ENVIRONMENTAL CODE OF PRACTICE
Hazardous Waste Management
Waste can be classified as either hazardous or non-hazardous
(which includes inert waste) and both categories require handling
and disposal in different ways. It is therefore important
that you are aware of what types of waste you are handling, as
misclassification could lead to you spending more than necessary
when dealing with your waste, or could lead to
environmental harm and an offence being committed.
By following the requirements of the duty of care and ensuring
that your waste is disposed of, recovered or recycled at a suitably
licensed site, you will be fulfilling most of the
requirements for dealing with non hazardous waste. However, there
are additional requirements and regulations under the Hazardous
Waste Regulations 2005, which replaced the Special Waste
Regulations 1996, which set out the process for managing hazardous
wastes.
Examples of the types of substances used by the marine industry
and that are classified as hazardous wastes include:
- Wood preservatives
- Most types of oil
- Tar
- Inorganic biocides
- Organic solvents e.g. acetone
- Organic halogenated solvents
- Paints and varnishes, including sludge from paint or varnish
removal
- Machining oils and emulsions
- Batteries & battery
acid
- Separately collected fractions of paint, resins, solvents, pesticides, fluorescent tubes
and other mercury containing wastes
- Acidic and alkaline solutions
- Wastes from the surface treatment and shaping of metals and
plastics
- Wastes from metal degreasing and machinery maintenance
- Packaging that contained hazardous materials
- Fluorescent light bulbs
Hazardous Wastes are identified as hazardous in the European Waste
Catalogue (EWC 2002). Hazardous wastes identified in the EWC
2002 include more wastes than those covered by the Special Waste
Regulations 1996. For example, fluorescent light tubes and
television monitors are hazardous waste. Following the
implementation of the Hazardous Waste Regulations in July 2005, the
mechanisms of controlling the management of Hazardous waste have
changed.
From 6 April 2009, the qualifying exemption for notifying the
Environment Agency when hazardous waste is produced on premises in
England and Wales was raised from 200 kilograms to 500
kilograms.
This means that all premises producing less than 500 kilograms of
hazardous waste in any 12 month period will no longer have to
notify the Environment Agency.
All other requirements of the Hazardous Waste Regulations will
continue to apply to all movements of hazardous waste, including
those from premises that are exempt from the notification
requirement.
A consignment note is required to accompany the waste but the
Agency does not need notification before the load is moved.
For further information please refer to the Environment
Agency's website.
The following key changes have been implemented following the
introduction of the new regulations:
- Obligation to notify premises where hazardous waste is
produced.
- Consignment notes will still be required to track the movements
of waste but the requirement to submit them to the EA has been
removed.
- The introduction of quarterly reporting of consignments to the
Agency. Charging for each consignment will be made on the basis of
these quarterly returns.
Hazardous Waste Producer Responsibility
It is the responsibility of the waste producer to:
- Determine whether the waste is hazardous or non-hazardous.
(Your waste contractor may be able to assist you with this)
- Identify the hazardous properties of the waste e.g. toxic,
corrosive, harmful, and assess this against the threshold
concentrations.
- Arrange appropriate storage, transportation and disposal.
It is illegal to store hazardous waste for longer than 12
months.
- All hazardous waste must be stored separately and not mixed
together.
- Hazardous waste must not be mixed with non-hazardous waste as
this will mean that the whole load will be classed as hazardous and
could cost more to dispose of.
- The Duty of Care regulations must be complied with at all
times.
Management of solvents
Members should be aware that the number of types of waste now
classified as hazardous has increased considerably. Many products
and waste used in boat building will be covered, for example any
drums used for storing resin, solvent and sludge from any cleaning
process and must be disposed of via approved routes for hazardous
waste.
Contaminated metalworking fluids, chlorine, phosphorus
compounds, phenols, creosols and alkalis are hazardous due to their
oil and chemical additive content. In addition where scrap metal
and cuttings are mixed with metalworking fluid waste, this will
also be treated as hazardous.
Consider the following action points when handling and storing
solvents:
- Solvents should be stored in a designated area which has
securely bunded compounds and restricted access. Such a storage
area should also have an impervious floor and a means of controlled
drainage
Tight fitting lids should be used on all storage containers to
prevent evaporative loss of VOCs from substances such as solvents
and paint thinners. This should include those containers which hold
soiled rags and cloths
Place cleaning solvent containers near work bays to prevent spills
and drips from tool cleaning
- Use a parts washer system where appropriate. This can be as
simple as a sink on top of a drum of solvent. Solvent is pumped out
of the drum into the sink for washing parts and equipment; used
solvent then drains back into the drum and solids settle to the
bottom. The solvent is replaced on a fixed cycle or when it becomes
too dirty for further use. Discuss with your suppliers the
availability and applicability of such systems
- Use sinks which have lids rather than pails or dunk
buckets. Preferably, the sinks should also have a drainage
grid that allows residual cleaning materials to drain back into the
sink. Stand sinks/buckets on drip trays and try to minimise
splashes
- Pre-rinse parts to be cleaned in a tank of dirty cleaning
solution so as to reduce loading on the clean tank
- Consider filtering the cleaning solvent to prolong its useful
life
- Collect sludge at the base of the solvent tank frequently to
maintain solution’s cleaning efficiency. Zinc and aluminium in
chlorinated solvents can lead to acid formation if allowed
to collect
- Make sure that you do not cross contaminate solvent tanks –
some solvents have very similar names and contamination can render
the whole tank unusable. If using numerous cold cleaning tanks,
standardise the solvent used to minimise the chance of cross
contamination and increase the potential for recycling
- Note that cold cleaning tanks need solvent replacing when the
contamination level reaches 10%. Vapour degreasers can operate at
contamination levels of 25-30%
- Establish guidelines as to which parts, equipment or tools
should be cleaned with solvents and educate staff to comply with
these guidelines
- Use manual wire brushing to remove caked on solids before
cleaning
- Clean parts and equipment before the resin, paint etc.
dries
- Ensure that parts are drained thoroughly after
cleaning
- When cleaning engine parts try to use paraffin based agents
instead of organic solvents
- Where possible, always avoid the use of ozone depleting
solvents
- Place clear information near work bays reminding staff of the
procedures, which they should follow with respect to solvents