# Mobile Services Dilemma



## Yulee (Jul 23, 2018)

*i'm not sure where else to post this so please move into correct place*

Hi, i'm in a bit of a dilemma and hoping for some info from anyone on here, i currently do mobile car valeting & detailing (part time) i received the following from the Natural Resources/environment stating that i have to use a "Water Containment Mat For Car Wash"

I understand that the location i was the drainage ran into a river (didn't know at the time) and can cause pollution but isn't using a matt on every service a bit over kill even in a middle of a town that's busy and the drainage run into the sewer and contained by the drainage company?

*Please see below the e-mail i received and any help/guidance would be a MASSIVE help *

" it was brought to the attention of Natural Resources that **** was carrying out commercial car washing at **** . The car wash effluent was not being contained or collected and was entering surface water drainage, which discharges to the environment.

Under The Environmental Permitting (England and Wales) Regulations 2016 it is an offence to cause or knowingly permit a water discharge activity unless you are complying with an environmental permit or exemption. A water discharge activity is the discharge or entry to a watercourse of anything that is poisonous, noxious or polluting.

Mobile runoff containment mats and pads are available to collect and contain car wash effluent, this can then be disposed of into a public sewer (with permission from the sewerage undertaker, i.e Welsh Water) or through a registered waste carrier.

Please follow this link to GPP 13 Vehicle washing and cleaning: https://www.netregs.org.uk/media/1414/gpp-13-v2-plussepa-plusniea-plusnrw.pdf. This guidance is for businesses that wash vehicles, and for anyone who washes vehicles as part of a business activity; it details pollution prevention requirements and responsibility. Page 13 is particularly relevant to your business at a mobile valet service, however, there is good practice information throughout the document.
"

Has anyone came across this or am i the unlucky one?

Thank you in advance


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## RS3 (Mar 5, 2018)

Christ!,
Now there's a can O' worms!.


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## Yulee (Jul 23, 2018)

RS3 said:


> Christ!,
> Now there's a can O' worms!.


Yeah exactly, I've sent an e-mail to the drainage company to see if i they can provide me a map or something but it's a nightmare!

after 2-3 years of business this is the first time i've been told considering every mobile valeting company i've seen don't have a "matt"


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## macca666 (Mar 30, 2010)

Can't offer advice in relation to your question however I've seen posts on social media where cars are on a mat which i assume is what you are describing so they are out there and being used by some.


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## AndyN01 (Feb 16, 2016)

About 4 decades ago I started work in the "Trade Effluent Inspectorate" of a Water Company.

Any business discharging anything into a sewer was required to have a licence to do so. They were charged according to how "polluting" the discharge was and the volumes concerned. I've been in court supporting the prosecution when the discharge was outside certain chemical/biological limits - and the fines weren't small.

I remember one where we were collecting samples running down the gutter and, sure enough, they were found guilty and fined. There was a significant difference depending upon whether the sewer was "foul" water going to a treatment works or surface water running into a river.

Given that environmental issues are a much higher profile than they were 40 years ago I can't imagine that the current legislation is anything other than more stringent and penalties more severe than that we used. A very quick browse comes up with up to 2 years imprisonment and/or a £40K fine :doublesho.

Perhaps something to ponder if you are a mobile business.

Andy.


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## Alan W (May 11, 2006)

Polished Bliss had to use a water containment mat when they were in their Kintore premises. Have a look at the Threads and link below.

Alan W

https://www.detailingworld.co.uk/forum/showthread.php?t=183883

https://www.detailingworld.co.uk/forum/showthread.php?t=411724&highlight=bund

https://www.detailingworld.co.uk/forum/showthread.php?t=400336

http://www.morclean.co.uk/Vehicle Wash/Car Valeting/PVC Washpad


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## Yulee (Jul 23, 2018)

AndyN01 said:


> About 4 decades ago I started work in the "Trade Effluent Inspectorate" of a Water Company.
> 
> Any business discharging anything into a sewer was required to have a licence to do so. They were charged according to how "polluting" the discharge was and the volumes concerned. I've been in court supporting the prosecution when the discharge was outside certain chemical/biological limits - and the fines weren't small.
> 
> ...


Thank you Andy, i want to make sure i am following all the correct rules as i DO NOT want any fines or imprisonment so i'm going to have to look for a matt 



Alan W said:


> Polished Bliss had to use a water containment mat when they were in their Kintore premises. Have a look at the Threads and link below.
> 
> Alan W
> 
> ...


Thank you i'll have a look.



macca666 said:


> Can't offer advice in relation to your question however I've seen posts on social media where cars are on a mat which i assume is what you are describing so they are out there and being used by some.


interesting as i never knew it was such a thing tbh. Thanks for the input!


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## Yulee (Jul 23, 2018)

AndyN01 said:


> About 4 decades ago I started work in the "Trade Effluent Inspectorate" of a Water Company.
> 
> Any business discharging anything into a sewer was required to have a licence to do so. They were charged according to how "polluting" the discharge was and the volumes concerned. I've been in court supporting the prosecution when the discharge was outside certain chemical/biological limits - and the fines weren't small.
> 
> ...


Where i was it the drainage was running into the river so i totally understand useing a matt but if it's treatment works do i still need to use a matt?

i'm trying to get in contact with my drainage company for more info etc as this is new for me and want to be 1000% safe!

