Compliance is not an option
July 01st 2008 Greg Bordiak, technical officer at BCAS looks at the Hazardous Waste regulations and how to comply
Of course I comply’, ‘I have a licence’, or ‘what registration to get rid of waste!’ Some typical responses to dealing with hazardous waste in the compressed air industry but the plain fact is that ignorance of the law is no defence.
Plain ignorance should not be an issue since the Environment Agency have provided many pieces of information on their website and in the form of information booklets. Having read the information the subsequent understanding may not necessarily end up with taking a cost effective route to satisfy the needs of the law.
As a provider of service and maintenance you may well be taking away a volume of oil from say a compressor. Are you aware of the Consignment Note required and the charge that goes with this to your customer levied by the Environment Agency? Also where is the oil taken to, perhaps your own ‘head quarters’, has your company got a licence to store this oil? If yes, then is the company aware that there is a possibility that if the right criteria are met then that storage on the company site could benefit from an exemption. The difference being that the site licence is at considerable cost and the exemption is free.
So I issue a Consignment Note, make a charge, my storage site has a licence or is exempt, and I use a licensed carrier to remove the bulk oil from time to time, so yes I comply.
That then means you also provide the customer with a quarterly report of the oil movement from collection from his site until final disposal….. or do you?
The Environmental Permitting (EP) Regulations came into force on 6 April 2008.
These regulations identify the charges to be made for the activities related to the Hazardous Waste Regulations. Have you checked to see if there are new forms required or charges to be paid or even exemptions you may benefit from or registrations to be made under these regulations so that you can still comply with and carry on legally in your business. Do you still comply?
For further information related to the Hazardous Waste Regulations and the compressed air industry contact BCAS, Greg Bordiak by email on greg@bcas.org.uk More articles from British Compressed Air Society: | 
