Farm Fuel Storage Compliance
SSAFO Regulations Upgrade — Environment Agency Rural Inspection Response
Executive Summary
An 800-acre mixed arable and livestock farm in the East Midlands received a formal SSAFO (Silage, Slurry and Agricultural Fuel Oil) notice from the Environment Agency following a Rural Inspection Programme visit. The farm's 3,000-litre above-ground diesel storage tank had been in place for over 15 years with no secondary containment, no overfill protection, and inadequate fill point safeguards. This case study documents the regulatory requirements triggered, the bund specification and installation, and the outcome of the EA follow-up visit.
Background — The Farm and Fuel Storage Setup
The farm operated a 3,000-litre above-ground steel diesel tank adjacent to the main yard, used for fuelling tractors, combines, and a mixed fleet of agricultural vehicles. The tank had been installed on a concrete pad approximately 15 years prior to the EA inspection and had operated without incident in that time.
However, the farm had never been assessed under the Water Resources (Control of Pollution) (Silage, Slurry and Agricultural Fuel Oil) (England) Regulations 2010 (commonly known as SSAFO), which came into force to replace earlier guidance and imposed statutory requirements on agricultural fuel oil storage above 1,500 litres.
The Environment Agency's Rural Inspection Programme is a targeted programme of unannounced farm inspections, typically triggered by EA intelligence (e.g., proximity to watercourses, previous incidents in the area, or complaints). The inspector's visit identified three specific non-compliances:
- No secondary containment bund around the 3,000L diesel tank
- No overfill protection device on the tank
- The fill point was located outside the tank's immediate vicinity with no drip containment
📋 SSAFO Requirements for Agricultural Fuel Oil (>1,500L)
The Water Resources (Control of Pollution) (Silage, Slurry and Agricultural Fuel Oil) (England) Regulations 2010 require that agricultural fuel oil storage above 1,500 litres must be:
- Contained within a bund with a capacity of at least 110% of the tank's maximum capacity
- Fitted with an overfill prevention device (automatic shut-off valve or audible/visual alarm)
- Protected at the fill point with a drip containment tray or collection device
- Constructed from materials with adequate structural integrity and impermeability
- Maintained in good repair and inspected regularly
These regulations apply automatically to any new agricultural fuel installation above 1,500L, and the EA has powers to serve notice on existing installations where they pose a pollution risk.
Bund Sizing Calculation
Tank capacity: 3,000L
SSAFO minimum (110% of tank capacity): 3,000 × 1.10 = 3,300L minimum bund capacity
Additional considerations:
• Freeboard allowance (150mm): approximately 200L additional buffer
• Allowance for rainwater accumulation (open bund, East Midlands rainfall): 400L
• Recommended total bund capacity: 3,900L+
Specified bund: 4,000L capacity steel bund with 200mm freeboard
The bund design also had to account for several practical agricultural site requirements:
- Heavy vehicle access — tractor and artic tanker delivery vehicles would need to approach the tank from one side
- Agricultural environment — the bund must resist UV degradation, frost, and chemical contamination from fertilisers
- Pump and outlet connections — the site used a self-service pump with digital meter; all pipework penetrations must remain within the bunded area or use appropriate sealed glands
Product Specification & Installation
| Component | Specification | Standard | Notes |
|---|---|---|---|
| Bund Structure | Mild steel bunded base unit, 4,000L capacity, shot-blasted and epoxy-coated internally, 200mm freeboard, forklift base channels | BS EN 12285 | Sized for 3,000L tank with SSAFO compliance margin |
| Bund Lid/Cover | Galvanised steel mesh bund cover panels, removable for inspection, UV stable powder coat | — | Prevents debris accumulation and rainwater ingress whilst maintaining inspection access |
| Overfill Protection | Magnetic float-operated overfill alarm with audible buzzer (90dB) and flashing amber beacon, 240V/battery backup | EN 13160 Class 1 | Activates at 95% tank capacity; SSAFO-compliant automatic overfill warning |
| Fill Point Protection | Heavy-duty polyethylene drip tray, 800×600mm, 60L capacity, with grating and drain valve | — | Positioned at tanker delivery connection point |
| Pipework Seals | Sealed gland entry system for pump and vent pipework penetrations through bund wall | — | Maintains bund impermeability at all penetration points |
| Spill Response | Oil spill kit, 80L absorbent capacity, in yellow weather-resistant cabinet, positioned adjacent to tank | — | Oil-selective absorbents appropriate for diesel fuel |
| Signage | SSAFO compliance signage: "Diesel Fuel — Secondary Containment System" + emergency contact number + no smoking signage | ISO 7010 | Installed on bund perimeter and fill point |
Installation Approach
The installation was completed over three days, working around the farm's operational requirements (harvest period constraints meant daytime tractor movements had to be accommodated).
Day 1 — Site Preparation: The existing concrete pad was inspected and found to be structurally sound but insufficiently impermeable (hairline cracks present). Cracks were filled with chemical-resistant polyurethane sealant. A channel drain connected to the yard drainage was identified and sealed. The existing tank was temporarily repositioned using a farm telehandler to allow the bund structure to be positioned.
Day 2 — Bund Installation: The steel bund unit was delivered on a flatbed, lifted by telehandler, and positioned on the prepared concrete pad. Level adjustment completed. Tank repositioned into the bund using the farm telehandler. Pipework penetrations sealed using gland system. Pump and meter refitted and tested.
Day 3 — Systems & Documentation: Overfill alarm installed and tested (timed test with EA inspector notified in advance). Fill point drip tray installed at tanker delivery point. Signage installed. Operating instructions and SSAFO compliance record pack provided to the farm manager. Photographic record compiled for EA submission.
EA Follow-Up Inspection Outcome
✅ SSAFO Notice Closed
The Environment Agency follow-up inspection was carried out 6 weeks after the initial notice was served.
- Bund specification: Inspector confirmed the 4,000L steel bund met and exceeded the SSAFO 110% minimum requirement
- Overfill protection: Alarm function tested by EA inspector — passed. Certificate of conformity for EN 13160 Class 1 device accepted
- Fill point protection: Drip tray and sealed delivery area accepted as compliant
- Documentation: SSAFO compliance record, maintenance log, and emergency response information accepted
- Outcome: Formal notice closed. No further regulatory action. Farm rated Green under EA Rural Inspection Programme.
The farm manager subsequently enrolled in the EA's voluntary Farm Advisory scheme to receive advance guidance on future regulatory changes.
Lessons for Agricultural Fuel Storage Compliance
This case study highlights several issues that are common across the UK agricultural sector:
- Age of installation is not a defence. Many farms have fuel tanks installed prior to the 2010 SSAFO Regulations that have never been assessed for compliance. The EA can serve notice on any existing installation where a pollution risk is identified, regardless of when it was installed.
- Proximity to watercourses significantly increases risk. Farms adjacent to rivers, streams, drains, or designated water bodies are disproportionately targeted by the EA Rural Inspection Programme.
- The 110% rule is a minimum, not a target. In open agricultural environments, additional capacity for rainfall accumulation should always be factored into the bund design specification.
- Overfill alarms are mandatory, not optional. The SSAFO Regulations specifically require overfill prevention devices — not merely best practice. EN 13160 Class 1 compliance provides the most defensible evidence of compliance.
Agricultural Fuel Storage Compliance Advice
Not sure if your farm's fuel storage meets current SSAFO requirements? Our team can assess your site and specify the right bunding solution before the EA comes knocking.
Get a Free SSAFO Assessment →