Advisory Note on the storage and transport of waste portable batteries www.defra.gov.uk
www.defra.gov.uk Advisory Note on the storage and transport of waste portable batteries Version 1 July 2009 Storage and transport of portable batteries Table of Contents Part 1 - Introduction ......................................................................................................... 3 Part 2 – Duty of Care and Waste Carrier Registration ..................................................... 4 Part 3 – Environmental Permitting ................................................................................... 6 Part 4 – Carriage of Dangerous Goods ........................................................................... 6 Part 5 - Hazardous Waste ............................................................................................... 9 Part 6 – Safe Storage of Batteries ................................................................................. 14 Part 7- Scotland and Northern Ireland ........................................................................ 156 Part 8 - Practical Examples: Back Hauling................................................................................................ 17 In store take-back........................................................................................ 19 Postal Returns............................................................................................. 19 Annexes ....................................................................................................... 20 Authorisation 214 for the transport of up to 333kg of waste portable batteries.......................................................................................................... 20 Mock Consignment Note................................................................................. 21 General Awareness Training for the handling of waste portable batteries..... 23 2 Part 1 Introduction 1. The Waste Batteries and Accumulators Regulations 2009 came into force on 5th May 2009. These regulations will lead to an increase in the collection of waste portable batteries for recycling – very few are collected currently. From 1 February 2010, retailers who sell 32kg or more of portable batteries in a year will have to accept waste portable batteries back from members of the public. There are also likely to be collections in public buildings, such as libraries. This means that people who have not previously been involved in storing and transporting waste (used batteries are classified as waste) will be in the future. 2. We (Defra) organised a workshop on 13th May 2009 to help those collecting batteries under the new system understand the range of legislation which applies to this activity. The main areas are the controls on “Hazardous Waste” and the movement of “Dangerous Goods”. The presentations from the 13th May workshop are online at: http://www.defra.gov.uk/environment/waste/topics/batteries/batteriesimplement.htm 3. The aim of this document is to summarise the information presented at the workshop and to help those storing and transporting waste batteries understand what they must do to comply with current legislation. We hope that it will be of particular interest to those who were unable to attend the workshop. 4. This note does not replace existing guidance on the individual pieces of legislation and those who require more detail should refer to that guidance. However, the note summarises the various requirements and points to where more detailed help can be found. It covers the first part of the collection system, from collection points (i.e. where the end-user disposes of the batteries for recycling) to the bulking-up point or waste treatment facility (if the waste is transported there directly). The note covers the position in England and Wales and summarises the different rules applied in Scotland and Northern Ireland. 5. For more detail on the Waste Batteries and Accumulators Regulations 2009, please refer to:Guidance note on the Batteries Regulations http://www.berr.gov.uk/files/file51268.pdf The Environment Agency’s battery pages http://www.environment-agency.gov.uk/business/regulation/101529.aspx 3 Who should read this note? 6. This note will be of interest to anyone who stores waste batteries after they have been deposited by end-users, transports the waste batteries or receives them at a bulking-up point, Civic Amenity Site or treatment facility. Why does Hazardous Waste and Dangerous Goods legislation apply to batteries? 7. Members of the public will return waste batteries of mixed sizes and chemistries (e.g. alkaline, lithium, nickel cadmium, nickel metal hydride, etc.). The battery chemistry cannot be identified simply from the shape or size of a battery. 8. For instance, some AA batteries have an alkaline chemistry whilst others may be of lithium or nickel cadmium chemistries. Batteries containing lithium are classified as “dangerous” under the Carriage of Dangerous Goods Act, while nickel cadmium batteries meet the definition of “hazardous” under the Hazardous Waste Regulations. 9. Dangerous goods (not just waste) are those that pose a risk to people, property and the environment. These types of goods can range from those that are obviously dangerous (such as explosives, flammables and fuming acids) to everyday products such as paints, solvents and pesticides found in the home and at work. When transported, these goods need to be packaged correctly as laid out in the various international and national regulations for each mode of transport to ensure that they are carried safely to minimise the risk of an incident. 