Appendix 6 – crematoria standards in the event of mass fatalities

SGAQ01(09) Additional guidance from the Scottish Government

1. This note is issued as a precautionary measure in the event of a national emergency giving rise to mass fatalities. The Scottish Government will alert SEPA when an emergency situation exists which triggers the guidance. There will be a similar alert when the situation is at an end after which the guidance will no longer apply.

Introduction

2. The Process Guidance Note for Crematoria PG 5/2(12) (as amended) comprises statutory guidance on standards which constitute Best Available Techniques for the operation of crematoria under the Pollution Prevention and Control (Scotland) Regulations 2012. This includes limits on the emissions of various polluting substances. SEPA is required to have regard to the guidance.

3. In the event of mass fatalities, such as could arise from pandemic flu, crematoria may need to operate for sustained periods. This means that there is a greater prospect of breakdown of equipment for abating air emissions. There could also be implications for staffing for crematoria.

Current guidance

4. The Scottish Government wish to remind SEPA and operators that paragraph 5.33 of PG5/2(12) states that it is good practice to ensure that spares and consumables are available at short notice and to have an audited list of essential items.

5. Paragraph 5.33 further advises that:

• those spares and consumables subject to continual wear should be held on site or should be available at short notice from guaranteed local suppliers so that plant breakdowns can be rectified rapidly; and
• staff at all levels need the necessary training and instruction in their duties relating to the control of the process and emissions to air and refer, among other things, to the Crematorium Technicians Training Scheme and to the Training and Examination Scheme for Cremation Technicians

Guidance in the event of mass fatalities

6. In taking account of the guidance in paragraph 5.33, SEPA and crematoria operators should bear in mind that:

• large quantities of spare and consumables may be needed in the event of an emergency causing mass fatalities; and
• an emergency causing mass fatalities may have implications for the number of trained staff that can be called upon

7. In order to minimise the potential for breakdowns during such an emergency, it is important that all crematoria plan for such an eventuality, taking account of the 2 points above.

8. If this is done, there might nonetheless be either a breakdown of equipment affecting air emissions or a shortage of staff trained on the air pollution aspects of operating the crematorium. There might also be a heightened demand which warrants operating any standby crematorium for longer than the 100 hours specified in paragraph 5.27 of PG5/2(12). In such circumstances, and in the public interest, the Scottish Government consider SEPA should take a balanced view to enforcement action in the event of a breach of permit conditions. If best endeavours have been taken to reduce the likelihood of a breakdown or staff shortage, it may well be appropriate to allow a crematorium to continue to operate while breaching permit conditions without any enforcement action being taken. One consideration may be whether the area in question is designated a local Air Quality Management Area for any of the pollutants emitted from the crematorium. Steps should be taken to rectify the breaches where practicable as soon as is feasible. The Scottish Government would not expect these allowances to be continued beyond the duration of the emergency.

9. This guidance is without prejudice to any restrictions or requirements there may be under health and safety legislation.

10. This guidance is issued under regulation 61(1) of the Pollution Prevention and Control (Scotland) Regulations 2012.

January 2015