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Posted By Debbie S
I have been asked by our operations director for some information regarding the transportation of fridges / freezers (White Goods). We have been asked to collect some shop soiled goods (dented doors/ body panels) and return them to the manufacturer. One of our depot managers is saying that we cannot move them as they still contain CFC gas and that this falls into Controlled Waste Regs!! The CFC in them is intact
We do move hazardous goods and have an appointed DGM and am waiting for an answer from him.
Can anybody shed some light on this please.
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Posted By J Knight
Hi Debbie,
this comes under the s34 Environment Act Duty of Care to Waste. Fridges are indeed hazardous waste, and in any event are controlled waste, and you do need a licence to move controlled. I don't know how or whether your DGSA stuff affects this; check it all out on the environment agency website (www.environment-agency.gov.uk I think) or look for the duty of care on netregs www.netregs.gov.uk. It might be easier to get a licenced contractor to shift them for you, but read the Duty of Care in any event,
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Posted By Robert K Lewis
If the fridges are to be returned to the manufacturer for repair they are not waste according to the definitions, at least as I understand them. There would be a clear intention to refurbich the damaged panels and sell the item via a retail outlet. The task is not any different from the delivery of new fridges.
If they are being taken to a licensed disposal site they do indeed become hazardous waste and the requirements for these movements have to be followed.
Bob
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Posted By J Knight
Bob's quite right, I should read the posts properly before replying. Waste is defined as ‘any substance or object which the producer or the person in possession of it discards or intends or is required to discard’. This is further refined by answering the question ‘Has the substance or object been discarded so that it is no longer part of the normal commercial cycle or chain of utility?’. Return for repair would not make it waste, return for disposal though would,
John
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Posted By Stupendous Man
Would agree with Robert, these are not waste items.
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Posted By Jonathan Breeze
Not part of the oringinal question, but...
What about return of second hand items for refurbishment and use by another user?
Enquiring minds would like to know.
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Posted By Debbie S
Many thanks for your help. I have had a look at the netregs website -very easy to follow. Have now got it saved as a favourite.
I can see that I need to go back to the manufacturer for more detailed information about their 'end intentions' before I can even think about transporting them.
Mind you I could suggest to my operations director that we apply to become a registered carrier.
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Posted By J Knight
Hi Jonathon,
If you're doing this as part of a Charity (as we are) you can apply for exemption (which we have just done),
John
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Posted By Bill Parkinson
Debbie
You will still need to be careful with regards to carriage of dangerous goods and they will have to be transported in accordance with the regs. You should consult with a DGSA regarding the requirements as their may be some exemptions but if the full requirements are required then you will run into problems (such as drivers fully trained etc.).
Some of this maybe resolved when the WEEE regulations come out but these have been delayed because of conflict with the Hazardous Waste Regulations. There is still some clarification as to whether returning them to the manufacturer would be regarded as waste from the producer especially if they are not to be returned back to you (as effectively they are waste to you). The government in its haste to avoid action from the EEC for non implementation of directives did not heed the issues raised some years ago regarding this hence the mess we are in.
Where we dispose of fridges then we have an organisation that comes and removes the refrigerant before transporting to disposal site as if there is a link during transport a liability issue can arise.
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