10. As Dangerous Goods, lithium batteries can normally only be transported by road and sea under certain restrictions. Transport of lithium batteries by air is banned. To help the collection of waste batteries, the Department for Transport has introduced simplified rules for the transport by road of up to 333 kilogrammes of mixed waste batteries. There is more information on this in Part 4 of this note. 11. Hazardous waste 1 has properties that may make it harmful to human health or the environment. The EU has legislation on:• • 1 the management of hazardous waste (Directive 91/689/EEC);and the definition of hazardous waste the List of Wastes Decision (Commission Decision 2000/532/EC as amended). In Scotland, hazardous waste is referred to as “special waste”. 4 12. The Hazardous Waste Directive will be replaced by the revised Waste Framework Directive in December 2010, however, the new Directive contains many similar provisions. 13. Hazardous waste regulations and their equivalent in Scotland are enforced by the environment agencies. Further details can be found on the agencies’ websites:Environment Agency for England and Wales: (http://www.environmentagency.gov.uk/business/topics/waste/32180.aspx), Scottish Environment Protection Agency (SEPA) in Scotland: (http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx ) Northern Ireland Environment Agency in Northern Ireland: (http://www.nienvironment.gov.uk/wasthome/regulation/regulations_hw.htm ) 14. Not all batteries fall under these classifications (hazardous and dangerous). The most popular type of portable battery – Alkaline - is not classed as hazardous or dangerous. However, a container full of mixed waste batteries is almost certain to contain a small proportion that are deemed to be dangerous and/or hazardous. Therefore all mixed waste batteries must be transported and stored appropriately. Anyone considering separating out lithium and nickel cadmium batteries (and this is not an easy task, even for experts) should bear in mind that, when concentrated, lithium batteries present a greater risk than when dispersed among other batteries and the controls on movement are more stringent. Consideration should therefore be given to whether it is easier to keep waste batteries mixed. Part 2 – Duty of Care and Waste Carrier Registration What is the Duty of Care? 15. If you are in possession, or have control of waste, you have a legal 'Duty of Care' to store it safely without causing pollution or harm and to only transfer it to someone who is legally allowed to take it. The Duty of Care applies to everyone who handles waste; from the person who produces the waste to the person who finally recycles or disposes of it. The Duty of Care is one of the main ways to combat flytipping. 16. If you are responsible for “controlled” waste (all batteries are likely to fall within this definition) you must ensure that the waste is stored safely, managed properly, recovered or disposed of safely, does not cause harm to human health or pollution of the environment, is only transferred to someone who is authorised to receive it and, when transferred, is 5 described in sufficient detail to allow subsequent holders to handle it safely. Waste Carrier Registration 17. If you intend to carry waste produced by others you must be registered as a “Waste Carrier” with the relevant environment agency. At present this registration costs £152 (£157 in Scotland and £120 in Northern Ireland) for the first three years and £102 (£108 in Scotland and £60 in Northern Ireland) for renewals. Renewals last for three years. Carrying waste without a relevant authorisation is an offence. 18. Following a review of the waste carrier system conducted last year, it is possible that businesses who only carry waste they produced themselves will, in the future, have to register with the Environment Agency. If and when the registration system changes, the requirements will be communicated to businesses. We consulted on these proposals in June 2008: http://www.defra.gov.uk/environment/waste/legislation/duty.htm#12 19. In practical terms, the person who has delivered waste batteries to a collection point is the waste producer, so even under the current regulations all movement of waste batteries from a collection point must be made by a registered waste carrier. From time to time, you will be asked by those responsible for the collection point for proof that you are properly registered. 20. As well as being registered, you must carry the waste correctly and deliver it to someone allowed to take it. So, when delivering the waste batteries, the collector should make sure that the site is authorised to take them. In most cases, this will mean that the site has an environmental permit or is covered by a properly registered exemption (see below). Part 3 – Environmental Permitting (England and Wales) (see Part 7 for Scotland and Northern Ireland requirements) 21. Under existing regulations, all collection points for waste batteries must have an environmental permit but the Environment Agency has adopted a low risk waste position which covers portable battery collection points accessible to the public. Low risk waste positions (in this case LRW 006) reflect the environmental risk posed by certain activities that do not currently benefit from an exemption from permitting. 6 22. LRW 006 allows the storage of up to 80kg of waste dry cell batteries (portable batteries), provided that the operator (e.g. retailer, person in charge of waste in a school, public building etc.) ensures that the activity does not cause pollution or harm to human health. It requires no notification and involves no fee. 23. This will only apply until February 2010 for retailers and April 2010 for other collection points. From 1 February 2010 there will be a formal exemption from the need for an environmental permit for retailers and any other distributors of portable batteries who are obliged to provide takeback facilities (that is, those selling 32kg of batteries or more per year). 