Legislation
The first part of the Hazardous Waste (England & Wales) Regulations 2005 came into force on 16th April 2005. The remainder of the regulations together with The List of Wastes (England) Regulations 2005 come into force on 16th July 2005. The regulations implement the European Commission Directive to control the management of wastes that appear on the hazardous list. The recent revision of this list has been incorporated into the European Waste Catalogue which defines all wastes by type. A number of wastes not previously considered to be hazardous, are now included. Some examples of these include; - fluorescent tubes (including UV tubes), televisions, computer monitors and scrap cars.
Registration as a hazardous waste producer
One of the significant changes to be introduced from 16th July 2005 is that, unless they are exempt, all premises where hazardous waste is produced will need to register with the Environment Agency.
Exempt premises are such as homes, shops, offices, farms, dental, veterinary or medical practices, ships, schools, prisons and charity premises, which produce less than 200kg of hazardous waste in any twelve month period.
Other businesses producing hazardous waste have a legal duty to register with the Agency. Pest control companies will be caught under this definition, if they generate hazardous waste. All premises registered will be given a unique registration number known as the "premises code".
The 200kg production limit only applies to exempted premises, It is not a generally applied to other premises.
How to register
The cheapest way to register is by completing forms on the Environment Agency website:
www.environment-agency.gov.uk/newrulesonwaste. Payment is by credit card and the charge is £18 per year. Registration is required before 16th July 2005.
One of the questions on the form concerns the S.I.C. (Standard Industry Code) covering the premise activity. For pest control companies, the relevant code is ("Pest Destruction Service [not agriculture]) 74.70/09." The Environment Agency has set up a help line on 08708 502858 to specifically answer questions on the premise registration topic.
Controlling hazardous waste generation
As stated above, pest controllers will need to register if they generate hazardous waste. However, not all waste created by pest controllers will be classed as hazardous, especially if proper control measures are implemented.
For example, empty packages which have contained a product which doesn't have a St.Andrews Cross, flame symbol or Skull and Crossbones, are unlikely to be hazardous although under COPR they must be emptied completely before being thrown away. If pesticide containers which do carry a hazard-classification symbol are completely emptied and triple rinsed, then they will cease to be classed as hazardous.
Customers of Killgerm Chemicals Ltd contracted to The Killgerm Controlled and Special Waste Disposal Scheme have access to advice, in the scheme booklet, which describes how good practice and controlled arrangements can reduce hazardous waste production.
Fluorescent tubes and aerosol containers
Fluorescent tubes and empty aerosol containers are classified as hazardous waste. The appropriate EWC six digit codes are:
| 20 01 21: |
fluorescent tubes and other mercury-containing waste; |
| 16 05 04: |
gases in pressure containers (including halons) containing dangerous substances (mirror entry). |
For pest control companies offering a service to customers which involves servicing EFK (electronic fly killers) or ILT (insect light traps) machines, then there may be a need to notify their premise as a hazardous waste producer.
Their customers would not need to be registered if they fell into the exempt descriptions e.g. offices, shops, agricultural premises, unless they produce more than 200kg of hazardous waste.
For reference, 200kg of fluorescent tubes equates individually to 1,400 Circline tubes; 2,400 Straight 18_ 15w tubes; or 1,063 Straight 2_ 40w tubes.
The pest control company itself would need to register regardless of quantity collected. Where the EFK/ILT servicing agreement between the customer and the pest control company stipulates that the fluorescent tubes are owned by the pest control company, then those tubes would not be included in their customers' assessment of whether or not they qualified as a hazardous waste producer.
The need or otherwise for the pest control company to hold a waste carrier's licence would also be addressed during these considerations.
Empty, intact aerosol containers which have held hazard classified formulations would be classified as hazardous waste and the pest control company would need to register their premise where this waste is stored.
Killgerm can provide information to assist its customers - contact them on 01924 268400 or e-mail .