MARCO MUIA BSc (Hons) MSc MCIWM, Managing Director
at Oaktree Environmental Limited. Marco specialises in all aspects of waste planning and regulation consultancy. He also holds the level 4 COTCs for Hazardous Waste Treatment and Transfer.
01606 558833 |
marco@oaktree-environmental.co.uk Twitter @wastechat.
Business Clinic
ENVIRONMENTAL
POPS and WEEE update
IN August 2020, the Environment Agency issued a letter providing a compliance update on Persistent Organic Pollutants (POPs) in Waste Electrical and Electronic Equipment (WEEE), which applies to any business managing WEEE.
CLICK HERE to view detailed guidance. Here, I’ve tried to provide a brief summary where WEEE is not a major part of your waste businesses but is still impacted by the guidance. The guidance includes a table of POPs and permitted concentration thresholds for waste.
What are POPs?
POPs are predominantly man-made organic compounds that are resistant to degradation in the environment. Their long-term effects include bioaccumulation via the food chain, in particular accumulation in fatty tissues leading to a multitude of adverse health impacts. CLICK HERE to view a list of the POP restrictions.
What WEEE contains POPs? •
Printed circuit boards Plastic components, including casings
• Cables and internal wiring •
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Some POPs have been banned for decades, such as the well-known insecticides DDT and PCB. Others are less well-known. It can be difficult to assess without expensive analysis, which will no doubt lead to disposal or destruction rather than re-use in cases of doubt.
What action do I need to take?
If your electrical waste has POP greater than the thresholds in the table then it must be destroyed using an approved process, including incineration and chemical destruction. Reusing waste containing POPs is not permitted and the waste cannot be turned into a product for reuse. It remains as waste.
This will cause difficulties with re-use of items of WEEE as there is an assumption that equipment manufactured after January 2009 is much less likely to contain POPs. These restrictions will impact on all WEEE recyclers as well, including those with an S2 or T11 exemption. If you do dismantle WEEE, any components containing POPs must be disposed of properly rather than recycled eg, incineration with energy recovery. Components that do not contain POPs can be recycled or recovered.
You must also avoid mixing POPs waste with other waste during storage,
collection and treatment. If you do mix waste, you must still destroy the POPs even if the mixing has diluted the POPs to below the concentration limits in the guidance table.
You must only reuse WEEE within the UK if you can demonstrate that you have checked each item to make sure it was manufactured after 1 January 2009 and met all the other relevant requirements for reusing WEEE. There are also similar restrictions on the export of WEEE so take advice before proceeding.
Ultimately it is a duty of care issue in that, when passing waste on to the next person, you use the correct EWC code and description to enable them to deal with your waste properly.
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