The Environment Agency has issued an opinion on the treatment and landfilling of hazardous waste due to problems that the organisation is experiencing with the management of these materials. For it to do so suggests a high degree of concern in relation to the treatment of hazardous wastes.
Recent legislative changes have resulted in a step-change in the way that the management and disposal of hazardous waste is operated and controlled. The ban on co-disposal of hazardous and non-hazardous waste at landfills has been of major significance to hazardous wastes management.
The Agency states that, with reference to the ban on landfill, it does "not expect to see this replaced by treatment plants mixing hazardous and non-hazardous waste for the purpose of dilution or concealment of the hazardous waste and the subsequent mis-classification of outputs as non-hazardous waste", which is perhaps an indicator of the types of problem being experienced.
As a result of in-depth audits at hazardous waste treatment plants the Agency has identified what it describes as "a number of poor, if not illegal, practices". Some treatment plant operators have apparently been treating waste without knowing what the end result might be or whether incompatible reactions might occur during treatment. The note issued by the Agency clarifies what it expects of all those treating and landfilling hazardous waste.
Overview of the Agency's Opinion
The Agency's opinion in overview is given below:
- "Wherever possible, producers should ensure hazardous waste is kept separate from non-hazardous waste.
- Any hazardous waste that has been mixed with non-hazardous waste should be separated out at the first opportunity where it is safe and feasible to do so.
- Hazardous waste requiring treatment must be treated at appropriately authorised plant before it is landfilled and must meet the relevant waste acceptance criteria.
- The purpose of treatment of hazardous wastes should either be to render waste non-hazardous, or to reduce its impacts when disposed of in an appropriate landfill.
- Treatment plant operators must be clear as to why a particular treatment method is being employed on a particular waste. They should ensure maximum efficiency of the treatment process and ensure that incompatible mixtures do not occur that may damage the environment or human health.
- Hazardous waste can be treated by way of chemical processes to make it non-hazardous. Simple physical processes alone are rarely sufficient to render a hazardous waste non-hazardous.
- Mixing hazardous waste with non-hazardous waste with the purpose of diluting it or masking the hazardous components is not considered acceptable treatment. Pre-mixing of hazardous waste with a non-hazardous waste for example, to facilitate handling, can be carried out prior to treatment. Pre-mixed wastes (whether from pits or vessels) should be classified and managed as hazardous waste.
- Sham treatment and the mis-description of hazardous waste as non-hazardous waste continue to be an enforcement priority for us."
The note from the Environment Agency contains further information on background legislation, government policy, treatment of hazardous wastes, the Agency's future vision and a position statement in relation to hazardous waste treatment.
The note on the Agency's opinion and position on these matters can be found on its web site.