24. Defra plans to introduce in April 2010 an exemption from environmental permitting for other battery collection points (e.g. those in public buildings). 25. Collection points other than those which are accessible to end users, such as bulking-up points 2 , will also benefit from an exemption from environmental permitting – the details of the exemptions are being developed as part of the review of waste permitting exemptions. Part 4 – Carriage of Dangerous Goods 26. This section assumes that you are transporting less than 333 kilogrammes of used portable cells or batteries. If so you can benefit from the special provisions the Department for Transport have put in place for such cases. 27. Carriers and drivers must be able to assess whether the amount of used cells or batteries they are carrying will exceed that amount. If you carry more than 333 kilogrammes you will need to comply with the full ADR regulations. Who needs to comply with the Dangerous Goods legislation (“ADR”) 28. ADR identifies 3 “roles”: • 2 The Consignor is the person consigning the used cells or batteries for transport – i.e. whoever collects and stores batteries (e.g. retailer, someone in a public building, school etc). Batteries can be stored at a bulking point for a period of up to 6 months after which they will need to be moved to a Treatment Facility. 7 • • The Carrier is the person that collects the used cells or batteries from the Consignor and packs them appropriately for transport. ADR has a role for the “packer” as well, i.e. the person ensuring that the used cells or batteries are packed and put in appropriate containers ready for their transport. However, in practice the carrier and the packer are the same person. Often these functions are covered by the Driver. The Driver is the person that drives the vehicle which will take the used cells or batteries to the intermediate bulking- up point. 29. When the collection box is full, the operator of the collection point - the Consignor - will arrange to have it collected by a carrier. 30. The Consignor must ensure that those used cells or batteries are taken away from the premises by a trained Carrier. The Consignor must be aware of the correct way of packing the used cells or batteries so that when the collector comes to take them away he/she can be satisfied that the Carrier is properly trained. The packing requirements are straightforward and are explained in the following section. 31. The Consignor, Carrier and the Driver need to receive training to ensure that they know their responsibilities. The training, which can be with a trainer or through written guidance, should also be straightforward. An example of the type of written guidance that could be used is at Annex 3. When training is complete, the consignor will needs to keep the guidance or another document certifying that he/she received the training and this needs to be kept for 3 years for inspection. 32. The training needs to be done every three years. 33. Once correctly packed, the Driver will take the load to a bulking-up point or treatment facility. No Dangerous Goods can be kept in a vehicle overnight so all waste batteries must be taken to such a place by the end of the day. This means that if a driver has several pick-ups to undertake he must complete them all within one day and get the batteries to a bulking-up point or treatment facility before the end of that day. How to pack and transport waste portable batteries Authorisation 214 34. To help encourage the collection of used cells or batteries for recycling while continuing to manage the risks posed by lithium batteries, the Department for Transport have issued an authorisation permitting the transport of used cells or batteries from consumer collection points to the 8 bulk up point by road without the need to comply with the FULL ADR regulations. These provisions, which apply until 30 June 2015, are contained in the Department for Transport’s Authorisation 214 which is available at:- http://www.dft.gov.uk/426155/425450/300/auth214.pdf The Authorisation requires that: 35. The lithium cells or batteries shall be packed with other battery types (i.e. mixed with other chemistries, so lithium-only loads are not permitted under Authorisation 214) in a closed plastic liner within a metal or plastic drum or box to prevent undue movement. Each plastic liner shall only be used once. 36. Each drum or box shall be marked on the outside with the words USED LITHIUM CELLS in capital letters which are a minimum of 12mm high on a contrasting background. 37. The maximum total quantity of mixed used cells or batteries per transport unit shall not exceed 333kg. 38. All personnel involved in the transport of the cells or batteries must undergo appropriate general awareness training commensurate with their responsibilities. 39. The 333 kg limit applies to the weight of all the used cells or batteries not just lithium ones – i.e. you must not carry mixed batches of used cells or batteries weighing more than 333 kg. If you wish to carry more than 333kg then you will have to comply with the full ADR regulations. 40. Finally, as already covered, all parties involved need to undertake general awareness training. This can be given by a trainer or by providing written guidance. A copy of the general awareness training (see Annex 3) must be kept for a period of 3 years. Special cases 41. The transport of lithium batteries by air is banned. As it will not be possible to identify which are lithium batteries and which are not, you should not transport used cells or batteries by air. Consignment by sea would need to comply with the requirements in the International Maritime Dangerous Goods (IMDG) code. In view of the air restrictions and the full requirements of ADR and IMDG Code, the Department for Transport does not recommend that you use postal returns as it would be too difficult in practice to comply with the legislation. 