Presentation to Why Waste Seminar 25 th February 2010 by Phil Pease IPA Chief Executive Officer IPA The Industrial Packaging Association

Phil Pease  Chartered Wastes Manager Specialty: Clinical & Hazardous Wastes Treatment  Member Chartered Institute of Wastes Management  Dangerous Goods Safety Adviser  CEO Industrial Packaging Association  Chair: of DfT Packaging Scheme Review Committee  Chair: British Standards Institution (BSI) Committees for - “Drums” & “Packaging and The Environment” Also…. Instructor-Trainer for First Aid at Work ….and Scuba Diving Instruction !!!

 Purchase, Re-Use and Disposal Options for Industrial Packaging Industrial Packaging  Treatment Options for used Industrial Packaging  UN & ADR Transport Regulations for Industrial Packaging Re-Use Packaging Re-Use  Consignment issues: Dangerous Goods vs Hazardous Wastes Dangerous Goods vs Hazardous Wastes  Local opportunities lost ? / to be gained?  The Future….

Purchase, Re-Use and Disposal Options for Industrial Packaging

Not just Chemical Company Packaging of course... Not just Chemical Company Packaging of course... Drinks Manufacturers: Fruit Juice Concentrates = Flammable Drinks Manufacturers: Fruit Juice Concentrates = Flammable Perfume Manufacturers: Concentrates = Irritant / Flammable Perfume Manufacturers: Concentrates = Irritant / Flammable Resins & Adhesives: Base Products = Flammable & Toxic Resins & Adhesives: Base Products = Flammable & Toxic Engineering : Mineral Oils = Hazardous Waste Engineering : Mineral Oils = Hazardous Waste All Manufacturing Sectors: Paints, Adhesives, Lubricants All Manufacturing Sectors: Paints, Adhesives, Lubricants Soaps & Detergents: Concentrates = Corrosive Soaps & Detergents: Concentrates = Corrosive

World-Wide Re-Use Infrastructure World-Wide Re-Use Infrastructure IPA JDRA RCMASA EIPA RIPA AOSD ICCR

Purchase & Use of Industrial Packaging Gaining real benefit from understanding Life Cycle Value Review of a true situation.... Review of a true situation.... Company’s Purchaser requires lowest cost 1000 litre IBC for non hazardous hair-care product base. Handling approx’ 10,000 units per year. Options are: ltr, UN Approved, Metal Base, with Ball or Ball £ ltr, Non UN, Wood Base with Butterfly £65 Option 2 has a face value saving of £10 per unit x 10,000 = Saving of £100k per year - quite significant !...or so you might think or so you might think

actual position: Following use, the IBCs require disposal – with following options: 1.The Option 1 IBCs retain a market value for re-use as a UN container. Typical Market Value: circa £17 credit 2.The Option 2 IBCs retain little / if any market value as not permitted for hazardous (UN) products, or even for food products. for hazardous (UN) products, or even for food products. Nil re-use market = disposal options only, hence represent a cost: Nil re-use market = disposal options only, hence represent a cost: Typical Market Cost: circa £10 charge Typical Market Cost: circa £10 charge Original saving of £10 per unit must be balanced against loss of £17 value at end of life plus a £10 cost for disposal Result: Perceived saving of £10 is actually negated by disposal costs plus the further loss of £17 value – so true position shows that the further loss of £17 value – so true position shows that Option 2 actually represents a net loss of £17 per unit Option 2 actually represents a net loss of £17 per unit or £170, now that’s REALLY significant!!! or £170, now that’s REALLY significant!!!

UN & ADR Dangerous Goods Transport UN & ADR Dangerous Goods Transport Disposal Options for Used Packaging Disposal Options for Used Packaging Re-Use options (in-house or 3 rd Party) Re-Use options (in-house or 3 rd Party) Hazardous Waste Consignment Hazardous Waste Consignment International Service Provision International Service Provision Purchase Considerations should include:

The IPA represents UK and European leading Manufacturers and Reconditioners of Drums and IBCs. These companies typically offer: Drums and IBCs in Steel, Plastic & Fibreboard National & International Delivery & Collection National & International Delivery & Collection Variety of Packaging Designs and Types Variety of Packaging Designs and Types Special / Hazardous Waste Treatment Special / Hazardous Waste Treatment UN Reconditioning & Leak Testing UN Reconditioning & Leak Testing Closed-Loop `Launder’ & Return Closed-Loop `Launder’ & Return Final Disposal / Recycling Systems Final Disposal / Recycling Systems Treatment Options for Used Packaging

Drum Disposal in the `Good Old Days’ - Circa 1970

Current typical recovery operation 2010 Treatment Options for Used Packaging

A professional reconditioning service will ensure each used industrial container (typically from 20 to 1200 litres) is inspected, cleaned and tested in an effort to gain the maximum re-use…..either returned to the supplier for refilling or for re-sale to the wider industry. Only the non re-useable containers (having been cleaned) will be crushed / shredded / granulated etc. in preparation for materials recycling or energy recovery. This inspection and cleaning of every container handled and the streaming for re-use or recycling means the Reconditioner is gaining the most environmentally and commercially efficient option for every used Drum & IBC collected.

