UK Environmental and Recycling Legislation

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The legislation regarding the disposal of Electrical and Electronic equipment is very clear. By contrast, the recycling of hardware is heavily legislated. In order to simplify and help our clients comply with the law, we have produced the following guide.

Terminology:

Waste is defined as anything that is thrown away. By using a licensed waste carrier, a company, organisation or entity is stating that any goods removed from premises are waste, irrespective of age or condition.

Hazardous Waste: Anything removed by a licenced waste carrier that contains hazardous components. Waste ICT goods deemed hazardous include: All Computer Monitors (TFT & CRT), Laptops, scanners, Universal Power Supplies, photocopiers, all-in-one printers. White Goods Deemed hazardous include: All forms of Television, fridges and freezers. Condition and functionality of these goods is irrespective.

Recycling is defined in the WEEE directive as the process of re-use as well as resource extraction by a licensed facility.

WEEE: Waste Electrical and Electronic Equipment, as derived from the WEEE directive, an EU directive, transcribed into UK legislation after being passed by Parliament in 2007.

EWC: European Waste Catalogue, defining types of wastes from all forms of industry and households. Each type of waste is defined by a six digit number, broken down into 3 groups of 2. An asterisk to the right of the number defined the waste as being hazardous. e.g.: Computer Monitors= 16 02 14*

Complying with the Law:

Loop-holes exist within the WEEE/ e-waste recycling industry within the UK. These are perceived by many 'recyclers' as being legal loopholes. However, the Duty of Care commences with the definition of Waste, hazardous waste and recycling (see above). These loopholes include:

Section 40 & 50 exemptions: Many WEEE recyclers operate under section 40 and 50 exemptions. These exemptions, which form paragraph 40 and 50 of the WEEE directive, permit the repair and refurbishment (section 40) and storage of up to 80 cubic meters of WEEE (section 50). The disassembly of equipment for the purpose of segregating materials is not permitted under such exemptions. Repair and refurbishment simply means re-use of the whole unit in it's original form. Check the license held by any recycler. If in doubt call the Environment Agency.
Export of hazardous e-waste: The practises of exporting working, redundant Computer equipment to developing countries remains a hot topic throughout the recycling industry. Environment Agency guidelines state that waste is waste and the European Waste Catalogue defines Hazardous Wastes very clearly. However, this legal loophole is exploited as a means to export non-working equipment and it is thought that thousands of container loads of equipment are leaving the UK every year. The Basel Convention, an agreement between all western countries was designed to prevent the transcontinental shipment of Hazardous e-waste but has had little effect. Ask to know where down-stream wastes end-up. They should all go to registered treatment facilities.
Transport of Hazardous WEEE: When collecting WEEE, a licensed waste carrier may only be used. Third parties nominated for transport by a recycling facility must be able to demonstrate that they hold a Waste Carrier license. The transportation of hazardous wastes of any form are prohibited within the UK unless accompanied by a Hazardous Waste Consignment Notice. The notice ensures compliance with ADR (European Agreement Concerning the International Carriage of Dangerous Goods by Road). The form must list the wastes and relevant EWC and UN classifications. It must be be signed, dated and the time added by the consignor (person disposing of the waste) at the time of loading. It must then be counter-signed by the consignee (person collecting the waste). If the form is not available, under no circumstances let the wastes leave your premises as any Duty of Care (and any prosecution) remains with the consignor.

Full licensing for any recycling company includes the purchase of an Environment Agency permit in a relevant area of expertise, whether that be WEEE, scrap metals, plastics etc. Licensing is only granted after planning permission has been obtained and must be followed by the training and examination of nominated employees by WAMITAB (Waste Management Industry training and Advisory Board).

ATF and AATF: WEEE Recycling Companies must be licensed as an ATF (section 23 Authorised Treatment Facility) and AATF (Approved authorised treatment facility). The former may recycle any WEEE as long as it does not contain Ozone depleting substances. An AATF has the added benefit of being able to issue evidence (notices describing quantities) to the European Union. They may not however collect equipment unless licensed as a waste carrier.

Responsibilities of our Clients:

Clients that produce in excess of 500 kilograms hazardous waste in any 12 month period must register with the Environment Agency as a Hazardous Waste Producer. Registration for the production of hazardous waste costs £18.00 online and provides a "premises code" for the building/ property from which hazardous wastes are to be removed.

Clients are required to counter-sign Duty of Care and Hazardous Waste notices produced by our drivers at the time of loading.

Responsibilities of IT-Green:

IT-Green collects redundant and obsolete I.T related hardware nominated by it's clients for recycling. Our service does not sub-contract the collection or transportation of goods from client's premises and instead maintains a fleet of vehicles, operated under our own waste carrier license.

As part of a collection, employees of IT-Green will load vehicles in line with Health and Safety requirements. Drivers are issued with generic method statements and risk assessments pertaining to their day to day work. Vehicles will not be loaded beyond their legal weight limit. During the loading process, all equipment you have nominated for recycling shall be labeled with your contract number.

All Drivers are issued with relevant legislative notifications. These include: Duty of care notices for non-hazardous waste and hazardous waste consignment notices for all waste deemed to be hazardous to health (as specified in the European Waste Catalogue). Our Drivers shall, wherever possible, advise you with regard to registration as a hazardous waste producer.

IT-Green operates an Authorised treatment Facility (ATF) and it's employees hold relevant training in Waste Management, transportation, logistics and IT.

IT-Green maintains an in-house Environmental Management System, derived from BS8555 and relevant to it's field of expertise. It's services are designed to ensure it's clients maintain continued compliance to relevant QA systems.

Data destruction:

Where our data destruction service has been requested, employees shall remove storage devices from your redundant hardware and batch process said devices within 2 working weeks after the collection date. Storage devices shall be subjected to the agreed data destruction method, after which a certificate will be produced. The certificate will contain details relating to: the base computer system make and model, drive type, unique serial numbers relating to the storage device and model number. All employees are skilled in the management of confidential waste and this is reflected in our zero incident rate.