Note: 'The Hazardous Waste (England and Wales) Regulations 2005' were amended by the The Hazardous Waste (England and Wales) (Amendment) Regulations 2016
Introduction
All waste produced by the University is controlled waste under legislation and must be appropriately handled and stored prior to disposal by approved waste disposal organisations. Certain types of controlled wastes are legally defined as 'hazardous waste' and as such require further measures regarding storage and subsequent disposal.
All producers of waste have a "Duty of Care" to ensure that the waste is made as safe as possible for handlers and is disposed of properly. This may be by decontamination e.g. venting or rinsing of bottles or autoclaving; and by secure packaging, labelling and information prior to the safe transfer of hazardous waste to a secure storage area and subsequent disposal by a licensed contractor (registered Waste Carrier).
Responsibilities
Each University Faculty and Directorate is responsible for organising the safe storage and disposal of hazardous waste produced by their activities. Where an activity such as laboratory projects or maintenance work produces hazardous waste, the risk assessment of the work activity must include arrangements for the safe storage and disposal arrangements of the waste substances produced.
The Faculty Operating Officer or Director of Professional services should appoint a staff member to manage any hazardous waste produced. Staff whose activities produce hazardous waste must inform the appointed person in order that arrangements can be made for the safe transfer and storage of the waste at the allocated hazardous waste storage area, prior to removal from site by an approved waste disposal contractor. The production of hazardous waste should be reduced as far as is reasonably practicable.
It is a criminal offence to dispose of any hazardous wastes inappropriately. Hazardous items should never be disposed of in the general waste, mixed with other wastes or poured down a drain. otherwise the University, or the individual involved, may be subject to prosecution by the Environment Agency or sewerage provider
What is Hazardous Waste?
Waste is generally considered hazardous if it (or the material or substances it contains) are harmful to humans or the environment.
To determine if waste is hazardous:
- look to see if the waste (or the substances used) include orange and black danger symbols or red and white hazard pictograms to indicate they're hazardous; this may be on the item itself such as a chemical bottle or aerosol can or on the safety data sheet.
- check the European Waste Classification Code (EWC) associated with your type of waste; if it has an asterisk, it's hazardous.
Where classification depends on whether dangerous substances are present at or above certain levels you should refer to the technical guidance on waste, WM3, for more information.
All hazardous waste must be managed safely.
Types of Hazardous Waste and Disposal Methods
Under no circumstances should any wastes be disposed of into external drains as these drain directly into local water courses, the pollution of which is a criminal offence and could lead to prosecution with significant financial penalties.
Aerosols
Aerosols will often contain residues of hazardous materials and as such have to be treated as hazardous waste.
Aerosol bins are generally not provided across the campuses but can be arranged where large volumes of aerosols are used. Please contact your local campus FM team to discuss storage options and collection arrangements if required.
If the occasional used aerosol can is produced please store and notify your campus FM team who can arrange for it to be picked up and taken to a central collection point for specialist recycling.
When disposing of aerosols:
- Ensure that your aerosol is completely empty before you decide to recycle it
- Do not pierce, crush or flatten the aerosol.
Asbestos
Asbestos waste or waste containing asbestos requires special handling and labelling and has specific Regulations, Codes of Practice and guidance. Depending on the type and amount of asbestos, a specialist disposal company may need to be used to handle the packing and disposal of the waste. Advice must be sought from the University Asbestos Manager or the Health & Safety Unit as soon as asbestos waste is identified or suspected.
Batteries
It is against the law to dispose of batteries in the general waste, instead they must be segregated and stored separately for recycling.
Dry cell batteries such as Nickel Cadmium (rechargeable), Alkaline and Lithium, can be placed in the pink battery bins located in various locations around campuses or sent to your local FM office. To ensure that these are stored safely prior to collection please make sure that any exposed terminals are taped up (this is to reduce the fire risk) and that leaking or damaged batteries are placed in clear plastic bags.
Wet cell batteries such as Lead Acid Batteries must be stored separately, in a safe, well ventilated area for disposal via an approved contractor. Contact your local FM team for more advice if needed.
Clinical Waste
This includes waste that consists of, or is contaminated with, human or animal tissue, blood or other bodily fluids or excretions, drugs or other pharmaceutical products, and any other waste arising from medical, nursing, pharmaceutical or similar practice.
