Paul Rendle-Barnes, group senior development manager at Avanti Environmental, looks at the changes that will come into play as regards packaging waste in a few weeks time thanks to the new WM3 guidance, while his colleague has some advice for all you waste producers… a CIWM Journal Online Exclusive
How businesses deal with their packaging waste is due to change soon. From 1 June 2015, the way waste will be assessed and classified in the UK changes significantly. Waste producers will need to comply with the revised guidance set out in WM3, the joint UK environmental regulators’ guidance on classification of hazardous waste.
The current guidance, “Hazardous waste: Interpretation of the definition and classification of hazardous waste (3rd Edition 2013)”, known as WM2 for short, is a comprehensive technical guidance document on the assessment and classification of hazardous waste. June sees WM2 updating to WM3. The forthcoming WM3 regulations will introduce new requirements as a result of several changes to the law including: amendments to the list of waste (or European Waste Catalogue), a major revision of hazardous properties and the adoption of the new systems of chemical classification (Source: www.gov.uk/government/publications/waste-classification-technical-guidance).
Packaging that cannot be proven to be free of any residue or contamination from a hazardous substance has to be classified and treated as hazardous waste. Under the new WM3 guidance, the framework for determining hazardous properties will change, meaning that some additional wastes may become hazardous. Anyone buying in products, will need to assess the hazardous properties of their waste packaging and will need to demonstrate a fully auditable trail of what happens to it.
But this doesn’t mean that companies will have to compromise on environmentally-friendly ways of dealing with their waste.
At Avanti, when we collect 1,000-litre intermediate bulk containers (IBCs)/flexible intermediate bulk containers (FIBCs), 205-litre and even 10-litre packaging containers, we decontaminate and process these via a “polymer separation” process. This polymer separation process means that the containers are decontaminated, washed and then reprocessed through the Avanti integrated recycling plants. The regulated process closes the loop and produces multiple grades of raw material that can be remanufactured into new bins, drums and even kerb stones.
Processes such as these undertaken by Avanti not only meet all regulatory compliance requirements, but also avoid the risk of fines or costly prosecutions. Additionally, by ensuring the waste is fully recovered and recycled into new products, this hugely contributes to sustainability and a company’s corporate social responsibilities.
Chartered Waste Manager, and Commercial Projects and Recalls Manager at Avanti, Chris Vasey, offers some advice to help waste producers: “Packaging just ‘being emptied’ doesn’t count. In order to be fully compliant with the new regulations, businesses will need to work with their waste management supplier to ensure:
- The premises from where waste is removed must be registered as a hazardous waste producer
- The waste packaging must be consigned correctly. Any packaging that has contained a hazardous product and has not been decontaminated by an approved method (with appropriate treatment of the decontamination residues), is to be automatically considered hazardous in nature, regardless of its weight or concentration of the hazardous substance originally contained in the packaging
- The site receiving the waste must have a suitable authorisation to receive that waste
- The site receiving the waste must send quarterly consignee returns for hazardous waste to the relevant regulating agency and waste producer.”