4. Waste storage, segregation and handling appropriate measures

These are the appropriate measures for waste storage, segregation and handling at regulated facilities with an environmental permit for treating or transferring chemical waste.

1. You must store waste in locations that minimise the handling of waste. Waste handling must be carried out by competent staff using appropriate equipment.

2. Where possible, you should locate storage areas away from watercourses and sensitive perimeters (for example, those close to public rights of way, housing or schools). You must store all waste within the secure area of your facility to prevent unauthorised access and vandalism.

3. Where relevant, you must conform to HSE standards and in particular to:

4. You must clearly document the maximum storage capacity of your site and the designated storage areas. You must not exceed these maximum capacities. You should define capacity in terms of, for example, maximum tank or vessel capacities, tonnage and numbers of skips, pallets or containers. You must regularly monitor the quantity of stored waste on site and designated areas and check against the allowed maximum capacities.

5. You must clearly mark hazardous waste storage areas and provide signs showing the maximum quantity and hazardous properties of wastes that can be stored there.

6. Storage area drainage infrastructure must:

  • contain all possible contaminated run-off
  • prevent incompatible wastes coming into contact with each other
  • make sure that fire cannot spread

7. Secondary and tertiary containment systems must conform to CIRIA guidance C736 Containment systems for the prevention of pollution.

8. You must store containerised wastes that are sensitive to air, light, heat, moisture or extreme ambient temperatures under cover protected from such ambient conditions. Covered areas must have good ventilation. This applies to any such container:

  • held in general storage, reception storage (pending acceptance) or quarantine
  • being emptied, repackaged or otherwise managed

For example, waste held in fibre or cardboard primary or secondary packaging should be stored under cover in a dry area and not exposed to rain or moisture. It must be kept off floors to prevent damage by damp.

9. You must store wastes in sealed metal containers under cover if they have the potential for self-heating or self-reactivity. You must monitor the containers for heat build-up. Such wastes include rags and filter materials contaminated with metal swarf, low boiling point oils or low flash point solvents.

10. Wherever practicable you should store all other wastes under cover. Covered areas must have good ventilation. This applies to any such container:

  • held in general storage, reception storage (pending acceptance) or quarantine
  • being emptied, repackaged or otherwise managed

Under cover storage provides better protection for containers than open air storage and minimises the generation of contaminated water. Covered storage also:

  • lowers temperature fluctuations that can cause pressure build up in containers
  • reduces the degradation of containers through weathering

11. You must not store hazardous waste in open-topped containers. Empty open-topped containers should be kept in a building or undercover to prevent rainwater ingress.

12. You must not store or hold wastes on site in vehicles or vehicle trailers unless you are receiving them or preparing them for imminent transfer (meaning that you will remove them from site within 24 hours, or 72 hours if over a weekend).

13. You should pay particular attention to avoid the build-up of static electricity when you are storing or handling flammable wastes and materials. You should use leak detection systems and alarms (for example VOC alarms) and automatic fire suppression equipment based on a recorded risk assessment.

14. You must provide adequate bunding of all storage areas, and containment and treatment of any water run-off.

15. You must not accumulate waste. You must treat wastes, or remove them from the site, as soon as possible. Generally you should do this within one month of receipt but all wastes must be removed within 6 months of receipt. This applies even when the waste might be used as a reactant. Where a shorter time period is given in a permit condition you must comply with the permit for that waste. Where a waste is stored for longer than allowed you must inform the Environment Agency.

16. All stored containers must keep the labelling they had at acceptance. If the label is damaged or no longer legible you should replace the label with that same information.

17. You must handle and store containers so that the label is easily visible and continues to be legible.

18. You should keep solid waste dry and avoid the dilution of hazardous waste.

19. You must keep clean rainwater and clean cooling water separate from wastes and waste waters.

20. You must keep incompatible wastes segregated so that they cannot come into contact with one another. You must store flammable wastes apart from other wastes to prevent fire spreading between them and other materials. You must use sealed drainage systems to prevent leaks and spillages contaminating other wastes.

21. There must be pedestrian and vehicular access (for example, forklift) at all times to the whole storage area so that you can retrieve containers without removing others that may be blocking access – other than removing those in the same row.

22. You must store all waste containers in a way that allows easy inspection. You must maintain safe access, with a gap of at least 0.7m between rows of bulk containers or palletised wastes.

23. You must move drums and other mobile containers between different locations (or loaded for removal off site) following written procedures. You must then amend your waste tracking system to record these changes.

24. You must stack bags and boxes of waste no more than 1m high on a pallet. You must not stack pallets more than 2 high.

