Disposing of hazardous waste in a safe and environmentally-friendly fashion poses a major challenge for many businesses, but by following some simple procedures, organisations can both comply with the law and make financial savings.
Hazardous waste can cause pollution and severe harm to anyone who may come into contact with it. Contact with hazardous waste can cause burns, poison people and in extreme cases, can even kill humans and animals. Improper disposal can cause fires and explosions too.
Figures from the Environment Agency show that approximately 4.3m tonnes of hazardous waste were moved in England and Wales in 2011. Nearly a million tonnes has to be processed through transfer facilities before final disposal or recovery. Afterwards, 27% of the waste was landfilled, 9% was incinerated, a further 27% was treated and 36% was recovered, recycled or reused. It doesn’t stop just there; provisional figures suggest that in 2011 around 173,000 tonnes of hazardous waste were exported to European destinations.
In the manufacturing industry it is only natural that businesses create a vast amount of waste material. However, if some parts of that waste contain hazardous substances, businesses have a legal obligation to dispose of it correctly.
Chemical manufacturers, electroplating companies, petroleum refineries, nuclear power plants and large and small construction sites are those most likely to require hazardous waste disposal.
The waste hierarchy policy
The government’s Strategy for Hazardous Waste Management was set in 2010 to offer companies support and guidance on how to dispose of their hazardous waste. The strategy outlines six different principles: waste hierarchy, infrastructure management, reducing reliance on landfills, no mixing or dilution, treatment of hazardous organic wastes and ending the reliance on the use of Landfill Directive waste acceptance criteria derogations.
Since then, the Waste (England and Wales) Regulations 2011 have tightened waste management policies, in particular the guidance on waste hierarchy, to rank waste management options according to what is best for the type of waste and the overall impact on the environment.
Created in 2011, the waste hierarchy pyramid favours prevention as the highest form of waste management, by instructing companies to use less hazardous materials during design and manufacturing. It then moves down to preparing for reuse, which involves cleaning, checking and repairing whole or spare parts that can be used again. Recycling is the next stage of the diagram, which includes turning the waste into new products, if it meets safety standards. The penultimate element of the hierarchy is other recovery, including anaerobic digestion, incineration with energy recovery, gasification and pyrolysis, which produce energy (fuels, heat and power) and materials from waste. The final, and therefore lowest-ranked, stage of the pyramid is disposal – i.e. sending your waste to landfill or incineration without any energy recovery.
Many companies use the third tier of the pyramid and reuse and recycle materials. However, if this is not possible then companies are using the fourth stage; incineration for energy recovery.
The charity WRAP has published a case study about the installation of a dust extractor and a biomass boiler in a factory of the furniture manufacturer Warren Davis. The company fed all of the extracted dust into a silo at the factory, which in turn was fed into the biomass boiler, which burns the sawdust and wood chippings created from manufacturing, providing heat for the factory. This resulted in better ventilation and the heat is now recovered from the waste wood for space heating, which has helped reduce the company’s heating and waste disposal costs.
Unfortunately for most companies disposing of hazardous waste the safest option is to destroy it via incineration without creating any useable energy, as the substances are dangerous and cannot be treated for reuse. While this is the safest option, it’s not very eco-friendly at all.
Correctly labelling your waste
Companies lose thousands of pounds each year because they aren’t aware of what constitutes hazardous waste. The reality is that many companies are so concerned about disposing of hazardous waste that they end up treating most of the waste they produce as hazardous, which is much more expensive to destroy than general waste.
This is unnecessarily expensive, as hazardous waste requires more processes to destroy it than general waste does, such as buying more hazardous waste disposal bags and paying to have the material transported to an incinerator.
It is also dangerous because some hazardous substances must be quarantined and cannot be mixed with any other materials. While there are no strict government regulations regarding the process of labelling waste, the UK government strongly advises to avoid any cross contamination of substances. Mixing hazardous and non-hazardous waste is also a criminal offence for which the business could incur a hefty fine.
The good news is that this is easily prevented with clear labelling and education. Products and substances that are hazardous are always clearly labelled with toxic or danger signs and asterisks, and they come in orange, black and red colours. If you are unsure, consider whether the product could be damaging to the environment. Paint cans, aerosols, oils, batteries, solvents and other toxic chemicals are all classed as hazardous and must be disposed of correctly.
Once you and your employees are confident on which substances constitute hazardous waste, make sure people know exactly where to dispose of them by clearly labelling separate bins and containers.
Be vigilant about where and how you store the hazardous waste too, as you cannot store hazardous and non-hazardous waste in the same location. Make sure containers are sealed, labelled, covered and waterproof. If you’re planning to dispose of the container, it may also need to be classified as hazardous waste if it contains residue of dangerous substances or materials.
Upon disposal of the container, the whole item will be classed as hazardous waste and will therefore need to be disposed of in the same way.
Hazardous waste from metal work
Metal production and processing are likely to produce large amounts of hazardous waste.
The following items must all be treated as hazardous waste and therefore disposed of efficiently and correctly:
- Swarf that could be contaminated with cutting fluid or oil
- Oil emulsions and greases
- Acids and alkaline solutions
- Solvents used for degreasing scrap and cleaning boilers
- Sand from casting processes that is contaminated with metals or chemicals
- Pollution containment equipment that has been used on spills of hazardous materials
- Computer monitors
- Fluorescent bulbs.
More recently, the disposal of ‘e-waste’ has become a growing concern. The ever-growing development of new technology means that mobile phones, laptops, TVs, tablets and other electronic devices are regularly disposed of in an incorrect way. Once dumped, the toxic substances in these electrical goods such as lead, mercury, cadmium, arsenic and flame retardants are released into the environment.
Last year nearly 50m tonnes of e-waste was generated worldwide, according to the UN’s Step Initiative, which was set up to combat the world’s e-waste crisis.
Licenses and permits
The government stipulates that a business or individual must have an environmental permit or registered waste exemption from the Environment Agency to use, store, collect, treat, recover, dismantle, recycle, burn or otherwise dispose of hazardous waste.
Often you may not need to register an exemption, but you will still need to follow the terms of one. For example, you can store your own waste temporarily, while you wait for it to be removed from your site.
You can transport waste produced by your own business directly to an authorised waste management site or recycling facility without being registered. However, you must register with the Environment Agency as a waste carrier if you transport construction and demolition waste produced by your own business or any waste produced by another business.
A consignment note is required for every load of waste you pass on or accept. Notes must be completed and signed by both the person sending the waste and the person receiving the waste. Copies of all the consignment notes taken must be kept for at least two years.
Disposing hazardous waste
Manufacturing businesses have a responsibility to ensure that the hazardous waste they produce, store, treat, transport or dispose will not harm others or impact on the environment.
A lot of companies are turning to external waste collection services to remove hazardous waste from their premises. This gives peace of mind that the waste will be properly disposed of while being protected throughout the transit process as well.
You must choose an authorised collection service with a licence to collect, treat and dispose of hazardous waste, as some may only be qualified to dispose of general waste. Give the authorised collection service your consignment note upon collection, which holds the details of the waste and must be kept with it throughout the disposal process.
Take a moment to identify and label the waste produced and refer to the waste hierarchy to ensure you have taken the appropriate measures to dispose of it. Reminding yourself of what actually constitutes hazardous waste will also make the whole process a lot simpler and keep all the relevant paperwork concerning any waste you pass on or accept. At the end of the day efficient hazardous waste management doesn’t need to be complicated.
By Dean Russell MP, Conservative Member of Parliament for Watford on 29 April 2021
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