09 April 2021
I have noticed, over the last few years, an increased focus on the subject of dust emissions from waste facilities. Almost without exception, dust is raised as a significant concern in the development and operation of waste facilities.
I consider it almost impossible to handle waste without generating some dust however, if this dust could harm human health or cause a nuisance, then the regulators will be involved. Both planning authorities and environmental regulators will address this issue when applications for authorisations are determined and when regulating operational sites. Within applications there is commonly a requirement to provide a Dust Management Plan. Dust Management Plans may also be requested from operators when dust has been identified as causing a problem.
If you need to prepare or update a Dust Management Plan here are 10 useful points to help you.
1. Your Dust Management Plan should contain an assessment of the potential for the activities on your site to cause problems from dust emissions and demonstrate how adequate mitigation measures will be used.
2. Dust management procedures should then be written that implement the requirements of the Dust Management Plan. These would typically be implemented via your Environmental Management System.
3. Determine if there is a potential for the dust to reach levels or contain substances that could be significantly harmful to human health, for example asbestos and bioaerosols. If so, then you need to consider human health in addition to the potential nuisance effects to neighbours
4. Most waste facilities do not require quantitative dust monitoring, visual monitoring is typically acceptable. Make sure you do not include the need to quantify dust emissions unless absolutely necessary as this can be expensive and time consuming.
5. Your Environmental Management System should contain procedures for incident reporting. Use these documents to self-report instances when significant dust emissions left the site boundary and what was done about the incident. These records can be invaluable if the regulators receive complaints and make investigations.
6. Provide training to all site workers with regard to what action should be taken to minimise dust emissions and what to do in case significant dust emissions occur. Keep training records to evidence this.
7. Maintain your dust control equipment so that it is always in good working order. The regulators will not make allowance for equipment failure if dust has caused nuisance to your neighbours.
8. Receptors - consider if there is a pathway for the dust to reach them. A receptor may be downwind of the site, it may be very close to the site but if there are buildings or trees in between then this will affect the potential for the dust to reach the receptor.
9. If there are significant dust emissions blowing across your site from neighboring sites, then record this as an incident on your site. Take photos, if possible, and record the fact that the dust was not generated on your site. Such records can remove you from regulators investigations.
10. Seek advice. Check out guidance documents M17 and M8 (these are due to be updated and merged some).Having submitted dozens of Dust Management Plans to the regulators we know that what is required to get approval on a Dust Management Plan is often not intuitive or even logical! So do contact us if you need any assistance or advice.