Guidance has been published by the Home Office on what scrap metal recyclers need to do to ensure they don’t break the law by trading in cash.

However, this guidance may only be relevant for around six months if Richard Ottaway’s Private Members’ Scrap Metal Dealers Bill becomes law.

The introduction to the guidance states: “The changes aim to remove the rewards that make metal theft such a low risk criminal enterprise for metal thieves and unscrupulous dealers.

“The revised legislation creates a new criminal offence which prohibits scrap metal dealers from paying for scrap metal in cash, only permitting electronic payment or payment by cheque.”

Itinerant collectors will be exempted if they have registered with their local authority and have obtained a separate order that exempts them from certain record keeping requirements.

Direct debits, BACS payments, credit transfers and mobile banking are all permitted as are cheques and reloadable electronic money products which are issued to a named account and undertakes full due diligence.

Any payment by cheque or electronic transfer that is anonymous is not allowed.

Scrap metal dealers will also be required to keep a printed copy of the electronic transaction receipt or a copy of the cheque. Records that do not contain this will be considered incomplete and an offence under the Scrap Metal Dealers Act.

Local authorities and the police will be responsible for checking the records of scrap dealers and will be responsible for ensuring compliance under the cashless trading provisions.

This will be implemented from 3 December 2012. 

reported by scrap ex

Following the example of the Northern Ireland Environment Agency, the  Environment Agency in England has written to exporters to tell them they must reveal the name of the waste producer on Annex VII documents when shipping waste and recycling.

A recent ruling at the Court of Justice of the European Union ruled that German scrap metal company Interseroh had to provide the waste producer’s name and details on the Annex VII documentation despite Interseroh arguing it could damage their business by providing commercially confidential details.

It had been common practice that the intermediary company would put something like ‘refer to shipper’. But now full details will need to be included.

In the letter, the Environment Agency wrote: “I am writing to advise you that in accordance with Regulation 18)b) of the Transfrontier Shipment of Waste Regulations 2007 it is an offence to transport waste other than in accordance with the Annex VII document.

“Not only must the Annex VII form accompany the waste in the container, but it must be properly and fully completed. This includes confirmation that there is a contract in place between the person arranging the shipment and the consignee where the shipment cannot be completed or is discovered to be illegal.

“Please also note the recent European case law has stated that details of the consignee cannot be withheld or left out on grounds of commercial confidentiality: the annex VII needs to be completed in full. Witholding such information would constitute an offence under Regulation 18(b) of the TFS Regulations as the shipment would not be in accordance with Annex VII document and the requirements of Article 18 of the European Regulation.”

reported by scrap ex

Are you ready for the waste exemption changes?

 New regulations changing waste exemptions were introduced on 6 April 2010. They affect the types of waste operation that are exempt and the rules which control them.

The information below will help you find out about the regulations that control waste exemptions and what types of waste operation are listed as exempt.

Registration of all but one of the exemptions is free and lasts for three years. To continue operating for longer than this you will need to renew your registration

How do I find out if my waste operation is exempt?

Step 1 – Decide, using the guide below, what category your waste operation falls into. Make sure you have also read and understood the important information under ‘Before you register’.

Step 2 – Use the links under  waste exemption categories to find a list of operations which fall under each category. These are all listed by number and have a one line description.

Step 3 – If the short description matches what you want to do, click on that exemption to find a full description and our guidance.

Step 4 – Use the guidance and description to help you decide if the exemption covers what you want to do. Check the details carefully. You need to be sure that you can always work within the limits and conditions and you will not cause pollution, nuisance or harm to human health.

Step 5 -  Follow the steps to Register your new waste exemption. We will provide confirmation of your registration after which you may start straight away. You can register several different exemptions at one place. Make sure you read the guidance on ‘place’ below.

Click here for the exemption table and when the changes are going to happen.

