Staying green with your packaging waste
08 June 2015
Although licensed waste management companies have a duty of care when they collect waste, businesses are still responsible for checking how that waste is processed to meet their own obligations. For businesses that produce the waste, this duty of care extends to ensuring the waste is compliantly and sustainably managed to reduce the environmental impact of waste disposal. Paul Rendle-Barnes at Avanti Environmental explains how this applies to businesses in the FM and cleaning sector
Waste covered by the Duty of Care includes the packaging of products used and not just the product itself. Common products such as biocides, disinfectants, wood preservatives and insect repellents can produce packaging waste that must be classified as hazardous. (Source: HSE - www.hse.gov.uk/biocides/basics.htm).
From 1 June 2015, the way waste will be assessed and classified in the United Kingdom changes significantly. Waste producers, such as businesses in the cleaning and facilities management sector that use "products" to deliver a service will need to comply with the revised guidance set out in WM3, the joint UK environmental regulators’ guidance on classification of hazardous waste.
The current guidance, "Hazardous waste: Interpretation of the definition and classification of hazardous waste (3rd Edition 2013)", known as WM2 for short, is a comprehensive technical guidance document on the assessment and classification of hazardous waste. The forthcoming WM3 will be an update introducing new requirements as a result of several changes to the law including: amendments to the list of waste (or European Waste Catalogue), a major revision of hazardous properties and the adoption of the new systems of chemical classification (Source: Consultation document – WM3, https://consult.environment-agency.gov.uk/portal/ho/waste/tech/guidance?pointId=3136200).
How will this affect you?
Packaging that cannot be proven to be free of any residue or contamination from a hazardous substance has to be classified and treated as hazardous waste. Under the new WM3 guidance the framework for determining hazardous properties will change, meaning that some additional wastes may become hazardous.
Anyone buying in products, from the companies responsible for treating swimming pools with chlorine to the companies responsible for industrial cleaning contracts, will need to assess the hazardous properties of their waste packaging and will need to demonstrate a fully auditable trail of what happens to it.
In advance of receiving any contaminated packaging (anything from 0.5 litres to 205 litre drums or Intermediate Bulk Containers or IBCs), waste producers should provide waste management companies with a Material Safety Data Sheet (MSDS) as they provide information on chemical products that helps users of those chemicals to make a risk assessment. The safety data sheet also describes any hazards that the chemicals cause, and gives information on handling, storage and emergency measures in case of an accident.
Closing the loop
At Avanti, when we collect 1000 litre intermediate bulk containers (IBCs)/flexible intermediate bulk containers (FIBCs), 205 litre and even 10 litre packaging containers, we decontaminate and process these via a "polymer separation" process. This polymer separation process means that the containers are decontaminated, washed and then reprocessed through the Avanti integrated recycling plants. The regulated process closes the loop and produces multiple grades of raw material that can be remanufactured into new bins, drums and even kerb stones.
Processes such as these undertaken by Avanti not only help the FM/cleaning sector meet all regulatory compliance requirements, but also avoid the risk of fines or costly prosecutions. Additionally, by ensuring the waste is fully recovered and recycled into new products, this hugely contributes to sustainability and a company’s Corporate Social Responsibilities.