3. Waste pre-acceptance, acceptance and tracking appropriate measures
The appropriate measures for waste pre-acceptance, acceptance and tracking at regulated facilities with an environmental permit for the treatment or transfer of waste batteries.
3.1 Waste pre-acceptance
1. You must implement waste pre-acceptance procedures so that you know enough about a waste before it arrives at your facility. You need to do this to assess and confirm the waste is technically and legally suitable for your facility. Your procedures must follow a risk-based approach, considering:
- the source and nature of the waste, including:
- the types of waste battery present (including their chemistry)
- how the batteries are, or will be, packaged (for example, including type of container, packaging material, measures taken to prevent physical damage, electrical shorting, exposure to liquids and high temperatures)
- the condition of the batteries, if known (particularly for high voltage electric vehicle batteries), for example, including information on their age, residual charge, any known damage or defects
- any hazardous properties or persistent organic pollutant (POPs) content
- potential risks to process safety, occupational safety and the environment (for example, from the presence of hazardous substances that could be dispersed during treatment)
- knowledge about the waste producer and previous waste holder
2. You must get the following information (in writing or electronic form) when you receive a customer query and before their waste arrives at your facility:
- details of the waste producer (who you are receiving the waste from) including organisation name, address and contact details
- where the waste is coming from
- full description of the waste including the quantity
- where relevant, its physical form and composition (for example, from safety data sheets or laboratory analysis)
- any hazardous properties and presence of any regulated chemicals, for example, POPs
- the List of Waste codes (European Waste Classification (EWC) code)
- the type of containers and packaging used for the waste
- where available, information regarding the age and condition of the waste and, where relevant, potential for self-heating, self-reactivity or reactivity to moisture or air
You can verify the pre-acceptance information by contacting or visiting the waste producer. Dealing with staff directly involved in waste production can help to fully characterise a waste.
3. You must assess the information obtained at the waste pre-acceptance stage to make sure you:
- only accept wastes that are suitable for treatment or storage
- avoid unnecessarily accumulating waste
- have enough storage and treatment capacity
- prevent waste arriving at the site in inappropriate containers or packaging
- identify waste that may require additional safety measures or precautions to be taken
- meet any relevant Control of Major Accident Hazards (COMAH) requirements, because wastes, raw materials and end-of-waste materials all contribute to COMAH limits
4. Where relevant, you should consider with your customer whether waste batteries are suitable for preparing for reuse (for example, re-using electric vehicle batteries for other energy storage applications). Where that remains a possibility, you should ensure the waste batteries are handled and transported with care to avoid any damage or loss that could affect reuse.
5. If there is a risk of radioactive contamination or presence of a radioactive source you must obtain confirmation that the waste is not radioactive unless your facility is permitted to accept such waste.
6. You must consider whether specific wastes, from among those you are permitted to receive, have properties that can pose unacceptable risks to the site or process. For example, due to risk of:
- fire or explosion
- corrosion
- uncontrolled reactions, for example, involving self-heating or gas evolution
You should establish a list of such wastes and procedures for managing the risks from them.
7. You must keep pre-acceptance records for at least 3 years in a computerised waste tracking system following receipt of the waste. If an enquiry from a waste producer does not lead to the receipt of waste, you do not need to keep records.
8. You must reassess the information required at pre-acceptance if the:
- waste changes
- process giving rise to the waste changes
- waste received does not conform to the pre-acceptance information
9. In all cases you must reassess the information required at pre-acceptance on an annual basis.
3.2 Waste acceptance
1. You must implement waste acceptance procedures to check that the characteristics of the waste received matches the information you obtained during waste pre-acceptance. This is to confirm that the waste is as expected, and you can accept it. If it is not, you must confirm that you can accept it as a non-conforming waste, or you must reject it. If you are rejecting hazardous waste you must follow the guidance on the procedure for rejecting hazardous waste. Procedures should be documented and auditable.
