Pre-treatment of waste, six months on
Although there’s been a duty to treat non-hazardous waste since October 2007, so far the Environment Agency (EA) has left businesses alone. However, now it’s decided to start checking up. What should you be doing?
Recap
From October 30 2007 all businesses have been under a legal duty to treat all non-hazardous waste before it’s sent to a landfill site. This duty is contained within the Landfill (England and Wales) Regulations 2002. (See Thenextstep for a previous article.) Note. Although the Regulations have been in place for a number of years, the treatment of non-hazardous waste rules weren’t introduced until last year.
Six months’ grace
Following the introduction of the new duties, the EA decided to give businesses a six-month window to get systems in place to comply. However, this period is now over and the EA has made it clear that it intends to carry out some spot checks to ensure businesses are doing what they’re supposed to.
Tip. Don’t assume that just because you don’t see an inspector at your premises your business is in the clear. As we said in a previous issue, inspectors can do many checks from their PC or at waste transfer and collection sites (see Thenextstep for a previous article).
What does treatment involve?
Treatment will be deemed to have been carried out when waste has been through a three-point test. It must be a physical, thermal and chemical or biological process - which can include sorting. It must change the characteristics of the waste in any, or all, of the following ways: decreasing its volume; reducing its hazardous nature; facilitating its handling or enhancing its recovery.
Tip 1. If you don’t want to treat the waste yourself, employ a waste contractor to do it on your behalf. According to the EA, many small businesses opt for this service. If you do, you’ll need to have evidence of an agreement between you and your waste contractor. Usually this is a letter of confirmation from the contractor stating that it will be treating the waste.
Tip 2. A common mistake is assuming that you can put all waste into a compactor. This is not the case. In fact, compacting waste will make it almost impossible to treat it.
What should you be doing?
The good news is that you may already be compliant without even realising it. Say, for example, your office has a paper recycling scheme in place - the residual waste that is collected for disposal to landfill is considered to be pre-treated. This is because its weight has been reduced from what it would have been if there was no paper recycling scheme in place. And there are other really simple methods of making sure that you’re compliant, probably without having to do any more than you do already. For example, if your office has the toner cartridges from its printers collected for recycling, then the residual general waste is considered to have satisfied the pre-treatment requirements.
Tip. Keep evidence, i.e. all waste transfer notes, contracts etc. with recycling firms, so that if an inspector requests proof of compliance, you can send them the information.
For a previous article on the Landfill Regulations (EN 03.02.05A) and on how the EA is completing checks differently (EN 03.02.05B), visit http://environment.indicator.co.uk.
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