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Posted By Jason911
I work for a large wholesaler as H&S officer. We sell electrical goods, but not under our own brand name, so we are not defined as a 'producer' under the Regs.
I have 2 problems with these new Waste Electrical & Electronic Equipment Regs as follows.
1. Certain other departments within my organization seem to be of the opionion that although these new regs are issued by the DTI, they come under the remit of H&S, but then you can apply H&S to almost anything can't you? Surely this is an waste issue?
2. The Regs seem to me, to be a complete shambles and I would be very interested to know what provisions any other firms out there have made, as far as taking back into their possession electrical goods for recycling.
Thanks in advance for your comments.
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Posted By tommy_t
Jason,
I understand that the regulations will be enforced by the Environment Agency - so they aren't Health and Safety, they are an environmental (waste) issue.
I also understand that the regs are at the consultation stage so there is no need to do anything as yet.
I believe that retailers will have the option of taking goods back instore or they will be able to join a scheme where they can direct consumers to local recycling centres.
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Posted By Les Welling
In my humble opinion this is not part of a H&S remit. I think the ball is firmly in the Environmental Managers court.
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Posted By George Wedgwood
It is really a H&S issue as most of what the EA does is related to the protection of our environment to ensure we stay healthy and safe from noxious waste, dangerous fly tipping and gas from landfill etc.? However, this is an interesting one as IOSH is kind of half-way on this and the Environmental SG has said little about it. Should IOSH get deeper into it? I think so as much of the processing that is coming on stream to deal with WEEE is potentially 'dangerous' and the risks in that area need balancing with the risks of the waste getting into society and perhaps poisoning us or other living organisms. The IET and other bodies like the IT industry is examining the regulations that are about to be finalised and lead in solder is a clasic - if you have not elimated that at source some time ago, then you may have a serious problem as a manufacturer. Of course IOSH is interested in the CLAW Regs so should it cot be interested in the safety of alternates and the safe treatment of the existing printercircuit boards that do contain lead?
I think the ESG should form a working group to look at the wider picture, to see if IOSH should have a bigger profile in the implementation of WEEE.
George
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Posted By Paul Bellis
Yes it is - if you manufacture electrical-electronic goods - its part of the RoHS
On the 1st July 2006 the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2006 implementing the European Directive came fully into force.
These regulations restrict the use of lead, cadmium, mercury, hexavalent chromium, PBE and PBDE in electronic and electrical equipment covered by the regulations.
see
http://www.rohs.gov.uk/Default.aspx
Paul
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Posted By Jason911
I know but I don't want to confuse the issue with this other set of regulations. I am only concerned with other retailers and how these new regulations are impacting them and not manufacturers.
Thanks
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Posted By tommy_t
As Jason says, we're now talking about two sets of regulations - RoHS regulations is about restricting hazardous substances during manufacture.
The WEEE regulations is about the recycling of unwanted (waste) electrical and electronic equipment.
The guidance on the regs is issued by the Department of Environment, Food and Rural Affairs and it will be enforced by Environment Agency.
My job covers both Health and Safety and Environmental Management, but if my company employed separate Safety and Environmental management roles, then I would be passing it to the Environmental Manager.
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