Chemical Waste Control in Hong Kong

Flammable Toxic Corrosive Oxidizing Major Hazardous Properties of Chemical Waste

Minority: co-disposal at landfill under controlled manner Majority: indiscriminate disposal into sewers, drains, or together with normal refuse Problem : Handling/Disposal of Chemical Waste Before Control

Hazards of Chemical Waste

Main piece of regulation: Waste Disposal (Chemical Waste) (General) Regulation under the Waste Disposal Ordinance Waste Disposal Ordinance is the main ordinance for controlling most types of wastes The Regulation implemented in two phases i.e. Phase I in end 1992 and full control in mid 1993 Phase I covers mainly asbestos and tannery off-cuts which are disposed of at existing landfill Full control in-line with the commissioning of the Chemical Waste Treatment Centre Implementation of Chemical Waste Control Scheme

Objectives of Chemical Waste Control Chemical wastes handled, stored, collected and disposed of properly Cradle-to-grave control from waste producer to disposal facility Waste producer: registration, proper packaging, labelling and storage of chemical wastes Collector: controlled through licence, comply with licence standards Disposal facility: controlled through licence, comply with treatment/discharge standards

What is Chemical Waste ? Section 3 of Regulation (a) Scrap material (b) Effluent (c) An unwanted substance or by-product arising from the application of or in the course of any process or trade activity AND specified in Schedule 1 of the Regulation AND in such a form, quantity or concentration so as to cause pollution or constitute a danger to health or risk of pollution to the environment Household chemical waste exempted Containers with chemical waste residue is also chemical waste

Divided into Part A and Part B Part A Waste - require prior notification to EPD - need to follow EPD’s direction - very toxic - environmentally persistent - require special disposal arrangement Schedule 1 of the CWR

Part B Waste - no prior notification - common types of waste - organic solvents - acids - alkalis - heavy metals - others

Schedule 1 of the CWR

Booklets

Trip ticket system employed for control Each party involved i.e. producer, collector and disposal facility has its respective legal responsibilities under the laws Cradle-to-Grave Control

Chemical Waste Control Scheme Waste Producer Waste Collector Waste Disposal Facility

Trip Ticket System Consignment note in triplicate Keep track of the movement of chemical waste from the point of generation to the point of final disposal Each party fill in the appropriate parts during consignment of chemical waste Each party should keep a copy (for at least 12 months) for future reference if necessary The collector and disposal facility required to summarize the trip ticket data in electronic file and submit to EPD

Trip-ticket System

Trip Ticket

Register with EPD as a waste producer Package chemical waste in proper containers Label chemical waste containers Store chemical waste properly Consign the chemical waste to a licensed collector. Fill in trip ticket for every consignment and retain one copy Duties of Waste Producer

Registration of Chemical Waste Producers F to identify and locate the various types of waste producers in Hong Kong so that EPD can monitor and ensure that they comply with the legal requirements; and F to maintain a public register of waste producers as required under s.6(2) of the CWR F Information includes :.  The names of producers of chemical waste  the location of the premises where the chemical waste is produced; and  A description of the business or activity in the course of or in connection with which the chemical waste is produced.

Containers should be in good condition and free from corrosion, contamination, damage or any other defect Containers should be securely closed or sealed In general, different waste types should be in different containers, especially for incompatible wastes Packaging of Chemical waste

For using containers with capacity larger than 450L, prior approval from EPD required which would be assessed considering the size, design, leakage control, alarm system etc. For wastes in solid and bulky form such as asbestos waste and PCB contaminated equipment, heavy duty and leak-proof plastic bags/sheets could be used.

