The hazardous waste collection industry is made upof a number of private enterprises who collecthazardous waste under contract and transport it torecovery and disposal facilities in Ireland andabroad. This service is commercially successful butthe major bottleneck associated with it (withnotable exceptions) is that it is not generallyavailed of by generators of small quantities ofhazardous waste. This is due to a number ofpossible causes: (a) the relatively high unit costinvolved, (b) a lack of knowledge on the part ofhazardous waste generators of, for example, theneed for segregation or (c) an unwillingness to takesteps towards the management of hazardous waste.

5.1 Problem identification

Collection of hazardous waste is problematic whensmall quantities are involved. Costs for dedicatedcollection services are relatively high and manygenerators lack the expertise to find outlets fortheir hazardous waste. An estimated 70,228 tonnes

in 1996 and 55,311 tonnes in 1998 of unreportedhazardous waste, excluding sheep dip, were notseparately collected. As a proportion of totalarisings (excluding sheep dip) of hazardous waste,this fraction of hazardous waste represents asignificant challenge towards achieving fullcompliance with legislation which requires thesegregation and separate collection of hazardouswaste.

Another indication of potentially unsegregatedhazardous waste is that only 500 or so industrialcompanies are utilising available collectionservices. The potential scale of the problem ofunreported waste is illustrated by the fact thatIrish industry consists of about 5,000 companies.In addition, there are a few thousand companies inthe service sector, such as garages andphotographic shops, which generate hazardouswaste. The majority of generators outside of the‘500’ are likely to be small scale generators andthese are not availing of the existing collectionsystems.

55

National Hazardous Waste Management Plan

5. COLLECTION OF HAZARDOUS WASTE

Photo 3 Small scale hazardous waste collection vehicle. (The waste types listed on the vehicle include batteries,photochemicals, oils, poisons, flammables, weedkiller, acids and medicines.)

5.2 Options to improve collection rates

A review of the situation in Denmark, Belgium, theUK, Germany and the Netherlands shows that all ofthese countries have established systems to collecthazardous waste from SME’s and from households.Systems that have potential to deal with SME andhousehold hazardous waste are described below.

SME’s and other industryFor small scale industrial generators, the optionsthat merit consideration include:

● the use of civic amenity sites and depots;

● the return of waste to suppliers (producerresponsibility obligations);

● collection on demand by commercial providers;and

● a mobile collection service with scheduled stopsat farms, shops, offices and small companies.

Household hazardous wasteFor households, available systems include:

● household hazardous waste depots at civicamenity sites and bring banks;

● mobile collection services which make quarterlyor biannual visits to neighbourhoods;

● door to door collection services; and

● bring systems using shops and other outlets toprovide take back services.

Mobile or door to door collection services arefrequently accompanied by the provision of storageboxes for hazardous waste. Given that collectionfrequency may be as low as twice per year, safechildproof storage is necessary.

Section 33 of the Act requires local authorities toarrange for the provision of waste collectionservices to households. Hazardous waste collectionservices, where established, should not berestricted to householders.

Other municipal hazardous wasteExperience in other countries has shown thatcollection by commercial providers is noteconomical for waste quantities less than 50 to100kg. A significant quantity of hazardous wastearises from small scale generators each year andextension of the collection system to small

generators not currently availing of a collectionservice is required. As stated above, local authorityhazardous waste collection services should beavailable to small scale non-domestic generators.Alternatively, the provision of such a service byother service providers could be made attractive byuse of subsidies or product and/or waste collectioncharges.

Storage and sorting of collected wasteStorage, sorting or transfer facilities may berequired for the handling of segregated orunsegregated hazardous waste collected by localauthorities or other service providers. Considerationfor such facilities should be taken into account atthe early stage of planning for collection systems.

Collection costsTypical costs of the above options, based oninternational experience, are listed in Table 5.1.The number of units used in calculating thecollection costs are based on typical requirements iflocal authorities were to implement the

56

National Hazardous Waste Management Plan

Photo 4 Storage box used for household hazardous wastein the Netherlands. The box is provided by the localauthority, has childproof locks and is typically collectedevery six months.

recommendations made in this Plan. Costs of takeback or return schemes and collection on demandservices have not been included for the followingreasons: (a) the cost of take back schemes will bevariable and in some cases may be relativelyinexpensive, on the condition that taking backgoods complements the existing logistics of productdelivery and (b) the cost of collection on demand isa function of the quantity of waste collected andits subsequent treatment. Actual costs under Irishoperating conditions will only be established oncesystems are operating.

Recovery and disposal costsThe costs in Table 5.1 are for collection only. Theestimated costs of recovering or disposing ofunreported hazardous waste are set out inTable 5.2. They are calculated on the basis of acollection cost of £60 per tonne plus a treatmentcost of £270 per tonne.

5.3 Improving the collection of hazardouswaste

The collection service is at present availed ofmainly by the largest generators of hazardouswaste; this is due principally to the unit cost for

collection. On the other hand, there are companieswho do not manage their hazardous waste in anenvironmentally sound manner. Two priorities willtherefore be set – (a) the enforcement of hazardouswaste management on industrial and commercialgenerators and (b) the provision of a hazardouswaste collection service to small scale generators.

