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jdscooling
03-02-2011, 10:48 PM
Please Help
I have pumped down several units from 2 sites and taken away the units, then reclaimed the refrigerant from my workshop/yard, I’m filling out The Hazardous Waste Regulation Consignments Note, and asked for the site address waste was removed from.....Technically I have removed it from the unit at my premises, or do I need to put both address down, but the form only has room for one address?

Thanks Jason

Brian_UK
03-02-2011, 11:58 PM
No, you took the waste from the original site not your yard.

It could also be argued that you Transported Hazardous Waste, do you have a licence to do so?

chillyhamster
04-02-2011, 10:57 AM
You don't need a licence to transport H W if you produced it, he only needs a licence to transport from the way station (his yard) to the recycling facility.

Fri3Oil System
04-02-2011, 11:59 AM
Hi,

regarding E.R. 1005/2009, you're allowed to treat the recovered refrigerant and recycle it with your own tools/methods, either on site, or at your place.
Then, the harzardous waste would be the oils and acids which are then separated from the gas itself.
In Spain, at least, there are companies(public ones normally) that come to your facilities and pick those residues, and they do it for free.

here is a link to the Spanish Ministry of the Environment where the consider this issue: slides 18 and 20.
http://www.mma.es/secciones/calidad_contaminacion/atmosfera/ozono/pdf/091212_Presentacion_MARM_v_imprimir.pdf

Regards,

Nando.

chilliwilly
04-02-2011, 07:04 PM
Yes that's something I've always wondered about, if you process contaminated gas on site or your workshop. Does this construe a non compliance under the hazardous waste regs? Even if you have a licence and you multi decanter the gas, is what's left classed as hazardous waste.

As it is only oily sludge with an acidic PH, I don't know what type of acid it is, but surely an alkaline solution would neutralise it. So then it just becomes a spent oil like your engine oil from your car. Which is tipped at the council tip.

clivemtk
04-02-2011, 10:05 PM
then have your van siezed for transporting hazardous waste without a carriers liecence

jdscooling
04-02-2011, 11:14 PM
I have now obtained a Premises Code Licence for Producing Hazard Waste,
This will clear up all the grey areas,
Not that it will be policed, it’s another way for the gov to make more money,

cheers
Jason

Brian_UK
04-02-2011, 11:54 PM
I think that you are missing then point.

You can register your premises as a waste producer but the waste is being Transported from somewhere else by you acting as a Carrier.

Different licence and more money, of course.

chilliwilly
05-02-2011, 12:50 AM
then have your van siezed for transporting hazardous waste without a carriers liecence

I have a licence, I just wondered if I processed my own waste. And neutralised the toxins, it would just be spent oil, like old engine oil. It would be no longer hazardous waste. The old engine oil would probably contain more toxins than my processed neutralised oil.

nevgee
05-02-2011, 07:39 PM
It's a veritable can of worms, I wonder that anyone really knows the answer to this. Some believe the waste is of their own making and don't need a carrier license which is contrary to others interpretation. Can we get a definitive answer to this anywhere?
:confused:

nevgee
05-02-2011, 08:54 PM
(Extract from

RECOVERED REFRIGERANTS AND THE HAZARDOUS WASTE REGULATIONS ACRIB copyright)


As the PRODUCER of hazardous waste you do not need to hold a WASTE CARRIER LICENCE* to be able to move
the waste For example: to your premises as a mobile service, or to a wholesaler, recycler or other transfer
station; unless you should need to carry CONSTRUCTION AND OR DEMOLITION WASTE in which case you must
hold a WASTE CARRIER’S LICENCE.
*Waste Carrier Licence may be required in Scotland or Northern Ireland.
In the case of Recovered Refrigerants, there are regulations which define how you handle and carry refrigerant
cylinders and other gases in vehicles:
• Cylinders shall not be thrown or subjected to impact.


• Cylinders must be stowed so that they cannot overturn.

• Cylinders can be laid flat and parallel to the axis or at right angles to the axis of the vehicle, however

those situated close to the forward transverse wall must be at right angles to the axis. Such cylinders

must be secured so that they cannot move.
• Cylinders which are carried in suitable securing devices, such as side wall fastening straps, preventing


the cylinder from overturning, may be placed upright. Likewise cylinders that are sufficiently stable to

prevent then overturning may be carried upright.
• Cylinders must be carried in open or ventilated vehicles. If this is not feasible then the cargo doors must


be marked in letters not less than 25mm high with the wording:


“WARNING NO VENTILATION OPEN WITH CAUTION”.




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