Rank: Super forum user 
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During a recent 14001 audit on the walk round with the auditor a look in the general waste bin showed wiring off cuts placed there by a contractor. As an electronics company we also place such off-cuts there, due to having to store such would tack a few years before any quantity of value would be accumulated.
Q1. Where in the WEEE Regs does it say that wiring off-cuts CANNOT be placed on the general waste bins?
Q2. If not the WEEE regs then where else doe it say off-cuts CANNOT be placed on the general waste bins and what is the concern with these off-cuts?
Thanks in advance for all assistance given.
Badger
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Rank: Super forum user 
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Hi Badger,
as far as I am aware there is no statutory requirement to separate out waste off cuts. Your auditor may though be taking your Environmental Management System, ISO 14001, to extremes : probably reading "all metals to be recycled" too literally.
PH2
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Rank: New forum user
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I wonder if the auditor was considering your compliance to the The Waste (England and Wales) Regulations 2011:
require businesses to confirm that they have applied the waste management hierarchy when transferring waste, and include a declaration on their waste transfer note or consignment note
introduce a two-tier system for waste carrier and broker registration, including a new concept of a waste dealer
make amendments to hazardous waste controls
exclude some categories of waste from waste controls.
The regulations implement the revised EU Waste Framework Directive 2008/98, which sets requirements for the collection, transport, recovery and disposal of waste.
As of September 2011 you are declaring that you have applied the Hierachy of controls to all of your wastes when you complete your waste transfer note. This includes recycling prior to disposal.
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Rank: Super forum user
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Also, copper contributes to landfill leachate that needs to be treated, as it can pollute ground water.
Hope this helps
Andy
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Rank: Forum user
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Barrie(Badger)Etter wrote: As an electronics company we also place such off-cuts there, due to having to store such would tack a few years before any quantity of value would be accumulated.
You would be surprised just how little copper wire waste you would need to collect before someone will collect and pay for it. As an electronics company we to create wire off-cuts. Before I joined it went in the general waste skip at the end of each day. A couple of phone calls and I found a local processor of WEEE waste who would provide a container, exchange it monthly and pay us per Kg. We now have a 1200 x 1000mm plastic bin in the corner of the warehouse where the off-cuts are dumped daily and gets exchanged at the end of each month with approx 250Kg in it. The income we get from the waste wire is more than the annual cost of getting the general waste skips emptied, due to the market value of copper.
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Rank: Super forum user
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I think the question is really about your understanding of the European Waste Catalogue and mnaterials classed as hazardous for landfill. Your auditor was probably expecting you to have done some form of assessment of the amounts involved and the changes made in the light of the European Court decisions. Metals such as copper, tin , lead, mercury etc should not routinely be landfilled so you need to investigate your options more closely.
You certainly should not be expecting your contractor to put this in your skip as the WEEE regs do define HIM as the producer, not you, and disposal is thus HIS responsibility not yours. He is after all in a better position to dispose of his off cuts as he is in that line of business. It is ultimately a lazy answer that you accepted and it has now bitten you firmly. Do NOT be conned by statements such as we are replacing your equipment and thus the waste is yours. Unless you want it do not accept it!
Bob
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Rank: Super forum user
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Rank: Forum user
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Barrie(Badger)Etter wrote:jfw
You have mail.
Badger Details forwarded in PM
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