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Posted By Malcolm Greenhouse
My outsourced maintenance contractor has informed me that they can no longer bring back to the main hospital site in their little vans the used fluorescent tubes they have replaced. They claim that this is hazardous waste and they are not licensed to transport from the 42 smaller units to the large facility from where we pay another contractor to dispose if properly. They are quoting new hazardous waste transport regulations.
Does anyone have any thoughts on the regulations for transporting hazardous waste with regard to this particular situation?
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Posted By Stewart Campbell
Hi,
Unless the tubes are broken, then the vans are transporting spent flurorecent tubes. No difference from transporting new flurorecent tubes. The tubes only become hazardous waste when they are broken.
The vans are not transporting hazardous waste. That said training in dealing with tubes if they got broken in transit will be necessary.
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Posted By SteveD-M
He's right he would be carrying or disposing of another waste and as such would be required to register as a waste carrier or broker or both.
There are very limited exemptions to this. Main reference EPA 90 and new EPR 2007.
All available on the EA website.
Cheers
Steve
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Posted By graeme12345
if you own the waste and it comes from your site you would be able to use your vehicles to take to the disposal site.
The contractor would need a waste carriers license becuase it would not be his waste and he would be transporting
If you want to keep the tubes on your site until it is more economical to dispose of them you will need a haz. waste registration report, obtain for about £18 on EA web site
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Posted By Stewart Campbell
Classification of spent unbroken tubes of hazardous waste implies that all fluorecent tubes are hazardous material and as such any transport of fluorecent tubes will require a hazardous goods license.
Can anyone confirm if this is true?
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Posted By Mitch
Malcolm,
And I quote 'Not all hazardous waste will be considered as dangerous for transport purposes' If the individual sites the tubes are collected from produce less than 200kg then you do not need to register. I would talk to your local Environment Agency office to clarify your situation but my understanding is that a limited amount of tubes with the correct training is acceptable.
Mitch
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Posted By Stewart Campbell
I have been in contact with SEPA on this issue to clarify my own knowledge. SEPA said that they are unaware of any licencing requirements to transport new fluorescent tubes. As soon as the fluroscent tube is spent then it transforms to become waste. This waste is automatically classified as hazardous. If you transport the tubes in house to the central point for collection, then no licence is required. However, if an outside company picks up and transports the waste tubes to the central collection point, then they will require a waste transpost licence.
I hope this helps.
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Posted By Raymond Rapp
I heard a similar conundrum on the radio recently, where the transportation of new fluorescent tubes is not hazardous waste but the transportation of spent ones is. Okay if they are damaged there are some nasties inside the tube, but is this crazy or what.
Little wonder everyone thinks 'elf and safety has gone mad.
Ray
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Posted By Smiff
The Haz Waste Regime is really not there for this type of scenario. Remember the 200kg threshold for producer registration. Without a porducer registration you cannot raise a consignment note, so your tubes slip under the regulatory radar. A simple procedure of keeping the cardboard sleeves from the new tube to safely house the spent one and briniging them back to base as they arise (eg 1s and 2s)is more than sufficient.
My test is;
"what's the worst thing that could happen"
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Posted By TBC
I think that if the contractor can't fathom out that he is not a 'waste carrier' - then I would look for a more clued up contractor.
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