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Posted By Hugh J O'Neill Question ref hazardous waste, transport and the DGSA regulations. I understand that the application of DGSA regs. will tighten up in the New Year to include smaller vehicles of 35 cwt or less. Hazardous wastes such as computer monitors, fridges and freezers aready have mechanisms in place to document and describe them i.e. the EWC (European Waste Catalogue) codes. Can anyone enlighten me what I might have to do if transporting such wastes in these smaller vehicles. The following sites give good info (lots) but I'm afraid I'm none the wiser. I can see the need for a ADR/DGSA advisor but I'd like some hints before talking to one. Any general info and advice gladly accepted. http://www.unece.org/tra...adr2005/05ContentsE.html http://www.hse.gov.uk/cd...s/carriagemanual2006.pdfThanks Hugh.
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Posted By Chris Packham
Try contacting the Chemical Hazard Communication Society (CHCS.org.uk)
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Posted By Hugh J O'Neill
Chris - will do, thanks for the info.
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Posted By Mike Palfrey
As far as I know, ADR, DGSA and other assorted "Transport of dangerous goods regulations" does not apply to the type of material you are transporting.
The quick test is; can you find a UN number for the goods in the ADR book?
If not, then the Regs do not apply.
Does the van that delivers this stuff when new have Orange Plates and an ADR trained driver? Why should it be more hazardous now it is "scrap"?
Regards
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Posted By Hugh J O'Neill
Mike, The picture is becoming clearer....thanks for offering an explanation and useful rules.
Cheers
Hugh
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Posted By Mick154
Explanation of the new legislation that comes into effect on 1/1/2007
At present, drivers of vans and light vehicles under 3 ½ tonnes do not require an ADR certificate to carry hazardous goods.
All hazardous goods can be carried in 3 ½ tonne vans and light goods vehicles, without much regulation provided that the goods are packaged and marked under limited quantity regulations and within certain load threshold limits.
However as from 1st January 2007, drivers of all vans and light goods vehicles carrying hazardous goods over limited quantities and over threshold limits must have the relevant ADR certificate – ADR Volume ll, 8.2.
Your goods for transport in the intended form I,e a fridges and freezers are fridges and freezers. Until you do something with them like cut them open take out the bits and segregate the recyclables from the hazardous parts then go to volume I part 3,chapter 3 of ADR look through the list at table A (dangerous goods list) see if a description is there, if it is then you carry under ADR, but some waste are not classified individually with a UN number you the have to look through the European waste catalogue or UK waste list to find a match, then it may be more apparent which way to transport
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Posted By Hugh J O'Neill
Mick,
Thanks...the picture is certainly getting less hazy.
I suppose I started from a 'enviromental' viewpoint and immediately assumed (wrongly) that all hazardous waste would be dangerous because ODS (Ozone Depleting Substances) and contain ingredients that can harm the environment and may harm human health.
That plus the inclusion of the asterisk on EWC (European Waste Catalogue) code made me think haz. waste requiring extra controls and risk assessment. I can see from your explanation: providing a fridge remains a fridge then there should be no real problem as far as ADR goes. It would just be a waste issue.
I've had a quick scan through the list of dangerous materials and see certain Clinical Wastes would certainly be both hazardous & dangerous. I'm not in the clinical waste business so that's not a concern for me.
I wonder how many businesses are, and could be blind to this possibility when the 2007 regs kick in? For example I see smaller NHS trust vans running around and no doubt some will be carrying clinical wastes. Will these guys be compliant from Jan 1 2007?
This could be an interesting item for someone to write up, with good practical examples,and to provide to ISOH as an article to be included in the SHP magazine?
Many thanks.
Hugh
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Posted By Mick154 if i can help at any time contact me as long as i dont have to work its free, 30 years transport (All tankers hazardous goods), 6 years dgsa, in and out of waste last 5years oxo@mick154.feeserve.co.uk
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Posted By Hugh J O'Neill
Mick,
Thanks.
We were just in the process of getting a 35 cwt van and thought DGSA might have stopped us dead in our tracks for 2007. However from what your saying (and others too), as well as what theRegs say I'm happier that we would only have to worry about larger quantities of batteries (say 500+
kgs). We are unlikely to go above these levels now and the near future. Above this weight we would call in a more specialist transport / waste transport company to make the collection/move.
Don't go away....I'm sure there are some more questions just round the corner on this and related items.
Many thanks -Hugh
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