Thanks again


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## fatdazza (Dec 29, 2010)

Yup, those are the rules. Most surface water drains (road gulleys etc) discharge direct to a water course without any treatment, and you cannot discharge “polluting matter” without a discharge permit. The run off from car washing although diluted could (in the regulator’s eyes) be polluting.

You were unlucky in that you got “caught”. 

Strictly you should catch any run off from your business and dispose of it either to a water recycling centre or via the foul sewer (which will end up being treated at a sewage treatment works) , but to do this you will need permission from your water company


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## TonyHill (Jul 28, 2015)

"brought to their attention"...someone has bubbled you then. Have you upset anyone recently??


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## AndyN01 (Feb 16, 2016)

Yulee said:


> Where i was it the drainage was running into the river so i totally understand useing a matt but if it's treatment works do i still need to use a matt?....Thanks again


I'm a long time out of the industry so I don't know.

The folks to ask are the one's that could prosecute you. :thumb:.

While the internet, forums etc. etc. may well be correct, the crunch comes if you're prosecuted. So ask and get an answer IN WRITING, signed by someone who has the authority to give you that information.

Hope it all goes well for you.

Good Luck.

Andy.


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## Darlofan (Nov 24, 2010)

If you use a mat what happens with it then? Mop it up with a sponge and tip it down the sink at home?

Not noticed any of these pop up car washes using containment.


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## robby71 (Jun 4, 2006)

We have quite a few vans, wagons, HGVs at work and use a steam cleaner to wash them.
A couple of years ago enviromental health paid a visit and banned the company from washing the vehicles as the water (TFR and water only) was going into a drain.
The company had to install a gulley, underground tanks and pipework which sent the water to another drain


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## A.B (Feb 8, 2010)

Yulee said:


> *i'm not sure where else to post this so please move into correct place*
> 
> Hi, i'm in a bit of a dilemma and hoping for some info from anyone on here, i currently do mobile car valeting & detailing (part time) i received the following from the Natural Resources/environment stating that i have to use a "Water Containment Mat For Car Wash"
> 
> ...


Where you cleaning cars at a company address or residential?


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## Yulee (Jul 23, 2018)

fatdazza said:


> Yup, those are the rules. Most surface water drains (road gulleys etc) discharge direct to a water course without any treatment, and you cannot discharge "polluting matter" without a discharge permit. The run off from car washing although diluted could (in the regulator's eyes) be polluting.
> 
> You were unlucky in that you got "caught".
> 
> Strictly you should catch any run off from your business and dispose of it either to a water recycling centre or via the foul sewer (which will end up being treated at a sewage treatment works) , but to do this you will need permission from your water company


100% i agree using the matt if the water source is't being treated but if the surface water is running into a treated tank on the side of the road why do i have to use a matt is a permit is needed anyway? (i'm going to seek more legal help anyway as it's just another massive cost for the business)



TonyHill said:


> "brought to their attention"...someone has bubbled you then. Have you upset anyone recently??


100% i don't think it's anyone i know as they would of have to be following me, understand the laws and get the address - i was at a block of flats with around 300-400 apartments so i got spotted and reported..



AndyN01 said:


> I'm a long time out of the industry so I don't know.
> 
> The folks to ask are the one's that could prosecute you. :thumb:.
> 
> ...


Will defiantly be speaking to the people who send the e-mail and asking for more info and legal side to make sure i am 100% - thanks again!



Darlofan said:


> If you use a mat what happens with it then? Mop it up with a sponge and tip it down the sink at home?
> 
> Not noticed any of these pop up car washes using containment.


Apparently you have to take the water with you and empty in a man cover that's treated.



robby71 said:


> We have quite a few vans, wagons, HGVs at work and use a steam cleaner to wash them.
> A couple of years ago enviromental health paid a visit and banned the company from washing the vehicles as the water (TFR and water only) was going into a drain.
> The company had to install a gulley, underground tanks and pipework which sent the water to another drain


Yeah the drainage wasn't "treated" drainage - same boat as i'm in but finding out what gulleys are treated and what's not is a nightmare.



A.B said:


> Where you cleaning cars at a company address or residential?


residential - Block of 300-400 flats next to a river


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## fatdazza (Dec 29, 2010)

Road gulleys do not drain to a "treated tank on the side of the road". They will nearly always end up in some kind of water course, be it a ditch or a major river. Sometimes via balancing ponds or tanks (to avoid surcharging water courses during periods of heavy rainfall). Nearly all of these have some ecological value and therefore the "regulator" (Natural Resources Wales in your case), will protect them from what is an unconsented discharge of pollution.

Only the foul sewers (connected to houses, businesses etc) end up at a sewage treatment works. Your water company (Welsh Water) will not allow you to start opening manholes on their foul sewerage system to discharge your waste. Totally impractical as it may be, they will most likely expect you to either take it to one of their sewage works for disposal or release it into the foul sewer from a business premises. In that case you will need permission from them to discharge that waste (trade effluent).


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## nog (Jul 14, 2013)

IIRC not allowed to wash cars at home/side of road in Germany. Factory I worked at in Wales had all outside drain covers painted blue or red(foul) and all staff informed to prevent any spillages going into blue drains with spill kits nearby- pretty standard practice in industry.


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