 There are four  main Waste exemption categories

• Treatment
• Disposal
• Storage

See net Regs for full details:

 http://www.environmentagency.gov.uk/business/topics/permitting/115492.aspx

Waste Management: BSI to look into reducing recycling and waste regulatory burdens

Mon, 22 Aug 2011

The British Standards Institution (BSI) is leading a project to see if a standardisation roadmap can be created that will reduce the regulatory burden on recycling and waste companies.

BSI will work with the Department for Environment, Food and Rural Affairs, Department of Business, Innovation and Skills, the Environment Agency, the United Kingdom Accreditation Service and Waste Watch as the first step to producing the roadmap.

This project team, will look to answer the following questions to work out what role standards should play in helping industry demonstrate compliance with the current permitting regime, such as Environmental Permitting Regulations, in an efficient manner:

• What standards exist that do and/or could support compliance with waste regulation and waste permits?
• What schemes already exist to support compliance with waste regulations and waste permits?
• What are the standards gaps?
• What standards could be developed to assist industry in demonstrating compliance with waste regulations and waste permits?
• How can standards further support waste regulation and enable industry to comply with it effectively and efficiently?
• How effective are the existing tools and mechanisms with regards to advising waste management permitting?
• What specific compliance issues faced by the industry can be resolved with the aid of standards?
• What cost savings and other benefits can be achieved according to industry?

BSI will undertake research to try to find out the answer s to these questions. This research will then be used to interact with individual industries across the wider waste management sector selected on the basis of agreed selection criteria such as amount of waste produced, amount of regulation in the sector and current usage of standards and certification.

The idea behind it is to see whether waste regulatory burdens can be reduced, identify which operations may be suitable for lighter touch regulation, promote adherence to standards as a means of providing a high degree of assurance of compliance with waste regulations and help the Environment Agency to focus on poor performance and illegal activity rather than on managed businesses.

Reported by scrap-ex.com

Business Innovation And Product Development

By Waste Or Sewage Businesses

 New and innovative technologies/products/processes or services might improve your business, and some ‘green’ technologies could benefit the environment, but before using these new technologies you need to consider all of the impacts that they might have on the environment.

 Examples of business and technological innovation include new:

•  Uses of waste
• Waste recycling or reprocessing activities
• Waste water treatment methods
• Approaches to cleaning up land contamination or water pollution
• Environmental and clean technologies
• Uses of chemistry and chemicals
• Uses of biotechnology or nanotechnology.

 Before investing any money in using innovative products/processes, you should get in contact with your environmental regulator as soon as you can so that they can give you any other advice. You must also ensure that you have all the correct permits/licenses and exemptions before you start any developments or trial activities.

 Using chemicals (REACH)

 If, within your business, you use or manufacture chemical substances, you must comply with the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), Regulation.

If you use a substance in an unusual way, then you should let your suppliers know the details about how you intend to use the chemical. However if you feel that this information will compromise your business, then you do not have to give the information, but you must carry out your own safety assessments and you must make sure that you provide the European Chemicals Agency (ECHA) with this information.

 Field trials and testing your new process or technology

 You will need approval from your environmental regulator to test/use any new process or technology that you might have developed. The environmental regulator will assess your new technology; however in some circumstances you might not need your environmental regulator’s permission for a trial run of your new product/process, but you should be careful as causing pollution is an offence for which you could be prosecuted.

 To make sure that you are fully prepared before your test trial you should:

• Contact your environmental regulator as early as possible
• Be ready to give all the information needed as quickly as possible, e.g. chemical descriptions of the product and past trials.

 To control air pollution you must have written authorization from your environmental regulator or local council if your tests are likely to cause emissions in the air.

 To prevent water pollution you must have permission from your environmental regulator before you release anything unclean into uncontaminated water, surface waters or ground waters.

If you are taking water from surface or ground waters then you will need an abstraction license unless you are taking water from a mains supply.

