Scrap Metal Dealer Waste Mangement Licensing Requirements

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Scrap Metal Dealer Waste Management Licensing Requirements


Overview


On May 1, 1994, a pivotal waste management licensing act was enacted. This legislation mandates any operator involved in depositing, recovering, or disposing of waste to obtain either a Waste Management Licence (WML) or an exemption. Non-compliance could result in fines or imprisonment. Licences are typically issued by regulatory authorities such as SEPA or the EA.

Licensing Criteria


To secure a licence, operators must demonstrate two main qualifications:

1. Fit and Proper Person: This involves having no environmental convictions and taking reasonable precautions to adhere to licence requirements.
2. Technical Competence: A Certificate of Technical Competence (COTC) issued by WAMITAB is required.

Specifics for Metal Recyclers


While metal recyclers in the UK face less stringent legislation than other waste producers due to extensive lobbying, they must still abide by significant licensing controls and observe a moderated Duty of Care regime. Licences are necessary for recycling operations, though some businesses might qualify for an exemption based on their size.

Enforcement and Compliance


In recent years, with support from trade associations, the Environment Agency has intensified actions against non-compliant sites. Licences, known as "Metal Recycling Site Licences," carry conditions, including the need for security measures, proper storage facilities, signage, and drainage systems.

Duty of Care


The Duty of Care is crucial, mandating businesses to ensure their waste is managed safely and legally. This applies to anyone dealing with controlled waste and requires a detailed transfer document between the waste producer and disposer.

Despite challenges in documentation, a concession was reached. The Environment Agency agreed not to strictly enforce the Duty of Care on the non-ferrous metal sector, a move welcomed by the British Secondary Metals Association.

Practical Applications


The Duty of Care regulations apply regardless of the waste's end destination, linking waste controls to carriers. While flexibility is afforded for smaller loads, transfers must still include a waste description even if documentation per container isn't practical. This ensures proper handling down the chain.

Current Guidelines


A recent agreement states no general enforcement action will be taken for transactions where the total scrap metal weight is below 1,500 kilograms. Exceeding this weight requires comprehensive documentation as dictated by regulations.

In summary, while concessions exist, stringent adherence to the Duty of Care and licensing requirements remains vital for compliance and environmental responsibility in the metal recycling industry.

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