We would like your views on the draft guidance document for the treatment and storage of aerosols and similar packaged wastes.
Start date: 22 December 2009
End date: 23 March 2010
Introduction
We have produced guidance for facilities that undertake the treatment and storage of aerosols and similar packaged wastes as an activity at an installation regulated under the IPPC Directive, as described in Part A(1) of Schedule 1 to the Environmental Permitting (England and Wales) Regulations. This guidance is an addendum to Sector Guidance Note S5.06, Guidance for the Recovery and Disposal of Hazardous and Non Hazardous Waste (S5.06), which provides guidance on indicative standards of operation and environmental performance for the wider waste treatment and storage industrial sector.
A consultation is required in this case because as a result of significant incidents we have produced new guidance, which sets out the indicative standards (what constitutes Best Available Techniques) for the storage and treatment of aerosol canisters and similar packaged wastes.
We are therefore seeking your views on this guidance to ensure that it is appropriate and provides you with the information you need in a clear and concise way.
How you can help
We welcome your comments on the draft guidance document, specifically whether the standards and measures in the guidance document are appropriate for the range of waste storage and treatment activities carried out on aerosol canisters and similar packaged wastes. If not, please specify which one(s) you consider not to be appropriate and why.
We would also value your views on the questions listed below:
1. Section 1.2 of the guidance document provides some examples of the EWC codes used to classify waste aerosols and similar packaged wastes (packaged wastes that, if heated, will become pressurised and present similar environmental hazards as aerosols). Are there any other waste codes that are commonly used to classify such wastes that should be referenced in the guidance as appropriate examples?
2. S5.06 currently requires the Operator to ensure that personnel involved in sampling, checking and analysis procedures are suitably qualified (HNC qualified chemist or higher). Do you agree that this requirement should also apply to personnel involved in checking waste aerosols and similar packaged wastes, which may include carrying out compatibility assessments of the residues collected from the treated canisters? If not, please explain why.
3. The principal objectives of this guidance are to promote techniques that minimise the likelihood and consequences of accidents, implement the waste hierarchy and minimise the use of raw materials and energy. Do you agree with these objectives and if so do you think that we have balanced them appropriately? If not, please explain why.
4. The guidance requires that all plant must be capable of collecting all of the gases released from the canisters during treatment, unless the site is taking only discharged canisters and it is not technically and economically viable to collect the gases so they can be recovered. Do you agree that these requirements are appropriate? If not, please explain why.
5. The guidance requires that canisters containing medicines are only treated using a process that ensures all released gases are collected to prevent dispersion into the environment. Do you agree that this is an appropriate requirement? If not, please explain why.
6. We have provided guidance on the type of containers that are suitable for the storage of canisters and recovered metal/collected residues onsite and have required the use of storage in cages or caged areas to prevent missiling of canisters in the event of fire. Do you agree that the guidance promotes a good balance between the requirements for the containment, inspection and, where necessary, ventilation of contents? Are you aware of any other storage containers or systems that should be reviewed or promoted in the guidance?
7. There are a large number of additional regulations and guidance documents regarding the storage (and transport) of aerosols. How do you feel this guidance ties in with the requirements made by other existing regulations and guidance (e.g. HSE guidance, DSEAR, regulations regarding the carriage of dangerous goods)? Do you think that the requirements of this guidance are consistent with and compliment these? If not, please inform us of any areas of concern.
8. As currently drafted, the guidance document only applies to the treatment and storage of aerosol canisters and similar packaged wastes as an activity subject to the requirements of the IPPC Directive. Do you think that the requirements of the guidance document should also be applied to facilities that are permitted to carry out waste operations under the Waste Framework Directive? If not please explain why, making reference to specific requirements of the guidance document where applicable.
9. Is there any additional information you feel that we should take account of in this guidance?
10. Finally, are there any other comments you wish to make regarding the content or presentation of the guidance document?
Consultation responses
Consultation responses should be sent to Peter Chesney by 23 March 2010:
We have no specified file format for responses in this case. However, we request that submissions are submitted in a separate document (not as tracked changes) and are able to be read by Microsoft Office or Adobe Acrobat.
If you wish your responses to remain confidential you should indicate this clearly.
