Hi All I have been asked to consider some H&S measures (risk assessment) for the mass storage of old and physically damaged car batteries in a warehouse environment. This would be bulk storage upwards of 500 at any one time. They would be delivered inside sealed large bins that can be moved by pallet truck/forklift etc. Does the bulk transport of these items fall under ADR? If so what is the threshold weight that would make this an ADR journey? These would not be physically handled but they might need to be if they were to fall out of the bin that stored them. Do I need to consider environmental licences for the storage of large amounts of this type of hazardous waste product? Any help on this would be really appreciated! Cheers DHM

DHM The rules relating to the permitting or exemption of waste storage are complex and depend on a number of factors not just the amounts stored, including what is the ultimate fate of the waste - e.g. disposal, treatment, recovery, etc. Start here http://www.environment-a...cs/permitting/32330.aspx as the exact requirements will depend on your specific circumstances.

Clearly from what you have said the site is a hazardous waste transfer station and therefore the site needs to have an Environmental Permit issued by the Environment Agency. To obtain an Environmental Permit the site needs to be under the control of a holder of a WAMITAB Qualification. Currently your site is operating illegally and if the Environment Agency find out they will take formal enforcement action. If the site was operated under an Environmental Permit the question that you have raised would not have arisen. I would suggest that you explain the above situation to your Manager/Directors and seek to gain an Environmental Permit as a matter of urgency.

dsb, Don't worry there is nothing illegal going on here! All of this operation is only proposed at the moment. I can assure you that should it go ahead then the correct permissions will be sought from the relevant agencies. Thanks for your advice though.