25. You must stack containers specifically designed for stacking, and no more than 2.2m high on a pallet.

26. You must store all other containers on pallets. You must not stack these pallets more than 2 high, except for empty containers which can be stacked 3 high.

27. Stacked bags, boxes and containers must be stable. They must be secured with, for example, banding or shrink-wrap, if required. The packages must not extend beyond (over-hang) the sides of the pallet. Any shrink-wrap used must be clear or transparent so that you can identify waste types, damaged containers, leaks or spillages and incorrectly stacked containers. You must be careful not to damage any packages during stacking.

28. All waste containers must remain fit for purpose. You must check any containers (and pallets they may be stored on) daily and record non-conformances. Non-compliant containers and pallets must be made safe. You must immediately and appropriately manage any unsound, poorly labelled or unlabelled containers (for example, by relabelling, over drumming and transferring the container’s contents). You must risk assess, approve and record the use of containers, tanks and vessels:

  • beyond their specified design life
  • where you use them for a purpose, or substances, other than the ones they were designed for

29. You must not handle waste or its packaging in a way that might damage its integrity, unless it is appropriate to destroy a waste or its packaging, for example by shredding. You must not, for example, walk on or throw waste or waste packages.

30. You should, where applicable and based on a recorded risk assessment, make inert the atmosphere of tanks containing organic liquid waste with a flashpoint less than 21°C. This can be done, for example, by using nitrogen gas.

31. You must store asbestos waste double bagged or wrapped, in sealed, closed and locked containers. You must not store asbestos waste loose. You must not put asbestos wastes into bays or transfer it between different skips or containers. You must not use mechanical equipment, for example loading shovels, chutes and conveyors to move asbestos waste.

32. You must not stack wheeled containers on top of one another. Do not stack empty wheeled containers into one another more than 2.2m high.

33. All containers that need them should have a lid or bung, and the lid or bung must be closed except when the container is being sampled, having waste added into it or having waste removed from it.

34. You must not stack skips containing waste. Skips containing hazardous waste must be enclosed when not being loaded or unloaded. You should store loose bulk hazardous wastes under cover.

35. You can use racking systems to store waste but you must consider segregation, ability to inspect, separation and fire suppression measures. Racking systems must be designed and constructed in accordance with HSG76 Warehousing and storage.

36. You must:

  • contain wash waters within an impermeable area and either discharge them to foul sewer or dispose of them appropriately off site.
  • prevent run-off into external areas or to surface water drains

37. You must manage waste in a way that prevents pests or vermin. You must have specific measures and procedures in place to deal with wastes that are identified as causing pests or vermin.

38. You must inspect storage areas, containers and infrastructure daily. You must deal with any issues immediately. You must keep written records of the inspections. You must rectify and log any spillages of waste.

39. You must train forklift drivers in the handling of palletised goods, to minimise forklift truck damage to the integrity of containers and infrastructure.

40. You must not carry out activities that represent a clear fire risk within any storage area. Examples include:

  • grinding
  • welding or brazing of metalwork
  • smoking
  • parking normal road vehicles, except while unloading or loading
  • recharging batteries

Bulk storage

41. Where relevant, bulk storage systems must conform to CIRIA guidance, and in particular to:

42. You must use tanks and associated equipment that are suitably designed, constructed and maintained. You must do a risk assessment to validate the design and operation of bulk storage systems. Before you use new tanks and equipment you must check they are working correctly. You must periodically examine and test that your tanks meet the standards set out in EEMUA Publication 231: The mechanical integrity of plant containing hazardous substances.

43. You should vent bulk storage tanks and silos through suitable abatement.

44. You must locate bulk storage vessels on an impermeable surface which is resistant to the material being stored. The surface must have self-contained drainage to prevent any spillage entering the storage systems or escaping off site. Impermeable surfaces must have sealed construction joints.

45. You must provide bunds for all tanks containing liquids (whether waste or otherwise) which could be harmful to the environment if spilled. Bunds must meet the CIRIA C535 or C736 standard and:

  • be impermeable, stable and resistant to the stored materials
  • have no outlet (that is, no drains or taps), and drain to a blind collection point
  • have pipework routed within bunded areas with no penetration of contained surfaces
  • be designed to catch leaks from tanks or fittings
  • have a capacity calculated following the relevant CIRIA guidance
  • have regular visual inspections – you must pump out or remove any contents under manual control after you have checked for contamination
  • be fitted with a high level probe and an alarm (as appropriate) if not frequently inspected
  • have tanker connection points within the bund where possible – if not possible you must provide adequate containment for spillages or leakage
  • have programmed engineering inspections (extending to water testing if structural integrity is in doubt)
  • be emptied of rainwater regularly to maintain the containment capacity

46. You must control sludge build up and foam in tanks, for example by regularly sucking out the sludge and using anti foaming agents.

