What Is Hazardous Waste? What Computer Waste is Hazardous?

 By Richard Tj

 

Background

 

Landfill legislation ties into the Hazardous Waste regulations through the use of the Waste Acceptance Criteria (referred to as WAC). The waste Acceptance criteria similarly follows on from the need to control wastes sent to Landfill, thus meeting current EU legislation, reducing our reliance upon landfill and ensuring pre - treatment (segregation & application of the Waste Hierarchy) to our wastes.

 

The UK currently operates four types of landfill sites, each capable of accepting certain forms of waste and only a few are able to accept Hazardous Wastes. The application of the “list of Wastes Regulations (2005) and it’s derivative codes, aims to ensure that wastes are sent to the correct place for disposal. Note: that the European Waste Catalogue (EU Commission decision 94/3/EC) was introduced into the UK via the The List of Wastes (England) Regulations 2005 via Statutory Instrument 2005 no. 895.

 

Relevance to WEEE

 

However, the WEEE Regulations and similar Producer Responsibility Regulations including the Batteries and Accumulators Regulations and Packaging Regulations all aim to further enhance the Landfill Directive and meet our obligations as a European Member state by diverting wastes away from final disposal in Landfill sites. Deemed recoverable wastes, they require treatment and recovery, as opposed to final disposal. Note: The WEEE regulations, like the Producer Responsibility Regulations are derived from the UK’s interpretation and adoption of the Broader EU Directives. Member states are permitted to interpret such Directives into their own Laws and the UK introduces such Directives via legislation. The UK’s interpretation of WEEE legislation should not be taken to be a duplicate of the EU directive.

 

Tied in with the List of Wastes, waste regulations including the Duty of Care and Hazardous Waste regs both require the use of suitable transfer notes (controlled waste and Hazardous Waste) for the movement of wastes throughout the UK. The notes employ the List as a means to clearly define the type of waste being transferred- this mirrors the broader Pan European model, in which EWC codes throughout member states can be easily interpreted.

 

Derogations relating to both non-hazardous and Absolute hazardous are clearly defined within the list, denoting whether a waste should be considered hazardous or not (in the form of a six digit number). In effect applying a definition to the waste, it should be applied at the point of transfer of the waste from holder/producer to waste carrier. The final disposal route should be decided upon depending upon the type of waste removed and may require pre - treatment (i.e. segregation) prior to final disposal. However, it should be noted that Producer Responsibility Directives such as the WEEE directive clearly require the separate collection of WEEE “as a pre - requisite to it’s successful recovery”.
 
How Hazardous Waste is Defined

 

Document HWR01 refers to the definition of Hazardous Wastes, with the application of Both “Absolute hazardous” and “Mirror Hazardous” as terms applied to the codes in the list (EWC). Absolute hazardous implies that by their very nature a waste is hazardous. In the list (EWC), 16 02 13* refers to hazardous electronic equipment and 16 02 14 as non-hazardous. There is no mirror entry for either (a mirror entry is where the same waste may contain either hazardous or non-hazardous components) and both entries are very generic, covering a wide range of equipment.

 

The Hazardous Waste Regulations (2007) offer a means to interpret the hazardous nature of a waste, with Annex 1(A and B) giving direct reference to known hazardous wastes. Annex II and III of the same regulations allow for further analysis of the properties of a waste. Like Appendix A of HWR01, the potential effects of the waste on the environment and people can be considered by assessing the potential harm, as well as the contents/ components of the waste. Annex II of the Hazardous Waste Directive makes reference to known substances/ compounds which are hazardous. Annex III provides reference to the potential harms a waste may give rise to. Listed H1 through to H15, they should be applied to a waste to decide whether it is hazardous in the first place. Although a subjective or prescriptive descriptor, it’s our professional belief that materials contained in some computer equipment we recycle meets H5 as we can apply the following description: ““Harmful”: substances and preparations which, if they are inhaled or ingested or if they penetrate the skin, may involve limited health risks.”

 

Of course, this subjective description is applied to certain computer wastes after referring to an MSDS or after assessment of it’s components. However, we’re certain that the following can be considered hazardous wastes under the general category of 16 02 13* on the following grounds:

 

• CRT monitors and Televisions: Presence of Lead, potential for Poly-chlorinated Biphenyls, presence of Phosphor. Lead is a heavy metal, causing long term damage to the human body.
• TFT screens in monitors, TVs and Laptops. Flat Bed Scanners: Presence of Mercury bearing Back lights. Potential for Leaded Solder. Mercury causes neurological damage after long term exposure.- Direct reference to Annex 1A of the Regulations.
• Laptops: Potential for Cadmium, Nickel and Zinc in Batteries. Cadmium is a heavy metal and is toxic in large quantities.- Direct reference to Annex 1B of the Regulations.
• Uninterruptible Power Supplies: Contain large quantities of Lead and also contain Sulphuric Acid. Similar to Car Batteries. Sulphuric acid causes burns.
• Battery Operated equipment: Presence of Batteries containing Nickel, Cadmium and Zinc.- Direct reference to Annex 1B of the Regulations.

However, it’s argued, much of our waste equipment can be considered hazardous. Even if there is not immediate risk to the Environment or human health, other categories provide a similar outcome, requiring the application of the term “Absolute Hazardous” to the above wastes. These include:

• Category H6: Toxic: Relates to the waste (or it’s contents). It does not infer a limit, although Page 5 of HWR01 does refer to “Appropriate thresholds”. However, there is no maximum to volumes of the above that could be incorrectly treated.
• Category H8: Corrosive: Sulphuric Acid, by it’s very nature is corrosive.
• Category H14: Ecotoxic: The eventual breakdown of waste electronic equipment would result in the release and concentration of the chemicals noted above in a small space. Their release would be toxic to the local environment through “Delayed Release”.