Material of containers should be compatible with the chemical waste to be store The containers should meet specified performance standards including drop test, leak proof test, internal pressure (hydraulic) test and stacking test

Labelling of Containers Every container should bear an appropriate label

The information entered should be correct and accurate (i.e. particular risks, safety precautions) "CHEMICAL The combined size of the words "CHEMICAL WASTE 化學廢物 WASTE" and characters " 化學廢物 " should not be less than 1/20th of the area of the label. For the small-size labels, the minimum size of the characters should be around 5mm high The label should be securely attached to the container and the information could be easily seen It is recommended to attach two labels on opposite side of the container

The label should be of appropriate dimensions The waste code is a general code to indicate the nature of the chemical waste contained. More details can be found from EPD’s booklet “A Guide to the Registration of Chemical Waste Producers”

The hazard symbol is used to indicate the major hazard of the chemical waste contained The size of symbol should not be less than one-tenth of the area of the label and in no case shall it be less than 500mm 2 (i.e. 25mm x 25mm)

Hazard Symbols

Some examples of appropriate hazard symbols

Labelling of Waste

Stored at a proper area Best be located within the same premises and close to the source of waste generation If not, find another area on the same floor or within the same building Used for storage of chemical waste only Enclosed on at least three sides Height not less than two meters or the total height of containers in stack, whichever is the less Storage

Adequate ventilation in the area to prevent accumulation of dangerous vapor No connection from the area to any surface drain or foul sewers Adequate space within the area for containers handling by workers Should not obstruct any means of escape If not within a building, provided with a roof or similar covering to prevent rain and reduce heat

The area should be kept clean and dry For liquid chemical waste, an impermeable floor or surface (such as epoxy resin) For liquid chemical wastes, a retention structure with suitable capacity

Containers of incompatible chemical wastes must not be stored together, and should be stored in different compartments separated by wall or partition

Stacking of containers inside the storage area is allowed provided that the wall or partition is impermeable; the stacks are secure so as to prevent falling; and the containers are stacked with each of them in the normal upright position Each chemical waste storage area should display a hazard warning panel, notice or marking at the entrance of the area. Such warning panel / notice / marking should:

- indicate the English words and Chinese CHEMICAL WASTE 化學 characters “CHEMICAL WASTE” and “ 化學 廢物 廢物 ”clearly and boldly in red on a white background with a letter/character size of not less than 60 mm high - be securely attached to or worked on a vertical plane of the storage structure - be weather resistant and rigid - be kept clean and free from obstruction CHEMICAL WASTES 化學廢物

Typical Chemical Waste Storage Area

 For small waste producers

Chemical Waste Storage Area

 Collector licensed under the Waste Disposal Ordinance  Submit a duly completed form together with an Operational Plan which provides details of operation including types and no. of collection vehicles/vessels, collection arrangements, staffing, waste handling and emergency response actions etc. Collection of Chemical Waste

 Two types of collection licence i.e. in-house and off-site  In-house licence is for collection of chemical waste produced by the licensee  Off-site licence is for the provision of chemical waste collection

 Licensed collector can only collect chemical waste from registered chemical waste producers and deliver the waste to disposal facilities specified in the licence  The collection should be operated in accordance with the licence terms and conditions  Most updated list of chemical waste collectors can be found from EPD’s website at waste/guide_ref/ref_cw.html

 The collection vehicle/vessel should be equipped with Collection Vehicle/Vessel - fire extinguishers - Tremcards (Transport Emergency Card) of the chemical wastes being carried

 Bear the following warning panels at the front and rear of the vehicle or on each side of the vessel  Each panel shall have a black border in yellow background. Words shall be at least 60 mm high.

 A “NO SMOKING 不准吸煙 ” notice with the English capitals and Chinese characters at least 60 mm high shall be prominently displayed on each side of the vehicle/vessel  This instruction shall be complied with by the driver or transport personnel during the collection operation

Typical Collection Vehicle

 There are two types of disposal facilities i.e. in- house and off-site  In-house disposal facilities can only treat those chemical waste produced by the licensee. Mainly found in factories producing large quantities of chemical wastes such as bleaching & dyeing, electroplating  Off-site disposal facility can treat chemical wastes produced by other chemical waste producers. The largest one is the Chemical Waste Treatment Centre at Tsing Yi Disposal of Chemical Waste

Chemical Waste Treatment Centre (CWTC)

 Another government facility is the SENT landfill, which mainly accepts solid chemical wastes  Other off-site facilities are mainly recycling plants i.e. recycle spent oil, recover precious metals form electroplating solutions or photofinishing waste  Disposal facility can only receive chemical wastes from a licensed collector  The disposal facility should be operated in accordance with the licence terms and conditions.

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