Martin Wiles Energy and Environmental Manager

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Martin WilesEnergy and Environmental Manager

• University of Bristol
• Energy Environmental Management Unit (EEMU)

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Martin WilesEnergy and Environmental Manager

• The University of Bristols Approach to Hazardous
  Waste

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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.

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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.

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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.

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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.

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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.

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The General 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

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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.

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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.

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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 hasnt
  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!

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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.

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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.

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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.

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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.

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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.

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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.

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Implementing the new clinical HW system

• Employed two waste management technicians.
• They covered the new system, also assist with
  wider waste issues and meter reading.
• Set up training for these technicians
• A train the trainer session will be run in the
  future.
• The technician are helping to carry out detailed
  audits within departments to identify exactly
  what waste they are producing and how the
  logistics of collecting it will work.
• Delay both technicians left!

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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. Managed
  to get coverage for all departments finding out
  if they are the right people!
• Training for these responsible people will
  start during the next six months.
• 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.

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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
  FAQs on.

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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.
• Visit by the Environment Agency!!!

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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.

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Thank you any questions