Under Scottish law, special waste (which is the same as hazardous waste)is any waste that is defined as hazardous by the European Hazardous Waste Directive.1
This report will detail all the steps necessary for the correct disposal of solvent contaminated printers clothes from an Edinburgh printing company. It will describe all the steps from point of origin through to the end disposal , including all the relevant legislation and the real codes and disposal sites that should be used if this was a real waste disposal stream.
Environmental best practice and Best Available Techniques (BAT) 2 will be considered which means that all the options, technology and prices will be considered that are at the disposal of the company in Edinburgh and the best option used. This will include attention given to the waste hierarchy of reduce, reuse, recycle, (and recover).
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The first step is to assess whether the waste produced is hazardous under the Hazardous Waste Directive 3 and the European Waste Catelogue (EWR) 4 The Scottish Environment Protection Agency(SEPA), Environment Agency and Northern Ireland Environment and Heritage Service have produced a document named 'The Interpretation of the definition and classification of hazardous waste' 5. which is is reference for all the legislation where reference is made to hazardous waste and its management. It provides guidance in the assessment of waste to everyone involved in the management, production, and control of hazardous waste.
Firstly it should be determined if the waste is a directive waste under the Waste Framework Directive 6. Almost all household waste, industrial and commercial waste is a Directive Waste and should be assessed to determine if they are hazardous wastes.
According to the directive the following are not Directive Wastes - Radioactive waste1; Waste resulting from prospecting, extraction, treatment and storage of mineral resources and the working of quarries; Animal carcasses and the following agricultural waste: faecal matter and other natural, non-dangerous substances used in farming; Waste waters, with the exception of waste in liquid form; Decommissioned explosives e.g. ammunition, fireworks, flares.
If a waste is any of the above it is not a Directive waste and cannot be termed a 'hazardous' waste.
Therefore the solvent contaminated clothing is a directive waste should be assessed as such.
The next assessment step is to check if domestic legislation contains specific provisions for the waste in question. For example does it display one or more properties in Appendix 3 of the Hazardous Waste Directive 7 and is therefore a hazardous waste. Most common solvents are flammable or combustible liquids who's vapours form explosive mixtures in air 8 . They are also toxic when inhaled. This classifies them under H3A Highly Flammable and H6 Toxic. The solvent contaminating the clothing therefore makes it a hazardous waste.
Once this has been determined the Hazardous Waste Directive 2005 should be consulted and the EWC . The Hazardous Waste Directive defines hazardous waste by referring to the EWC . According to the EWC the solvent contaminated clothing is 15 02 02* Protective clothing contaminated by dangerous substances. It could also be labelled with 14 06 03* other solvents or solvent mixtures. As the most appropriate code - 15 02 02* is a mirror entry in the EWC ( i.e. it has the potential to be either a hazardous waste or not depending on the content of dangerous substances, as opposed to an absolute entry which are automatically considered hazardous) the next step is to determine if the contaminant is known. In this case it is known as a solvent which is designated as hazardous and has hazardous properties as stated above under Appendix 3 of the Hazardous Waste Directory. Hence it is then determined to be a hazardous waste and must be disposed of as such.
Under Duty of Care 9 any producers of waste must classify and describe waste correctly and this includes selecting the most appropriate six digit code from the European Waste Catelogue.
The European Hazardous Waste Directive (Council Directive 91/689/EC)
The European Waste Catelogue 2002
The Environment Agency, The Scottish Environmental Protection Agency, The Northern Ireland Environment and Heritage Service. 'The Interpretation of the Definition and Classification of Hazardous Waste (Second Edition). Technical Guidance WM2. 2008
The Waste Framework Directive (Council Directive 75/442/EEC) Article 1(a)
The European Hazardous Waste Directive (Council Directive 91/689/EC), Appendix Three.
Pradyot P. 'A Comprehensive Guide to the Hazardous Properties of Chemical Substances', Wiley and Sons, 2007. pp 537
The Environmental Protection Duty of Care Regulations SI 1991/2839
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Step Two - Consideration of the Waste Hierarchy
As waste is being produced the Waste Framework Directive 10 and the Pollution Prevention and Control (Scotland) Regulations 2000) 11 require the implementation of the waste hierarchy i.e. that the waste be primarily reduced, reused or recycled (recovered). As the waste has already been produced , research needs to be done as to the Best Practice as to how to dispose of it. Can it be recycled in any way or recovered i.e. by washing of the clothes or is the best option to send it for disposal, by certified professionals.