2. Your procedures must follow a risk-based approach, considering:
- the source, nature (including type and chemistry of batteries), condition and age of the waste
- any hazardous properties of the waste
- any persistent organic pollutant content in the waste
- potential risks to process safety, occupational safety and the environment (for example, the presence of Li-ion batteries)
- knowledge about the previous waste holders
3. You must weigh each load of waste on arrival to confirm the quantities against the accompanying paperwork, unless alternative reliable systems are available (for example, based upon volume). You must record the weight in the waste tracking system.
4. You must visually check wastes and verify them against pre‑acceptance information and transfer documentation before you accept them on site. The extent of the initial visual check should be determined by the waste type and how it is packaged.
5. You must check and validate all transfer documentation and resolve discrepancies before you accept the waste. If you believe the incoming waste classification and description is incorrect or incomplete, then you must address this with the customer during waste acceptance. You must record any non-conformances. If you have assessed the waste as acceptable for on-site storage or treatment, you must document this.
6. You must have clear criteria that you use to identify and safely manage non-conforming wastes, including its quarantine or rejection. You must also have written procedures for recording, reporting and tracking non-conforming and rejected wastes. These must include:
- using appropriate dedicated quarantine storage
- notifying the relevant customer or waste producer
- recording a summary of your justification for accepting non-conforming waste in your electronic (or equivalent) system
You must take measures to prevent the recurrence of non-conforming or rejected wastes.
7. The person carrying out waste acceptance checks must be trained to effectively identify and manage any non‑conformances in the loads received, complying with this guidance and your permit conditions (for example, including the different types, properties and chemistries of waste batteries or similar wastes that may be received at the facility).
8. If there is a known risk of radioactive contamination, you must check the waste to determine that it does not include radioactive material, unless you are permitted to accept these materials.
9. You must minimise the manual handling of waste. You should use mechanical unloading technologies where it is possible, safe and practicable to do so.
10. Wastes must be visually inspected to check that they are as expected and match accompanying paperwork (for example, regarding battery types, quantity and packaging). Loads must be checked for non-conforming wastes (for example, batteries that are of a non-conforming type or chemistry, or that show signs of damage, or other non-battery wastes) prior to being accepted and moved to a dedicated storage area. For example, damaged batteries could be identified by signs of physical damage (dents, puncture, cracks), swelling, smoking, leaking or overheating. Loads identified as containing non-confirming waste must be identified and moved to a quarantine storage area at the earliest opportunity, where you can investigate and manage the non-conformance.
11. Waste batteries must be received and handled in appropriate containers or packages that are secure, prevent damage and leakage of materials, and are resistant to any corrosive chemicals contained in them (for example, battery electrolyte). This must be a requirement of your waste pre-acceptance and acceptance procedures.
12. You must check all waste containers and packages to make sure they are fit for purpose, including that they are:
- in sound condition
- undamaged
- not corroded
- suitable for the contents (for example, its mass and other physical or chemical properties)
- provided with well-fitting lids, where relevant
- provided with caps, valves and bungs in place and secure, where relevant
- certified to relevant UN standards, where relevant
You must risk assess containers, particularly those made of plastic, if they have exceeded the manufacturer’s use by date.
You must quarantine non-conforming containers and deal with them immediately and appropriately. You must record all non-conformances.
13. If waste batteries are not received in appropriate containers, they must be risk assessed and, if safe to do so, repackaged as soon as it is practicable and before being moved to the general waste storage area. If they cannot be safely repackaged for storage, they must remain in the quarantine area whilst you investigate and manage the non-conformance.
14. All waste packages and containers received must be marked or labelled with relevant information, including:
- a description of the waste
- the date of arrival on site
- relevant hazard codes
The mark or label must also enable you to identify the waste producer and comply with relevant appropriate measures for waste tracking.
15. The site must have written procedures for safely managing non-conforming or quarantined wastes, including, for example, other types or chemistries of batteries that you are not permitted to accept, other unexpected non-battery wastes or damaged waste batteries. At treatment facilities, this could include the prioritisation of damaged batteries for treatment, where permitted and it is possible and safe to do so, supported by an appropriate risk assessment.
16. If identified during acceptance or storage, damaged batteries must be risk assessed (for example, considering the risk of potential emissions, fire and electrical hazards) and, where necessary and safe to do so, placed in appropriate rigid, lidded, leak-proof and chemically-resistant containers and segregated from other waste batteries.
