EA concern for health and safety of staff on AD sites

The REA has recently been notified by the Environment Agency that they are assessing AD sites with greater rigour and scrutiny than has been the case in the past in light of the number of  containment failures that have occurred at AD facilities.

The EA has  in recent weeks ‘red-carded’ a number of sites until specific issues were addressed as they deemed the risk to their inspecting officers to be too great.  In light of this, the EA is carrying out a H&S desk-top screening assessment at all sites that they regulate. This exercise is designed to weed out any sites that do not have any form of Environmental management System (EMS) or health and safety contingency plans in evidence which may result in jeopardising the health and safety of EA officers visiting these sites.

The screening work will consist of a desk-based assessment focussing on the written management system required by all AD plant permits. The EA believe that failing to manage and operate AD plants in accordance with adequate managements systems has been one of the main causes of the containment failure incidents to date.   

It is recommended that sites are able to demonstrate that they have the following information readily available. The operator needs to demonstrate to the EA that the site is ‘under control’:
• Incident and contingency management plans 
• Technically Competent Managers - attendance on site
• Is there a DSEAR plan for the site?
• Use of gas alarms within the site
• Staff competence in dealing with incidents etc
• Process control and systems monitoring
• Plant and equipment maintenance and inspection
• Gas storage systems 
• Liquid containment systems

This work potentially has much wider significance than the health and safety of EA inspecting officers. If the EA are not satisfied that a permitted AD plant can be or is not being safely operated, in accordance with its permit, they will consider what further actions are appropriate. This could ultimately lead to them suspending or revoking the permit if they do not consider the site to be operating in a safe and responsible manner.

The REA is keen to receive feedback from members on the impact if any, this has on them. Comments should be sent to

Updated: 08/01/14

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