The primary goal is to not produce the waste at all. If it can be avoided by for example using a different product that is non hazardous. As solvents are very widely used in the printing industry then this is not practical at this point in time.12
If this is not achievable then the amount of waste needs to be reduced by for example, putting into place training that ensures good handling practices so less solvent is split on the clothes.
The solvent contaminated clothes can be washed to get rid of the solvent but the effluent from the washing process then needs to be treated as it cannot be discharged to the sewage system or into groundwater. This would probably involve a sewage treatment plant and an authorisation under the Controlled Activity Regulations 13 or a Pollution Prevention and Control (PPC) 11 permit. As the amount of waste of solvent contaminated clothes is probably small it would be far too expensive for the company.
The waste can be taken to a landfill that accepts this waste, and is the nearest to Edinburgh, is in Tyne and Wear 14 but there are many extra costs associated with this. Firstly if the waste does not meet the accepted levels then it needs to be treated at a cost to the company, either by on premise treatment or external contractors. The company would then need an an Environmental Waste Transfer Licence .The requirement to register as a carrier/broker is contained within The Control of Pollution (Amendment) Act 1989 14 and The Controlled Waste (Registration of Carriers and Seizure of Vehicles) Regulations 199115. This application is made to the Scottish Environmental Protection Agency and is at a cost of £158 16
Different firms were researched in order to ascertain the cheapest and best for the disposal of the waste. Many firms that cater for hazardous waste disposal are not in Edinburgh and can be as far away as the Midlands in England. The emissions from the transport would be large. One example is Nationwide Skip Hire 17 which would charge £68 per bag and the transport would come form England.
The best option for the disposal of the solvent contaminated clothing is through a company called ABC Rapid Response 18 a waste disposal company in Edinburgh. They would charge £35 for each sack of contaminated clothing. They are registered with SEPA as follows REGISTERED FIRM - LICENSE NO. SCO/046628. They are local so would not have to drive far to to collect the waste hence reducing emissions to the environment from the transport.
The Waste Framework Directive (Council Directive 75/442/EEC)
The Pollution Prevention and Control (Scotland) Regulations 2000)
Business gateway, 'Reduce and manage solvent use in your printing business.' www.bgateway.com
Envirowise. 'Dealing with Hazardous Waste In Scotland. Getting it Right' GG 721. Section 5. pp 10
The Control of Pollution (Amendment) Act 1989
The Controlled Waste (Registration of Carriers and Seizure of Vehicles) Regulations 1991
ENVIRONMENT ACT 1995 WASTE MANAGEMENT FEES AND CHARGES (SCOTLAND) SCHEME 2011
Nationwide Skip Hire. http://www.nationwidehire.co.uk/waste-disposal/specialist-waste-removal/
ABC Rapid Response. http://www.abcexterior.co.uk/
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Step Three - Storage
If the waste needs to be stored for any length of time and as solvents are flammable and toxic the waste must be segregated from other waste streams and stored in an appropriately labelled bag. If ABC were to be used they would provide their own labeling for the bags and require that double bagging is used.
Step Four - Consignment of the waste
Under The Duty of Care 19 requirements are made that movements of hazardous waste are tracked by the Scottish Environment Protection Agency using a consignment note system. The consignment notes must be bought from SEPA at a cost of £15 a note. The note is filled in appropriately and the pre-notification section must be sent to the local SEPA office at least 3 days before the movement of the waste. Allow at least 3 days but no longer than a month before the waste is moved. With the carrier the company must fill in section D and ensure the carrier has filled in section C before the waste leaves the premises. Make sure at least three copies of the note travel with the waste. The consignee retains the pink copy, and returns the gold copy to the carrier/haulier: these notes must be kept for at least three years. The consignee sends the yellow copy (deposit information) to SEPA. 20
19. Environmental Protection (Duty of Care) Regulations SI 1991/2839
20. Envirowise. 'Dealing with Hazardous Waste In Scotland. Getting it Right' GG 721. Section 4. pp 8
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