Where are you in the waste hierarchy?

Does your lab comply with the latest changes in the Waste Framework Directive?

Implementation of the revised Waste Framework Directive has brought some changes to the Hazardous Waste Regulations. These changes have been brought in by the Waste (England and Wales) Regulations 2011 and the Waste (Miscellaneous Provisions) (Wales) 2011 Regulations.

The most noticeable change is that from the 1^st October 2011, a new statement must be added to the Consignor’s Certificate of all waste transfer notes including Part D of the Hazardous Waste Regulations 2005: Consignment Note. This reads: “I confirm that I have fulfilled my duty to apply the waste hierarchy as required by Regulation 12 of the Waste (England & Wales) Regulations 2011”.

In practice what this means is that as a waste producer, you are required to take advice, consider, and document your processes to show how you deal with your waste in the order;

1. Prevention;
2. Preparing for re-use;
3. Recycling;
4. Other recovery (for example, energy recovery);
5. Disposal.

Prevention at the top of the list is down to good practice. Good inventory management helps prevent over-ordering, and the use of a supplier that delivers on their own vehicles helps to reduce packaging. Modern analytical and test instrumentation and methods often use smaller volumes of material, and investment in the very latest techniques does not just benefit the environment – less waste means reduced costs per test.

Stages two and three in the Waste Hierarchy have been common practice in non-hazardous waste for some time, with the separation of easy to recover materials such as glass, cardboard, paper, plastic, metals, and wood already being well advanced. Many large waste producers already use balers and compactors to compress their non-hazardous waste into bales that they get paid for. Putting aside legal and moral obligations, with commodity prices having enjoyed a sustained period of high prices, and landfill prices increasing, segregation and preparation makes sound economic sense when the revenue gained is added to disposal savings. Smaller producers commonly have separate collections of recoverables either in wheeled bins dedicated to a single stream, or in co-recycling bins where recyclable materials are mixed in a single bin for separation at a MRF (Maximum Recovery Facility). The laboratory sector is particularly fortunate in that many of the better known suppliers of chemicals and consumables offer free collections of recyclable materials including rinsed primary and secondary chemical packaging, pipette tip boxes, temperature control packaging (polystyrene shippers), and drums.

Whilst most companies and organisations and their employees are keen to meet their responsibilities in relation to green issues, and have already made great in-roads with non-hazardous waste, how many consider fully the best environmental option for materials once they leave site, particularly with those materials most likely to be environmentally harmful – hazardous waste?

Most continuously review onward disposal routes and methods when volumes are large and regular, and therefore cost and environmental impacts are significant, but for the typical laboratory where waste streams are likely to be sporadic, varied, and in small quantity it is impossible to consider every item of waste, particularly on a one-off clearance of old, out of date, or redundant laboratory reagents in small packs.

Sadly, because sorting waste is labour-intensive many disposal companies will just send “lab smalls” directly to high temperature incineration. Whilst robust rules on emissions and comprehensive vapour scrubbing ensure that no harmful gases reach the atmosphere, and there is therefore no environmental damage, precious recoverable resources are lost.

The selection of the right disposal company or contractor is therefore a very positive step in meeting the new Waste Hierarchy obligations, with the better ones continually increasing the proportions recovered. Where a waste chemical by a process of accumulation or bulking with similar materials from other laboratories can be turned into a resource, there are benefits not just to the environment, but also in cost. The selection of a hazardous waste transfer station like Labwaste Ltd that specialises in the complexities of laboratory derived wastes that is licensed to receive a wide variety of materials for sorting even tiny quantities for recovery or re-use is paramount. If a Licensed Waste Carrier is used, then it is prudent to select one that transports your waste to a similar facility where recoverables can be extracted. A specialist transfer station will;

1. Bulk virgin solvents for re-use;
2. Blend flammable liquids for alternate fuel use in power stations and cement kilns;
3. Recover metals from metal salts;
4. Bulk mercury for onward re-distillation;
5. Pre-treat and recycle primary chemical packaging;
6. Recycle Waste Electronic & Electrical Equipment (WEEE);
7. Accumulate for re-sale high value salts and solutions;
8. Recycle Plastics, Metals, Wood, Cardboard, and Paper;
9. Recycle Batteries & Aerosols;
10. Recycle Fluorescent Tubes and Mercury containing lamps;
11. Re-use drums and containers.

Even then, not all Transfer Stations are alike: many at the industrial scale consider the small quantities of mixed hazardous waste derived from laboratories to be uneconomic to recover.

The performance of your chosen contractor can be easily monitored by studying the detail of the waste return provided after disposal – an “R” code in the column marked Waste Management Operation means that your waste was recovered: A “D” code signifies that it went for disposal. Whilst there will always be some materials that are unrecoverable, current incentives make it economically viable to recover an ever increasing range of materials, with the best hazardous waste disposal companies like Labwaste achieving recovery rates in excess of 75% by weight.

For many there are some very simple gains to be had. Producers of Clinical, Biological, and Offensive Wastes should consider sending their waste to a waste-to-energy incinerator where electricity and/or steam are generated from the calorific value of the materials burnt. This gives an “R” code on your disposal documents that sending your waste to a standard incinerator or alternate treatment plant would not. With modern disposable plastics, waste properly used can be a useful energy source that could otherwise end up in landfill if alternate treatment is used.

Responsible companies should also be aware of “greenwashing”. Many suppliers use green issues as a marketing tool without considering the overall environmental impact of their recycling and recovery initiatives. Clearly there is no environmental benefit in recycling if the energy used in the collection, treatment, and recovery processes outweigh the energy saved by recycling. The exporting of waste, and complex chemical recoveries should be avoided.

The Duty of Care applies to all, and the responsibility does not pass to the disposal contractor on collection. It is now a legal, and not just a moral obligation to ensure your waste is as high up the hierarchy as possible.

The author: Bob Hilliard Bob is a director at Labwaste where he is responsible for devising innovative and novel re-use and recycling routes for hazardous and difficult wastes from laboratories