47. You should equip storage and treatment tanks with an automatic level monitoring system and an associated alarm or trip system. These systems must be sufficiently robust (for example, be able to work if sludge and foam are present) and regularly maintained. You must fit tanks with suitable overfill protection.

48. You must be able to close all connections to vessels, tanks and secondary containment via suitable valves. You must fit a valve close to the tank if you have bottom outlets, and have at least 2 isolation points in case of valve failure.

49. You must direct overflow pipes to a contained drainage system (for example the relevant secondary containment) or to another vessel where suitable control measures are in place.

50. Tanks, pipework and fittings must be examined by a competent person, following a written scheme. The scope and frequency of examination must also be determined by a competent person. You must work out how often to carry out these internal examinations using a risk assessment approach. This should be based on:

  • tank service
  • maintenance history
  • known and potential damage mechanisms and their rates of attack

You should also do intermediate external examinations. You must act on the results of the examinations and do any necessary repairs to ensure the tanks remain fit for service. You must keep the results of examinations and repairs.

51. You must have systems in place to make sure that loading, unloading and storage are safe, considering any associated risks. This can include:

  • having piping and instrumentation diagrams
  • using ticketing systems
  • using key locked coupling systems
  • having colour coded points, fittings and hoses
  • using specific coupling or hose sizes for certain waste transfers

52. As a general rule, you must not use open topped tanks, containers, vessels or pits to store or treat hazardous or liquid wastes.

Transfer of waste into and from tankers

53. All pipes, hoses, connections, couplings and transfer lines must be fit for purpose and resistant to the wastes being stored. You must use a suitable pipework coding system (for example, RAL European standard colour coding).

54. Site staff must supervise loading and unloading activities, either directly or via CCTV.

55. You must make sure that transfers into and from tankers only take place after you have completed any relevant verification and compatibility testing, and then only with the approval of an appropriate chemist or manager. The approver must specify:

  • which batch or load of material is to be transferred
  • the receiving storage vessel
  • the equipment required, including spillage control and recovery equipment
  • any special provisions relevant to that batch or load including minimising odour and other fugitive emissions

56. You must have in place systems to prevent ‘tanker drive off’ (a vehicle pulling away whilst still coupled).

57. You must make sure that the transfer of waste from tankers is only carried out by competent staff. You must give them enough time, so they are not under pressure to work more quickly than is deemed acceptable.

58. You must have measures in place to make sure that couplings are a correct fit. This will prevent couplings from loosening or becoming detached. You should provide, maintain and clean your own couplings and hoses to guarantee their integrity and fitness. You should also:

  • make sure you take special care so that a coupling is able to withstand the maximum shut valve pressure of the transfer pump
  • maintain a sound coupling at each end of the transfer hose, even when a gravity feed system is in place, and protect the transfer hose
  • control potential leaks from coupling devices by using simple systems such as drip trays

59. You must make sure that transfers into and from tankers only take place in bunded areas designed to contain a worst case spillage. You must have emergency storage for leaking vehicles to minimise any acute incidents caused by a seal on a tanker failing.

60. You should have systems and procedures in place to make sure that wastes due to be transferred comply with the carriage of dangerous goods when they are packaged and transported.

61. You must make sure that the transfer of waste from a tanker to a drum or vice versa is done in a dedicated area. A minimum of 2 trained and competent staff, working to formal written instructions, must perform the transfer. They must check any pipes and valves before and during the transfer. You must fit dip pipes with a shut-off valve to control the dispensing into containers and prevent overfilling.

62. You must make a record of any spillages. You must retain spillages within the bunded areas and collect them promptly using, for example, pumps or absorbents.

63. You must make sure that tankers are not used as blending or reaction vessels as this is not their designed purpose.

64. You must take operational and design precautions when mixing or blending wastes, depending on the composition and consistency of the wastes (for example when vacuuming dusty or powdery wastes).

65. Where you use rotary-type pumps, they must be equipped with a pressure control system and safety valve.

66. You must pump sludges. Do not pour them.

67. When loading and offloading odorous, flammable or volatile liquids between bulk storage tanks and tankers, you must use vapour balance lines to transfer the displaced vapours from the receiving vessel to the vessel you are pumping from.

68. You must follow safe operating procedures designed to reduce the risk of explosion and fugitive emissions when you transfer waste from powder tankers into silos. You must use trained and competent personnel.

