Hydrocarbons - is it law to recover them?

[Argus]

…………… Stavros Dimas of the EU said in his letter regarding hydrocarbon recovery:

"I would like to stress that the following remarks only reflect the opinion of the Commission services and are not legally binding. A legal interpretation of Community legislation is, under the Treaty, the exclusive competence of the European Court of Justice."

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I haven't found any EU legislation as yet.

It could take some time to decide and in the scheme of things, is small beer in the EU courts.
It is important that the commission has given an opinion as this sets a precedent, the courts will decide if a change is needed to the Directive. But I should stress again that this referred to an interpretation of WEEE, not Hazardous Waste, which has its own directive that is harmonised in UK law as the Hazardous Waste Regulations.


I suggested that you consider them as waste industrial solvents, which are the views, I believe, that the Environment Agency will take.
There is some detail on the classification of waste substances in the list of hazardous waste that accompanies the HW regulations that you have already found.

2005 No. 895 The List of Wastes (England) Regulations 2005

You need to read the two together.

For example, it is arguably safe management to blow HC's off.

Does HRP receive hydrocarbons for disposal?

There is a strong argument to suggest that it is not safe or legal to expel waste flammable material of any kind to the atmosphere. It depends on whether you want to take the risk.

You also need to consider the Health & Safety practices in your own company and the premises where you are working. HCs have a tendency to collect in low lying areas.

What’s been considered acceptable practice since time immemorial doesn’t mean that it’s acceptable or legal now.

I don’t know about HRP taking back waste, you’ll have to ask them what their policy is.
I believe that you will get a more definitive answer from BOC.
ACRIB also have some guidance on the subject on their website.

The technique of recovery is the same as you would use for other refrigerants, making allowances for the hazards of the material and the equipment needed.


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