9 Part 5 Hazardous Waste Consigning the waste 42. This section covers the regulations which apply in England and Wales to track hazardous waste from where it is disposed of to where it is treated. As explained earlier, mixed loads of batteries are considered to be hazardous waste. 43. There is a slightly different system in Scotland where hazardous waste is referred to as “special waste” and in Northern Ireland. 44. SEPA has produced guidance on consigning special waste which is available on the SEPA website:http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx 45. The NIEA has produced guidance on consigning hazardous waste which is available on the NIEA website:http://www.ni-environment.gov.uk/wastehome/regulation/regulations_hw.htm 46. A consignment note needs to be completed for each batch of waste batteries being moved. A standard consignment note is made up of five parts, each must to be completed by a specific person acting under a specific “role”, in a similar way to the ADR regulations. 47. Figure 1 – A consignment note – divided into 5 parts. (N.B.This is a diagrammatic representation. See Annex 2 for a more realistic sample). 48. The “roles” are as follows: - Producer - Carrier - Consignee 10 49. Under the batteries regulations a producer is the person who puts batteries on the market. However, in the context of the hazardous waste regulations, a Producer is the operator of the first premises collecting the waste batteries (e.g. retailers, public buildings, etc), with the exclusion, as always, of domestic premises. All premises in England and Wales where more than 500kg of hazardous waste is collected (or produced) per year (apart from domestic waste from domestic premises) must be notified to the Environment Agency.(This is not the case for premises located in Scotland or Northern Ireland). Information on how to notify premises can be found on the Agency website at:http://www.environment-agency.gov.uk/business/topics/waste/32198.aspx. 50. We expect that many battery collection points will collect less than 500 kg of batteries and other hazardous waste and therefore will not have to be notified. However, please note that the 500kg limit includes all hazardous waste collected at the premises, not just batteries So, for example, if your premises collects 100 kilogrammes of batteries and 450 kilogrammes of other types of hazardous waste (for example, CRT televisions if you are an EEE retailer), you will need to complete a notification. 51. The Carrier is the person collecting and transporting the hazardous waste (e.g. collecting from a store). 52. The Consignee is the person receiving the waste (e.g. the operator of a bulking up point). They will, in turn, be the Producer for any onward waste movement, for example where hazardous waste is moved from a bulkingup point to a treatment facility. (NB A bulking-up point will almost certainly have to be notified as a site where hazardous waste is produced). 53. The consignee (if located in England or Wales) must make quarterly returns to the Environment Agency of the amount of hazardous waste they have received in the format specified by the Agency. This will include a summary of every consignment received at their site. The Environment Agency makes a charge of £10 per quarterly report for dealing with this information. For waste originating from Scotland or Northern Ireland the consignee is required to send a copy of the completed consignment note to SEPA or NIEA respectively. The Consignee must also make quarterly returns to producers to confirm receipt of the waste. 54. Each person must fill-in the relevant section of a consignment note and keep a copy of it. 11 Single and Multiple collections Consignment Notes 55. Consignment notes can be of two types, either for single journeys or multiple journeys. For collections from premises in England and Wales the consignment note can be downloaded free of charge from the Environment Agency’s website:http://www.environment-agency.gov.uk/business/topics/waste/32196.aspx, or if you prefer, you can print your own, provided they contain space for all the required information. 56. In Scotland and Northern Ireland consignment notes must be purchased from the respective Agencies. For details of fees in each jurisdiction and guidance on the completion of consignment notes please see websites: http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx and http://www.ni-environment.gov.uk/wastehome/regulation/regulations_hw.htm 57. In the case of a single journey, there is one producer (usually also the consignor), one carrier and one consignee. This will happen when a vehicle is sent out to collect from one collection point and to transport the batteries to a bulking-up point or treatment facility. 58. It is much more common that a vehicle will collect from a number of collection points. For such multiple collections, there will be a number of producers, but only one carrier and one consignee. Guidance on consignment notes for multiple collections in England and Wales is at:http://www.environment-agency.gov.uk/static/documents/GEHO0507BMSJ-ee.pdf 59. To simplify the job for all parties involved, consignment notes can be preprinted with any information which does not change from one trip to the next. This only applies to England and Wales. They can also be completed electronically – see:http://www.environment-agency.gov.uk/business/topics/waste/34867.aspx . Life of a Consignment Note 60. The responsibility for filling-in the consignment note starts with the producer of hazardous waste (e.g. retailer) – although in practice this is often done by the carrier (the producer must still sign it as being correct). The producer (or the carrier on their behalf) must complete parts A, B and D and retain a copy. 61. On collection, the collector must complete part C and take the batteries to the consignee. He retains part C and the consignee fills out part E and keeps a copy and gives a copy to the carrier. The consignee will return a 12 fully completed copy of the consignment note to the producer. and the NIEA or SEPA for waste arising in Northern Ireland or Scotland respectively. 