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Understanding your legal obligations

Published:  09 October, 2015

The CEA was set up by the Coal Board as a “not for profit” educational charity and membership organisation with a remit to help educate the nation in the most efficient use of fuel. Nothing has really changed, and this is as relevant today as it was 82 years ago. This is currently being achieved through a series of conferences and workshops looking at the legal obligation of companies to carry out a technical risk assessment on their boiler plant and to suitably train their staff. CEA’s workshop “Technical Boilerhouse Risk Assessment to achieve compliance with BG01” is designed to help companies meet this obligation.

The core activities of the association include organising conferences, workshops and seminars, managing the CEA’s involvement in exhibitions, hosting an annual Memorial lecture and the presentation of the Lord Ezra award for innovation.

CEA and its members also work very closely with other organisations in the publication of guides and best practice information and play an active role in the formulation and development of British and European Standards and Directives. (Lord Ezra, a previous Chairman of the Coal Board, has been associated with the CEA for over 30 years).

CEA was originally formed to promote the science of combustion engineering and today it embraces the study of efficient energy use, the exchange of new technology information, the training of industry professionals, the development of standards and good practices and the provision of services for its ever growing membership.

David Kilpatrick, Director of the Combustion Engineering Association, commented: “With a long history of promoting efficiency in the utilisation of all types of fuel, we proudly continue this ethos in the 21st Century. Through education, representation, promotion and specialist advice, we continue our aim to promote the science of combustion engineering and to encourage best practice”.

CEA Chairman Derry Carr added: “Our aim is to continue to develop our services in order to bring the best solutions possible for each and every Member of the Association and each client, and to continue to help make industry a safer place to work when dealing with combustion plant and associated materials and equipment”.

The Medium Combustion Plant Directive (MCPD)

As part of its on-going programme, the CEA’ s planned conference for November 17th 2015 in Daventry will explain the Medium Combustion Plant Directive (MCPD), which is designed to help combustion plant owners understand their legal obligations under this directive that will be transposed into EU law in the near future, followed by the transposition into UK law soon after that, with various staging dates for different plant sizes to follow. Other legislation such as the Energy Efficiency Directive (EED) and the Energy Saving Opportunity Scheme (ESOS) will also impact most UK commercial and industrial activities.

The Medium Combustion Plant Directive (MCPD) is gathering momentum and will start to take effect in 2017; Paul Whitehead continues leading this project and is the CEA representative with Defra and the EA as a member of their technical working group.

November 17th 2015 will see the first conference in Daventry to start making UK industry aware of what they will need to do to achieve compliance once the directive is passed into UK law. Defra and the EA will be explaining some of the issues from the regulators point of view, and other speakers will help clarify various aspects of combustion and emissions associated with the directive.

The MCPD will be a change to how the UK (and the EU) addresses emissions to atmosphere from industry; it will affect almost everybody who is using boilers, burners and engines for any process above 1MW thermal input.

CEA also continues to work with Defra and the EA on the Large Combustion Plant Directive (LCPD) for any processes above 50MW thermal input.

Key focus areas of the CEA:

Technical Boilerhouse Risk Assessments to Achieve BG01 compliance

In 2011 the HSE guidance document PM5 for automation in the boilerhouse was withdrawn; this was replaced with a new guidance document INDG 436 “Safe management of industrial steam and hot water boilers”, supported by BG01 “Guidance on Safe Operation of Boilers”.

To date CEA and its members have delivered 15 conferences in support of BG01 throughout the UK. The conference programme has developed over time into a two day conference workshop as a result of feedback from delegates who were asking for more practical help and guidance. Each conference venue has attracted a significant number of delegates and exhibitors alike with very good feedback.

The Boiler Operation Accreditation Scheme (BOAS)

When asked about the CEA’s plans for the future, David concluded: “CEA already have the BOAS accreditation for industrial boiler Operators and Managers, leading to the three distinct categories of boiler operation, Cat 1. Hot Water Boilers, Cat 2. Shell Steam Boilers and Cat 3. Water Tube Boilers, with some 2500 people having been trained and accredited across all industrial sectors to date.” Applicants can apply for one or more of the categories and will be assessed accordingly by independent Assessors.

There has also been international BOAS (I-BOAS) training delivered outside of the UK to some 60 people. This is a different version of BOAS, removing the UK legal aspects as UK law does not apply in other countries. I-BOAS is not transferable back to the UK should these people ever come to work in the UK.

