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Don’t forget the paperwork

Thanks to the Hazardous Waste Regulations, disposing of refrigerant now requires a fair bit of form-filling. HRP Engineering Support Manager Derek Alway explains the process and reveals a time-saving solution

We all like to keep the job simple. As a wholesaler we do understand that form-filling can be a chore but with increasing regulation it is now a necessary part of an engineer’s routine.

Tackling the paperwork surrounding refrigerant disposal of under the 2005 Hazard Waste Regulations could be a nightmare, with some tricky form filling required.

So, after talking to the Environment Agency, at HRP we’ve devised a simple, pre-printed form which will help our customers process their waste refrigerant legally and safely.

It’s important that engineers and contractors understand their responsibilities surrounding the regulations.

Most of you will come across them on an infrequent basis as you go about your work, but you still have to be up to speed on the law. And failure to complete the paperwork correctly can now mean a hefty fine.

It is fair to say that the authorities designed the regulation originally without considering too deeply the role of the wholesaler in the rac industry, acting as a transfer station for recovered refrigerant on its way back to the re-processor.

Under the regulations we all have specific responsibilities and the wholesaler needs engineers to complete the paperwork correctly and legibly or we can’t take the refrigerant you’ve recovered from a job and re-process it.

‘Waste producers’

The first thing to get to grips with is that under the regulations, engineers recovering refrigerant are viewed as ‘waste producers’ because they are seen to be the source of the waste.

If you are removing the waste refrigerant from a refrigeration or air conditioning system you will need a City & Guilds 2078 qualification or the CITB equivalent safe handling certificate.

The regulations state that you will require a waste carrier’s licence. This is issued by the Environment Agency (EA) and allows you to transport the refrigerant away from site.

The regulation says that you will need a Premises Code from the EA to record the fact that you are a producer of waste. This code must be renewed every 12 months, but the Agency will not send you a reminder, so you will need to keep a record of the renewal date. Without this code, HRP cannot accept your refrigerant consignment. It’s down to you or your boss to apply to the EA for this.

Fourthly, the regulation says that a consignment note must accompany each shipment of waste when it is removed from site. The EA’s version of this note in its original form can be challenging to complete but here HRP has come to the rescue (see below).

Lastly, you will also be acting as a record keeper, having received a response from the wholesaler, on the fate of the refrigerant you returned – whether it was re-processed or destroyed – and so you must maintain records of this data for three years. There’s a lot to do and it all has to be completed correctly.

At HRP we have devised a Consignment Note that can take care of most of it. It is straightforward to complete. The EA are happy with it too – they’ve told us so – and it also looks after the difficult side concerning such elements as European Waste Catalogue Code and UN Identification Number, which are pre-printed on the form, along with other details.

You have to fill in the part of the form covering the Description of the Waste, the Carrier’s Certificate and the Consignor’s Certificate. This is pretty simple and comes down to your name, address and date, along with details about the refrigerant and cylinder serial numbers.

HRP fills in the bit at the bottom concerning the Consignee’s Certificate but we can do this only if you have a Premises Code and have completed the rest of the form correctly. We have to be able to read it too – otherwise it isn’t legal. You’d be amazed by the number of forms we see that are difficult to read.

After that, the refrigerant can be sent off for analysis and processing and a full ‘cradle to grave’ paper trail can be maintained.

There’s a £10 environmental charge payable to the wholesaler when an empty cylinder is delivered to you; this charge is passed on to the EA when you return the cylinder.

We believe our Consignment Note fits the bill in simplifying the paperwork surrounding the recovery of refrigerant under the Hazardous Waste Regulations.

We’re happy to provide these Consignment Notes to our customers free of charge. We think it’s the way forward – and that’s why we like to keep it simple.

For more details contact Derek Alway, HRP Limited, Tel: 01359 270888

Disposing of refrigerant: what you need

1)    Refrigerant handling qualification

2)    Waste Carrier’s Licence

3)    Premises Code

4)    Consignment Certificate

5)    Record of disposal from wholesaler