Category Archives: Guidances

Environmental Compliance Update: Monitoring Fugitive Emissions from Shredding Waste Upholstered Domestic Seating

 

Environmental Compliance Update: Monitoring Fugitive Emissions from Shredding Waste Upholstered Domestic Seating

🔍 Background: The Environment Agency has issued RPS 297, providing guidance for waste treatment sites handling shredded waste upholstered domestic seating (WUDS) containing persistent organic pollutants (POPs). Whilst this position statement only applies to England, if you are handling POPs/WUDS in Scotland and the rest of the UK it would be prudent to take this into account.

📋 Key Conditions to Meet:

  • Appropriate Disposal: Ensure shredded waste is sent to an authorized Industrial Emissions Directive Chapter 4 compliant permitted incinerator.
  • Health and Safety Monitoring: Maintain workplace exposure monitoring data showing fugitive particulate levels below 5 mg/m³.
  • Fugitive Monitoring Plan: Collaborate with the Environment Agency to establish a monitoring plan by August 31, 2024.
  • Results Reporting: Submit monitoring results to popsinsofas@environment-agency.gov.uk by December 20, 2024.
  • Abatement Equipment: Install abatement equipment by December 1, 2025, if necessary based on monitoring results.

🔗 Read the full RPS here: Monitoring Fugitive Emissions from Shredding Waste Upholstered Domestic Seating (RPS 297)

ℹ️ Please note: While this update provides valuable guidance for waste treatment sites, it is important to recognize the current challenges in monitoring for Persistent Organic Pollutants (POPs) and the lack of an agreed sampling methodology in the UK. Additionally, RPS 297 only applies to England and for those operating in other parts of the UK there is currently no similar Position Statement.

🌍 Albion services: If you work with waste upholstered domestic seating Albion can offer the following services:

  • Compliance Assessment: Determine the extent of compliance with regulations regarding the handling, shredding, and disposal of waste upholstered furniture.
  • Risk Assessment: Identify potential environmental and human health risks associated with shredding waste.
  • Consulting: Provide guidance on best practices for managing waste including segregation, handling, storage, and transportation.
  • Training: Develop bespoke training programs for your staff on safe handling practices, environmental regulations compliance, and risk mitigation strategies.
  • Monitoring: Help develop monitoring protocols to track compliance with regulatory requirements.

Contact Us: Have questions or need assistance?
📞01292 610428

 

Dangerous Goods Safety Advisor (DGSA)

2023 Changes to the Law regarding DGSA’s

Companies who have previously transported dangerous goods only as consignors (according to the description given in the ADR manual, “Consignor” means the enterprise which consigns dangerous goods either on its behalf or for a third party. If the transport operation is carried out under a contract for carriage, consignor means the consignor according to the contract for carriage) were not obliged to appoint a safety adviser before, but will now have to do so since 31st December 2022.

 

What is a DGSA?

A dangerous goods safety adviser is a person certified to provide advice to organisations whose activities include moving dangerous goods.  Dangerous goods are classified under ADR, which stands for the “European Agreement Concerning the International Carriage of Dangerous Goods by Road”, there are 9 classes of dangerous goods which include materials and substances from explosives, toxic substances, radioactive material to flammable liquids and solids.

In order to become a DGSA, an individual must obtain a vocational training certificate after receiving appropriate training and pass a written exam.

The DGSA is responsible for helping to prevent the risks inherent in the carriage of dangerous goods, specifically the risk to people, property and the environment.

The responsibilities of the DGSA include:

  • monitoring compliance with the requirements governing the carriage of dangerous goods
  • advising undertakings on the carriage of dangerous goods
  • preparing an annual report about the performance of the undertaking in transporting dangerous goods
  • investigating any accidents or infringements of regulations and preparing reports
  • monitoring the provision of training and advice to other staff
  • reporting of incidents and accidents to DfT

 

It is an employer’s responsibility to contract a third party to act as a DGSA for their undertaking if they do not have a member of staff trained as a DGSA.

 

A common factor in the Waste industry is the transportation of Asbestos Waste, in which there are specific Road Transport Regulations to comply with. We have compiled a quick guide which details the classification, packaging, labelling, and documentation required under ADR for the transport of Asbestos Waste.

Asbestos by Road Chart

Albion Environmental have highly experienced and certified DGSA’s who can provide consultancy support for any organisations who require a Dangerous Goods Safety Advisor.

 

Dust Monitoring

How do you measure dust and why is it important?

Dust Monitoring by Albion Environmental

Particulate Matter (PM) is one of the main forms of urban air pollution, and it mainly includes smokes, soot, and dust. PM is a key indicator of air pollution due to its potential to harm human health. It is often split into PM10 and PM2.5, the latter of which is inhalable (it can penetrate through to deeper parts of the lung compared to PM10, which can only access the lung’s larger airways).

Outside of urban environments, many work activities can create dust, and dust can be an issue in almost any industry. Some of the main industries which can experience dust issues include construction and demolition, certain parts of the food industry, woodwork, as well as waste management.