BOAS for Managers

Managers often have to look after the boiler plant as just one of their daily duties and there is more to know than you might first think. As part of the on-going BOAS developments a bespoke training programme covering all aspects of a manager’s responsibilities has been developed, creating a more ‘in depth’ course covering the basics of using and checking the daily logbook of activity, internal audits, safety issues, traceability, emissions, environmental, legal compliance and training etc. These and many other aspects are included in the course, all of which to help ensure total safety.

Incidents are rare, but if you were unlucky and had a boilerhouse or biomass incident, a major steam leak or worse an explosion, the boilerhouse would fill with smoke or steam very quickly; it happens in seconds. You need to consider that people may be trapped in the boilerhouse and not necessarily at ground level, as was the case at a recent explosion, how would they find their way out? Emergency procedures are required and must be disseminated to all staff working in that area.

Boiler Water Treatment

The Association is looking to organise a future conference and workshop that explains in detail all aspects of boiler water treatment; the intention is to deliver this with our friends and colleagues at ICOM. The conference workshop will cover all aspects of boiler water and the treatment necessary to ensure an efficient and long lasting boiler plant. It will include pre-treatment of boiler water, the issues regarding the chemistry and what you need to know, the different water quality in areas of the country and how these differences affect the boiler, the quantity and use of appropriate chemicals, TDS levels, automatic monitoring, boiler blowdown, condensate return, scale build up and efficiency as a result of poor treatment. Delegates will have the opportunity to discuss particular issues with the various speakers and exhibitors throughout the day.

Industrial Gas Accreditation Scheme (I-GAS)

The CEA is about to launch ‘I-GAS’ to industry which is a new accreditation for people wishing to be trained on industrial gas installations. The first I-GAS training courses have been delivered by Blue Flame at Newcastle-under-Lyme and assessed by Kiwa Training from Cheltenham, and they focus on some of the areas that are specific to industrial gas installations. Industrial managers often ask to see “GasSafe” certification when subcontracting gas repairs and work to local contractors, but most people don’t understand “GasSafe” is only a legal requirement for domestic and light commercial installations; it has been the best available up until now and was certainly better than nothing, and I-GAS will resolve the problem of having a nationally recognised accreditation for those working on gas installations in factories.

I-GAS focuses on the industrial gas installation where a person may be required to work on large gas equipment where they need to be deemed as competent to do so, until I-GAS was developed this industrial area of gas work was not covered.

Biomass

The CEA has hosted several Conference Workshops over the last two years to help anybody planning to build, install or run a biomass system, from the smallest to the largest plants.

As many organisations wish to enhance their “Green Credentials” and comply with the drive to use renewable energy sources, the development of biomass systems in the UK has continued to expand, supported by measures such as the Renewable Heat Incentive (RHI) and the Renewables Obligation. The rapid development of this industry can have a positive environmental impact but biomass combustion is not clean, increasingly, there are questions over the sustainability and safety of biomass systems. Feedback from members has suggested that some recently installed systems in local schools and government establishments are no longer in use.

To date there have been several serious accidents and at least one known fatality in the British Isles directly connected to biomass heating systems; accidents which could easily have been avoided if a process that ensures safe design and safe systems of work in biomass had been applied. Other installations that have been witnessed fall short in terms of the overall design and considerations that should have been given to safety at the design and build stage.

CEA says it has been working closely with Element Consulting, a member of CEA, who are very experienced in the field of biomass design, build and operation. Element’s Ali Nicol supported by David Kilpatrick, have successfully delivered safety and awareness training throughout August for some 60 people involved in biomass installations spread across Scotland, this included Managers, Engineers, Electricians, Fitters and Operators.

There have also been several serious large fires attracting significant press attention and questions over safety and the storage of raw materials. A recent explosion at a Wood Flour Mill in Cheshire has highlighted the potential danger from explosions, which can occur from a build-up of wood dust and other stored materials.

Ali said “The most effective biomass systems are the result of a close working partnership between client, architect, mechanical and building services engineers where all aspects of design, management and operation are carefully considered and integrated, with an emphasis on health and safety”.

Biomass systems are subject to the same general health and safety principles, codes of practice, and design, installation and operation standards that apply to gas, oil or coal fired boiler systems, including, for example, the provisions of the Pressure Systems Safety Regulations (PSSR) 2000.

For further information please visit: www.cea.org.uk