Rank: Super forum user 
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We have a small compound which is secured at the back of our factory that is used to store empty oil drums. The drums in question used to hold extracts and perfumes and originally held 205L.
During our manufacturing process all drums over 200L are stored on sump pallets, in compliance with the oil storage regs, however when the drums are emptied they are moved into the compound to await uplift from our approved carrier.
The drums are not cleaned out so there will be a very small residue of product in the drums when being stored. The drums contained a range of products from combustable, flammable and a very small amount of environmentally hazardous material.
Should this area be sumped to catch any residual leaks? The oil storage regs stipulates only where the drum is holding over 200L should it be bunded.
I'm open to all advice and guidance :)
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Rank: Super forum user
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I can't answer your question directly Guru, but it is worth checking with your insurer as thay may have a view and be able to advise.
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Rank: Super forum user
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We had a recent risk insurance survey carried out for the site and no concerns were raised regarding the small compound of empty drums.
Im curious as to whether there is a legal requirement to have such an area bunded?
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Rank: Super forum user 
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Hi guru, not sure about the legal aspect - but we certainly had our empty container in a bunded area at my last place of work - they were chemical drums and dye stuffs - inc permethrin - although to be fair the site was IPPC registered; as an aside we came in one day to find that a 'production manager' had had a part of the bund removed over the weekend because it kept filling with water and the empty plastic drums kept floating around!!! You need to check what is in your area in terms of environmental risk - are there any watercourses, drains etc nearby and is the site on a flood plain or aquifer? The EA website 'what's in my back yard?' is a good place to start looking.
http://www.environment-a...omeandleisure/37793.aspx
Risk assessment will then define what you should be doing as I am sure in the event of a pollution incident the EA would be quite willing to at least try to prosecute/impose sanctions; especially if there has been no consideration of the risk posed.
You could always call the EA anonymously to ask the question of course. Feel free to pm with any specifics that you think I may be able to help with.
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Rank: Super forum user
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Irrespective of the legal requirements etc if you store various products that could become a chemical cocktail mix of hazardous problems and you had a fire or a leak into the environment etc you would be responsible for the outcome and the insurers / legal enforcers etc would soon find things to hit U with irespective of civil areas
I would look at what I have and look to prevent cross contamination, fire, explosion and leaking etc in the waste storage areas in the same way U do in the production areas; as even small amounts of hazardous materials are still hazardous.
Additionally if U treat hazardous substances as hazardous substances throughout the process [the whole life of the product at work] staff begin to appreciate that even waste hazardous substances should be treated with care as against just treating the 'new' products with care and I would look to use all the contents of the drums in the first place as waste costs U lots of £ but I appreciate that this is not always possible
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