62. The Environment Agency has further guidance on using consignment notes in England and Wales that can be found at:http://www.environment-agency.gov.uk/hazwaste . 13 Figure 2 – Life of a consignment note Source: Environment Agency Waste Carrier Household Separately collected domestic fraction – no consignment notes required Consignment note required Household Carriage of Dangerous Goods applies Carrier Register Must store carrier copies of note at principal place of business for one year. Carrier registration required Destination Site (consignee) Collection Point (Haz waste Producer) Consignee must send Producer Return. Either copy of consignee consignment note OR Quarterly return from from Regs. Household Premises Notification Required if 500kg+ of more of all hazardous waste produced in any 12 month period at that premises. Producer Register Must store producer copies of consignment notes, and producer returns from consignee for 3 years. Site Register Must store consignee copies of consignment notes for waste received. Hold at notified premises. Must also store their outgoing producer notes and producer returns from final disposal site. If exempt hold at principal place of business OR each producer can ask the EA to agree to let them hold it in another place. Duration depends on activity, but will be a minimum of three years. (see guidance) 14 Site Return to EA Provide Quarterly returns to EA. Specific guidance on reporting of battery movements reduces associated charges. Part 6 – Safe Storage of Batteries 63. There are no specific health and safety requirements for storing batteries, but normal health and safety rules apply. This includes that the responsible person should assess health and safety risks. In a workplace, the ‘responsible person’ is the employer or person who occupies or owns the premises. In all other premises the ‘responsible person’ will be the person or people in control of the premises. 64. Health and Safety Executive considers the risks from storing small quantities of portable batteries to be very low if sensible common sense precautions are taken. But these should be taken into account in a business’s health and safety risk assessment. The five steps of risk assessment 65. The basic five steps in a risk assessment are:a. Identify the hazards. The hazards from batteries are mainly leakage of chemicals and fire. b. Identify the people at risk if there is an incident. This may include both people who use the premises and those nearby. Particular attention should be paid to people who may be especially at risk such as: • employees who work alone, e.g. cleaners, security staff; • unaccompanied children and young people; • people who are unfamiliar with the premises, e.g. visitors; customers; and contractors. • people with disabilities or those who may have some other reason for not being able to leave the premises quickly; and • people with language difficulties. c. Evaluate the risk to people if an incident occurs and take any necessary measures to ensure the risk to their health and safety is as low as is reasonably practicable. The specific circumstances will dictate the appropriate measures to prevent or reduce the risk of an incident, but for batteries may include: • Using a collection box which limits the size of objects that may be inserted and minimises the possibility of leakage; • Locating the collection box where it can be readily monitored; 15 • To regularly check the contents of the collection box and move to a secure and safe storage area when deemed necessary; • To locate collection boxes where they are unlikely to be exposed to fire or sources of heat; interfere with normal access routes, or emergency escape routes. d. Prepare a plan and provide instruction and training of what to do in the event of an incident. This should include who is to inform the emergency services if necessary. e. If you employ five or more people, the significant findings of the risk assessment should be recorded in compliance with other Health and Safety (and Fire Safety) Legislation. f. Keep the assessment under review and revise where necessary; for example, if conditions change, or following an incident to prevent recurrence. Part 7 Scotland and Northern Ireland This section explains the main differences between the regulations in England and Wales compared to those in Scotland and NI. Scotland Waste Management Licensing 66. Paragraph 17 of Schedule 3 to the Waste Management Licensing Regulations 1994, as amended, provides an exemption for battery collection points. This can be registered on-line through the SEPA website and is free of charge: http://www.sepa.org.uk/wmxreg/pages/welcome.aspx 67. It covers the storage of up to 5 cubic metres of mixed municipal batteries for up to 12 months in a secure place. Special Waste 68. The main differences between the system in England & Wales and in Scotland are: - producers do not need to register as producers of special waste all movements of special waste must be prenotified, except successions and movements of only lead acid batteries. 