Those of us in the electrical and electronics waste recycling industry have a burden of compliance administration and prescriptive regulation we must adhere to. This includes Industrial Emissions Directive (IED) applications that should have been submitted by now. With this in mind, we are on the advent of a major change in the way
the Environment Agency regulates the interpretation, assessment and classification of hazardous waste. Regulatory guidance as it currently stands is WM2 Version 3. This will be superseded by WM3 in just a few weeks. The change comes into force on June 1st and risks being missed, even by the most conscientious operators.
The change is driven by European Regulation (EC) No 1272/2008 (otherwise known as the CLP regulation) on classification, labelling and packaging of substances and mixtures. This came into force on 20th January 2009 across the EU. The CLP Regulation adopts the United Nations’ Globally Harmonised System on Classification and Labelling of Chemicals (GHS) across all European Union countries, including the UK.
The Environment Agency proposes to publish WM3, which includes the changes required by the CLP regulation, in mid May. This leaves very little time for industry to understand and assess implications this may have to our business by the time it comes into force. There is still uncertainty from our regulator, the Environment Agency, regarding the classification of a major stream of electrical waste that is currently classified non hazardous.
We will also see changes to descriptions found in the List of Waste contained within the European Waste Catalogue (more commonly and incorrectly known as EWC codes). Therefore permits will have to be amended in line with this. WM3 may also mean that hazardous waste consignment notes will have to be amended to accommodate these changes.
However, with all this uncertainty in mind the regulator has indicated they will initially operate a light touch approach when enforcing this guidance. In my experience the lightness of touch depends very much on the type of relationship you have with your Environment Agency officer. So, in short, my advice for ensuring you don’t put your compliance record at risk is first, find an introductory WM3 course from a recognised training supplier (there
are plenty out there ). Secondly, have very good packet of biscuits waiting for your Environment Agency officer next
time they visit your site.
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