IPA
THE INDUSTRIAL PACKAGING ASSOCIATION
www.theipa.co.uk
Representing Industrial Packaging within Government, Regulations, Standards and Enforcement Collection of Empty, Uncleaned Packaging & IBCs
January 2015
Page 1 of 2
Following recent changes to the Environment Agency’s WM2 (rev3) Guidance on Hazardous
Waste, the following guide is provided to assist IPA members:
1.
Is it Waste?
Empty, Uncleaned Packaging destined for direct reuse may not be a waste item.
For example – used packaging that is suitable for reuse and requires only a simple rinse,
inspection and test prior to reuse, may not be classed as a waste item.
Used packaging that is damaged or requires specialist, industrial processes, such as chemical
cleaning or physical re-shaping / de-denting / reconditioning would be classed as waste.
2.
Is it Empty?
*Empty” means that all reasonable efforts must have been made to remove any left-over contents
from the container. This may involve for example physical or mechanical means such as draining
or scraping. The method of emptying will depend upon the container and the substances
involved.
2.1
Note: The ADR regulations forbid drivers & driver assistants from opening Dangerous
Goods Packaging – therefore the driver must rely on the description of ‘empty’ on the
consignment note or other appropriate, safe method to check if the container is empty.
3.
Is it Hazardous?
WM2 (rev3) simplifies the classification process for hazardous waste. In summary, any empty,
uncleaned packaging, with a hazardous product label or containing used Mineral Oils is
considered to be Hazardous Waste.
To comply with transport and safety regulations such as ADR and COSHH, the correct product
labels must remain in place and be legible.
3.1
Note: Packaging that is not cleaned may not be crushed or bailed as this would render
the product residues unidentifiable – thereby breaching safety, environmental and transport laws.
4.
Consignment:
4.1
Dangerous Goods
Empty, uncleaned packaging that contains Dangerous Goods (as defined by ADR) must be
consigned in accordance with ADR. However, allowances are in place, such as ADR 1.1.3.5 and
UK specific derogations which enable transport without the full ADR / UN description.
4.2
Hazardous Waste
Empty, Uncleaned packaging containing Hazardous Waste must be consigned in accordance
with Hazardous Waste Regulations. The IPA has agreed use of a simplified consignment note
with the UK Environment Agency and that the correct EWC Code to use is: 15-01-10*.
A continuation sheet should be attached to the Hazardous Waste Consignment Note to indicate
each of the hazard properties found in the consignment.
4.3
Note: Used packaging that is NOT correctly emptied must use the EWC codes for each
waste product within the packages.
The Industrial Packaging Association
Boval House, 24 Mount Parade, Harrogate, North Yorkshire HG1 1BX England
Tel: +44 (0) 7770 – 633320 Fax: +44 (0) 7053 642594
E-Mail: [email protected]
January 2015
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5.
Receipt & Storage of Empty, Uncleaned Packaging:
If the empty, uncleaned packaging is waste, then either an appropriate Exemption Permit or a
Waste Treatment or Transfer Permit must be in place for the premises.
If the empty, uncleaned packaging is consigned as Hazardous Waste then the receiver should
have a Hazardous Waste Treatment or Transfer Permit.
The consignment documents should be checked to ensure that all details are correct – including;
• Hazardous Waste Producer registration number, contact details & signature.
• Consignment Note Number.
• Correct Waste Description and EWC coding
• Carrier details - including Waste Carriage Registration and signature.
• Waste Receiver details and appropriate permit numbers for transfer or treatment
The actual load should be checked to ensure that all items are as described – including;
• Packaging types – such as Drums, IBCs and related capacities.
• Amounts as described
• Product labels for any residues are in place and legible – especially hazard labels
• Product hazards are as described on the consignment note & continuation sheets
• Product hazards as described are acceptable within the site’s permitted activities.
5.1
Note: It is not standard industry practice for receivers of empty, industrial packaging to
sample or analyse each residual product within empty, uncleaned packaging, as this
would prove commercially impracticable. The inspector / un-loader relies on the correct
product labelling to be in place and legible. The product details as labelled on each
container should be checked against the site’s permitted materials and other safety
considerations such as COSHH.
5.2
Note: It is not standard industry practice to store empty, uncleaned packaging in
segregated areas according to product residue types. Empty, uncleaned drums and IBCs
are typically stored according to the design type of each container, as the risks associated
with properly emptied containers are accepted to be significantly lower than full or part-full
packagings.
6.
IPA position on scrap recycling of used packaging:
The destruction of perfectly reusable drums and IBCs is contrary to good environmental practice.
The Waste Hierarchy clearly states that reuse is preferred to recycling and each Duty of Care or
Hazardous Waste consignment document includes a clear undertaking by the Consignor to
ensure this hierarchy is maintained.
The crushing or bailing of uncleaned packaging is dangerous and illegal, as it causes the labelling
and identification of residual products to be impossible – putting any subsequent transporters or
handlers of the packaging at serious risk and in breach of both transport and safety laws.
For further information on handling Empty, Uncleaned Packaging please contact The IPA.
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