Clinical Waste must be suitably packaged in yellow clinical waste sacks / bins ready for disposal via collection arrangements for special incineration. Disposal of such waste is to be arranged by the Faculty/Directorate originating the waste with an approved contractor.
Fluorescent Tubes
Fluorescent tubes and lamps are also banned from disposal in general waste and skips and must be managed, stored and disposed of separately. Estates and Facilities teams are responsible for this waste stream however please contact your local FM team if you see any being disposed of incorrectly.
Laboratory Waste
Chemicals & Solvents
Containers of aqueous waste must be appropriately and conspicuously labelled and hazardous liquid wastes must be placed in securely-fastened screw-top bottles, 'Winchesters'.
Organic solvent waste must be segregated as halogenated or non-halogenated waste, stored in appropriate labelled containers and removed to the hazardous waste storage area.
Not all solvent mixtures are accepted for removal by approved contractors. Contact the relevant contractor prior to mixing solvent wastes.
Lab Smalls
Laboratory smalls (liquids) must be securely packaged to prevent leakage and spillage. It is recommended that vials and small bottles containing hazardous waste are placed in a metal container and surrounded with absorption granules. The container should have a secure metal lid. Alternatively, bulk laboratory liquid "smalls" should be packaged in a sturdy cardboard box with each container protected by bubble-wrap, mica-fill, spillage absorption granules or other suitable protection. Larger items may be placed in a suitable cardboard box, packed so they cannot spill and surrounded by spillage granules. A further option is the use of Fibreboard kegs with a double polythene bag lining.
Laboratory smalls (solids) for waste disposal must be placed in a suitably-labelled container and stored securely in a suitably-labelled cardboard or plastic box. Large quantities must be bagged or placed in suitable containers labelled with the contents. All individual items must be identified along with their hazards.
Low Hazard Aqueous Waste
Low hazard aqueous waste may be placed in recycled, glass Winchesters.
Disposal methods must be included in the risk assessment for the substance, process or project in which the substance is used. Before discharging to drain, safety and environmental requirements must be considered as a Trade Effluent Discharge Consent may be required. It is also important to note that certain chemicals, solvents and flammable liquids are prohibited from entering the drainage system. If in doubt please contact the local campus FM team.
The full list of prohibited substances can be found at http://www.legislation.gov.uk/uksi/1989/1156/schedule/1/made
Winchesters and plastic bottles used for low hazard aqueous substances in the laboratory must be vented in fume cupboards and washed out prior to disposal providing only trace amounts will be discharged to foul sewer and the contents are not prohibited from being disposed of in this manner. Labels stating "cleaned for return" are to be affixed to the exterior of the cleaned Winchesters and bottles and the containers moved to the appropriate chemical store for recycling.
Note: Currently, only Fisher and Merck plastic bottles and glass Winchesters are recycled.
After cleaning, other brands of Winchesters and plastic bottles can either be used as containers for liquid waste or, if there is no environmental risk, disposed of in bins provided for the disposal of glass or, if plastic, placed in the mixed recycling. If a risk to the environment remains after cleaning, or the container has not been cleaned, the container must be disposed of as hazardous waste.
Oils
Oils are harmful to the environment and require specialist disposal arrangements. Waste oil must be collected and stored in suitable containers (e.g. empty 25 litre oil drums or Winchester for small quantities) correctly labelled and removed to the allocated hazardous waste storage area.
Any oil soaked items such as oily rags, filters and used spill absorbents must also be stored separately, clearly labelled and disposed of as hazardous waste.
Advice should be sought from your campus FM team when needed.
Paint
Many non-water based paints will be classed as hazardous material and as such have to be treated as hazardous waste.
Paint bins are generally not provided across the campuses but can be arranged where large volumes of paint waste have or are expected to be produced. Please contact your campus FM team to discuss storage options and collection arrangements if required.
When disposing of waste paint:
- Ensure that the paint tin is empty or has been allowed to fully cure and solidify.
- Ensure that the paint lid is firmly affixed.
Radioactive waste
This must be undertaken with advice from the University Radioactive Waste Adviser (RWA) who can be contacted via the Health and Safety Unit at safetyunit@gre.ac.uk
Some examples of the classification of common wastes (for England) are provided by: https://www.gov.uk/how-to-classify-different-types-of-waste/overview
Sharps
Sharps must be discarded in approved sharps bins conforming to BS7320. Sharps comprise items such as hypodermic needles (and attached disposable syringes if removal is inadvisable), small shards of broken glass, mercury-free glass from broken thermometers, scalpel blades and other small sharp items.
