Clarehill Plastics Limited, manufacturers of Harlequin Oil Tanks has called for all new and replacement domestic oil storage installations in the United Kingdom, to be afforded the same degree of environmental protection as installations in many mainland EU countries.
At present, Building Regulations throughout the UK require that prior to the installation of a new or replacement domestic oil storage tank, a Risk Assessment is undertaken to determine whether or not a spill from the installation would pose a risk to nearby groundwater sources. In the event, that such a risk exists then secondary containment should be afforded to the installation, either by the installation of a Bunded Tank or the construction of a masonry bund.
However, according to Harlequin's John Switzer, all too often the risk based approach is simply not working.
“Theoretically, the risk based approach has much to commend it, but in the real world it is cumbersome, clumsy, unfit for purpose and cannot be relied upon to provide the level of environmental protection that any reasonable person would expect. Firstly, it fails to provide any protection whatsoever to unknown and unsighted water sources; and secondly it is impractical, requiring that a detailed visual inspection be undertaken of an area not less than 50 x 50 metres. At many domestic properties, it simply is not possible to have access to such a vast area, with the result that even Building Control Officers are reportedly falling foul of the very Regulations they are responsible for implementing.
“It is our opinion that in the real world, the whole premise of the risk assessment is fundamentally flawed. Fuel storage requirements at commercial, industrial and institutional installations require that externally positioned, fuel storage installations with an installed capacity of 200 litres or more are afforded secondary containment. Ironically, such sites will often incorporate pollution prevention features such as interceptors, spill kits and spill control procedures which are rarely found at domestic installations. Therefore, the implications of a comparatively small spillage at a domestic storage installation can be more severe than a larger spill at a commercial installation. However, current fuel storage requirements at domestic installations fail to recognise this reality and therefore fail to provide domestic oil storage installations, with the same level of environmental protection that commercial installations enjoy.”
In England and Wales, there is a longstanding requirement that all new and replacement domestic oil storage installations must either be installed by a member of a recognised competent persons scheme, or receive approval from Building Control. However, a small yet significant number of oil storage installations continue to be undertaken 'beyond' the regulations and with scant regard for the environmental consequences of such installations.
A review by Clarehill Plastics Limited of 200 domestic single skin oil tank installations in England and Wales, installed in the past 7 years revealed that in 85% of instances, a single skin oil tank had been installed where a Bunded Tank was required.
In light of the understandable concerns over domestic oil storage installation requirements, proposals have now been put forward for the introduction of compulsory secondary containment at new and replacement domestic oil storage installations, as part of a review of The Building Regulations in England and Wales being undertaken by The Department for Communities and Local Government (DCLG). Ahead of its submission to the review, Clarehill consulted with a number of leading oil storage tank resellers and installers to get their feedback on the current risk based approach to domestic installations.
“The feedback from resellers and installers alike was pretty consistent. There is an acknowledgement that in the real world, the risk based approach to domestic oil storage installations is not working and cannot work.
“Many installers and resellers with whom we spoke have already began to adopt a 'Bunded Tank Only' approach to all new and replacement oil storage installations. Quite simply, they see Single Skin Oil Tanks as being typified by unknown risk and the potential for almost limitless liability, in the event they unwittingly install the wrong type of tank at the wrong installation. It's not going too far to say that an increasing number of installers are actually ahead of the Regulations in many instances. Only this week, a major national oil tank reseller formally discontinued the supply of Single Skin Oil Tanks. “
“Of special concern, are reports of a small but significant element of rogue installers who bypass the current risk based approach and use the continued availability of single skin oil tanks to install an uncontained single skin tank, where a Bunded Tank is required. It should be stressed that few if any of these installers are accredited oil storage technicians. More often than not, they are simply 'handymen' who turn will turn their hand to fitting just about anything from gas boilers to oil tanks, so long as the money's right! The attitude amongst such people is essentially that regulations are somebody else's concern and if, or more likely when, something goes wrong – they are unlikely to be hanging around for too long. Understandably, responsible installers are increasingly frustrated that by doing the right thing and ensuring compliance with prevailing Regulations, they render themselves uncompetitive against a small number of cowboy installers.”, explains John.
In light of the feedback from resellers and installers, Clarehill's submission to the DCLG commissioned review, calls for the current risk based approach to domestic oil storage to be replaced with a requirement for the compulsory provision of secondary containment at new and replacement domestic oil storage installations. As well as bringing domestic installations in England into line with existing requirements at most non-domestic installations, the proposals also begin to align fuel storage regulations in the UK with the higher standards that have for some time prevailed in many mainland EU countries. And of course, if secondary containment were to become the norm, then life is made harder for cowboy installers. The proposals contained within Clarehill's submission have been endorsed by the training, standards and registration agency for the oil heating industry in the British Isles, OFTEC – The Oil Firing Technical Association.
Another benefit of a move to secondary containment at all new and replacement installations, is an overall cost saving to the economy in England and Wales of c.£12.5m per annum and a potentially even greater saving to the total UK economy.
“Consisting of a 'tank within a tank', Bunded Tanks by default will cost more than a comparable Single Skin Oil Tank. Bunded Oil Tanks already comprising over 70% of domestic oil tank sales in England and Wales. The incremental cost of switching the remaining 30% of tanks to Bunded models would be c.£88.2m over the next decade. However, according to figures prepared by the world renowned London School of Economics, the gross benefit of the introduction of compulsory bunding at domestic oil storage installations over the next 10 years would be £213.8m. By subtracting the Gross Cost from the Gross Benefit, it is apparent there is a potential saving to the oil heating industry of £125.6m over 10 years, or c.£12.5m per annum. If the same analysis were to be undertaken for Scotland and Northern Ireland, then the total saving to the UK economy could be over £20m per annum.
“So, whilst oil pollution costs the environment, pollution prevention needn't cost the earth and is economically beneficial.”, concludes John.
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