16 69. The consignment note system is similar in Scotland with a similar five part note to be completed for each movement. SEPA has produced guidance on consigning special waste which is available on the SEPA website: http://www.sepa.org.uk/waste/waste_regulation/special_waste.aspx Northern Ireland Waste Management Licensing 70. Regulation 16A of the Waste Management Licensing Regulations (Northern Ireland) 2003 (as amended) provides an exemption for battery collection points where “collection point” is a place where end users are able to deposit waste portable batteries or accumulators , i.e. the premises of a distributor, thus fulfilling its duty of care take back responsibilities. 71. Collection points other than those which are accessible to end users such as a bulking-up points, will be required to register for an exemption under paragraph 52 of Schedule 2 to the Waste Management Licensing Regulations (Northern Ireland) 2003 (as amended). The exemption, which presently has an annual fee of £530, will allow up to 5 tonnes of automotive batteries and accumulators and 10 tonnes for portable batteries and accumulators to be stored for a period of up to 6 months after which they will need to be moved to a Treatment Facility. Hazardous Waste 72. Similar to the system in Scotland, hazardous waste producers are not required to register with the NIEA. All movements, with few exceptions, must be pre notified prior to movement with the NIEA. Part 8 Practical Examples 73. This section provides some examples of how businesses could carry out the storage, collection and transport of batteries in compliance with the regulations referred to in this guidance. These examples must not be read in isolation, but together with the rest of this note as there are cross-references to the relevant parts of the guidance. Back Hauling Back-hauling is the transport of batteries within an existing supply chain via the supplier’s vans or lorries. In other words, the same vehicles that deliver goods will take away the waste batteries deposited in the store. 17 1) Batteries are safely collected in the store – see Part 6 for advice on how to assess that you are collecting safely. 2) The company delivery lorry comes – the driver has received awareness training on handling lithium batteries in accordance with Authorisation 214 and has a document confirming this in the lorry. 3) The retailer will also have received the training so that they can assess that the batteries are packed correctly for transport. They will also have a signed document to show that they have done the awareness training. NB This will last 3 years. (See Part 4) 4) The driver must establish the weight of the batteries. He must be able to demonstrate that he is not carrying more than 333kg of waste batteries. This can be done by having a container which cannot take more than 333 kg of batteries (Part 4) 5) The supplying company (not the individual driver) needs to be a “registered Waste Carrier” and the retailer can (and should if not familiar with the driver) ask the driver for proof. (Part 2) 6) The lorry driver has a pre-printed block of consignment notes with him.(Part 5) 7) The driver puts the weight of batteries on the consignment note and asks the retailer to sign and keep his copy of the consignment note for 3 years. The driver signs his own copy and keeps it for filing in the company system (also for 3 years). (Part 5) 8) The driver puts the batteries in the safe container with the lining and closes the lid. (The retailer needs to ensure it’s done correctly). The driver puts the container in the lorry and makes sure it’s well placed so it doesn’t move during the journey. (Part 4) 9) By no later than the end of the day the driver takes the batteries to a location where they will be bulked-up. (Part 4) 10) The driver asks the responsible person at the bulking-up site to sign his section of the consignment note and leaves him the bottom section for the returns. NB If the bulking-up site is located in England or Wales the operator must make a quarterly report of the amount of batteries collected to the Environment Agency and to the store. (Part 5) If the site is located in Scotland or Northern Ireland the operator must send a copy of the completed note to the respective Agencies. 11) The person responsible for the bulking-up site in England or Wales must keep all the consignment notes given to him by all the drivers in the company and every quarter send a return to the EA on the batteries that they have received. He pays a fee of £10 per return. (Part 5) 18 Collections from Shops selling more than 32 kilogrammes of batteries per year Such shops will need to be ready to take back waste portable batteries on 1st February 2010. Before then we recommend that you contact one or more Battery Compliance Schemes to discuss collection of waste portable batteries from your store for recycling. You have a right to have the waste portable batteries taken away by any of the compliance schemes free of charge. Schemes will arrange collection dates to minimise the environmental impact of the transport involved. Retailers should discuss collection dates with compliance schemes. We do not recommend that you move the waste portable batteries yourself. 1) Batteries are safely collected in the store – see Part 6 for advice on how to assess that you are collecting safely. 2) A retailer contacts a Battery Compliance Scheme to arrange collection. 3) The scheme arranges for a professional waste company to collect the batteries. The scheme must ensure that the collector knows the rules for collecting waste according to Duty of Care, Waste Carriers, Hazardous waste and transport of Dangerous Goods. 