New Waste Regulations

[Mr Muddy 141]

Hopefully everyone can just cut, paste and email the letter from this thread.

 

But I will need someones help filling the gaps.

[StephenWalsh 73]

I have copied this from a website:

 

Trade Waste Agreements
It is an offence not to have a Trade Waste Agreement (an arranged waste collection) if you produce any waste from your business. If you do not have a Trade Waste Agreement then you should make immediate arrangements for the collection or transfer of all your trade waste. These documents should be kept for 2 years as can be requested at any time, this is a legal requirement for your business to show how your waste is being disposed of.

Under Environmental Protection Act 1990 and Regulations made under it, failure of a business to prove that the waste it produces is being disposed of responsibly through the submission of a Waste Transfer Note will result in a Fixed Penalty Notice or the beginning of Court Proceedings.

I am already registered with Killgerm under their trade waste scheme, it's just the transfer note thing. But for anyone who isn't already registered...

[outandabout 27]

Too much hassle for me without the opportunity for more profit. I'm giving up rodent jobs completely and sticking to a bit of bird proofing, moles, rabbits, fleas and wasps.

 

When joe public can "double bag any waste rodenticide and place into household refuse" as I read on an amateur use bromadiolone rodenticide - I'm done with it.

[Mr Muddy 141]

Too much hassle for me without the opportunity for more profit. I'm giving up rodent jobs completely and sticking to a bit of bird proofing, moles, rabbits, fleas and wasps.

 

When joe public can "double bag any waste rodenticide and place into household refuse" as I read on an amateur use bromadiolone rodenticide - I'm done with it.

 

Mate, the moles and rabbits you’ll be alright with (as long as you don’t use gas). But fleas and wasps, you’re still going to need to do the quarterly returns. I’m not even sure about bird proofing if you’re cleaning up after the birds.

 

Basically, if you want to be legally earning money from pest control you’re going to get your pants pulled down.

[DKGPestControl 22]

This whole thing seems fairly simple to me in the main, just more expense and poxy paperwork!

 

The one thing we don't need in the pest control industry is paperwork!

 

Killgerm have been helpful, Laura has spent quite a bit of time on the phone to them over this, but seems we have everything in place as of now.

 

Yet another price increase coming for 2014 contract renewals!

 

At least we don't have to label are mole traps and log how many times they have been used (yet)

Edited March 17, 2014 by DKGPestControl

[StephenWalsh 73]

I spoke to a guy yesterday from a waste disposal company who said we don't need to make the quarterly returns, an annual return will do.

[outandabout 27]

 

Too much hassle for me without the opportunity for more profit. I'm giving up rodent jobs completely and sticking to a bit of bird proofing, moles, rabbits, fleas and wasps.

 

When joe public can "double bag any waste rodenticide and place into household refuse" as I read on an amateur use bromadiolone rodenticide - I'm done with it.

 

Mate, the moles and rabbits you’ll be alright with (as long as you don’t use gas). But fleas and wasps, you’re still going to need to do the quarterly returns. I’m not even sure about bird proofing if you’re cleaning up after the birds.

 

Basically, if you want to be legally earning money from pest control you’re going to get your pants pulled down.

 

Ha, you're right there. I have a way though:

 

I won't produce any hazardous waste from wasp or flea jobs, I will keep all the empty tubs etc for personal use. I will use ALL of the insecticide, so there will be no waste. Fair comment about the pigeon waste but I'm in the fortunate position where I can pick and choose my jobs.

 

The only waste I will produce (gloves, cardboard) cannot be classified as hazardous waste.

 

If regs continue to tighten I may just step away from the industry and do something more profitable/less hassle.

Edited March 21, 2014 by ekpestcontrol

[DKGPestControl 22]

If the gloves, masks or other ppe is contaminated then it will be classed as hazardous. you will need to wear gloves when using the chemicals or decanting them into applicators.

 

Coveralls, boot covers, masks, gloves etc etc from flea treatment will be hazardous waste.

 

If you ready product labels a lot of them state that the packaging isn't to be reused for any other purpose.

 

What will you do with the empty K-Othrine WG250 or other insecticide bottles you get?

 

I don't see any way to avoid this legislation change.

It is an unwanted one but just got to get on with it.

Matt on the other hand just doing moles has no worries.

 

I'm lucky to have Laura in the office to do paperwork so not caused us too much hassle, but I feel sorry for one man bands, who struggle to keep up with work load and paperwork they already have.

[Matt 160]

There is no law to say you have to use disposable PPE when applying pesticides.

 

Polycotton (machine washable) coveralls, nitrile guantlets etc, they are all reusable.

 

I don't think an empty plastic bag from a tub of Ficam D would contain enough pesticide to make it hazardous waste; the issue is more around the reclassification of second generation rodenticides from 'controlled' waste to hazardous waste.

 

Without a doubt, anyone using pesticides is at some point going to produce a small amount of waste, but you aren't going to have to issue transfer notes to customers for that.

