Review Of Special Waste

The following submission has been prepared under the aegis of the Environment, Health and Safety Committee of the Royal Society of Chemistry.

We became aware of this Consultation from the DETR website. The Society appreciates this opportunity to comment on the DETR Consultation "Review of Special Waste Regulations".

We welcome this attempt to obtain views from all interested parties "on any issue relating to the current or future control of special and hazardous waste in the UK". However the consultation requires more supporting information and a longer time scale for a properly considered response. For example it should include basic data such as estimates of Special Waste arisings over say the last two years.

In addition we feel that the Environment Agency's interpretation of the current Special Waste Regulations (SWR) may be fundamentally flawed in certain respects. This may stem from incorrectly linking certain scientific and legal issues to do with Special Wastes, and it may have
implications for many samples.

For example is the presence of a chemical/substance in a waste at a concentration which could make it special, sufficient to make it special? Our understanding is that the Environment Agency does take this view. However we would not agree with it.

At the very least, new Regulations should be worded in such a way as to clearly distinguish between the different interpretations referred to above.