Apparently I'm a waste producer

I enquired about a permit to dispose of F gas yesterday, and they informed me that I was the waste producer and not my customer, unless they ask me to decommission, in which case they become the producer and I become the transporter. I know I have posted about this topic before, but never bothered pursuing it further, but now I'm getting requests to decommission systems and issue a consignment note, I thought I'd better get it right.

So I obtained a waste producers licence yesterday to produce waste and transport it to the waste depot,(HRP), cost £28.00 over the phone. After reading it further on the environmental agency website, it says you don't have to register unless you produce more than 500 kg of waste per year. So I could have saved the hassle and the money, I've still got to get my head around filling in the consignment note though. Probably going to take me longer to do that than actually decommisioning the system.

You need a premises code to be able to return bottle to the wholesaler, so need it even if your under 500kg.

You may also need a waste carriers licence if you carry scrap parts, or even incomplete lengths of pipe, or they can impound your van (so i have been told....)

Yes they assigned me a code, if I actually carry the fridge or parts back to my premises, I will need to get the waste carriers licence. I'll leave that problem for them. I was suprised that HRP don't charge per kg, I always thought they did.

I wonder if they class 100 grams of pure 404a left in a dumpy, scrap, hazardous waste, or spares?

Quote:

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Originally Posted by chilliwilly

Yes they assigned me a code, if I actually carry the fridge or parts back to my premises, I will need to get the waste carriers licence. I'll leave that problem for them. I was suprised that HRP don't charge per kg, I always thought they did.

I wonder if they class 100 grams of pure 404a left in a dumpy, scrap, hazardous waste, or spares?

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Producing waste and carrying waste is the one thing that catches
everyone and almost nobody seems to understand what to do.

I have always said that it is the waste side of our industry that gets
us into trouble. You can drive around with a van load of refrigerants,
flammables and other gasses with little or no worry but as soon as
you recover some refrigerant or oil and put it into your car you are
in a whole different would.

If you remove the stuff from a fridge you are the producer, not the
customer and the waste belongs to you.

To store the stuff or travel with it you need a licence and you need
to identify the waster and have it documented.

As for HRP charging for the waste, they do it in two ways.

One is to hire a small bottle (a dumpy) and pay a fee which
covers the cost of the rental and waste processing (up to the
weight limit of the cylinder).

The other way is to hire a large bottle and then per Kg for the waste
you put inside it.

If you think it is complicated spare a thought for the Scottish, the
Scottish authorities (SEPA) charge for issuing each waste transfer
document and it is only valid for the day of use (no over night stop offs)
and it is illegal to drive over the Scottish border without the correct
documentation.

It is the one part of our job that we could easily fall foul of.

Regards

Rob.

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The only thing that works in our favour when traveling with this stuff is the
police know even less about it than we do and if you get stopped by the police,
the chances of them knowing the intricacies of the law are low, so they would
talk to you about the speeding offence, tailgating, using a mobile phone or
some other crime you have committed but they know little about the stuff you
have in the back.

The people you do need to be aware of, are the VOSA guys. They do random stops
on duel carriageways into and out of towns, they have check points or take over
a lay-by for a morning and man it with the police to stop vehicles (mostly company vans)
and do a complete survey of you and the vehicle.

They dip your diesel, check your tyres, engine emissions, weight and other things. If you
are in the wrong they issue you with fixed penalty notices, warnings or even seize the vehicle.

Those guys just love it when you have a van full of stuff you can't account for :eek:

Rob

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Now you have set me off on one..................

The one thing that gets me going is waste (not in a good way) :p

It's the one side of the industry we all pretend does not exist and it's
the one side of the industry that we are not bothered about, But it is
the one side that will come and bite us.

We don't vent refrigerants anymore, we don't leave leaks any more so
the chance of getting into trouble from that is negligible but as soon as
you put a small cylinder of used refrigerant into the back of your van.......... :confused:

Right breath.................... :o

Rob

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Just like when you get arrested...you are not obliqued to say anything....etc...so why tell them its recovered refrigerant?? :D:):)

Man, am I glad we live in the wild west some times, LOL

Yet a gypsy can fill his van and dump it anywhere and no one says a thing! The worlds gone mad. If you were to throw all your rubbish in a bin at site no one would ask a question, but if you put it in your van to take it to save the world from pollution, your liable. Madness.

Just all be aware from 2014 in the UK you will have to be registered as a waste carrier and required to have a licence. The fact is as soon as you remove oil refrigerant etc. from a customers equipment you have generated the waste and it now belongs to you. We may have a claim to all that "smidge copper" we generate now as it becomes our waste ;)