4) The remaining steps are the same as for back-hauling. The retailer must have had the basic dangerous goods training to ensure that they know how batteries should be packed for transport. (Part 4) They must ensure the person collecting is that sent by the compliance scheme. The retailer must sign and receive consignment notes from the collector (Part 5). Postal Returns We do not advise postal return as a way to collect batteries from consumers because it is not possible to identify the quantity of batteries being posted, drivers might not know that they are carrying batteries and therefore what action they need to take to carry the batteries safely. It would also be difficult to ensure that batteries are not sent via air. The Department for Transport’s rules for the carriage of batteries are clear - they must be carried by road or by sea. This is because the risk level is heightened when batteries are being flown. 19 Annexes 1 - Authorisation 214 for the transport of up to 333kg of waste portable batteries Source: Department for transport 20 2 - Hazardous Waste – Mock Consignment Note – Source – Environment Agency PART A Notification Details 1. Consignment note code: ABC123/AB001 3. Premises Code: ABC123 2. The waste described below is to be removed from: 4. The waste will be taken to: (name, address, postcode, telephone, e-mail & fax) (address and postcode) The Collection Point, High Street ,New Town, The Shire, XX12 3YY Battery Recycling, Low Street, Old Town, The Shire Tel 0123 456789, [email protected] YY12 4XX 5. The waste producer was (if different from 1) (name, address, postcode, telephone, e-mail & fax) PART B Description of waste 1. The process giving rise to the waste(s) was: Domestic waste collection point 2. SIC for the process giving rise to the waste: ?????? 3. WASTE DETAILS (where more than one waste type is collected all of the information given below must be completed for each EWC identified). Physical Form Hazard code(s) Container type, Description of List of Wastes Qty (kg) The chemical / number & size Waste (EWC) code biological components of the waste, their concentrations Solid H3A, H4, H5, H8, 1 lined rigid bin, Variable depending Separately 20 01 33* 18kg H14 50L on battery type, Collected likely to include. Municipal Lithium oxides , Fractions of metal oxides, and unsorted Domestic salt electrolytes batteries. May (e.g.LiCoO2, include alkaline, LiPF6) mercury, Nickel Lithium, Cadmium cadmium, nickel and Zinc metal metal hydride, Metal Oxides silver oxide, (manganese, lithium, and zinc cadmium zinc) carbon batteries. Metal Hydroxides (excluding lead (Potassium, Nickel, acid batteries) Cadmium, Sodium ) Organic Carbonates Mercury ADR information for each EWC identified above: EWC code Description for Carriage UN Identification number(s) Proper Shipping Name(s) Un Class(es) Special Handling requirements 20 01 33* PART C Carrier’s certificate PART D Consignor / Holders certificate (If more than one carrier is used, please attach a schedule for subsequent carriers. If a schedule of carriers is attached tick here) I certify that I today collected the consignment and that the details in A2, A4 and B3 are correct & have been advised of any specific handling requirements: I certify that the information in A, B & C above is correct, that the carrier is registered or exempt and was advised of the appropriate precautionary measures. All of the waste is packaged and labelled correctly & the carrier has been advised of any special handling requirements. 1. 1. Consignor / Holder name (please PRINT) 1. Carrier driver name (please PRINT) Tony Driver Mr Alan Node on behalf of (name, address, postcode, telephone, e-mail & fax) 2. On behalf of (name, address, postcode, telephone, e-mail & fax) The Local Authority, Middle Street, Old Town, The Shire, YY32 1ZZ Tel : 0987 123456 e.mail: [email protected] 3. Carriers registration no/ exemption reason: The Collection Point, High Street ,New Town, The Shire, XX12 3YY Tel 0123 456789, [email protected] Signature A.Node Time 18.00 Date 29/02/2008 ABC/012345 4. Vehicle registration no: AN07 1DE Signature T.Driver Time 18.00 Date 29/02/2008 PART E Consignee’s Certificate (where more than one waste type is collected all of the information given below must be completed for each EWC) Individual EWC code(s) received Quantity of each EWC code received (kg) EWC code accepted / rejected 21 Waste Management operation (R or D code) 1. I received this waste at the address given in A4 on 29/2/2008 Name: (please PRINT) BERNARD ATTERY 2. Vehicle registration no (or mode of transport if not by road): AN07 1DE On behalf of (name, address, postcode, tel, e-mail & fax): Where waste is rejected please provide details: Battery Recycling, Low Street, Old Town, The Shire, YY12 4XX Tel : 0987 654321 e.mail: [email protected] 3. I certify that the waste management licence / permit / authorised exemption no(s). Signature: Bernard Attery Date: 18.30 authorises the management of the waste described in B at the address given at A4 Time: 29/02/2008 22 3 – General Awareness Training for the handling of waste portable batteries Source DfT and VCA Carriage of Dangerous Goods by road Advice for General Awareness Training on the Movement of Portable Waste Batteries If you transport dangerous goods it is a requirement that personnel involved in any aspect of the transport chain shall be trained. Training has to be commensurate with responsibilities and a record must be maintained. This advice is intended to assist those organisations collecting waste batteries from consumer sites such as shops and offices. It is not definitive and may need to be adjusted to take account of particular distribution systems. If you are involved in the transport of portable waste batteries, then as part of the requirements you need to have some general awareness training