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. 30.6.2005 Page 1 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. 30.6.2005 Page 2 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: 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. 30.6.2005 Page 3