The new Hazardous
Waste ( England and Wales ) Regulations 2005 will be
implemented on 16th July 2005 . There are many changes
to the current Special Waste Regulations, but the two
key ones are that Hazardous waste producers will be required
to pre-register before any Hazardous waste can be collected
from their premises and the Regulations apply the European
Waste Catalogue codes of Hazardous wastes that will affect
a much wider range of producers.
The list below is not exhaustive, but summarises the
main requirements. There is also a range of web links
that will get you more detail.
- From 16th July 2005 , it will be an offence for
hazardous waste to be collected from a site that has
not been registered or is exempt.
- All non-exempt sites that produce hazardous waste
must be registered even if they are unlikely to have
that waste collected for some time. Recent EA Guidance
has clarified that it is an offence to produce hazardous
waste on site and not be registered.
- The Regulations will implement, through the
List of Wastes ( England ) Regulations 2005, the
European Waste Catalogue list of Hazardous wastes
for the purposes of collection. This can be found
at www.hmso.gov.uk and
will mean that things like PC monitors, PC base
units, fridges, TVs, oily rags and separately collected
fluorescent tubes will require collection under
the new hazardous waste notification and documentation
procedures.
- From 16th April, the EA will accept postal registrations.
From 3rd May, Registrations can be made on line through
the following website www.environment-agency.gov.uk.
There is also a guide
that takes you through the registration process.
- Each site producing hazardous waste has to have
a separate registration although multiple sites can
be registered on the same notification. Therefore,
a head office could register all its sites centrally,
but each site would have a separate unique registration
number and require a separate fee.
- Some sites are exempt if they expect to produce
less that 200kgs of hazardous waste a year – although
they would then have to register if, part way
through the year, they went over the threshold.
These include agricultural premises, office premises,
shops, premises where WEEE is collected, dental,
veterinary and medical practices and ships. The
EA indicate that 200kgs is approximately 10 small
TVs, 500 fluorescent tubes or 5 small domestic
fridges.
- Domestic waste is excluded from the Hazardous
Waste Regulations on collection from the domestic
property, but is then subject to the Regulations
if it is separately collected or if it consists
of asbestos. This includes Prescription Only Medicines
(other than cytotoxic and cytostatic medicines)
which will be hazardous waste.
- The Regulations will
require a new consignment note to be used from
16th July 2005 in place of the current Section
62. Each consignment will require a fee to be
paid to the EA by the consignee with their quarterly
returns to the Agency. Clearly, this will be
charged back to the collector, but a consignment
might well attract more than one consignment fee
if, for instance, it goes through a transfer station
and the collector would have to ensure that this
was considered in the price.
- Collection rounds will be possible but again, each
site where the waste is collected would have to be
left a copy of the consignment note, so the process
of tracking and the paper trail will get quite complex
especially as each collection will count as a consignment
from the fee point of view.
- The Regulations ban the mixing of Hazardous waste
and state that it must be stored separately on site.
However, clarification on the interpretation of this
is still awaited from the EA as it would, for instance,
preclude the collection of computer systems that included
a base unit and screen.
- Registration as a Hazardous Waste producer places
a statutory duty on the EA to inspect the site where
the hazardous waste arises.
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