I have a site who dispose of empty resin tins and paint tins in their general waste skips. How can I advise them against doing this and what piece of legislation backs up my reasoning?

If empty packaging contains residues or is contaminated by any hazardous substances which display a hazardous property, then this will be classified as hazardous waste under the EWC code 15 01 10*. This is an absolute hazardous entry.

For example:

  • An empty tin of resin containing any quantity of resin (resin is hazardous, and possesses a range of hazardous properties)
  • An empty paint can labelled with danger symbols, containing dried paint or contaminated residues of a paint that contain ecotoxic heavy metals (note that dried paint may increase the concentration of other hazardous substances present as water/solvent evaporates)

This packaging would only be non-hazardous if:

  • It does not contain any contamination or residue (e.g. the residues and contamination have been removed by effective cleaning), or
  • The contamination or residual material is not a hazardous substance(s)

The legalisation that covers this is Waste Classification – Guidance on the classification and assessment of waste – Technical Guidance WM3′. The industry guidance on the assessment and classification of waste packaging, both of which can be found here:

How do we identify if a load will be ADR or not? What is ADR?

ADR comes from the French for the “European Agreement concerning the International Carriage of Dangerous Goods by Road” which is a treaty dating back to 1957 from the United Nations regarding the governance of international transport of Dangerous Goods.

ADR sets out the requirements for the classification, packaging, labelling and certification of dangerous goods. It also includes specific vehicle and tank requirements and other operational requirements.

If site have containers where the labels have been removed or there are no distinguishing marks what steps can be taken to get the material removed?

One of our mobile chemists can come out to your premises, sample the material and we’ll analyse the material and quote you based on the results.

What is the difference between having a waste classification and a WAC test?

Waste classification is the analysis used to classify if the material is either hazardous or non-hazardous waste, following the procedure in the Environment Agency Document WM3.

WAC testing is required after waste classification and tells you what type of landfill can be used to dispose of the material, once it has already been classified as hazardous or non-hazardous waste.

How can an oil spill on soil or soft ground be contained?

If a spill has contaminated the ground, the soil will need to be cleaned up along with any floating oil and any affected water.  If the spill is recent, small and limited to shallow soil, then this is a minor spill.  Check the soil, working out from the source of spill to find out where the oil now is and if it’s limited to a few buckets worth of soil, dig up the oily and stained soils. Remove any free oil and dispose of soil through a specialist waste contractor.

A larger spill of oil has the potential to contaminate a lot more soil and groundwater. In this case, both soil and groundwater need to be assessed and possibly cleaned up by a specialist waste contractor.

Acumen Waste’s industrial site services division are experienced in a variety of soil and groundwater clean ups and can attend site do discuss requirements.

Is landfill the only option when disposing of leadshot blast waste?

No there are other recycling and treatment options for leadshot blast waste, but are dependent on comprehensive testing.

Acumen can provide both on site chemists and full testing services.

How do we know what wastes a subcontractor can manage on our behalf?

Acumen have a dedicated supply chain management team who are responsible for any works that are not conducted on their own wheels. These are generally trade waste services and general waste skips. Should a waste partner be utilised for any waste service then Acumen will provide a comprehensive environmental sustainability pack which will detail the carrier and disposal licence for that individual waste activity.

Do we need to use a ventilated drum for aerosols?

Storage of aerosols must take place in secure well ventilated containers which are not subject to extreme temperatures or direct sunlight.

Aerosols are often contain gases that are denser than air, such as propane and butane, which can accumulate in low lying areas and form a potentially explosive atmosphere.  Vented drums enable these to escape, so by reducing the potential of an explosive atmosphere being created in the drum.

Do you think the FORS standard of vehicles will, in time, become mandatory?

FORS (Fleet Operator Recognition Scheme) encompasses all aspects of safety, fuel efficiency, vehicle emissions and improved operations and helps fleet operators to measure and monitor performance and alter their operations in order to demonstrate best practice.

What is the difference between commercial waste and waste produced on construction sites?

