Defra advises against post-back schemes for batteries

Defra issued the advise in an advisory note on the storage and transport of waste portable batteries published last week (July 24) in which it raised concerns surrounding the safe transport of potentially hazardous material in a postal return system and how to identify the quantity of batteries being posted.

In the document, Defra states: “We do not advise postal return as a way to collect batteries from consumers because it is not possible to identify the quantity of batteries being posted, drivers might not know that they are carrying batteries and therefore what action they need to take to carry the batteries safely. It would also be difficult to ensure that batteries are not sent via air.”

The advice comes after the Environment Agency published a position statement in May 2009 which looked to relax the regulatory burden that could ‘inhibit' postal returns for businesses (see letsrercycle.com story).

Advice

Publication of the advisory note follows a commitment made by Defra at a workshop held on May 13 2009 to help companies and schemes understand the Waste Batteries and Accumulators Regulations which came into force on May 5 (see letsrecycle.com story).

The advisory note is intended to help businesses storing waste batteries with a means by which to comply with legislation on battery disposal set to come into force under the Battery Directive on January 1 2010 (see letsrecycle.com story).

The 26-page document identifies a number of issues surrounding waste portable batteries and offers an overview of the collection system and the specific measures that need to be taken when dealing with hazardous waste or dangerous goods in accordance with the relevant legislation.

The note is split into eight parts, and offers advice on a range of topics from Duty of Care to environmental permitting, carriage of dangerous goods, hazardous waste, safe storage of batteries, Scottish and Northern Irish regulations and practical examples of back-hauling, in-store take-back and postal returns.

In its practical examples, back-haulage of batteries is laid out in an 11-step guide from safe collection of batteries in store to the movement of material to the bulking site and the waste carrier keeping consignment notes.

The advisory note suggests that shops should contact compliance schemes to arrange for the collection of waste batteries, with take-back expected to be more prevalent from February 1 2010 when retailers producing over 32kg of batteries will have to accept waste portable batteries back from the public.

Regulations

In its carriage of dangerous goods section, the advisory note identifies a particular health and safety issue posed by the content of batteries and includes a suggested provision of only transporting up to 333 kg of mixed waste batteries per load.

This is because, despite the most popular type of battery being alkaline, the majority of mixed collections will include batteries containing lithium – which are classed as ‘dangerous' under the Carriage of Dangerous Goods Act – or nickel cadmium, which is classed as ‘hazardous' under the Hazardous Waste Regulations.

The note explains that operators of collection points handling lithium batteries will need to arrange for collection of the material through a trained carrier. The carrier must then ensure the batteries are not in a lithium-only load but packed with other battery types in a closed plastic liner within a metal or plastic drum or box clearly marked ‘USED LITHIUM CELLS' in letters at least 12mm high. And, the advisory note also outlines that the movement of lithium batteries by air is banned.

Under Hazardous Waste Regulations, the collection site operator must not have over 500kg of any hazardous wastes – batteries included – on site at one time. All premises within England and Wales which exceed the 500kg limit in a year have to report to the EA but the advisory note claims that it does not expect many battery collection points to exceed this figure by collecting batteries alone.

Once the waste portable batteries have been disposed of, the person who receives the waste from the collection site operator – known as the producer of the waste – will need to make quarterly returns to the Environment Agency of the amount of hazardous waste collected, including a summary of every consignment received at their site.

Defra has stated that the advisory note is a “living document” but as legislation is updated and modified it will strive to keep the note up-to-date as well.