LAW
REQUIRED OF YOU TO COMPLY WITH LEGAL AND HEALTH & SAFETY LEGISLATION
WHAT’S
NEW hazardous waste regs could mean that YOU are breaking the law
JULIA INGLESON, Managing Director of authorised waste treatment facility, Recyclite Ltd, warns of the legal requirements of the new Hazardous Waste Regulations (HWR)
AS of 16th July 2005 disposal of hazardous waste, which includes end of life fluorescent tubes and other gas discharge lamps, is subject to new regulations that mean many golf, sports and leisure clubs in the UK could already be breaking the law. Under these regulations, users can no longer dispose of fluorescent and sodium lamps, or other hazardous waste such as computer monitors, along with general waste. To do so is illegal, and leaves the organisation open to a fine by the Environment Agency.
Exemptions
Unless you are entitled to exemption, you are required to register annually with the Environment Agency before you can consign end-of-life lamps or other hazardous waste. The regulations also cover crushing on site, whether by an outside contractor or by your own equipment. You are exempt from
registration if you produced less than 200kg of hazardous waste in a 12-month period, AND you are classified as an exempt premises. It is important to note that this 200kg criterion includes all hazardous waste, not just waste lamps. Bearing in mind the weight of such items as computer monitors, this weight factor can quickly be reached. However, even if you are
exempt from the annual registration, you will still be required to complete certain sections of a special
Consignment Note (available from the Environment Agency at the cost of £20 for a book of 20 forms, or that the recycling organisation can provide) and to pay a fee of between £5 and
£19 (which also goes to the Environment Agency) for each consignment of hazardous waste despatched or collected.
Disposal options
Businesses can take their own waste to a specially designated Hazardous Waste Landfill site, however they will still be required to fill in a
Consignment Note and pay the fee. The problem here is that with only ten such sites in the UK you could be in for a long journey, and Civic Amenity (CA) waste disposal sites are now enforcing bans on accepting any commercial waste.
New hazardous waste
regulations could mean many businesses breaking the law. Moreover, deliveries to these sites have to be pre-booked and a suitable vehicle is required to tip the waste directly into the hole. The alternative is to take it
direct to an Authorised Treatment Facility (ATF), such as Recyclite, or to have a contractor remove the waste. If the waste producers move their own waste then a Waste Carriers licence, issued by the Environment Agency, is not required. On the other hand independent collectors of waste, or contractors who remove hazardous waste as part of the contract, must have a waste carrier's license. However, before they can remove the waste material carriers and contractors must have sight of the producer's registration, or be notified of exemption criteria. The waste producer will also need to complete the consignment note and pay the appropriate fee to the carrier/contractor. Where the producer, carrier
and/or contractor takes the waste directly to an ATF, unless the waste is properly packaged in specialist boxes or containers, there may be grounds for rejecting it on Health and Safety issues. If the hazardous waste contains non-specified other waste, eg cardboard packaging it may also be rejected or charged for in addition.
So, to summarise:
• The only difference in whether or not you are exempt, is the need to register and pay the annual fee
• All producers of hazardous waste have to complete a consignment note and pay the hazardous waste movement fee
• You can take hazardous waste to: a designated hazardous waste landfill site (10 in the UK); an authorised treatment facility; or you can arrange for your contractor or an independent carrier to collect the waste
Commercial implications
The importance of having the consignment note cannot be overstated. It is the evidence that you have officially handed over the hazardous waste to an authorised third party. This is your proof on onward traceability. Failure to comply can have far reaching implications. New hazardous waste
regulations could mean many businesses breaking the law. First of all, as has been said, you have a legal obligation and can be fined by the Environment Agency if you fail to adhere to the law. Second, if you are ISO certified, breaking the law can result in the removal of that certification.
Third, with more and more firms pursuing their supply chain's compliance with legal requirements, best practice management and Corporate Social Responsibility issues, any unlawful business practices can result in immediate loss of contracts. Further information about the new regulations can be found at the following websites:
www.hazardouswaste.org.uk www.environment-
agency.gov.uk www.envirowise.gov.uk It is possible to register online at the Environment Agency website by clicking on the ‘Waste’ page. If you need any help, Recyclite’s service desk, 01953 451111, can guide you through the requirements.
Exempt Premises
Domestic premises, Shops, Offices, Agricultural premises, Dental, Veterinary or Medical premises, Ships, Schools, Prisons, Charity premises (Consignment Notes and Fees still required).
Sports and leisure clubs in the UK could already be breaking the law
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68