Hazardous waste workshop – mobile systems
February 1st 2008 The compressed air industry provides service and maintenance as a core activity
and therefore anything that adds cost, such as the introduction of legislative
controls, is not a welcome addition to the company/customer relationship.The
BCAS held a workshop on 30 January 2008 to focus on the implications of the
mobile services guidance produced by the Environment Agency
The mobile services
guidance produced by the
Environment Agency is part
of the many provided under the
Hazardous Waste Regulations.Of
particular concern is the charge
made for the removal of waste oil
from a customer's site, which is £10.
For a company to benefit from
the Mobile Services feature of the
regulations then it should not
generate more than 200kg of waste
oil from any one customer site in a
12 month period.The movement of
that waste oil must be subject to a
consignment note to identify that
the oil is to be removed from the
customer site and taken to another
facility such as the Mobile Service
providers own premises.
This part of the problem was
identified during the workshop, the
movement of waste oil and the
quantity collected from any one site
was the issue.Rather than any
concerns in exceeding the 200kg
upper limit in a 12 month period or
even in one movement, the issue was
at the other end of the scale where it
was demonstrated that there were
many movements of 2kg to 3kg from
any one site with up to eight sites
being visited in a day. Under the
current system the £10 charge would
be made for each and every one.
Another cause for
misunderstanding of the Hazardous
Waste Regulations was the lack of a
simple explanation of the systems
involved where the relationship
between people, places and
activities could be identified.To this
end it was agreed that a flow chart
would be produced by BCAS with
the help of the Environment Agency
to help explain the relationships
between consignee, consignment
note, service premises and so on.
Of key importance was an offer by
the Environment Agency that the
BCAS should put forward a case for
its members to be able to perform
the mobile services activity without
having to make the £10 charge for
each and everyone of the
movements of waste oil.This would
be considered on its merits and may
result in a benefit to members
without compromising the
environmental aspects of the
Hazardous Waste Regulations. More articles from BCAS: | 