 

In addition, I understand that domestic properties are going to be exempt, so providing you restrict your flea and wasp work to domestic properties I can't see the EA being interested.

 

As DKG says, none of this will apply to a jolly molecatcher like me though :-)

[StephenWalsh 73]

I actually got some good advice on this from a mate who is a tatooist. He was telling me that all his used needles and such are classed as hazardous, he has a sharps bin in his studio and once a year gets a firm to pick it up, they sort the paperwork and pays them a £100 or so depending on the weight. Exactly the same for us, now I keep all my empty containers and soiled ppe in a bin in the stores, I have a trade waste agreement with a localish firm, paperwork sorted, problem solved. The EA aren't going to hassle me over these arrangements.

[Matt 160]

I actually got some good advice on this from a mate who is a tatooist. He was telling me that all his used needles and such are classed as hazardous, he has a sharps bin in his studio and once a year gets a firm to pick it up, they sort the paperwork and pays them a £100 or so depending on the weight. Exactly the same for us, now I keep all my empty containers and soiled ppe in a bin in the stores, I have a trade waste agreement with a localish firm, paperwork sorted, problem solved. The EA aren't going to hassle me over these arrangements.

The whole point is about the removal of 'waste' SGARs and items deemed to be contaminated by them from client sites.

 

Regardless of what you do with the waste produced at your stores, it looks like you will now have to issue a transfer note to your client when you remove bait boxes and 'spent' bait from their premises.

 

In addition, you now have to register as a waste carrier as you are transporting the waste which has been transferred from another business.

 

It's all nonsense. Why the EA have suddenly decided to create all this red tape is the question pest controllers should be asking their associations and their MPs.

[DKGPestControl 22]

Domestic work is exempt from requiring us leaving a transfer note with the client, but the waste produce at domestic properties will require a consignment note when it is collected from the store and this is when it will become commercial waste and the EA want to know how you have disposed of it.

 

As for using disposable PPE, it just makes life easier than keeping maintenance reports, Disposable masks etc don't require maintenance sheets but will require waste transfer notes left with commercial clients.

 

It seems your dammed if you do and your dammed if you don't!

[Matt 160]

There is a world of difference between having waste removed from your stores by a licensed contractor, and becoming a waste removal contractor just to replace a mouse box or some unused bait....

 

I used to have an arrangement for the removal of my 'controlled waste' from the stores, and always tried to minimise it. You also have to register with the EA for the storage of hazardous waste, which is not a big problem in itself, but the thought of having to produce transfer notes when you change an EFK tube or uplift some competitors mouse boxes is just hideous in my opinion.

 

Why are the rules changing?

 

Because there have been problems with fly tipping of pest control waste? No.

 

Because there is an issue with secondary poisoning from mouse boxes at waste dumps? No.

 

Because the EA exist to justify their own existence and the pest control associations don't do enough to protect the industry? Quite possibly.

 

Whatever the reason, I'm glad to be out of it and sympathise with those of you left trying to make a living out of the shrinking and badly regulated pest control industry.

[outandabout 27]

Well Stephen, I can't argue with what you've said. I've agonised over this issue for a while now and I'm just going to have to bite the bullet and tow the line.

 

Just signed up as a lower tier waste carrier, and will just charge a high price from now on for ALL rodent jobs that come my way.

 

This is the only way I can see of making it work for me, and my regulars will hopefully understand.

 

I f+£cking hate it though, this new legislation is a great example of double standards and jobs for the boys.

Edited March 28, 2014 by ekpestcontrol

[StephenWalsh 73]

It's all gone a bit crazy. Fancy a story that made me laugh and feel a bit silly at the same time?

 

I did a very small net installation for a charity just before Christmas, and was instructed by the Architects who were in charge of a refurb at the building and realised a bit of bird proofing was in order at the last minute. I duly obliged and a couple of days ago I got a call from the charity because they had a dead pigeon on top of the net (outside the proofing) and the Architects gave them my name.

 

Is it my responsibility? Nope. Did I say as an act of total niceness on my part to go and get rid? Yep.

 

So I get there and are met by a senior person of some description. The conversation went like this:

 

Customer: "Are you here for the dead bird?"

Me; "That's right."

Customer: "Well, I'm glad you came, we've had nothing but trouble over this net."

Me: "Really, why?"

Customer: "Well for a start off the Committee hauled me over the coals because it isn't compliant."
Me: "What?"

Customer: "Whoever put it up didn't bother about it being compliant!"

Me: "I put it up!"

Customer: "Well, it isn't compliant."

Me: "Compliant with what?"

Customer: "Animal Cruelty."

Me: "Ah, the Animal Welfare Act doesn't say you can't put nets up to exclude birds."

Customer: "That's not what the Committee has told me."

Me: "I'll just get the dead bird."

 

Oooh, just had a thought. Was the dead bird controlled, hazardous, trade or some other classification of waste???

Edited March 28, 2014 by StephenWalsh