Changes to the Environment Agency Technical Guidance, that came into force in September, means that all chemically contaminated packaging is now classified as hazardous waste. This requires tighter controls wherever such waste is being produced and disposed of, explains Chris Edwards, technical manager at Grundon Waste Management
The new Environment Agency guidance, ‘WM2: Hazardous Waste: Interpretation of the definition and classification of hazardous waste,’ defines the methods which must be used to assess whether waste streams are classified as hazardous or not.
For waste to be classified as hazardous it must contain one or more of the 15 specified hazardous properties listed in Annex 111 to the Waste Framework Directive. Common examples include H3 Flammable, H4 Irritant, H5 Harmful, H6 Toxic and H14 Dangerous to the Environment.
However, the most significant amendment to the new guidance is how contaminated packaging is assessed. Previously, packaging containing residues of, or contaminated by, dangerous substances EWC 15 01 10*, and metallic packaging containing a dangerous solid porous matrix (for example asbestos), including empty pressure containers 15 01 11*; were subject to hazard property threshold limits related to the chemical contaminant within. These have now been reclassified as Absolute Hazardous (AH).
All packaging that is contaminated with any quantity of any substance that exhibits any hazardous property will now be classified as hazardous, irrespective of the concentration of that contaminant. All waste packaging arising from all processes on every site will need to be reassessed and, if hazardous components are present at any level, the packaging will be considered a hazardous waste.This adds to the challenges faced by those tasked with managing the disposal process.
Reporting procedures
The ability to demonstrate compliance is vital which is why providing an audit trail that shows exactly how much waste is collected is part of Grundon’s partnership approach. Reporting procedures are an important consideration. All the materials collected by the company are weighed so it is known exactly how much is being recycled or disposed of and copies of the documentation is given to customers so they can demonstrate compliant disposal to the necessary authorities.
Sustainability is increasingly important and the number one priority for waste disposal should always be diversion from landfill and increased recycling or reprocessing. This is something that Grundon has been successful at helping its customers with. Between 2009 and 2012, the company was able to cut the amount of clients’ technical waste going to landfill from 25% to just 4.6% and increased the amount of materials sent for recycling from 23.5% to 42.6%.
The majority of hazardous waste collected by Grundon goes to its Hazardous Waste Transfer Station where it undergoes a series of visual checks and chemical screening before being segregated, reprocessed and repackaged for recycling, treatment or disposal.
In response to increased demand, the waste transfer station has undergone a major expansion programme and this autumn sees the launch of a new aerosol decommissioning and recycling facility called HazPak, designed to speed up recycling and increase the range of materials that can be treated.
As one of only two plants in the UK to offer Best Available Technology (BAT) for the disposal of waste aerosols, it crushes and compacts the aerosol cans, separating out the respective materials and contents for total recovery and recycling.
An alternate route also sees hazardous waste going to the company’s high temperature incinerator, creating electricity which goes into the National Grid.
Customer education
Education is important, as many customers are unaware that their waste falls into the hazardous category and therefore do not take steps to manage its correct disposal.
A common issue facing many industrial environments is that items that fall into the hazardous waste category are not obvious. Although in the home, items such as aerosols, oily rags or cleaning materials can be disposed of in domestic general waste, in a commercial environment these may fall into the hazardous waste category and need to be disposed of in a compliant fashion.
One of the biggest challenges for Grundon is customer education – helping them to understand what is and what is not hazardous waste. Understanding the different waste streams is essential. Once you have a clear idea of the type and amount of waste being produced, then it is possible to look at the disposal options.
Companies are often unsure whether the quantities of waste they generate are enough to warrant specialist service. The only real way to demonstrate this need is to carry out an audit, which is something the technical team at Grundon undertakes on a regular basis. It enables the company to show where efficiencies can be made, recommend solutions and to ensure that companies get the most out of the treatment options available.
Strict rules and regulations also govern the transport of hazardous waste and Grundon’s specially-designed fleet of vehicles and ADR-qualified drivers enable a variety of different containers to be collected in one trip, keeping costs down, reducing vehicle emissions and streamlining the collection process for clients.
Grundon Waste Management
T: 01491 834340