17. Following assessment, and where safe to do so, damaged batteries that are assessed as posing an increased risk of fire (for example, Li-ion batteries) should be segregated and:
- placed in an appropriate fireproof container (for example, a UN approved steel drum or container, filled with an inert packing material, such as vermiculite or sand, and designed to safely vent any released gases)
- moved to a dedicated location or quarantine area that is a safe distance from combustible or flammable materials, possible sources of ignition, buildings, equipment and site perimeters
- kept under cover in a cool, dry and well-ventilated location
- subject to regular checks and monitoring (for example, to identify changes in temperature or thermal runaway)
If the damaged batteries are not in fire-resistant containers and it is not safe to remove them, the containers should be held in enclosed steel cages, or similar resistant structure, to minimise the risk of battery ejection and propagation in the event of a fire.
Large Li-ion battery packs or modules (for example, from electric vehicles (EVs) or battery energy storage systems (BESS)) that are damaged and assessed as posing a risk of thermal runaway or fire should be isolated within an appropriate exclusion zone or in a dedicated, fully enclosed and ventilated fire-resistant container or enclosure provided with appropriate fire detection (for example, gas, heat or thermal) and suppression systems.
Storage areas
18. All relevant waste storage areas (quarantine, reception and general) and treatment processes in your facility must have the physical capacity needed for the waste you receive. You must not receive wastes if this capacity is not available. The amount of waste you receive must also comply with storage limits in your permit.
19. The waste offloading, reception and quarantine areas must have impermeable surfaces with a sealed drainage system. This system must collect all surface water run‑off from these areas and channel it to a blind sump unless you can lawfully discharge it.
20. You must clearly designate a waste reception area (or areas). Staff controlling the inspection, reception and validation of waste at the facility, must be trained in their respective roles
Quarantine storage
21. Your facility must have a dedicated waste quarantine area or areas, which you use to temporarily store waste being rejected, or non-conforming waste whilst it is being inspected or assessed.
22. Quarantine storage must be for a maximum of fourteen days. Records must be maintained of the removal of quarantined waste from site. For some limited and specific cases (for example the detection of radioactivity), you can extend quarantine storage time if the Environment Agency agrees.
23. You must have written procedures in place for dealing with wastes held in quarantine, and a maximum storage volume.
24. Quarantine storage must be separate from all other storage and clearly marked as a quarantine area.
25. You must store the waste in quarantine in appropriate closed containers or under weatherproof covering. You must segregate or isolate incompatible wastes.
3.3 Waste tracking
1. You must use an electronic or computerised waste tracking system to hold up-to-date information about the available capacity of the waste quarantine, reception, general and bulk storage areas of your facility including treatment residues and end of waste product materials.
2. Your waste tracking system must hold all the information generated during:
- pre-acceptance
- acceptance
- non-conformance or rejection
- storage
- treatment
- removal off site
This information must be readily accessible.
3. You must create records and update them to reflect deliveries, on-site treatment and dispatches. This can be done on a ‘loads received’ basis. Your tracking system will also operate as a waste inventory and stock control system. It must include this information as a minimum:
- the date the waste arrived on-site
- the producer’s details (or unique identifier)
- a unique reference number
- waste pre-acceptance and acceptance information (including non-conformances and rejections)
- the quantity delivered
- the intended treatment or transfer route
- accurate records of the nature and quantity of wastes held on site, including all hazards – and identifying the primary hazards and presence of any regulated chemicals such as POPs
- where the waste is physically located on site
4. The tracking system must be able to report:
- the total quantity of waste present on site at any one time
- a breakdown by type of the waste quantities you are storing pending treatment or transfer
- the quantity of waste on site compared with the limits authorised by your permit
- the length of time the waste has been on site
- the quantity of end-of-waste product materials on site at any one time, and, where applicable details of any non-conformances and rejections
5. You must store back-up copies of electronic records off site. Records must be readily accessible in an emergency.
6. You must hold pre-acceptance and acceptance records for a minimum of 2 years after you have treated the waste or removed it off site. You may have to keep some records for longer if they are required for other purposes, for example, hazardous waste consignment notes.
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