Commercial waste is defined as any waste product that is created from commercial activity. Generally this is light compactable or recyclable wastes that are disposed of via REL/FEL, wheelie bins or bagged collections.

If I arrive on site to find fly tipped waste what do I do and who should I call?

Acumen operate a 24hr emergency response line and have dedicated teams who are able to react quickly to immediate and scheduled requirements including fly tipped waste collections.

What is the most suitable material to contain a spill on site if no spill kit is available?

If you have a spill and a spill kit isn’t readily available, you may be able to contain it using materials already on your site like for instance dry sand/sand bags and earth may soak up a spill of oil or chemicals. Sand bags can be used to channel substances to a collection point, to block off drains, contain spills or to dam ditches. Once contaminated, sand and sand bags must be properly disposed of in accordance with the Duty of Care and not washed into drainage systems.

Other items could be used such as:

  • tarpaulin and wooden planks to create a temporary boom in a river;
  • fire hoses used as a boom;
  • straw bales used as a boom and absorbent;
  • a car foot well mat or a sheet of polythene, weighed down with sand or earth as a drain seal.
Can all spills be hosed/jetted into drains?

No, they can’t.  Spills should be contained where possible at the source. If the primary container or secondary containment have been breached or failed for any reason, try to contain the spill where it’s happening. This will reduce the quantity of material released, meaning there’s less spilt material that can cause pollution.

If you can’t stop the spill where it’s happening, aim to stop it as close to the source as possible. Where the spill has escaped from the primary and secondary containers you should try to stop it spreading.  Use absorbents such as spillsorb, booms and spill mats to soak up the spill and to stop any further spread. All used absorbents must be disposed of according to Duty of Care and, if soaked in oil or chemicals, will be classed as hazardous waste.

In some very small cases, it may be possible to hose spilt material into a drainage system if it’s a sealed drainage system, allowing the incident to be dealt with more quickly and safely. However, you must make sure the spilt material won’t cause any unwanted reactions such as creating an explosive atmosphere within your drainage system.

What is a roll on roll off skip?

The next step up from a traditional skip, Roll On, Roll Off skips (also known as RoRo skips) are ideal for construction and industrial organisations who need to dispose of a high volume of waste with capacities ranging from 20 yards up to 40 yards.

Are there weight limits on skips?

The capacity of a skip is measured in cubic yards. As a rule of thumb, one cubic yard will contain up to one metric tonne (1,000 kilograms) of waste.  Therefore, a skip with a capacity of eight cubic yards will carry a maximum weight of eight tonnes.

Can I use skips for hazardous waste?

Some hazardous material is suitable to be collected in skips, examples being contaminated soil, asbestos and shotblast.  You must always check with the skip provider if the material you want to place in the skip is appropriate first.

Do all skips have drainage holes?

No, skips are available with drain holes, capped drains, or fully sealed, dependant on the material which is to be placed in the skip. Acumen will work with procurement and site management teams to advise what container is most suitable.

How do I know if hazardous containers are UN approved, how do I know if a container needs to be UN approved?

All packages manufactured under the UN certification scheme for the carriage of dangerous goods are marked with a code that indicates the physical nature of the product for which they are suitable, materials used to construct the package, maximum gross mass or specific gravity, year, and location of manufacture and whether the packages are suitable for dangerous goods of packing group I, II or III. The code always starts with the letters “UN” in a circle.

Packages that do not display the UN certification mark must not be used for dangerous goods.

Can all liquid wastes be collected in a tanker?

No, although there is a wide variety of hazardous and non-hazardous liquid wastes that can be which include:

  • Flammable solvent-based paints, resins and adhesives
  • Rinse waters, spent solutions and effluent sludges from metal plating and treatment processes
  • Acid and caustics
  • Oil and water interceptor waste from vehicle and plant wash-down interceptors
  • Contaminated water
  • Leachate from landfills
  • Spray booth liquids and sludges
  • Pharmaceutical and pesticide contaminated liquids
  • Garage and petrol station forecourt interceptors
  • Aqueous washings
  • Food wastes from bakeries, food processing facilities and food factories, including cooking oils and washings
  • Gully waste from roads