which will help you consign, pack and transport the batteries safely. The Department for Transport has issued an authorisation allowing mixed waste batteries to be transported by road without the full application of the ADR provisions. If you don’t comply with the conditions of the authorisation, then you need to comply fully with the provisions of ADR which are more onerous. A load of mixed waste portable batteries will contain various types of batteries, probably including lithium batteries. Lithium batteries are classed as dangerous goods in transport because, if transported incorrectly, they may catch fire and consequently pose a hazard to people. For this reason you need to be aware that whenever you transport a mixed load of batteries, that load is highly likely to contain some lithium batteries. What training do you need? Well that depends on your role in the transport chain but it isn’t complex or difficult, it’s quite straightforward. This note aims to give you the training you need in order to ensure you fulfil your obligations in relation to your role. 23 A. If you are a consignor – i.e. the person who allows other people to deposit their waste batteries on their premises for future collection and removal e.g. retailer or the responsible person in a public building, school, library etc. • • • • Make sure you site your collection container in suitable place so people can easily deposit their waste batteries and that the person coming to collect the container or its contents can get to it easily without disrupting your usual business too much. You could put the container outside if you want provided it can cope with the varying weather conditions. You need to make sure that the container you provide is suitable for the batteries. The batteries will be collected inside a plastic liner placed inside a box or drum. Plastic liners can only be used once. The driver will need to know the weight of the batteries in your container as he can only carry a maximum of 333kg on his vehicle. Either your container can be marked to indicate approximate weights or the driver can weigh the batteries. You need to be present to ensure the driver removes the batteries and places them in the required box/drum for transport as per the authorisation. The liner must be sealed shut (using a tight knot, tape or cable tie to ensure that batteries can’t move about) before being placed in the outer box or drum which is marked with the required lettering as per the authorisation. If the box or drum doesn’t display the marking, don’t allow the driver to use it. You are the consignor and hence responsible for making sure the batteries are packed for transport properly. You could face enforcement action if you don’t. B. If you are the driver arriving to collect the batteries • Check what container the consignor has. You may need to tip the batteries into a liner if the container doesn’t have one so make sure you have a supply on the vehicle. If it does have one, you may need to replace it when you remove it and it’s contents of batteries. Again make sure you carry a supply. • Check the weight of the batteries as you can’t go over the 333kg limit. • You need check that the liner has been tightly closed so the batteries can’t jump about inside. If the consignor hasn’t done this then you will need to. • The sealed bag needs to be put in the outer drum or box, if it isn’t already. You need to ensure the boxes or drums you put on your vehicle are marked according to the authorisation i.e. USED LITHIUM CELLS in capital letters which are a minimum of 12mm high on a contrasting background. Make sure that the box or drum is tightly packed. This also ensures the batteries and the liner don’t jump about too much whilst your vehicle is on the move. • When you have finished collecting or the 333kg limit has been reached the batteries need to be taken to the bulk up point. Make sure you empty all the 24 boxes/drums containing the waste batteries out of the vehicle as no batteries must be left in vehicles overnight or taken or left overnight in a location that is not designed for the collection and storage of large quantities of waste batteries. C. If you are the carrier supplying the driver who is going to collect the batteries: • You may need to ensure your driver has the right boxes/drums on his vehicle before setting off. In addition that he has a supply of liners and suitable means of sealing them. It maybe that the consignor has all this in place so you don’t need to do anything except advise the driver only to pick up batteries that are in the right boxes /drums. • You need to ensure that the driver knows about the 333kg limit and doesn’t exceed it on his vehicle so you need to check and agree with the consignor how this can be achieved. It is essential that trainees show they have understood their duties and in this respect an assessment should be carried out. Set out below are some test questions that could be used. 1. 2. 3. 4. 5. Why are lithium batteries are considered dangerous in transport? What type of liner should the batteries be put in? What words should be marked on the outer drum or box? How big should the letters be? What’s the maximum amount of waste portable batteries that a driver can carry on his vehicle? 6. Who’s responsibility is it to ensure the driver only fills the correctly marked boxes or drums? 7. A driver finishes his collection round can he take his vehicle home with the batteries still on board? 8. Who’s responsibility is it to ensure the driver has the correctly marked boxes or drums? 9. Who’s responsibility is it to ensure the maximum limit of batteries is not exceeded. 10. What sort of things can you use to seal the liner shut? 25 26
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