69. You must carry out routine maintenance to prevent failure of the plant or equipment. This may include the failure of a pump seal or the blockage of a filter pot commonly used at transfer points.

70. You must continue using the waste tracking system that began at the pre-acceptance stage for the whole time waste is kept at the site.

Aerosol storage

71. You must store aerosol canisters under cover in secure, well-ventilated containers, and within caged storage areas. You must also store them in a well-vented place that is not subject to extreme temperatures or direct sunlight. You must not store canisters in open containers to prevent the risk of them spreading fires by ‘missiling’ or ‘ejection’.

72. You must segregate aerosol canisters from other flammable wastes and potential sources of ignition. Preferably put them in a separate building, or use a fire resistant enclosure or fire wall. You must not hold any combustible material within the storage area, other than the canister’s packaging, containers and the pallets on which they stand.

73. You must provide suitable containment measures (for example drip trays) for aerosol canisters held in containers which cannot collect and hold free liquids released from the canisters. Or you should transfer them to secure containers that are able to hold free liquid.

74. During storage, lids on containers holding aerosol canisters must remain securely closed at all times when not being filled, emptied or internally inspected. When not in use, the doors or hatches of cages must remain closed and locked.

75. You must not overfill containers used to store canisters. Overfilling can result in canisters being actuated and discharging their contents, either:

  • under the weight of the canisters above them
  • when the container lid is closed
  • when containers are stacked

76. Cages used to store aerosol canister containers must be robust, fire resistant and of an appropriate mesh size (based upon the size of the canisters being stored). This is to constrain the canisters and prevent any ejection. Where the cage is not constructed with a mesh roof, the mesh wall panels must extend into the roof space of the storage area to make sure that the structure is completely enclosed.

77. You should store aluminium canisters separately from steel canisters (especially rusting canisters). This will:

  • prevent thermite sparks during storage, handling and treatment
  • allow the different metals to be more easily recovered

Sorting, repackaging and bulking

78. Sorting is the placing together of containers with other waste containers of the same type, without emptying the contents from the container. You must have a permit that specifically allows you to carry out storage activities (coded D15 or R13).

79. Repackaging is the removal of waste from a container, or into a container. This may involve bulking it with other wastes of the same type from other containers. You must have a permit that specifically allows you to carry out repackaging activities (coded D14 or R12).

80. Bulking of waste that is not regarded as repackaging includes:

  • discharging from a tanker to bulk storage of wastes of the same type
  • tank to tank transfer where both tanks contain wastes of the same type

These activities are storage (coded D15 or R13).

81. You must only bulk or repackage wastes together if they are materially the same. They must not react when they are bulked and they must not change the waste’s composition.

82. If a waste is mixed with other similar wastes, where the resulting mixture does not have significantly different characteristics from the mixed wastes (for example blending compatible combustible or flammable wastes as a fuel), this activity is mixing or blending (coded D13 or R12). Any other mixing that changes a waste is treatment.

83. You must have a permit that specifically allows you to mix hazardous waste with any:

  • non-hazardous waste
  • hazardous waste in a different category
  • non-waste

84. You must not mix, bulk or repackage:

  • wastes which could be recovered with other wastes if this means that the waste must now be sent for disposal or a lower form of recovery
  • liquid wastes or infectious wastes with other wastes for the purpose of landfilling
  • oils where this could affect their regeneration or recycling
  • wastes containing Persistent Organic Pollutants (POPs) with another material solely to generate a mixture below the defined low POPs content
  • waste to deliberately dilute it

85. You must transfer wastes from containers into other storage vessels using a dip pipe, not by pouring.

86. Repackaging or mixing must only take place in a dedicated area or store which has the plant and equipment needed to deal with the specific risks of that process. For example, this could include abatement or local exhaust ventilation.

87. Except for small packages with a volume less than 5 litres, or damaged containers, you must move containers using mechanical means. For example, use a forklift truck with a rotating drum handling fitting, or using pumps for liquids.

88. You must label containers of repackaged or mixed wastes so that you can identify their contents and origin through the tracking system. After repackaging, you must move the bulked materials and emptied containers to an appropriate segregated storage area.

89. You must have a risk assessment and carry out appropriate compatibility testing to make sure that bulked wastes will not react with each other, or with the container into which they are being placed.

Laboratory smalls

90. Where possible, you should sort and segregate laboratory smalls at source so that you do not need to reopen or re-sort containers.

91. If you sort laboratory smalls for compatibility reasons you must carry this out in a dedicated area of a building, with self-contained drainage.

92. You must write and follow procedures for the segregation, sorting and repackaging of laboratory smalls.