Duty of Care – Your Waste Responsibilities

 All the waste that is produced by your business or within your work place is regulated by waste laws. This means that you must make sure that you produce, store, transport and dispose of the waste that your business produces without it being hazardous to the environment. This process is called your Duty of Care.

 Examples of business waste are:

• Waste paper
• Empty printer cartridges
• Packaging and defective products from factories
• Scrap metal
• Old window frames from building sites.

 The Duty of Care applies to controlled waste, but there are types of waste that the Duty of Care does not cover:

• Radioactive materials
• Some animal-by products
• Explosive waste.

To ensure that you are complying with the Duty of Care you should

• Make sure that your waste is stored and transported securely and appropriately,
• Make sure your waste is being handled by people/businesses that are authorised to do so,
• Make sure you complete Waste Transfer Notes (WTNs) to keep a record of all the waste that you transfer. These notes should be kept for at least two years.

 The only people who are allowed to deal with your waste must have the correct permit, licence or exemption; they must also be a registered carrier and they should have a certificate of registration to prove this. The types of people that collect waste are

• Waste contractors
• Scrap metal merchants
• Recycling businesses
• Your local council
• Skip hire businesses.

If you transport your own waste then you can pass it on to Waste Transfer stations or Waste Treatment and Disposal Sites or recycling company.

 How waste is stored is very important as all waste has the potential to harm the environment.  When storing waste you should,

• Use suitable waste containers
• Separate the different types of waste
• Contain liquid wastes
• Protect waste from vandalism

You must get a duty of care form from anyone who deals with your waste.

See netregs for full details.

Environmental Permits

•  Environmental Permitting is a regime that controls the impact of business activities transfers that could affect human health or the environment.
• You must have an environmental Permit before you start operating a regulated facility.
• Environmental Permitting has enabled the combination of different permitting regimes.
• Some old permits have now been converted to environmental permits as well.

There are two types of permits; these are standard permits and bespoke permits.  Standard permits are cheaper, quicker and easier to apply for.

 Bespoke permits are more expensive and take longer to be issued. This type of permit contains site specific conditions and should be applied for if the operations run at your business are the following:

•  Not covered by standard rules or you do not want to apply for a standard permit
• Could have a high impact on the environment
• Are innovative or complex.

 If you already have more than one existing environmental permit then they can be combined into a consolidated permit. However these permits can only be consolidated if they are from the same regulator, have the same operator and cover.

 If you start operating a regulated facility before being issued a permit then you could face going to prison or a heavy fine. You should also check to find out if you will need any other license, registration or permit before setting up and operating your facility.

 To apply for an environmental permit, you must complete a form that is provided by your local environmental regulator. You can apply for a permit if you are the operator of a regulated facility. The cost of an application will depend on the nature of your facility and the amount of time an application will take to be processed will also depend on how complex it is and whether it needs public consultation.

Banned from landfill

All landfill sites must have licenses regulations are changing all the time so you must keep up with Environment Agency guide lines.

•  Pollution prevention and control (PCC permitting ) commenced                 6^th April 2008
•  Waste management licensing ( WML) commenced 6^th April 2008
•  Batteries directive commenced 5^th May 2009
• Mining waste Directive commenced 7^th July 2009

 Waste that has been banned from landfill.

• Used tyres
• Infectious clinical waste (from hospitals, medical or veterinary)
• Explosive (ammunition, gunpowder, flares, detonators.)
•  Corrosive (acid or alkaline sludge.)
•  Flammable with flash point of 55c(magnesium, phosphorus, alcohol or camphor)
• Oxidising (ammonium nitrate, potassium chlorate, potassium permanganate, sodium chlorate.

Future environmental permitting

•  Waste carriers & brokers registrations     Date expected   summer 2010
• Water discharge consent                                      Date expected  April  2010
• Groundwater authorisations                              Date expected April   2010
• Radioactive substances regulations                Date expected April   2010
• Water abstraction & impoundment licences  Date expected April 2011
• Revised waste exemptions                                  Date expected April 2010

 (See Netregs for further information)

Office Waste

What types of hazardous waste do you produce?

