Staffordshire County Council
Guidance for Premises Managers on new requirements relating to the disposal of
Hazardous Waste
On 16 July 2005, the Hazardous Waste Regulations 2005 (HWR) come into force. Their
purpose is to introduce effective controls for wastes that are harmful to human health or
the environment. They ensure that such wastes are properly managed from their
production to their final destination for disposal or recovery.
What are the main changes?
The regulations introduce the need for hazardous waste producers ie all County Council
establishments, to “notify” (register) their premises to the Environment Agency (EA). The
regulations do allow for certain premises to be exempt from notification provided they meet
all three of the following conditions:
1. The premises falls into any of the following categories:
 Office premises,
 Residential home,
 School, university or other educational establishment,
 Premises forming part of a hospital or nursing home,
 Shop premises,
 Premises used for agriculture,
 Domestic premises, prisons, charities.
AND
2. The waste is collected by a registered carrier.
AND
3. The total amount of hazardous waste produced at the site in a twelve month period is
no more than 200 kg.
Unless your establishment meets the above criteria, you will need to “notify” the
Environment Agency.
Note: Exemption from notification does not exempt the establishment from other HWR
requirements including the use of consignment notes. For example an office, removing
less than 200 kg of hazardous waste, must prepare hazardous waste consignment notes
in the normal manner regardless of their exemption to “notify”.
What else has changed?
The HWR prohibit the mixing of hazardous waste with non-hazardous waste. They also
prohibit the mixing of different categories of hazardous waste. This applies regardless of
whether the establishment is exempt from the requirement to notify. Managers should
therefore ensure that adequate arrangements exist for the suitable storage of various
waste categories whilst awaiting collection.
How do I “notify” my establishment?
After 15 July 2005, it will be an offence to produce at, or remove from, a premises,
hazardous waste, unless the premises have been notified to the EA or are exempt from
notification.
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Application for notification may be made by telephone (cost £23), internet, email or on disk
(cost £18), and on paper (cost £28). Full details on how premises managers should notify
are available via the following link to the EA website
http://www.environment-agency.gov.uk/subjects/waste/1019330/1029396/
If your establishment uses a registered carrier, they may offer to undertake the notification
process on your behalf. There will almost certainly be an additional charge for this service
but you may consider it worthwhile paying this to avoid the internal form filling.
Some establishments have already received letters from their waste carriers advising that
they will automatically undertake notification on behalf of the establishment and will charge
a fee of £49 for this service. If you have received such a letter and do not wish to have this
done on your behalf, you should advise the carrier as soon as possible and refuse to pay.
What constitutes Hazardous Waste?
The List of Wastes Regulations 2005 give the definitive list of wastes that are categorised
as hazardous. A material is classed as hazardous if it contains a dangerous substance*.
The list is broken down into 20 chapters, most of which are not likely to be found in County
Council establishments. However, it is important that the full list is thoroughly considered
by each establishment so that all likely hazardous wastes can be identified. The full list
can be accessed at http://www.opsi.gov.uk/si/si2005/20050895.htm
The following list gives an indication of the types of hazardous waste that might
reasonably be found in some County Council establishments:
Infected clinical waste
Sawdust, shavings, cuttings, wood, particle board and veneer contaminated with
dangerous substances*,
Some laboratory chemicals,
Some paints, varnishes, adhesives, sealants & resins containing dangerous substances*
Some printing materials (etching, inks, toner)
Wastes from photographic processes,
Some machining oils and some spent grinding materials
Oil and fuel wastes (except edible oils)
Organic solvents, refrigerants
Absorbents, filter materials, wiping cloths and protective clothing contaminated by
dangerous substances*
Most vehicle components
Transformers/capacitors containing PCB’s
Fridges and other equipment containing CFCs, HCFC and HFC
Items containing free asbestos
Fireworks waste
Gases in pressure containers
Batteries
Various construction and demolition wastes
Fluorescent tubes and other mercury containing waste,
Detergents
Cathode Ray Tube TV’s, computer monitors.
This list is not exhaustive. Where any doubt exists, reference should always be made to
the full list (see above).
* A dangerous substance is a substance which has inherent dangers, ie identified as toxic,
very toxic, corrosive, harmful, irritant, flammable, very flammable or radioactive. All
substances included in Chemicals (Hazard Information & Packing for Supply) Regulations
2002 are classified as dangerous.
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What does 200 kg of waste look like?
To help managers get an impression of what 200 kg of waste looks like, this would equate
to approximately: 10 small TV’s or 14 lead acid batteries or 500 fluorescent tubes or 5
small domestic fridges.
What do I do now?
As a premises manager, you are advised to take the following steps in order to comply
with the HWR’s:
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Using the information at the top of this note, determine whether or not your premises
are exempt from the requirement to notify.
If you do need to notify, use the links above to obtain more details on the most suitable
process for you notify and then notify the EA before 15 July 2005. During the process,
you will need to quote your Site Industry Classification – this can be found on the EA
website (see below). To assist managers, SIC codes relevant to some SCC
establishments are listed in an appendix to this guidance note. Your notification will be
valid for 12 months and will be accompanied by a registration/ premises code which
must be written on all future consignment notes which the waste carrier will provide.
Confirm that your waste carrier(s) is/are registered – Ask to see copy of their waste
carriers licence and check it’s up to date. For further advice on the County hygiene
services contract (including collection of clinical waste including sharps), contact
Caroline Clarke, Staffordshire Purchasing on 01785-356272.
If you decide your establishment is exempt from registration, you will need to inform
your waste carrier accordingly. This can be done by letter or completing a form
provided by the carrier).
Ensure that arrangements are made for the adequate segregation of hazardous and
non-hazardous wastes and differing categories of hazardous wastes. This should be
done in accordance with the categories in the list of waste regulations (see above).
Waste consignment notes and other records relating to the disposal of waste must be
kept on-site for a minimum of three years.
Remember notification is an annual process. You can re-notify up to one month prior
to the expiry of your current notification.
Obtaining other Site Industry Classification codes
See http://www.environment-agency.gov.uk/subjects/waste/1019330/1029396/ for other
codes not listed in the attached appendix.
Related advice
The proper disposal of computers and other IT equipment can sometimes be costly,
difficult to arrange and not environmentally friendly. With these factors in mind, the County
Council has arrangements in place to facilitate the recycling /re-distribution of surplus
computers and other IT equipment. For more details on how to access these
arrangements (and possibly reduce the volume of hazardous waste produced at your site)
managers should contact Melanie Slater, ICT Procurement Manager for SICT
(Staffordshire ICT) on 01785 278000 or melanie.slater@staffordshire.gov.uk
Further Advice
Further advice on anything included above can be obtained from your Directorate’s Health
and Safety Team.
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