to the current going rate. The larger the quantity is usually the better regarding the price that can be negotiated. For smaller enterprises, it may be the best deal can be obtained by giving the waste away in exchange for free skip facilities. Failing this, the services of a reliable and most importantly a registered waste disposal company will have to be brought in.
3.5 Hazardous Waste
Many items of workshop waste fall under this heading and can be easily overlooked due to their everyday use. Reference should be made at regular intervals to the various guidance notes contained in the links below regarding the classification of waste.
3.6 Record Keeping
The Act requires all those subject to the duty of care to make records of waste they receive and consign, to keep the records and to make them available to the waste regulation authorities if required.
The local manager’s main concern is to ensure that the waste carrier or the waste merchant is properly licensed. Never allow any waste to leave your premises until a waste transfer note has been completed.
3.7 Links to Waste References
4. Fleet Selection
Road vehicle technology has significantly progressed since 2010. This has resulted in the availability of Ultra Low Emission Vehicles (ULEV’s) which provide significantly lower environmental impact
Each FRS should give consideration to scoping and specifying ULEV’s for fleet provision wherever appropriate.
Additional measures to managing and reducing environmental impact should also be pro-actively pursued. Such measures include:
- Vehicle Speed Limiters
- CO2 Upper limits on fleet specifications
- Route Planning
- Car Sharing Schemes
- Education and Driver Training