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New Waste Regulations..


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Anyone heard the latest rubbish from the EA and the HSE regarding pest control waste?

You can read more about it HERE (link).

 

From what I can gather at a glance, 'spent' bait will no longer be classified as 'controlled' and will now be classified as 'hazardous', and as such, will need a consignment note when you remove it from a clients premises. :no:

 

There is a partial victory in all of this in that the BPCA have managed to get an exemption from the standard fee of £5 for every consignment note.

 

It also seems that any vehicle used to transport pest control waste will now have to be registered as a waste carrier; previously if it was your own waste generated as part of your everyday work there was no requirement.

 

It's crap like this that makes me glad that I don't do general pest control work anymore. Happily, I'm now 100% non-toxic, and just do moles.

 

For those of you reading this that work in the conventional pest control industry you have my sympathies :yes:

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It is a bizarre state of affairs when rodenticides become more hazardous as soon as you take them out of the tub! They are 'not classified' when you buy them, they are 'not classified' when you use them..... but become classified as 'hazardous' once you remove them.

The tub they are in is just a tub until all the bait is removed.... then it becomes hazardous. Although the gloves you pick up the bait with remain 'controlled'.

It would be nice to think that somewhere along the line we see common sense prevail.....

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the big boys get bigger and the cowboys and new start ups increase by the day. one more reason my business will be up for sale in the next year or so...

 

 

Good luck with that Dido.

 

Only the other day I had someone phone me out of the blue to ask if I was selling (I don't know who it was before anyone asks). If only they'd called me 18 months ago....

 

 

It is a bizarre state of affairs when rodenticides become more hazardous as soon as you take them out of the tub! They are 'not classified' when you buy them, they are 'not classified' when you use them..... but become classified as 'hazardous' once you remove them.

The tub they are in is just a tub until all the bait is removed.... then it becomes hazardous. Although the gloves you pick up the bait with remain 'controlled'.

It would be nice to think that somewhere along the line we see common sense prevail.....

 

 

I remember when the regs first came in. At that time I was a big user of Strychnine. I used to use a motorbike to go and pick it up at the Boots chemist on the high street to avoid the traffic and load all the bottles into my coat pockets before heading home to put it away in the cabinet. When the new regs came in which prevented the burial of the empty bottles on site I had to fork out for disposal. I suggested that I could take the empty bottles to the waste transfer station to save money and was told that I couldn't unless I registered as a licenced waste carrier. So I could carry the full bottles any way I liked, but when they'd been emptied out and washed out they were too dangerous for me to carry!! Madness, complete madness....

 

What exactly constitutes 'spent'?? Most redundant bait can be recycled for use elsewhere surely?

 

Am I right in thinking domestic premises are exempt? In which case farms, etc, where someone's living on-site might also be ok. Or is that wishful thinking?

 

 

Nope.

 

From what I can gather, any 'spent' rodenticide bait that is removed will be classified as 'hazardous' and require a waste transfer note.

 

Blatta will be much better informed of this issue than me.

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Matt, if I remember correctly Mr Muddy is correct and waste pesticides produced at domestic premises are exempt.

 

With regards to the 'Waste Transfer Note', the derogation will allow pesticides to be removed and so long as a full 'log' of how much, where and when, is sent through quarterly. Details of exactly what information is going to be acceptable is not clear at this point but you will not have to submit loads of individual Waste Transfer Notes. There will be a charge of £10 per quarter.

Note that this will get the waste as far as your depot / office waste area; after that any waste will have to be collected as hazardous waste with all the charges that will be involved with this.

 

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Matt, if I remember correctly Mr Muddy is correct and waste pesticides produced at domestic premises are exempt.

I stand corrected.

 

So any local authority, or company providing services to domestic properties will not have the same burden of regulation and administration? Seems unfair to me, and yet another way to try and separate the commercial and domestic sectors...

 

 

With regards to the 'Waste Transfer Note', the derogation will allow pesticides to be removed and so long as a full 'log' of how much, where and when, is sent through quarterly. Details of exactly what information is going to be acceptable is not clear at this point but you will not have to submit loads of individual Waste Transfer Notes. There will be a charge of £10 per quarter.

Note that this will get the waste as far as your depot / office waste area; after that any waste will have to be collected as hazardous waste with all the charges that will be involved with this.

It still sounds like a right arse to me Blatta... what about storage? Let's say (for example) you have technicians spread all over the country that work from home... will each home address have to be registered for the storage of hazardous waste? Or will they have to deliver their waste straight to the office/stores as soon as they pick it up from the clients premises?

 

The other problem will be PC companies leaving their waste on clients sites when contracts come to an end. Who picks up the tab? When it was controlled waste it was no great issue, and no great cost...

 

All in all, I'm glad I'm out of it.

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Registering as a waste carrier.

 

This might not be such a big problem as it sounds.

Registration is free if you’re just transporting your own organisation’s waste.

They’re also asking for your company registration number, so I don’t know what that means for sole traders. I doubt it will even discourage cowboys.

 

Here’s the link.

www.gov.uk/waste-carrier-or-broker-registration

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Matt, clearly it is still a pain in the arse! It involves developing a whole new set of systems and then a whole new load of on going paperwork. The details are still being discussed and the industry is trying to establish where the boundaries are.

 

Muddy, the 'cowboys' will not be discouraged; in fact it will just widen the gap between those that try to meet the legislative minefield and those that do not bother. The higher the overall costs of 'red tape' the easier it is for cowboys to undercut / have larger the margins. When the potential margins are higher, it becomes more attractive to the 'cowboy' element.

Edited by blatta
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Muddy, the 'cowboys' will not be discouraged; in fact it will just widen the gap between those that try to meet the legislative minefield and those that do not bother. The higher the overall costs of 'red tape' the easier it is for cowboys to undercut / have larger the margins. When the potential margins are higher, it becomes more attractive to the 'cowboy' element.

 

Very true Blatta,

 

And I’ll tell you something else cowboys don’t bother with: Insurance.

 

While I can’t envisage a scenario where an empty sack of bromabait could lead to an insurance claim, I’m sure as hell it will lead to increasing premiums.

In fact, I’m not sure a lot of peoples’ insurance policies will be valid if they’re unwittingly transporting hazardous waste they aren’t declaring?

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