EC Regulation

[Abe]

As a starting point we can look at the following EC Regulation.

http://www.dti.gov.uk/access/regulation2037.pdf

This Regulation has largely been framed in accordance to the requirements of the Montreal Protocol.

Regulations are binding on an EC member state in its entirety requiring no domestic legislation to give effect to the Regulation.

This Regulation goes back to 2000 I think, so am wondering if theres something more current.

If any forum members are inclined to study the relevant parts and bring to our attention any pertinent sections, that would be welcomed.


Im still looking into the " hazourdous waste controls" and disposal of them , I shall post once Ive finalised my research into them

[Argus]

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I?ve posted on these issues regularly over the recent year or two. Some of them have been around for many years, the Hazardous Waste Regulations came into force in July this year, but we can hardly say that it is unknown. They have been in discussion with the government for at least a couple of years.

The Montreal Protocol agreed on curbs and curtailments to Ozone depleting substances of all kinds, not just refrigerants. The international Secretariat is UNEP.
You can read it all here:
http://www.unep.org/themes/ozone/

The ODS regulations came out originally 11 years ago, so as a EU mechanism for the Montreal Protocol, it?s been around a long time. The first regulation on ODS was No: EC 3093 / 94 in 1994. It was replaced by EC 2037/2000, five years ago. This is still current, though there are some revisions in Article 5 under consideration now.

It deals with ODS only, not HFCs. A regulation on HFCs is in preparation in the European Parliament now.

The DTI have a site devoted to ODS regulation, including the text and guidelines:
http://www.dti.gov.uk/access/ozone.htm

Article 5 deals with HCFCs and in section1 (v), the commission is already considering a revision of the dates with consideration to HCFCs (R22 is of particular interest), so the phase-out dates after 2010 and recycle use dates will probably change.

Although the Regulation passes directly into force in member states, the members in the EU have the opportunity to impose their own penalties for breach.
In the UK it is a Statutory Instrument, 2002 No. 528 ?The Environmental Protection (Controls on Ozone-Depleting Substances) Regulations 2002?. In it they describe what they will do to you when they catch you doing what you shouldn?t.

You can see it here:
http://www.opsi.gov.uk/si/si2002/20020528.htm

The new Hazardous Waste rules are laid out in the Environment Agency?s web site

http://www.environment-agency.gov.uk/subjects/waste/

Most companies have already set themselves up to deal with it. The first rule you are likely to break, probably unintentionally, is not to register your company and premises. You have to do this NOW.
If you are a contractor then you will be a mobile waste collector.
The second is to deal with waste that you think is not hazardous, It is not only refrigerants, include all used oil, dead driers, fluorescent tubes from cabinets, insulation materials from cabinets, electrical and electronic items of all kinds?..
Include in Hazardous refrigerants, not only HFCs, HCFCs, and CFCs, but ammonia and HCs.
The view from the EA, as I understand it is that unauthorised transport and deliberate venting is in their view the same as fly-tipping and they intend to prosecute.

To make a bad situation worse, the rules in Scotland and Northern Ireland are different to England and Wales.
Be careful if you do a job in Glasgow and bring waste refrigerant into England!

We have not mentioned WEEE and RoHs??

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[Abe]

Argus,


Thats a really useful and informed input by yourself Argus, I am aware that in the past you have posted valid reference material, so its appreciated we have on this forum a qualified view and direction that you are providing.

Would it be too much to ask without being unduly invasive of your privacy , if you are actively involved in this side of the business , ie: Environmental issues

[Argus]

Thank you for that, Aiyub.

I have kept a close eye on certification and regulatory issues for some time. I am not an expert in legal matters, nor am I a lawyer; I just read the words and approach the issues with a little technical knowledge.

The main problem, as I see it, is that, like it or not, the regulations coming in are inevitable. Most of them are long overdue. However there is an inherent resistance to understanding change in this industry that you seldom see in others.

Most of the so-called 'new' regulations are nothing of the sort. They have been in preparation, sometimes for years. The F Gas regulation is a good point in question. That one has been on the go since 2003, and should be in force within 12 months.

The UK government is committed to consultation on all these issues; some departments 'consult' better, to a wider forum and more effectively than others, but the run up to new regulations often gives the wider population the opportunity to get involved, shape opinion or, at the very least, to keep informed.

Most departments, DEFRA, DTI etc. have policy units who often seek opinion. It's worth talking to them. Some have regular meetings with industry.

In one form or another, various issues are all written about on the internet? The hard part is sometimes sorting through it all, and putting the knowledge you gain to effective use.

As I said, I?m not a lawyer, I just read the words.

I'm happy to share what understanding I have with you.

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