Treatment Options for Used Packaging To gain the maximum benefit from the services offered by reconditioners, the following should be considered: Used packaging should be as empty as practically possible for the container type Pre-Rinsing is not usually required – and could reduce values - for example steel drums could rust if not properly dried internally. Product labels must always remain in place – to indicate true contents Correct closures should be securely in place

UN and ADR Transport Regulations provide for various aspects of packaging and IBC re-use including; Reconditioning, Re-Use, Repair, Routine Maintenance and also Remanufacture

Reusable Drums and IBCs manufactured for use with Dangerous Goods must be embossed with both the UN symbol & the tested standard to enable fillers to ensure safety in first use & repeated re-use with dangerous goods. 1A1/X/300/07/GB/1027 Example of a typical embossed UN mark

The embossed markings show the tested standard of the packaging and (with reference to ADR) which classes of product it can contain 1A1/X/300/07/GB/**** 1 = drum A = steel 1 = non removable head X = packing group I, II or III 300 = vapour pressure in kPa 07 = year of manufacture GB = country of certification **** = manufacturer’s certificate number Unless shown in the mark (eg; 1A1/X1.4/300) the specific gravity for liquids is 1.2

The UK Department for Transport operates a Reconditioner Scheme which regulates the industry, audits the companies registered and issues the UN Certificates and marks for drums reconditioned for dangerous goods use The UK Department for Transport operates a Reconditioner Scheme which regulates the industry, audits the companies registered and issues the UN Certificates and marks for drums reconditioned for dangerous goods use Note the same format for the UN manufacturers’ marking – but with the addition of “RL” which indicates; Reconditioned & Leak Tested The reconditioner’s certificate number may be replaced by the company name There is no similar scheme for IBCs in the UK However the IPA are developing a Code of Practice – to be issued Jan 2008

IBCs are also suitable for multiple re-use but not referred to in UN & ADR as “reconditioned” but as; IBCs are also suitable for multiple re-use but not referred to in UN & ADR as “reconditioned” but as; Routine Maintenance Routine Maintenance (cleaned, dried & inspected) Repair Repair (new part/s fitted) Remanufacture (different design parts with re-testing) The modular design of the typical rigid, composite IBC makes them ideal for repeated repair & re-use - - however beware !!.... The replacement of any part that is not as per the original tested specification will cancel the UN certificate – meaning it is no longer suitable for use with Dangerous Goods.

The company carrying out IBC Repair work for Dangerous Goods / Haz Wastes must also maintain a record for each unit processed and leak tested Also – any IBC that has been subject to Routine Maintenance or Repair must have durable markings to identify who, when and where the work was carried out Also – any IBC that has been subject to Routine Maintenance or Repair must have durable markings to identify who, when and where the work was carried out In addition: for “Repair” (replacement of any worn / damaged parts) – that the IBC has been leak tested to the correct UN/ ADR standard – that the IBC has been leak tested to the correct UN/ ADR standard

BE CAREFUL… When re-using any packaging for dangerous goods / hazardous wastes which utilises plastic elements (such as all the Drum and IBC types below) – there is a 5 year maximum life limit ! BE CAREFUL… When re-using any packaging for dangerous goods / hazardous wastes which utilises plastic elements (such as all the Drum and IBC types below) – there is a 5 year maximum life limit ! This is why it is critical that the date of manufacture, repair or re-manufacture is indicated on the container.

Consignment Issues – Dangerous Goods vs Haz Waste The UN & ADR Transport Regulations includes exemptions specific to the transport of Empty, Uncleaned Packaging. This is (as always) a little complex – so seek the advice of a DGSA - but essentially it enables; No requirement for the orange marker plates No requirement for full ADR Consignment Notes – basic wording only No requirement for external fire extinguishers (though this is still recommended and a small one in the cab is required) No requirement for full 5 year ADR certified drivers (though awareness training is required) Take care: Not Dangerous Goods – but still Hazardous Waste?.... eg; Mineral Oils

End of Life = End of Value ???.. Resin Contaminated IBCs Shredding Sticky mess ! Wash & Dry Systems Clean, Dry MaterialFor Sale !

Local Opportunities Lost ? We are (slowly) beginning to understand the fact that materials can be reduced, re-used, recycled, recovered etc… Unfortunately we have a long way to go …… in Yorkshire alone we landfilled approx’ 90,000 tonnes of rigid plastics materials in 2007 At a (low) average of £150 / tonne in value that’s £13.5 million ! Enough to make even a hedge fund manager cry!

Local Opportunities to be gained ? In West Yorkshire alone we have a wealth of specialists: Waste Cleaning Equipment manufacturers: eg; Rotajet Systems, Ossett Waste Shredding & Compaction Equipment manufacturers: eg; Meltog Machinery Co. Leeds Specialised Plastics Recyclers / Reprocessors: eg; Linpac Castleford, i-Plas Halifax, etc Specialist Advice & Support: Chamber of Commerce / Yorkshire Forward CO2 Sense etc.

The future ? With increased awareness, cultural change and new technologies we can see real progress – but we must not allow ourselves to be left behind in the UK….

IPA Website © Copyright 2004 The Industrial Packaging Association | Site by Optix SolutionsOptix Solutions The IPA website provides details of all UK members involved in Manufacture and Reconditioning of drums and IBC packaging - From the homepage select; Member Products & Services We also have page of News & Information which provides Codes of Practice, Guides and updates on various issues and regulations etc.

CONTACT: Phil Pease The Industrial Packaging Association P.O. Box 110 Knaresborough North Yorkshire HG5 8ZX Tel: – Website: Thank you