Provision of a service for industryThere are a number of legislative and other optionsthat could be used to ensure that industry usesauthorised outlets for hazardous waste. The everdecreasing willingness of landfill operators toaccept industrial hazardous waste is likely to beone such driving force (see chapter 6 for furtherdetail on hazardous waste landfill). It is notconsidered unreasonable to assume that a largeproportion of unreported industrial solid hazardouswaste is disposed of to landfill. Landfill capacity inmany parts of Ireland is expected to be at apremium in the short term. In addition, localauthorities are generally not making provision forthe acceptance of hazardous waste at existingfacilities (most of which are unlined).

There is no statutory obligation on local authoritiesor other public bodies to provide collection servicesfor hazardous waste to other than households. If

57

National Hazardous Waste Management Plan

Facilities Number of Investment Cost Annual Operationalunits Cost

Civic amenity sites 36 £1,800,000 £2,700,000

Take back systems in shops for households 20,000 £250,000 £500,000

Mobile collection services 32 £1,280,000 £2,800,000

Storage boxes 500,000 £2,000,000 £150,000

Take back systems for non-IPC licensed industry – not available not available

Collection on demand – not available not available

Table 5.1 Estimated cost of hazardous waste collection systems

Estimated unit cost Total annual cost

Treatment of 98,228 tonnes of unreported hazardous waste collected £32,415,240(at £330 per tonne) – 1996 data

Treatment of 74,311 tonnes of unreported hazardous waste collected £24,522,630(at £330 per tonne) – 1998 data

Table 5.2 Estimated cost of recovery and disposal of unreported hazardous waste

the segregation and separate collection ofhazardous waste from other sources is to beensured, enforcement will be required from adifferent direction. Economic instruments arediscussed in chapter 4.7 and are the option mostlikely to be supported by waste management policy(see chapter 2.3). Experience in other countriesdictates that economic instruments will requirelegislative backup.

Many waste generators may be unaware that theyhave responsibility for ensuring the propermanagement of waste (Section 32(1) of the Act).This illustrates the need for information to beprovided to all commercial generators. Theinformation should include waste managementoptions as well as informing them of any otherobligations that may exist. There may be a need fortechnical or financial assistance to the wasterecovery industry and/or waste generators in orderto ensure that each are in a position to promotetheir service and avail of the service respectively.

In preparing waste management plans, localauthorities should identify the generators of

hazardous waste within their functional areas. Withdetailed local knowledge, local authorities are inthe best position to ensure that generators ofhazardous waste in their functional areas, forwhom they have responsibility, are provided withthe information and support which will allow themto manage their hazardous waste in a manner thatwill not cause environmental pollution.

In summary, industry will be required to segregateand make use of authorised hazardous wasterecovery and disposal routes by a mixture of driversincluding the unavailability of landfill, theavailability of recovery alternatives, economicinstruments and the strict enforcement oflegislation.

Provision of a service to small scale generatorsThe Waste Management (Planning) Regulations, S.I.No. 137 of 1997, require that local authority wastemanagement plans specify arrangements for thesegregation and separate collection of certainhazardous waste streams. It is assumed in makingthis Plan that the hazardous waste directive will beamended and that Member States will be required

58

National Hazardous Waste Management Plan

Photo 5 Bin used for the storage, pending collection, of waste oil filters.

to organise collection services for all householdhazardous waste. Waste management plans arerequired to have regard to anticipateddevelopments which may affect the operation of awaste management system. It is recommended thatlocal authorities make provision for the collectionof household hazardous waste.

At a minimum, each local authority should makeprovision for the establishment of receptacles forthe collection of hazardous waste at bring banksand civic amenity sites. The fact that such facilitiesare being provided at many locations isencouraging and users of civic amenity facilitiesshould be able to dispose of hazardous waste. Suchdepots should serve both households and smallbusinesses.

A method of increasing the number of collectionpoints, and hence hazardous waste quantitiescollected, is to use shops, wholesalers and otherretailers to provide receptacles for certainhazardous waste types. This method should besuitable for a number of discrete product wastessuch as batteries, fluorescent lamps, waste oils andoil filters. Take back systems may be used andcould be supplemented by producer responsibilityobligations (such as deposit and refund schemes) tofurther encourage collection (see chapter 4.7.2).Retailer collection services may be supplementedand serviced by local authority controlledcollection. The estimated cost of shop take backsystems is shown in Table 5.1. This system dependson the co-operation of the shops involved.Participation on a voluntary basis would bepreferable although legislation imposing producerresponsibility obligations may be required to ensurethat producers and retailers make provision for thereturn of certain products.

If collection from small generators is to bemaximised, a mobile collection system that calls toneighbourhoods in urban areas and, if feasible,local community centres in rural areas should beestablished. Storage boxes should be distributed toensure safe storage of hazardous waste betweencollections.

In conclusion, presented above are some of theoptions available for hazardous waste collectionfrom householders and other small scale generators.Provision should be made by local authorities for

the collection of household hazardous waste. Anysuch service should be available to smallcommercial generators, in addition to householders,who may not have alternative affordable means ofmanaging hazardous waste.

59

National Hazardous Waste Management Plan

60

National Hazardous Waste Management Plan