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Building Regulations Approved Document J - 'Unworkable'
9th May 2010
Following the failure of the last Labour Government to adequately address the issue of secondary containment at domestic oil storage installations, the newly updated 2010 edition of The Building Regulations Approved Document J (ADJ) has been described as 'plainly unworkable' by one English oil storage tank installer.
The installer who did not wish to be named, contacted OilFiredUp.com highlighting his concerns over revisions to the Oil Storage Tank Risk Assessment Methodology set out within ADJ. The Assessment asks a number of questions which an installer needs to answer, before an oil tank can be installed. Its purpose is to determine whether oil storage installations should be provided with secondary containment, so that in the event of a spill, an environmental pollution incident will be avoided. Where secondary containment is required, Building Regulations currently provide for compliance through either the construction of a masonry bund, or through the installation of an integrally bunded tank.
The 2010 edition of ADJ however adds a further question to the Assessment. It now requires an installer to now determine whether or not; a new or replacement fuel storage tank installation will be installed within a 'Zone 1 Area of an Environment Agency Groundwater Source Protection Zone'.
"The addition of the Zone 1 requirement, renders ADJ unworkable. Indeed, until I read ADJ, I'd never even heard of a Groundwater Source Protection Zone; speaking to other installers, neither had they. More worryingly, when I contacted my local Building Control Office who is responsible for enforcing the Building Regulations, they'd never heard of them either.
"It turns out that that after some searching and via the Environment Agency website, a map of such areas does exist. It allows installers to identify Groundwater Source Protection Zones by entering a postcode. However, the resolution of the map is so poor that it is impossible to identify specific properties or installations, making the search function somewhat pointless. And new build properties are unlikely to appear anywhere on the map to begin with.
At OilFiredup.com, we checked several properties in the English Midlands via the Environment Agency website and we can only agree - the system is plainly inadequate. Besides which, how realistic is it to expect oil tank installers to crank up a laptop, every time they turn up on-site?
"The Risk Assessment has always been something of a joke - everybody knows that. It's little more than a sop to the fag end of the industry. All too often it is used as a mechanism whereby a small number of rogue installers install a single skin tank, where a bunded tank is required; in the process undercutting environmentally responsible installers and leaving the taxpayer to pick up the pieces.
"But with the 2010 revisions to ADJ, that sop has now become a farce. ADJ is now plainly unworkable. Submissions were made to DCLG as part of the review process that could of course have avoided this nonsense in the first place. Those submissions were both self-financing and self-regulating. They could have massively reduced the impact of single skin tanks upon the environment. Instead, common sense went out the window and we've been left with an inherently impotent document which continues to penalise responsible oil tank installers and penalise the environment."
In related news, Labour's John Denham, Secretary of State for Communities and on whose watch the revised version of ADJ was prepared, managed to cling on to his Southampton Itchen seat at the General Election - but saw his majority cut from 9,302 votes to just 192 votes.
