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  1. #1
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    Hazardous Waste Regulation



    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



  2. #2
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    Brian_UK is offline Moderator I am starting to push the Mods: of RE Site Moderator : and general nice guy
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    Re: Hazardous Waste Regulation

    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?
    Brian - Newton Abbot, Devon, UK
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  3. #3
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    Re: Hazardous Waste Regulation

    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.
    it's only a fridge, fix it. ;)

  4. #4
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    Re: Hazardous Waste Regulation

    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_...v_imprimir.pdf

    Regards,

    Nando.
    Last edited by Fri3Oil System; 04-02-2011 at 12:02 PM. Reason: forgot to post the link :D

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    Re: Hazardous Waste Regulation

    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.
    Training may be finished but experience is never complete.

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    Re: Hazardous Waste Regulation

    then have your van siezed for transporting hazardous waste without a carriers liecence

  7. #7
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    Re: Hazardous Waste Regulation

    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

  8. #8
    Brian_UK's Avatar
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    Re: Hazardous Waste Regulation

    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.
    Brian - Newton Abbot, Devon, UK
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  9. #9
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    Re: Hazardous Waste Regulation

    Quote Originally Posted by clivemtk View Post
    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.
    Training may be finished but experience is never complete.

  10. #10
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    Re: Hazardous Waste Regulation

    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?
    Reality is an elusion created by alcohol deficiency. Quaff and enjoy. [Yorkshire, UK]

  11. #11
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    Re: Hazardous Waste Regulation

    (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”.



    Reality is an elusion created by alcohol deficiency. Quaff and enjoy. [Yorkshire, UK]

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