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  1. #1
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    Lost in Regulations



    Hi, I've been wondering just how much certification we as refrigeration engineers need to offer full services to our customers.

    I have my 2079 level 1, which I know allows me to buy, transport, recover and leak test systems. But do I also require certification or registration to carry to carry my oxy/acetylene cylinders? (My insurance doesn't seem to think so but in today's world it really doesn't seem to fit that I'm not buttering some ones bread so I can buy my own)

    Also I was curious as to weather or not I should be registered as a hazardous waste producer/carrier since I am expected to remove such items as a pot compressor that contains waste oil. This thought occurs due to a conversation I had with some one from the Environmental agency that told me that if I remove the oil from a compressor that makes me the producer of hazardous waste and not my client whose site I am on and thus I need to register to do so.

    I have tried to find the answers online and by phoning SEPA directly (they said they would call back and never did) to no avail, I'm sure the information is out there, probably hidden in the long winded, over complicated regulations but I can't seem to find it.

    Or is it just the case that I can do all this with out paying to be certified so long as I keep following regulations.

    Any kind of direction to aid my search would be gratefully excepted, any direct statement that includes a definitive list would make my day, year, life.

    Oh I'm new by the by, Hi!



  2. #2
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    Re: Lost in Regulations

    Just a little addition to the above, do we need to be certified electricians to work on control circuits? That one has always bothered me, I work along side a man who is a time served electrician but what happens if I change job or I start out myself? (he doesn't know by the way and since we are the company I have no one else to ask)

  3. #3
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    Re: Lost in Regulations

    So after 6 hours of head ache yesterday, I spend 3 minutes online and find out the following.

    I know am exempt from ADR under Limited Quantity exemptions.

    In regards to removing oil from a system, in Scotland I don't have to register as a special waste producer unless I intend to send over the border, but as soon as the oil is out of the system that brings us straight in to storage and/or transport.

    I know I am exempt from regulation of oil storage under the Water Environment (oil storage) Regs 2006 because I store all my oil in my vehicle, but does this cover used oil? I don't think it does.

    I am still unsure about transporting used oil, from what I have read so far, I believe that if I wish to transport any quantity of used oil I am required me to obtain a Special Waste Consignment Note (SWCN) each and every time I need to move it. I would love some clarification to this one as at the moment I have been turning down certain jobs because they expect me to remove oil from system and site, I have tried phoning SEPA for clarification but constantly get the brush off.

    I hope there are people out there reading this, I know if they are they are probably thinking "what an idiot" but really I could use some advice on this, it worries me that I'm not providing a full service to my customers due to, well I'm just going to say either my own ineptness.

  4. #4
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    Re: Lost in Regulations

    I'm back on the Pale

  5. #5
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    Re: Lost in Regulations

    Quote Originally Posted by frank View Post
    Thank you very much for a response and the link, unfortunately this guide pertains to England and Wales mostly, better suited for a company down south who may some times come to scotland. SEPA have now phoned me back (I have already had to turn down my job) and I have found out the following.

    Both oil and refrigerant become classed as special waste as soon as it is removed from the system and thus comes under the special waste regulations. This would mean registering and can become rather expensive.

    Possibly waste oil that has not been removed from a compressor is not classed as waste, I am making an assumption here but I think that means it will be covered under the water environment regs 2006.

    A very pleasant lady from SEPA tells me she will be me some documentation to clarify special waste regs, I will endeavour to share if/when I get it.

  6. #6
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    Re: Lost in Regulations

    Quote Originally Posted by LostInRegs View Post
    Just a little addition to the above, do we need to be certified electricians to work on control circuits? That one has always bothered me, I work along side a man who is a time served electrician but what happens if I change job or I start out myself? (he doesn't know by the way and since we are the company I have no one else to ask)
    Quote Originally Posted by LostInRegs View Post
    Thank you very much for a response and the link, unfortunately this guide pertains to England and Wales mostly, better suited for a company down south who may some times come to scotland. SEPA have now phoned me back (I have already had to turn down my job) and I have found out the following.

    Both oil and refrigerant become classed as special waste as soon as it is removed from the system and thus comes under the special waste regulations. This would mean registering and can become rather expensive.

    Possibly waste oil that has not been removed from a compressor is not classed as waste, I am making an assumption here but I think that means it will be covered under the water environment regs 2006.

    A very pleasant lady from SEPA tells me she will be me some documentation to clarify special waste regs, I will endeavour to share if/when I get it.
    To answer the electrical question, no you do not have to have a qualification
    but you do need to be competent and one way of proving competency is to
    hold a qualification. Other ways of proving competency are experience,
    if you can do the job and know how to do the job then you are deemed competent.

    As for the waste issue, I have limited knowledge of the Scottish system but I do
    know they are very strict about the waste transfer documentation and I know you
    have to have a separate document for each transfer and there is a cost for the documents.

    You are not allowed to cross the boarder with the waste and the transfer documents are
    valid only for the time of the journey and that does not include overnight storage.

    Limited I know but as far as I understand the Scottish SEPA work very similar to the
    English EPA and apart from the few document and cost differences, they are almost
    the same rules and regulations.

    Regards

    Rob

    .
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  7. #7
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    Re: Lost in Regulations

    This is starting to worry me, I wonder if it's better to ask the wholesalers to collect the bottles rather than us taking them back?

  8. #8
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    Re: Lost in Regulations

    Quote Originally Posted by r.bartlett View Post
    This is starting to worry me, I wonder if it's better to ask the wholesalers to collect the bottles rather than us taking them back?
    ..

    Every time I talk to someone about refrigeration I always
    emphasize the waste transfer issue.

    We don't often come into contact with the authorities
    but the ones that worry me the most are the VOSA guys
    ( Vehicle & Operator Services Agency ) they do random
    checks at the side of the road and have the authority to
    seize the vehicle if they so choose.

    Of all the things we need to be aware of, waste is the one
    we know the least about and pretend it doesn't matter but
    it is probably the one that will catch us out if we are unprepared.

    Waste is quite simple.

    Always declare what you have and use a waste transfer document.
    Always know what you have and how much and log it on the document.

    That's all it takes, you do not have to register if you are dealing in small
    quantities and you can get the wholesaler to pick up the waste (if they offer that service).

    Regards

    Rob

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  9. #9
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    Re: Lost in Regulations

    .

    For information.

    Number one.

    One-Off Recovered Refrigerant Removal Operation
    You can remove recovered refrigerant as a one-off operation, servicing a specific site – recover refrigerant, remove it from the site and transfer it to a wholesaler, refrigerant distributor or reclaimer. If you are removing less than 500kg from that site in any 12 month period, you do not require a Premises Code for that site

    Number two.

    Operation as a Mobile Service
    You can operate as a hazardous waste MOBILE SERVICE, which allows you to collect amounts less that 500 kg from any site you service, collecting all the recovered refrigerant together and handling it as a single quantity, but:
    a) You must have a Premises Code for your own business site, before you start.


    Either individual amounts from any one site to the limit of 500 kg or register your premises
    and then collect up to 500 kg's, store and combine together.


    Rob

    .
    Last edited by Rob White; 03-03-2014 at 10:11 AM.
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  10. #10
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    Re: Lost in Regulations

    .

    See

    http://www.refcom.org.uk/downloads/R...us%20waste.pdf

    It covers England, Wales and Scotland.

    Rob

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