Martin Wiles

Energy and

Environmental Manager

University of BristolEnergy & Environmental

Management Unit (EEMU)

Martin Wiles

Energy and

Environmental Manager

The University of Bristol’s Approach to Hazardous Waste

Format of case study

• Finding out about HWR.

• Identifying what we needed to do.

• Auditing.

• First steps to compliance.

• Developing specific systems.

• Our main management system.

• Future developments.

• Conclusions.

The starting point

• Early 2005 – Aware of new Hazardous Waste

Regulations (HWR) coming into force.

• Very unclear what impact HWR will have.

• Starting talking to departmental supervisors to find out

how ‘special waste’ is managed.

• Felt the need to pull together people with a vested

interest in HWR to develop an overall approach.

• Set up Hazardous Waste Working Group (HWWG)

April 2005. Chaired by Deputy Director Building

Services.

Finding out more

• First meeting of HWWG agreed approach to HWR. The

aim was to start by reviewing current practices, leading

to auditing and then any new procedures.

• Invite Environment Agency to a HWWG meeting to

discuss specific issues and help direct us in an

approach to HWR.

• It became clear that the EA was not set-up to help us in

this way, but did identify lots of potential areas for non

compliance – thanks!

• Departmental representatives very worried by EA

meeting.

Finding out even more!

• Unclear where responsibility for meeting HWR lies

within the University. Departments? Estates Office?

Safety Office?

• Opened up a more general debate on meeting the

requirements of Environmental Legislation.

• Clear that depts had a key responsibility, but they

needed help in complying.

• Also concern that a mixture of approaches would be

adopted by departments and lead to problems in

terms of reporting, returns to EA and so on.

Auditing and Responsibility

• On the back of another project (incineration),

funding is made available to carry out a general

compliance audit for the University (£5-10K).

• Responsibility for addressing HWR placed with the

Energy and Environmental Management Unit

(EEMU). EEMU to set up procedures to assist with

compliance.

The Audit

• Explain regulations and role of regulator.

• Identified actions including;– Appoint responsible person– Register sites/premises– Codify waste (EWC codes)– Introduce or revise paperwork for consigning and storing

waste– Prohibit mixing of non-HW and HW– Audit HW procedures, facilities & personnel– Records and returns– Recommended a management structure

• Lots of other specific issues for departments

relating to these actions

The Audits General Conclusions

• Many hazardous waste streams already have

procedures in place, e.g. fridges, fluorescent tubes.

• New collection systems set up for batteries, paints,

oily rags etc. Safety Office managed systems for

chemical and radioactive waste.

• Some refinement of existing systems was required.

• Major stream for HW identified as ‘clinical’ waste.

• Vet school, Medical school, Hospital.

• Much confusion over definitions, clinical, infectious,

non infectious, haz. and non-hazardous.

First steps to a compliant system

• Prior to audit we had identified the need to register

sites with the Environment Agency.

• Debate over what was a site, how different sites were

linked. Debate over registering buildings.

• EA defined in the end, enabled UoB to register 8

sites. There are likely to be more possible sites, we

are evaluating if more fall into scope.

• Consignment notes were required.

• Modified template from regulations to do this.

Consignment notes

• Set up a system to provide consignment notes with

a site specific reference.

• Used this for internal transfer/consignment notes,

but using for third party carriers hasn’t been so

easy.

• Third party contractors have issued their own notes

and codes and refuse to use ours even though the

regulations put the onus on us!

Developing Management Procedures

• Environmental unit to set up management procedures.

Already set up systems for fridges etc.

• Identified ‘clinical waste’ as a major HW issue.

• Much of the clinical type waste fed into an incinerator,

therefore needed a collection system compliant with

HWR.

• Initial thoughts focused on bins externally placed to

departments, which departmental technicians could

place bags of coded waste into for collection by a third

party or our staff.

Developing a Hazardous Waste Collection System

• Reviewed this approach with our compliance

consultant, identifying potential points of failure for

such a system.

• For this system, no control on what is put in the bins or

for that matter what is left by the bins!

• Call this a critical control point.

• Decided to review a range of options with the aim of

setting out the critical control points and the costs

associated with reducing our exposure in these areas.

Developing a Hazardous Waste Collection System

• As part of the compliance audit work, our

consultants reviewed all the options and carried out

a risk analysis.

• Based the analysis on five consolidated potential

contravention risks.

• Duty of care, waste segregation, consignment

documentation, records and returns and accidents

and emergencies.

The five options considered

1. HW is bagged by departmental staff and collected by a

third part contractor or UOB staff to incinerator.

Basically no change.

2. As 1, but EWC coded, bagged and stored by the

department ready for collection.

3. As 2, dept staff move to a storage area within or by

their building ready for collection, ie external bins.

4. As 2, but departmental staff move to a central

University store and are received by store personnel.

5. Waste technicians collect waste directly from labs, lab

staff sign for waste transfer, labelling and bagging.

Results of risk assessment

• Option 1 – Failed all five critical control paths

• Option 2 – Failed two

• Option 3 – Failed four

• Option 4 – Failed three

• Option 5 – All five critical control points effective

• Costs, option one the most expensive, followed by

Option 5, closely followed by 4 and 2.

Which system to use

• Agreed best option was to employ staff to collect

waste directly from labs/source.

• Estimated costs of setting up and running this

procedure, £30K set up and £50K running costs.

• Funding – would have been borne by estates office

(added to our resource allocation system), but

closure of existing incinerator offered about

£50,000 a year to cover these costs.

Implementing the new ‘clinical’ HW system

• Employed two waste management technicians in April

2006.

• They cover the new system, also assist with wider

waste issues and meter reading.

• Setting up training for these technicians, including a

‘train the trainer’ session. To be carried out in July.

• The technicians to carry out detailed audits within

departments to identify exactly what waste they are

producing and how the logistics of collecting it will

work. August and September.

Implementing the new ‘clinical’ HW system

• Departmental ‘responsible’ people are being

recruited and will act as the initial contact for the

audits, further ‘responsible’ people will be recruited if

needed following the audits. Recruitment has started

and we have about 50% coverage.

• Training for these ‘responsible’ people will start in

September.

• By then the types of waste, locations for collection,

bags, labels and so on will be identified and in

place. The system will be rolled out department by

department.

Implementing the new ‘clinical’ HW system

• In the meantime, using a compliant system of collection, bagging and labelling, collecting for disposal at our incinerator via a designated incinerator operator, or via a third party contractor.

• Compliant but open to risk.

• Carrying out returns to EA for consignment.

• Setting up web site with all regs, procedures and FAQ’s on.

Future developments

• Tackling our hospital sites. Dealing with two hospital

trusts who deal with our waste and have very

different approaches.

• Variations to scheme, due to amounts of waste at

our vet school site, bins are being used currently,

rather than direct collection from labs. Reviewing this

as part of auditing.

• Reducing the amount of HW, education of users, tie

up with purchasing.

Conclusions

• Steep learning curve.

• Tried to reduce risks within system.

• Favoured service based system.

• Do need to be pragmatic and practical.

• Costs of system possibly higher, but more time

required to evaluate.

• Benefit from use of incinerator.

• Invaluable help from compliance consultant.

• Regional variation of EA approach.

Thank you & any questions