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Ron Hunter  
#1 Posted : 15 July 2010 11:14:27(UTC)
Rank: Super forum user
Ron Hunter

We are about to embark (after appropriate training etc, and all in accordance with the HSE’s Asbestos Essentials Task Manual) on conducting in-house a range of non-licensed straightforward tasks across our extensive property portfolio. All things are very much “good to go” other than the conveyance and disposal issues associated with the asbestos waste arising. We envisage having our mobile squads out there for the day carrying out several non-licensed tasks over a range of properties, with all waste arising (coveralls, PP3 masks, tack-rags, vinyl tiles and other scrapings etc.) being carefully double bagged, tagged, secured in a lock-fast container in the van and then collectively taken to the waste transfer station at the end of the day. We would seem to be in “dispute” with the relevant authorities (Scotland) regarding our proposals for carrying and disposing of our waste, and they suggest that we need to carry the waste from each property directly to the waste transfer station, with a separate conveyance note for each (at £15 a time, thank you very much!). Such an approach is commercially untenable, and OTT when we consider the relative environmental risk posed by this waste to be extremely low (insignificant?). The quantity of asbestos fibres in our waste is typically extremely low (air testing during our trial tasks gave typically <0.01% f/ml) in comparison to that in the tools & other equipment we carry (the HEPA vacuum) or in comparison to the amount typically carried by an Asbestos Surveyor back to a laboratory for analysis. Has anyone out there (Scotland, England or Wales) arrived at a practical solution to the carriage and disposal of waste arising from these tasks which has the blessing of the Enforcing Authorities?
DSB  
#2 Posted : 15 July 2010 13:33:49(UTC)
Rank: Forum user
DSB

Ron, In England & Wales what you have described can be addressed by completing a single Consignment Note for multiple collections- the from required is different from the usual Consignment notes to allow for the recording of the different types of waste collected and the actual premises from where it is collected. Despite the law being different in Scotland the application of the above should be the same.
Ron Hunter  
#3 Posted : 15 July 2010 13:46:27(UTC)
Rank: Super forum user
Ron Hunter

Many thanks for reply dsb. Would it be possible to point me to the relevant guidance document (netregs link etc) covering this in England and Wales?
martinw  
#4 Posted : 15 July 2010 14:23:11(UTC)
Rank: Super forum user
martinw

Ron HSE http://www.hse.gov.uk/pubns/guidance/em9.pdf Which refers to EA and consignment note. http://www.environment-a.../topics/waste/32180.aspx http://www.environment-a.../topics/waste/35054.aspx This is not my area of expertise and I am only copying the links. Others on this site will have experience and it may be worth contacting the EA if any further clarification is necessary. Martin
Ron Hunter  
#5 Posted : 15 July 2010 16:01:17(UTC)
Rank: Super forum user
Ron Hunter

Martin, many thanks your links led to the useful http://publications.envi...pdf/GEHO0110BRRD-e-e.pdf I now have to determine an equivalence in Scotland with SEPA!
bob youel  
#6 Posted : 15 July 2010 17:09:18(UTC)
Rank: Super forum user
bob youel

Remember CAW is not via environmental law it is via H&S law so you have 2 different law areas to work with [I know that other laws apply also but I am keeping this simple] Additionally you are working in 2 different countries so irrespective of what you do in England if the Scottish law is different you must obey that law [and its guidance and its enforcers interpretations etc] so on evaluation only use Scotish law etc examples to base your answer on common sense says that multi collection with one trip to a waste management site achieves the same outcome as single collection then to the waste management site but common sense does not always apply
martinw  
#7 Posted : 15 July 2010 18:00:24(UTC)
Rank: Super forum user
martinw

Ron have a look at 3.2 on the following hyperlink, the pdf should prove informative http://www.sepa.org.uk/w...tly_asked_questions.aspx regards Martin
buzzz  
#8 Posted : 15 July 2010 21:20:53(UTC)
Rank: Forum user
buzzz

We've been through this ourselves, it makes no sense to employ external contractors to do jobs which you can do except they may have asbestos in them! We found that taking loads to the transfer station, even at the end of the day, proved costly. They charged us for the 'per tonne' price irrespective of how little we had. In the end we have opted for on site sealed asbestos skips where we can bring the waste back to site. We have liaised with the local EA and because it is our own generated waste we have been exempt from a permit meaning it's a much more cost effective way of managing it.
ADH  
#9 Posted : 16 July 2010 09:43:01(UTC)
Rank: Forum user
ADH

Have a look at this: http://www.opsi.gov.uk/s...pdf/uksi_20100675_en.pdf page 184 onwards (The Environmental Permitting (England and Wales) Regulations 2010) - this might help, but remember it is only England & Wales at the minute
Ron Hunter  
#10 Posted : 16 July 2010 12:22:49(UTC)
Rank: Super forum user
Ron Hunter

Cheers adh, however it appears asbestos-containing waste is excluded from those provisions.
Ron Hunter  
#11 Posted : 21 July 2010 14:36:04(UTC)
Rank: Super forum user
Ron Hunter

Many thanks to those responding. Via the link provided by martinw I found a rich seam of "Special Waste Advisory Notes" at: http://www.sepa.org.uk/w...aste_advisory_notes.aspx One of these (SWAN/14) provides me with a quite specific solution to our particular scenario. Such a pity these things are so difficult to find on the SEPA website. Also disappointing that these Advisory Notes weren't references by them in numerous conversations!! Another problem resolved via the power of this Forum. Good stuff. Thanks to all again.
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