The disposal of WEEE at The University of Manchester

Combining the strengths of UMIST andThe Victoria University of Manchester

Waste Co-ordinator

• Simon Atkinson

• Joined Uni. in Jan 2007

• Previously employed with Environment Agency (for 11 years)

• Last 7 years spent in waste regulation

• Work in ESU (part of Estates Directorate) at U o M

Combining the strengths of UMIST andThe Victoria University of Manchester

Overview

• Things to avoid• What we should be doing• Duty of Care checks• Examples of non-compliance• Enforcement• EA Audit• Key waste streams• The future• Is it hazardous?• Is it waste?

Things to avoid!

What we should be doing

• Separate collection of WEEE • Should store WEEE in a manner that does

not prevent re-use/recovery• Dispose of to an ATF/AATF (via a PCS or

directly)• Comply with s34 EPA Duty of Care &

Hazardous Waste Regs. 2005• Setting up systems/procedures to ensure

above

D.o.C. Checks (1)

• Only use a registered waste carrier– Should have a reg. no. and be valid

• Can search on EA website at http://www2.environment-agency.gov.uk/epr/search.asp?type=register

• Is it being taken by a PCS? http://www.dti.gov.uk/innovation/sustainability/weee/page30269.html

Waste Carrier check

Waste Carrier details

D.o.C. checks (2)

• Check to see whether site/operator has a “permit” from the EA– Does it have a PPC Permit, WML or an exemption

(e.g. para. 50 exemption for storage of fridges)

• Is the site an ATF/AATF? http://www.dti.gov.uk/innovation/sustainability/weee/page30269.html

• Ensure the site is permitted to accept that specific waste type

• Obtain a copy of the permit from the EA

Permit check

Permit details

D.o.C. Checks (3)

• Keep copy of waste transfer note for 2 years• Keep copy of Hazardous Waste Consignment

Note for 3 years• Ensure you keep a “Register” of Hazardous

waste movements (i.e. copy of consignment note and “consignee return”)

• If bulk up items at a central location, then may need to register this activity as a para. 50 exemption http://www.environment-agency.gov.uk/subjects/waste/1416460/1334460/1329426/1737529/1737616/?version=1&lang=_e

Examples of non-compliance

• WEEE being carried by general waste contractors to a local transfer station– Site had a w.m.licence but not permitted to take any

WEEE

• Waste fridges/freezers being removed by W & S Recycling being taken to a site in Derby that did not have a licence/exemption & under investigation by the EA at the time

Enforcement

• EA position on enforcement see http://www.environment-

agency.gov.uk/business/1745440/444663/1106248/?lang=_e

• Doesn’t really cover producers of WEEE• “Will not interfere with legitimate trade in second-

hand or re-furbished goods”• EA have teams that carry out hazardous waste

audits of businesses• Current priority is WEEE, particularly IT

equipment that is potentially being “disposed of” abroad

EA Audit @ UoM

• Looked at disposal of all major WEEE streams– Checked registered carrier info– Checked destination– Checked transfer notes– Looked at internal procedures

• Particular attention on disposal of IT Waste– Checked Hazardous Waste Consignment

Notes/register

• Also looked at storage arrangements

Key waste streams (1)

Fluorescent tubes• Disposed of by Mercury

Recycling through Recolight (PCS)

• PPC Permit for site, registered carriers, use Haz. Waste notes etc

• Supply containers FOC. (these registered as a para.50 exemption)

• Still some inappropriate storage though

Key waste streams (2)

IT related WEEE• Disposed of to CDL Ltd.• Mixture of non/working items therefore

all goes as “waste”• CDL have a w.m. licence and are registered

AATF• Use Haz. Waste notes for CRT monitors (stored separately

prior to disposal)• Items that cannot be re-furbished sent to local treatment

plant run by SIMS Group (has a w.m. licence) – only 1% of waste goes to landfill

• CDL provide Asset Inventory reports that details each individual item

Key waste streams (3)

Fridges/freezers• STARS use a waste broker to arrange collection from Halls on a

carrier round & to fill in paperwork – disposed of to W&S Recycling

• W&S dispose of to a number of sites across the country- (makes compliance more difficult)

• Main Campus using general waste contractor – Disposed of to SIMS Group

• Need to keep register of Haz. Waste movements

• EA audit – Not always receiving consignee returns from W&S (i.e. consignment note with Part E filled in)

Key waste streams (4)

Electrical Items

• Collected by CCU on request

• Bulked up in a skip & carried to local treatment plant by general waste contractor

• Have separate storage available for hazardous items (TV’s with c.r.t.’s)

In the future?

• Produce less waste –particularly IT related WEEE & also less packaging?

• Do we keep inventory of items to return to producer – discuss with procurement?(http://195.92.246.148/knowledge_network/documents/HTM_07_05_Exec_summ_20070718111931.pdf )

– Formalise disposal arrangements in contracts– Obtain details of Producer Compliance

Scheme registration

Is it Hazardous ?

• Little guidance on what is/not hazardous WEEE http://www.defra.gov.uk/environment/waste/topics/electrical/pdf/weee-

hazwastebrief-july06.pdf

Hazardous

Fluorescent tubes, sodium lamps

CRT monitors and TV’s

Fridges/freezers

LCD Monitors???

Are LCD monitors hazardous?

• Most LCD’s (including thin film transistor screens) have fluorescent tube back lights. These will contain mercury and are identified as hazardous components by virtue of EWC entry 20 01 21*

• Where a monitor contains a fluorescent tube backlight it will be hazardous

• New technology is emerging using emitting diode backlights. These are currently very limited in use and unless evidence is presented to the contrary, it should be assumed that any backlight in LCD screens is a fluorescent tube

Is it waste?

• EA FAQ’s Document “Fully functioning EEE (even if second hand) is

unlikely to be waste, it can be freely traded on the international market.” http://www.environment-agency.gov.uk/business/1745440/444663/1106248/1622041/1106527/?version=1&lang=_e

• DoH Technical Memorandum “If EEE is sold to a second user as working serviceable equipment, it is not classed as WEEE”.

• Local EA advice: mixed loads of equipment some working, some not, then whole consignment IS waste. If you can separate out working items for sale/donation then these may not be waste

• Guidance referred to in EA briefing Note on Enforcement, “ not waste if fully functioning…..and is directly reused for the purpose for which it was originally intended….”

http://ec.europa.eu/environment/waste/shipments/pdf/correspondents_guidelines.pdf

Any questions ?

Combining the strengths of UMIST andThe Victoria University of Manchester

Contact Details

Simon AtkinsonWaste Co-ordinator

University of Manchester

Telephone: 0161 306 5963

Email: simon.atkinson@manchester.ac.uk

Combining the strengths of UMIST andThe Victoria University of Manchester