Used Spill Absorbents (granules, pads and rags)
In accordance with University spill procedures, used absorbents should be discarded in a separate container or drum and clearly labelled, detailing the nature of the absorbed substance; this is to ensure that the used granules, pads or rags are safely handled and can be correctly disposed of. Please contact your local FM to arrange collection.
Waste Electrical & Electronic Equipment (WEEE)
Under the Hazardous Waste Regulations and Waste Electrical and Electronic Equipment (WEEE) Directive all electrical, electronic and IT equipment is designated as hazardous waste and must be disposed of in accordance with strict regulations. It is illegal to dispose of WEEE waste in the 'general waste.'
If you have items of electrical or electronic equipment for disposal please contact your local Campus FM team, via the Estates and Facilities Helpdesk system, who will arrange for the safe and proper collection and disposal for you.
You will need to provide general details of the equipment you are disposing of, e.g. what it is, approximate size and weight, quantities, present location.
Please ensure that equipment awaiting disposal is kept in a safe place to avoid causing obstructions, prevent environmental harm and reduce risk of injury to staff, students and visitors.
Please notify the officer responsible for maintaining the asset register in your Faculty, Directorate, Institute or Department of the disposal.
For further information relating to the appropriate management of WEEE waste please refer to the University Guidelines on Waste Electrical and Electronic Equipment, and the buying guide 'Retirement of Obsolete IT Equipment Collection, Disposal and Recycling of Waste Electrical & Electronic Equipment (WEEE)', found here.
Documentation for Hazardous Waste Disposal
Before disposing of waste, each waste needs to be classified and described. Hazardous waste containers must be appropriately labelled, clearly stating the contents of the container and the hazard classification of the waste. If unsure, refer to the supplier/manufacturer's safety data sheet of the substance for hazard classification and labelling, your COSHH assessments for the material(s) and / or the government guidance document WM3 if needed.
The following forms are available for staff to label and identify waste;
- Waste Chemical form
- Halogenated waste label
- Aqueous Waste label
- Non Halogenated waste label
Any contractors handling university waste must be registered with the Environment Agency and hold a valid waste carriers' licence. A check must be made on all waste contractors, including carriers, brokers and dealers.
A Waste Consignment Note must be completed to accompany hazardous waste when it is moved from any premises. Most waste contractors will prepare the consignment note however it is your responsibility to ensure a consignment note will be supplied and to ensure that the information is correct.
Due to changes in the Hazardous Waste Regulations, the University is no longer required to register premises / buildings that produce hazardous waste with the Environment Agency. However, the regulations do still require a unique consignment note code for each collection.
If a consignment note needs to be prepared on site, the first 3 characters of the consignment code for any wastes moved from the University premises should be "UNI" followed by 3 characters to represent the campus ie MED for Medway, followed by 5 characters unique to each individual waste movement.
Each waste needs to be classified and described as follows:
- the waste classification code, also referred to as LoW (List of Waste) or EWC (European Waste Catalogue) code - whether it's hazardous
- the type of premises or business where the waste was produced (SIC 2007 CODE)
- the name of the substance or substances
- the process that produced the waste
- a chemical and physical analysis
- any special problems, requirements or knowledge related to the waste
A copy of the 'consignment note' must be retained for three years from the date on the note by the individual/Faculty/Directorate arranging the removal of the waste. Such records (known as a 'register') should be kept at the premises that produced or stored the waste. This is a legal requirement and could be audited by the Environment Agency at any time; it is important that this information can be supplied to the FM team or the emergency services when required to do so. The carrier who collects the waste will take two copies of the consignment note.
The business that receives the hazardous waste is legally required to provide a consignee return to the producer/holder of the waste at least every quarter. These form part of the records that must be kept and should be requested from the contractor when not received. Copies of quarterly returns should also be forwarded to the local campus FM team to ensure information can be included within the Estates Management Record required by HESA.
When there is more than one carrier or a load is rejected you must also keep a record of 'carrier schedules' i.e. a list of carriers.
Further information on consignment note requirements can be found at https://www.gov.uk/dispose-hazardous-waste
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