Waste facilities can generate dust through mechanical grabbers and mobile plants which sort and load waste, and through waste shredding and sieving. Additionally, heavy duty vehicles driving on and off waste sites can generate fugitive dust emissions, which can be entrained onto local roadways. It is important for waste facility operators to minimise the dusts emitted, from and at sites, to avoid legal claims over nuisance. The main motivation for lowering dust generated, should be to protect health.

How can dust affect us?

Dusts come in different sizes, and can be categorized as “inhalable dust” or “respirable dust”, based on their ability to infiltrate parts of the body. Different sizes and types of dusts can have different health effects, though excessive amounts of exposure to any dust can lead to respiratory problems.

If dust is allowed to build up in the lungs, it can cause lung damage, which may result in breathing impairments. Some dusts can be the source of  lung diseases and cancers, and others can lead to asthma, rhinitis, and extrinsic allergic alveolitis. Preventing the onset of dust-related diseases is hugely important, as the chronic effects of dust are often permanent, and can be disabling.

Managing dust in the workplace

The HSE recognises the need to prevent these issues arising by providing plenty of information on dealing with dust at work. Their Dust in the workplace: General principles of protection publication makes it clear that dust exposure must be prevented, or if this is not reasonably practicable, it has to be adequately controlled. If a site’s dusts fall within the definitions of a ‘substance hazardous to health’, then COSHH requirements apply to it, such as the need to assess the risks posed for site staff or visitors, and to ensure exposure is appropriately managed.

If a site monitors the concentrations of dust they emit, or the exposure levels for staff, and finds that there are any health concerns, then they need to implement control measures to mitigate these, at the very least. Control measures for dust can include dust enclosure systems, dust extraction, or water suppression.

Generally speaking, controls should be selected based on the hierarchy of H&S [JB1] controls, which places RPE[JB2]  at the end as a last resort, for example. Sites may also choose to take into consideration the costs, suitability, and ease of application of each control.

What can you do?

Although the UK has a wet climate, the amount of water available could drop by at least 10-15% in some areas by 2050, due to the climate crisis. As such, sites should consider alternative controls to water suppression, or improve their water efficiency through measures such as: water-efficient equipment; harvesting rain-water or re-using grey water; and insulating pipes to prevent leaks. Grants and loans for water efficiency measures can help: www.netregs.org.uk

How can Albion help?

Here at Albion, we can provide occupational dust (and bioaerosol) monitoring surveys, to inform you of the risks for workers at waste facilities. This involves one-day visiting the site, followed by a clear report interpreting the results and providing tailored recommendations on how to manage dust in accordance with COSHH guidance.

Albion Environmental has a number of environmental monitoring specialists, trained to complete a wide range of services within the field of environmental monitoring, including those related to air pollution. Find out more about the environmental work we do here:


Continuing Competence Refresher

Is your Continued Competence Test looming? Do you feel fully prepared?

Did you know Albion have a one-day Continuing Competency Refresher course?

Our Continuing Competence Refresher course is designed to provide candidates who are looking to undertake their WAMITAB Continuing Competence test with a one day mentoring session to assist them prepare.

The structure of the mentoring session involves discussions between an experienced WAMITAB assessor and the delegate.

During these discussions, the assessor will establish the level of knowledge the delegate holds and  highlight any areas of weakness or they wish to review in more detail.

The assessor will then go through the weaker areas with the delegate by using the most recent literature available from WAMITAB for revision to ensure they are up to date and feel confident to take their test. Additionally, the delegate may wish to further revise the areas in their own time.

For further information on our Continuing Competence Refresher course please contact Kirstie on 01292 610428 / email Kirstie@albion-environmental.co.uk.

Update from JAUPT on Periodic Training

At Albion Environmental we aim to ensure that our clients are always kept up to date with any updates that could impact their continuing development.

Which is why we want to make our clients aware of the recent update from JAUPT in relation to their Driver CPC Renewal. JAUPT advises that the EU commission have reviewed the Driver CPC Directive that now specifies that “a range of different subjects should be covered over the 35 hours”. Therefore, JAUPT wishes to reemphasise that drivers must not unnecessarily repeat the same periodic training subjects within a rolling five-year period. 

In addition, the Traffic Commissioners Office have also made a statement regarding periodic training – “Driver CPC training should either be varied or specifically tailored to a driver’s weaknesses. Taking the same courses repeatedly is not good enough. Failing to put structured development plans in place for drivers not only increases the risk of an incident occurring but would reflect very poorly on an operator if they were called before a Traffic Commissioner.”

Whilst you can undertake a wide range of courses to contribute to the compulsory 35-hours. We would recommend that you undertake a course relevant to the waste management sector, this would be so that you may update your knowledge of waste legislation.

Albion Environmental deliver a 7hr JAUPT approved Driver CPC course in Waste Management Legislation, which provides essential knowledge for all drivers involved with waste.

If this is a course you would be keen to explore or would like further information on, please contact Kirstie MacDougall on 01292 610428 / email Kirstie@albion-environmental.co.uk.