30th October 2007 is the deadline for pre-treatment of all non-hazardous waste going to landfill.

It’s also the deadline by which all liquid wastes will be banned from all landfills. Liquid wastes may include out of date raw materials or finished products, vessel washings, or failed finished product.

Liquid wastes may be able to be re-used in-house (worked off into other products, where it’s safe to do so), or by other companies, such as formulators who can use your chemicals in their products.

Consider alternative disposal routes:

► Composting and land-spreading non-hazardous chemicals which have a genuine agricultural benefit
► Treatment and disposal at a registered waste treatment plant who have a consent to discharge to foul sewer
► You may even be able to treat the wastes in your own effluent treatment plant, and discharge to foul sewer under your own consent to discharge.

Where you still have to send liquid wastes to landfill, there are a number of treatment options, mainly adsorption onto a variety of inert materials to prevent leaching. However, the treatment route may be decided by the waste contractor, and you don’t always have control of what happens, or the costs.

Action list for liquid wastes:

► Is it really waste? If you have in-date raw materials or finished products, see if your suppliers will take the raw materials back, and get your sales team to ring round existing customers with large discounts on the finished products
► Look at selling in-date chemicals on an online exchange, eg http://www.thewesgroup.co.uk/chemicals.asp (they also take out-of-date materials)
► For in-date materials, don’t forget your competitors – they may be interested in buying raw materials you no longer have a need for (eg if you’ve over-ordered, or no longer make the product they’re used in). A nominal sum eg £1 should be charged, invoiced and paid as proof of what has happened to the materials, and to demonstrate that they have not been disposed of as waste. Your competitors may also be interested in buying and selling on any finished products you have made, but your sales team can’t sell, eg if you main customer for a product has gone out of business.
► If you have out of date raw materials, speak to the supplier – will they still take them back? Can the supplier analyse them to confirm whether they are still usable? If they are still usable, will they issue a new certificate of analysis so you can use them in your products, or sell them to someone else
► If you have out of date finished products which are still good quality, can you analyse them in-house and issue new certificates of analysis, allowing you to sell them? If this isn’t practical, can you work the material off gradually in new batches of the same or similar product?
► If you have no option but to dispose of liquid wastes, check you have identified the waste correctly, and are using the right EWC (European Waste Catalogue) code. Using the right EWC may mean you don’t need to send your liquid wastes to landfill
► Consider solvent recovery in-house eg www.centec.uk.com/recovery.htm or using solvent recovery specialists eg www.chemrec.co.uk/, or www.srm-ltd.com/pages/our_services.html
► If you use contractors to handle your liquid wastes, audit them – have they identified the EWCs correctly? Are they using appropriate disposal routes?
► Finally, if your liquid wastes are going to landfill, discuss any treatment options with your waste contractor, and compare the benefits and costs of various treatment methods. There may be a choice of treatments, which can affect the costs.

News article 02 October 2007.