Posted By Martin A Stear Dear colleagues Does anyone know the legal provisions for disposal of small containers that have contained chemicals (typically printing inks, solvents etc.). Maximum size of 5 litres, which have been drained into full containers, as far as possible. Can these containers, with residues, be disposed of as general waste or are there special requirements? Martin Martin Stear Workplace Environment Solutions Ltd 69 Manchester Rd Knutsford Cheshire WA16 0LX www.healthsafetyspecialists.co.uk 07789 276670

Posted By Thomas Kennedy There was a case reported a number of years back in the Environmental Business magazine (I think) . The article had the headline "when is empty, empty?". It concerned the EA (or the predecessor) when they tried to prosecute someone for failing to consign empty containers. The company had went to the same lengths as you (rinsing out etc) but there was still some residual contamination. The judge found the containers were nominally empty and that the special waste regs did not apply. Here's how. 1. Determine the risk phrases for your substance and the appropriate classification for the hazardous substance (i.e what makes it special?). 2. Each classification has a threshold expressed as a percentage - determine what this is for your substance. 3. Multiply this figure with the weight of the empty container. This will give you a threshold for the quantity of the solid or liquid in the container that makes it special. 3. Stay below this and your' outwith the regs. For example: Osmic Acid The substance has Risk phrases 26/27/28 and is rated very toxic (T+) . T+ equates to the special waste classification H3. The approriate threshold hee is >0.1%. Weight of empty container (for example 100 grams) X 0.1 = 10 ml. Thus a container weighing 100 grams and holding <10ml = nominally empty. 4. Remember you need to describe for duty of care purposes the containers as "nominally empty contaminated with .... " as they are of course not truly empty. 5. Last bit of advice is don't trust strangers! Run it by the Environment Agency and listen to their arguements, if any? Tommy