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Posted By tom johns
Hi
can anyone help
If Artex containing asbestos is worked on i.e Drilling holes (non licensed)for light fittings using PPE and a H vac would the waste i.e. overalls,disposable mask etc put in a bag be less than 0.1 waste and not be classed as hazardous waste.
Bearing in mind the bulk of the waste would be in the vac.
If not would i need a carriers license to transport it?
How and where do i apply for one.
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Posted By jervis
Not sure but i would think you would have to go through borough council !
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Posted By Robert K Lewis
The figure is 0.01%w/w as asbestos fibre. You will need to do the calculations. The HSE regard applied artex to be around 2%w/w asbestos. If you are below the 0.01% the waste can be treated as non contaminated and enter the normal waste stream for the material it is mixed with.
Do not however try deliberate dilution as the Env. Agency look on this very dimly. You will need either the DoC transfer Note or the Consignment note as applicable.
Bob
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Posted By Cas
Tom
From HSG248 -
"The Environmental Protection
Act classifies construction and demolition waste as 'controlled waste' of which there are two types:
Special waste: waste that contains 0.1 % (w/w) or more asbestos
non-special waste: waste containing up to 0.1% (w/w)asbestos.
All movements of special waste must be consigned in accordance with the requirements of the Special Waste Regulations 1996."
A couple of suits used in the manner described and carefully removed and double wrapped in polythene bags could be placed in a general builders waste skip and would be classed as non-special waste, no carriers licence required.
I wouldnt use asbestos waste sacks in this instance as this may cause unnecessary alarm somewhere along the line.
Couldn't you dispose of the suits along with the contents of the vac? Once full the vac will need to be emptied within an enclosure under negative pressure, to cut along story short this must be done by a licenced asbestos contractor.
(w/w) stands for 'weight for weight' in case you didn't know.
Hope this helps
Cas
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Posted By tom johns
Thanks for the info
Bob
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Posted By tom johns
Thanks Cas
We hire the H vac so dont have to empty it I think I might apply for a carriers licence and safely store the bags an ask a removal contractor to dispose of for me.
Could you guide me to a link to get a carriers license I have looked but i'm not sure
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Posted By Cas
Tom
Tom
You could be opening a can of worms. The following is from the Control of Asbestos Regulations:
“Bags, wrapping or packaging containing asbestos waste should be
appropriately labelled and transported to a licensed disposal site in an enclosed
vehicle, skip or freight container. A receptacle should be used to transport the
asbestos waste that ensures that the bags, wrapping and packaging cannot become
damaged or otherwise opened in a way that may release asbestos material or
asbestos fibres. The specific requirements of various Hazardous Waste Regulations
in England and Wales and the Special Waste Regulations in Scotland should be
adhered to, as appropriate.”
You need a carriers licence
You need a sealed container
You need to have a licence to hold asbestos waste on your site and a sealed container to hold it in and an asbestos management plan to demonstrate you are controlling the waste etc..
Seems like a lot of hassle for the odd couple of suits.
Sorry cant help with the carriers licence side of things.
Cas
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Posted By Robert K Lewis
Cas
Apologies 0.1%w/w it is, as clarified in EA document HWR01. However the Special Waste Regulations are superseded by the Hazardous Waste Regulations.
There is a duty in these regulations to separate where possible therefore mixing should not deliberately occur. Thus to put the vacuum residue in with the PPE etc would be regarded as a direct breach of this duty.
Bob
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Posted By graeme12345
TJ, is this is a one off and for what you have, I advise no, although others will state you have to jump through this hoop and cross that "i"
But if you are doing this daily / weekly then you should have good SSoW for your procedures and employees.
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Posted By Dave Wilson
Not quite correct.
If you look in the EWC waste booklet Contaminated overalls and filters, rags etc have its own code 15 02 02 with an asterix and therefore are 'Hazardous Waste' and must be treated accordingly. Ie Hazardous Waste Regs apply there would not be enough of these for the CDG and ADR to apply
If you want to register as a 'Waste carrier' (this is not a waste licence) then the EA website
http://www.environment-a...75883/?version=1&lang=_e
costs about &85 for 5 years I think
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Posted By Dave Wilson
Interestingly the HSE have launched it new Asbestos Awareness campaign today and it says on there that overalls etc must be disposed off in special asbestos waste bags and disposed of at a proper land fill
Check it out
http://hse.gov.uk/asbestos/hiddenkiller/index.htm
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Posted By tom johns
Thanks for the info guys
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Posted By Cas
Gents
Thanks for the input, asbestos is an area I am interested in but I am unfamiliar with the documents you (Bob & Dave) are referring to, would it be possible for you to explain what RA HWR01 is as well as acronyms EWC CDG and ADR. Also, what legal standing do these have?
Bob I respect your opinion but I don’t see why the suits can’t be disposed of along with the contents of the vac, surely this would be the ideal way to get rid of them?
This is a useful thread but I am still unclear on what exactly what should be done with said suits.
Can I put to you another way – if I carry out an occasional asbestos survey and am left with a used suit, wet wipes, maybe a filter from my mask and such like, can I wrap it and put it in a skip??
Dave, you have a wealth of knowledge in this area and I would value your comments.
Best Regards
Cas
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Posted By Robert K Lewis
Cas
HWR01 is the number of the DEfRA guidance note number for the Hazardous Waste Regulations. It is explicitly stated in this document and in the regulations that mixing of higher risk waste, eg vacuum dust, with lower risk, eg lightly contaminated overalls, is not permissible. The logic is that the dust is likely to have greater than 0.1% w/w of asbestos although the actual finite weight is lower.
The exemption for ACM to be sent to Monocell landfill rather than hazardous waste sites only refers to ACM with asbestos firmly bound in the matrix - by definition almost, coveralls will have dust on the surface ie not firmly bound, hence free asbestos fibres are foreseeable.
Bob
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Posted By Robert K Lewis
Cas
Ps
EWC is the European Waste Catalogue and is enforced under the Environmental Protection Act, Hazardous Waste Regs and WEEE regs in UK
Over to you Dave:-)
Bob
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Posted By Cas
Bob
Interesting...........
Let me take a little time to digest this new (to me) information before I make further comment.
What you said regarding fibres bound in a matrix has put a slightly different slant on this for me. Good point.
Cheers
Cas
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Posted By Dave Wilson
Been away!!
CDG - Carriage of Dangerous Goods Regs 07
ADR(it's French) - Is the UN CDG orange books for transporting DG by road
EWC - European Waste Catalogue - classifies waste etc. (This is where you get the Waste Codes for consignment notes)
EAC - Emergency Action Codes for use by consignors and placarding vehicles, lets the emergency services know what's on board and what emergency precautions to take
All the above can be downloaded from the tinternet free
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Posted By Dave Wilson
Cas,
It may be better to send me an email with any Q you may have.
But here goes!
Asbestos waste is classed as Hazardous Waste, this include used rags, overalls and RPE etc.
To move ANY waste on the highway you need to register with the Environment agency (£85 for 5 years.
Asbestos waste which is 'Hazardous Waste' is also classed as 'Dangerous Goods' and therefore the CDG/ADR applies. However the requirements of CDG/ADR do not apply if
Transporting Less than 1000kg of White asbetso or 333kg of Blue / Brown Asbestos, however by way of something called Special Provision 168 (SP168 for you DGSA) means that the DG/ADR does NOT apply to BONDED Asbestos.
So 3 ton Asbestos Cement sheet Haz Waste but not DG
1/2 Ton AIB Haz Waste & DG
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Posted By Cas
But my suit after a survey - where does it go?
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