All business will produce some hazards office waste  

Example

• Fluorescent tubes, energy-saving light bulbs, sodium lamps,  
• Toner and ink jet cartridges from printers and photocopiers
•  Old computer monitors

Printing waste

Save Money by recycling or reusing your printer cartridges rather than disposing of them in landfill or incineration.

Cut your costs by recycling

• paper
• printer and photocopier cartridges
• solvents
• silver halides
• Cardboard and other packaging materials.

Items discarded from offices that are classed as waste.

• Catering waste, including used cooking oil, raw ingredients, waste food
• Paper, i.e.:  white and coloured paper, newspapers and magazines.
• Redundant office equipment, i.e.: computers, monitors, printers, mobile phones
• Packaging, i.e.:  cardboard, plastic, food packaging, cans, glass and plastic drink bottles
• Fluorescent light tubes
• Toner cartridges
• Building waste, i.e.:  from refurbishment or construction work.

You must Comply with proof of disposal with a Duty of Care for Waste

You must keep records of all transfers of your waste.

Use an authorized waste carrier Use E.A waste directory to check them out.

http://www2.environment-agency.gov.uk/epr/search.asp

If you do not check and keep proof of this you could be held responsible if your waste is disposed of illegally, for example by fly-tipping.

 Our Recommendation for cartridge disposal is

 Impact Inkjet & Toner Recycling Ltd

What they Offer

They offer a free collection

• Within the Kent and London area if you have 20+ Original cartridges to collect.
• Outside of these areas free collection on  200+ cartridges
• Deliver to their site.

Or why not use their free post service

• Free post for Inkjets & Mobile Phones only

See their website for further information www.impactrecycling.co.uk  or contact them 01634 255400

The government is revising the list of waste activities that are exempt from environmental permitting.

Draft regulations have been published and are expected to come into force on 6 April 2010

Who will the revised waste exemptions affect?

The new regulations will affect you if you:

• Operate a waste recycling, recovery or disposal business
• Currently operate under an exemption
• Operate under an EA low risk position.

If you have an environmental permit, you may find that you only need an exemption under the new regulations

Low Impact environmental activities,

If you carry out waste activities that are relatively low impact you may be exempt and you may need to:

• Register an exemption for an exempt waste operation

• Simple exemptions will need to be renewed every three years.

What is an exempt waste operation?

There are a range of waste activities that may be exempt from environmental permitting, including:

• Composting biodegradable waste for cultivating mushrooms
• Crushing, grinding or other size reduction of waste
• Cleaning or coating waste packaging, containers and textiles
• Storing waste securely
• Treating waste to recover materials
• Burning waste in an exempt incinerator at the place where the waste was produced
• Storing waste electrical and electronic equipment (WEEE) for recovery at another place.

Non-hazardous waste exemptions and hazardous waste exemptions have changed see EA website for further details.

Register your exemption

There are only two main types of exemptions.                                                  (simple exemptions & complex exemptions)

If your activity is exempt from permitting you may need to register it with the Environment Agency.

If you want to register a simple exemption you must complete notification form WMX00.

If you want to register a complex exemption you must complete a notification form for your specific exemption. For example, you must complete notification form WMX19 if you want to register an exemption for construction waste under paragraph 19.

Most complex exemptions must be renewed every year. If the risks are too high, the EA may refuse to register your activity as exempt and you will need to apply for an environmental permit.

Environmental permitting in the future

Environmental permitting is being extended to cover other existing permitting regimes in the future.

• Waste carriers & brokers registrations                Summer              2010
• Waste discharge consents                                       April                    2010
• Groundwater Authorizations                                 April                     2010
• Radioactive substances regulation                       April                     2010
• Water abstraction & impoundment licenses      April                     2011

It will also be used to put into effect new permitting requirements in future EU directives