Sewage Regulations - EN 12566-3 - EPP2

Sewage Treatment Plant - New UK Standard - Why it's a Bad Test

By January 1st, 2012, all discharges both to ground and water, from septic tanks and sewage treatment plants, either new or existing, will have to be registered with the Environment Agency under the new EPP2 regulations. All septic tank discharges to watercourse will be refused. Only plants with the EN 12566-3 will be accepted for the 'exemption'.

Why we think the EN 12566 is a bad test

European Standard EN 12566-3 "Small wastewater treatment systems for up to 50 PE"

Sewage Treatment Plant manufacturers now have to send their units to the Continent to be tested and certified for both tank and process performance over a period of 38 weeks. They come away with the EN 12566-3 2005+A1 2009 Certificate, which also allows them to be CE marked, though CE marking is not yet mandatory in the UK. The old British Standard was the BS 6297 1983, but this is now superseeded for package underground plants.

However, the law allows that manufacturers can opt for their plants to be 'tested' in the UK, but the test must be 'an equivalent or superior test', though this will not allow CE marking, nor will the plant be considered suitable for an Exemption from a Discharge Permit under the new EPP2 rules. You would have to apply for a Discharge Permit form the Environment Agency.

Confusion Surrounding the EN 12566 Standard

At present Trading Standards have not confirmed what makes up such a test, or where it can be taken, or who should test it.

Each area has its own Trading Standards Officer and it is down to individual opinion as to whether a plant is Legal or not. Manufacturers in a few areas have been told to cease production due to the lack of an EN certificate and in other areas they are being allowed to continue production without ever having been tested by anyone! In our opinion, these plants should NOT be on the market as many do not work. The rogue manufacturers hide behind the confusion regarding the 'equivalent or superior' test and the lack of action against them.

In any case, the EN 12566-3 2005, which was supposed to be a 'harmonised' test across all EU member states, in order that sewage plants could be traded freely across Europe, is no longer accepted by some EU countries. France now requires a separate, more stringent FR EN test and Germany - where the major EN test centre is situated - also has its own test criteria. Crystal Tanks supports France in this action, as, in our opinion, the EN 12566-3 2005 is a flawed test that was badly thought out.

Why we think that the EN 12566-3 is a Ridiculous Test

You would think that a test for CE marking would be a set test, like an 'A' level, where every plant sits the same 'exam'? - NO. Each manufacturer is free to choose the following:

The strength of the sewage
The amount of the sewage treated per day
How long the plant has for its 'start-up' period
The number of persons that the plant is designed to serve

It is like having an 'A' level exam where everyone can choose their own degree of difficulty, subject matter, number of questions and the time allowed for revision.

No two plants, sold as the same size, undergo the same test. Yes, it is ridiculous. What is more ridiculous is that there is no 'fail' mark level as the test only determines the 'percentage reduction in influent (sewage going in) pollutants', so, in theory, if you filled a bucket with sewage, allowed it to settle and poured off the liquor, the bucket would be given an EN 12566-3 2005 Certificate and classed as a sewage treatment plant as it had reduced the percentage of influent pollutants! It would then be Legal in the UK!

The EN 12566-3 test only tests the SMALLEST plant in the range, not every model. We find that it is usually the larger plants in a range that have the worst performance. This is because plant volume often does not increase pro rata with plant population size, for example, one leading manufacturer's plant has a total retention time for treatment of 50 hours for the 6 person plant but only 26 hours for the 20 person model - almost half the digestion time, so how can it achieve the results obtained for the EN Certificate which tested the smallest plant?

Also, some 'models' that were tested were downsized to 4 persons for the test (to make the results better) but are not actually for sale as such!

Now for some more stupidity. The Environment Agency do not ask for a 'percentage reduction in influent pollutants', but for actual maximum limits in mg/litre of BOD, Suspended Solids and Ammoniacal Nitrogen in the final effluent. These are NOT stated on the EN test certificate, only on the actual full EN test report which the manufacturers often refuse to give out (why?) - even to us! We have seen test results where the plants fail the UK limits on over 30% of the test occasions but still boast the EN Certificate. You would be in trouble with the Environment Agency, but their plants are absolutely Legal. This is why we say, over and over again, DO NOT BUY A SEWAGE PLANT WITHOUT SEEING THE ACTUAL EN TEST REPORT - You wouldn't buy a car without seeing the performance data.

The EN test is not cheap - around £40,000 per plant tested, so it is no wonder that many smaller manufacturers have not sent plants to the Continent for testing - the UK has no EN test centre. We have even seen copies of forged EN test certificates where the manufacturer simply copied another manufacturers' certificate and changed the name of the company! They would find it much harder to forge the test report, so again we say DO NOT BUY A SEWAGE PLANT WITHOUT SEEING THE ACTUAL EN TEST REPORT.

We are a responsible company and for this reason, we have suspended sales of our Crystal ECO as a stand alone plant until we have the EN 12566-3 Certification.

Both the ClearFlo and the BIOROCK have the EN 12566-3. The BIOROCK also has the French version of the more stringent EN test. The CUBE is exempt as it is an above ground plant and these do not fall within the EN 12566.

The EN 12566 currently consists of 7 parts. Some parts are still in preparation whilst others are finished and published for adoption as National Standards. Part 3 below is now a British Standard and designated as BS EN 12566-3:2005+A1:2009.

EN 12566 parts are:

Part 1: Pre-fabricated septic tanks;

Part 2: Soil infiltration systems;

Part 3: Packaged and/or site assembled domestic wastewater treatment plants;

Part 4: Septic tanks assembled in situ from prefabricated kits. (in preparation);

Part 5: Pre-treated effluent filtration systems;

Part 6: Prefabricated treatment unit used for septic tank effluent (in preparation);

Part 7: Prefabricated tertiary treatment unit (in preparation);

The announcement was made in EU Directive 89/106/EEC for construction products.

As far as we are aware, there are no plans for an EN test for above ground plants.

Only sewage treatment plants previously certified and tested to BS EN 12566-3:2005 or newly certified to BS EN 12566-3:2005+A1:2009 (it has been amended in 2009) are considered for the Discharge Exemption and are only actually Legal if they have an 'equal or superior test'.

Treatment Plants and Information

Septic Tanks

Crystal ClearFlo

Crystal Cube

BIOROCK

Treatment Options

Cesspit Problems

Wastewater Legislation

Cesspit Conversion

Septic Filters

Consent to Discharge

Tank Installers Wanted