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Where possible, you should locate storage areas away from watercourses and sensitive perimeters (for example, those close to public rights of way, housing or schools). You must store all waste within the secure area of your facility to prevent unauthorised access and vandalism. Such contracts not only give peace of mind to the employer — by ensuring that storage systems are maintained in a safe and workable condition — but also provide a written history for regulatory inspections and insurers. No, it’s not. That’s what HSE means when they say “you are free to take other action”. However, HSE go on to state that “if you do follow the guidance you will normally be doing enough to comply with the law”. You must clearly mark hazardous waste storage areas and provide signs showing the maximum quantity and hazardous properties of wastes that can be stored there.

HSG191: Emergency planning for major accidents: Control of Major Accident Hazards Regulations 1999 (COMAH) Secondary and tertiary containment systems must conform to CIRIA guidance C736 Containment systems for the prevention of pollution. Not following HSE guidelines is legal. However, following the guidelines is normally “enough to comply with the law”. What’s more, because the advice is from the British government, it’s advice which is as objective and trustworthy as you can get in occupational safety. Why Aren’t HSE Guidelines Legally Binding? HSG158: Flame arresters: Preventing the spread of fires and explosions in equipment that contains flammable gases and vapours

If a waste is mixed with other similar wastes, where the resulting mixture does not have significantly different characteristics from the mixed wastes (for example blending compatible combustible or flammable wastes as a fuel), this activity is mixing or blending (coded D13 or R12). Any other mixing that changes a waste is treatment. You must not carry out activities that represent a clear fire risk within any storage area. Examples include: wastes which could be recovered with other wastes if this means that the waste must now be sent for disposal or a lower form of recovery HSG90: The law on VDUs: An easy guide: Making sure your office complies with the Health and Safety (Display Screen Equipment) Regulations 1992 (as amended in 2002) You must have systems in place to make sure that loading, unloading and storage are safe, considering any associated risks. This can include:This guidance is issued by the Health and Safety Executive. Following the guidance is not compulsory and you are free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law.”

You must follow safe operating procedures designed to reduce the risk of explosion and fugitive emissions when you transfer waste from powder tankers into silos. You must use trained and competent personnel.In 2009/10 the storage, warehousing and road haulage industries reported over 8500 work related accidents to the Health and Safety Executive (HSE) and Local Authorities. Almost 1600 of these accidents were classified as major injuries such as fractures and amputations. Resources HSG209: Aircraft turnaround: A guide for airport and aerodrome operators, airlines and service providers on achieving control, co-operation and co-ordination HSG250: Guidance on permit-to-work systems: A guide for the petroleum, chemical and allied industries You must make sure that tankers are not used as blending or reaction vessels as this is not their designed purpose. Ensure, so far as is reasonably practicable, the health and safety of yourself and others who may be affected by what you do or do not do.”

HSG232: Sound solutions for the food and drink industries: Reducing noise in food and drink manufacturing You must take operational and design precautions when mixing or blending wastes, depending on the composition and consistency of the wastes (for example when vacuuming dusty or powdery wastes). Under cover storage provides better protection for containers than open air storage and minimises the generation of contaminated water. Covered storage also: You must provide bunds for all tanks containing liquids (whether waste or otherwise) which could be harmful to the environment if spilled. Bunds must meet the CIRIA C535 or C736 standard and:

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You must make sure that transfers into and from tankers only take place in bunded areas designed to contain a worst case spillage. You must have emergency storage for leaking vehicles to minimise any acute incidents caused by a seal on a tanker failing. You should equip storage and treatment tanks with an automatic level monitoring system and an associated alarm or trip system. These systems must be sufficiently robust (for example, be able to work if sludge and foam are present) and regularly maintained. You must fit tanks with suitable overfill protection. HSG166: Formula for health and safety: Guidance for small and medium-sized firms in the chemical industry