HOW TO DETERMINATE IF THE WASTES THAT ARE PRODUCED ARE DANGEROUS
Many companies ignore they are producing dangerous wastes and even those which are aware of the problem ignore the correct course of action for disposal and the consequences if these wastes are not properly disposed of.
IS IT POSSIBLE TO USE THE GREEN POINT SYSTEM WITH INDUSTRIAL CONTAINERS?
No. The Ecoembes organisation doesn ́t allow this. An option would be to create voluntarily a similar system following the requirements of the law.
WHO IS RESPONSIBLE FOR THE FINAL DISPOSAL OF INDUSTRIAL CONTAINERS AND WASTES?
The end user of the container. In the case of industrial or commercial containers, of all the various companies that are involved in the sales chain from the moment the product is first marketed to the buying, selling and distribution of the products, the responsibility for the proper transportation and disposal of the waste in accordance with the regulations, will be the end user of the product.
WHO MAY ACCEPT THE WASTE WASTE FOR PROCESSING AND DISPOSAL?
Only authorised companies,for its classification and ultimate disposal.
In all cases, the holder of the wastes will be obliged, while they are in his/her possesion, to maintain them in an adequate condition of safety and hygiene.
The containers that are nearly empty, but have wastes of solvents remaining are especially dangerous because of the risk of explosion if they come into contact with flame or heat.
Storage of the wastes should be in containers in well ventilated zones and which are not exposed to heat or sources of ignition whilst they are awaiting disposal.
Don ́t take wastes, cloths, gloves, etc., mixed with paints or oils to landfill sites or mix them with urban rubbish as this would cause hazards at landfill sites.
ARE ALL CONTAINERS THAT WERE ONCE USED FOR CHEMICAL PRODUCTS ALSO CONSIDERED DANGEROUS WASTES?
Not always, but to know whether it is considered dangerous waste or not, guidance should be taken from the European List of Wastes. Order MAM/304/2002.
They are only considered dangerous if the percentage in weight of dangerous substance in the container is enough for the waste to present one or more of the listed characteristics in Annex three of the directive 91/689/CEE (Explosive, Combustible, Flammable, Irritant, Harmful, Toxic, Carcinogenic, Corrosive, Infectious, Teratogenic, Mutagen and dangerous for the environment).
Order MAM/304/2002 of 8th of February annex 2 B): “Any waste classified as dangerous through a specific reference or generally dangerous substances should only be considered dangerous if the concentration of these substances (given as a percentage by weight) is enough for the waste to present one or more of the listed characteristics in annex three of the directive 91/689/CEE of the board”.
HOW IS THE CODING OF DANGEROUS WASTES CARRIED OUT?
To find out the code of each waste it is necessary to refer to Directive 91/689/CE and also to the Order MAM/304/2002 “European List of Wastes, procedures for classification and disposal of wastes”.
General characteristics of the labelling:
- Size of the label: 10 × 10 cm. (minimum).
- The label should be firmly fixed onto the can and it can be of the following types:
- Labelling material: paper (placed inside the container), laminated on the exterior.
- Labelling on the back: using adhesive labels.
No. Only specifically authorised companies for the handling and disposal of dangerous wastes within each of the autonomous counties.
WHAT ACTION CAN BE TAKEN AGAINST COMPANIES THAT DON ́T COMPLY WITH THE LAW IN THIS MATTER?
Fines and closure, among others.
In the majority of cases, the necessary information for the classification of chemical wastes is held by the waste producing company, but it may be that such information is not known or where it is availabe, or those responsible for such matters don ́t know how to use it.
In order to carry out the classification, three helpful tools are available:
- Safety data sheets for the products that have been used in the formation of the
- wastes.
- European list of wastes.
- Analytical description by external laboratories.
The best and most profitable for any company, is for the company itself to classify its own waste, although there are cases where this is not possible.
Never use drains or sewers to dump waste wastes, including chemicals soluble in water.
EXAMPLE OF DECLASSIFICATION OF A DANGEROUS WASTE:
Containers once holding solvents.
When consulting the European List of Wastes, a company in the process of classifying some containers that previously contained solvents, may encounter a dilemma as to what code to assign to the waste: 15 01 10 Metal containers
In principal they may be treated as contaminated metal containers, but it isn ́t always clear if they contain dangerous substances. The safety data sheet shows that this product contains dangerous substances and that leads us to believe that the container holds also this substance, though in smaller proportions. All this indicates it is a dangerous waste.
It is necessary to look at the hazard characteristics associated with each substance, to see if the H factor associated with this product falls within the established thresholds which are considered to be dangerous and this may show the waste to be present in quantities smaller than those established in the regulations and therefore not harmful.
To obtain information about the substance and it ́s respective dangers turn to section 3 in the data sheet where the following can be found about the components of the solvent.
Containers once emptied may keep impregnated solvent. This solvent normally evaporates within a few days, showing an empty inside, though some of the dangerous substances may still be left behind. Flammable substances (F= H3) evaporate leaving behind harmful substances (Xn= H5) and irritant substances (Xi= H4). The concentrations established in Order MAM/304/2002 are more restrictive for irritant substances, therefore will be the one to consider as a reference, as it is very difficult to estimate how much of each substance is left.
For the waste not to be considered harmful, the concentration must be less than 20% by weight, eg (the total weight of the container = the weight of the container + the weight of the substance).
According to information supplied by the manufacturer. the weight of an empty container is 500 grammes and the maximum quantity of irritant substances with the risk of R36 that could be contained is 100 grammes.
The weight of the empty solvent container, once dry is 525 grammes. As it contains 4.8% of irritant substances as a maximum, it follows that these 25 grammes of substance came from the solvent which is considered to be the total of the irritant substance. As the quantity of the irritant substance is less than 20%, the waste may be declassified and may be dealt with as non harmful waste.
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