End of life vehicle industry
The introduction of the End of Life Vehicles Regulations 2003 (ELVR2003) means that every year 2 million vehicles will be processed to ensure that potential pollutants such as fuel, oils, brake fluids and other liquids are removed, collected and stored. Operators will need to ensure that de-pollution of vehicles is carried out in a manner that both controls environmental risk (ELVR2003) and the risks to the health and safety of those working in the industry (Health and Safety at Work etc Act 1974).
This has presented a number of challenges which need to be risk assessed and controlled including:
- petrol recovery from end-of-life vehicles;
- oil recovery from vehicle shock absorbers;
- detonation of airbags.
The Trade Associations dealing with this industry include the British Metals Recycling Association (BMRA) and the Vehicle Recyclers’ Association (VRA)
HSE guidance publications include:
Guidance on work with liquefied petroleum fuelled vehicles (autogas) can be found on the UKLPG website.
Petrol is one of the pollutants that needs to be recovered, stored and dispensed by those who process end-of-life vehicles. The average vehicle processed contains 10 litres of fuel creating a serious health and safety risk from fire and explosion, particularly petrol driven vehicles. It is essential that those processing vehicles have equipment and working practices that can properly control the potential risks of petrol draining. The Health and Safety Executive has worked with the industry to produce the guidance mentioned that can help operators control the risks of fire and explosion from petrol draining.
Frequently asked questions
The vehicle de-polluting industry, manufacturers, the Health and Safety Executive and the Environment Agency have responded to a number of common questions. Some of the most frequently asked questions are:
Can I work under a vehicle whilst it is on the forks of a lift truck?
No, the vehicle must be secure to work on. Using a solid rig is the usual way of achieving this, ensuring that it is capable of supporting all foreseeable loads and is compatible with the lifting equipment used to deliver the vehicle to the rig.
Do I have to use a proprietary de-polluting rig?
No, neither the Environment Agency nor health and safety legislation require the use a proprietary system, the operator can use their own ingenuity to determine which is most appropriate to their operation, so long as it enables the operator to depollute the vehicle safely in both environmental and health and safety terms.
Is there an approved method for recovering petrol?
No, again the requirements are both to recover and do so safely, it is for the operator to identify the most appropriate way of achieving this. The Health and Safety Executive has provided the industry with guidance on how to recover, store and dispense petrol safely.
Does airbag detonation damage operators hearing?
Yes, the very high noise levels generated when detonating airbags can present a real and immediate risk to hearing. This risk is increased the closer the operator is to the vehicle and particularly if the vehicle windows are missing. A simple control measure is to run the detonator control to a sound insulated refuge/booth from which the operator can detonate the airbags. You will need to assess the operation to ensure that controls are adequate to protect both those involved in the operation and others in the area.
Does every airbag need to be detonated?
You must use your best endeavours to detonate or remove airbags. However, there may be exceptional circumstances in which safety would be compromised: examples could include contact with body fluids or sharps remaining in the vehicle. In cases where airbags are not detonated or removed the waste transfer note should highlight the presence of explosive devices.
How do I de-pollute a vehicle contaminated with blood, body fluids, hypodermic needles etc?
These vehicles do present a biohazard. However, in most cases you should be able to simply avoid the risks:
- Do not sit in any vehicle assessed as being suspect. Needles can be hidden in upholstery.
- Lean into the passenger compartment to pull the bonnet release: if this could expose you to risk of contact with biohazards then the bonnet can be prised open from outside the vehicle.
- Do not recover any needles.
- Where unacceptable risks of contact with biohazards remain, then the particular depollution operation should be omitted and this should be noted on the waste transfer note.
What protective clothing do I need to wear?
- Protect your feet
Use footwear with toe protection to protect from falling objects. If it is likely that you may step on sharp objects then the footwear should have a protective sole-plate.
- Protect your eyes
Eye protection is necessary as you will be removing parts above your head and it is likely that materials will be ejected.
- Protect your hearing
Hearing protection may be needed if it is not reasonably practicable to achieve control by other means.
- Protect your skin
Suitable overalls and gloves should be worn.
They should protect against the risks from:
- oils, fluids and fuels absorbed into the body through the skin;
- highly flammable fuels. Anti-static footwear and fire-retardant/resistant overalls should be provided and worn if draining fuels.
The fluids you are dealing with are likely to be toxic and/or flammable and can soak into some clothing materials. Personal protective equipment should be kept clean to prevent the contaminant fluids being held against your skin.
You can protect the environment AND control the health and safety risks in the workplace at the same time. If you have further questions, ask your local inspectors. The Health and Safety Executive will advise on health and safety matters and the Environment Agency on the environmental aspects of the ELV directive.