Storage and transfer of asbestos wastes

Quick guide 215_12 Issued 12/02/2014

What’s this This document provides advice on permitting and compliance

document activities at waste facilities that store and transfer asbestos wastes.
about?
It does not cover asbestos contaminated soils or building rubble.
Document
details
Who does it Aimed at helping compliance officers and permitting officers with
apply to? technical standards and specific compliance issues surrounding
asbestos wastes.
While this is an internal guide, it may be shared externally where
appropriate to help deliver a consistent regulatory approach.
Related
documents
Main issues Identifying relevant asbestos wastes, on page 2
covered by this
Regulatory requirements, on page 2
guide
Labelling, on page 4
Storage standards, on page 4
Handling asbestos, on page 5
Feedback
Safe storage at transfer stations, on page 6
Classification and coding, on page 7
Related documents, on page 8 Contact for
queries
Chris Hall
7 22 2516
Paul Fernee
7 21 2624

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 Identifying relevant asbestos wastes

What is Asbestos is a naturally occurring fibrous mineral. There are three main types
asbestos? of asbestos, commonly referred to as:
 white (chrysotile);
 blue (crocidolite);
 and brown (amosite).
White asbestos was by far the most widely used form, however many
products are a mixture of more than one type. Inhalation of asbestos fibres
can cause lung disease and cancer due to the action of the fibres on the
lining of the lung.
Asbestos is considered either unbonded or
bonded. Unbonded asbestos is fibrous or
damaged / broken bonded asbestos.
Bonded asbestos in good condition is
normally relatively safe. The fibres from
unbonded asbestos can easily become
airborne and so is considered more
dangerous than bonded.

Uses of Asbestos was extensively used as a building material

asbestos1 in the UK from the 1950s through to the mid-1980s. It
was used for a variety of purposes and was ideal for
fireproofing and insulation.
All new uses and re-uses are now banned
(www.hse.gov.uk/asbestos/regulations.htm).
However, any building constructed before 2000 could
contain asbestos. This is normally in the form of
cement bonded panels but asbestos may also be
found in unbonded forms.
Asbestos was also used in vehicle components, for
example brake pads and brake shoes, as pipe
lagging, and in gaskets

Regulatory requirements

If asbestos is If waste is suspected to be asbestos or containing asbestos, it should be

suspected treated as if it is asbestos unless confirmed otherwise.

1
All photos are reproduced from the HSE website and guidance.
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 Working with Anyone working with asbestos has to comply with the Control of Asbestos
asbestos Regulations 2012.
There are some thermal treatment processes that can decompose certain
asbestos wastes to a non-fibrous state or vitrify it to a safe glass-like
material. Any treatment of asbestos waste requires an environmental permit.
Treatment activities also require a licence from the HSE (Health & Safety
Executive) depending on the activity undertaken. However, there are
currently no commercially available permitted asbestos treatment activities in
England or Wales.
The HSE provides guidance on this in an approved code of practice:
Managing and working with asbestos

Transferring Asbestos waste is almost always hazardous waste.

or storing as
Transferring
hazardous
A hazardous waste consignment note must be used when asbestos waste is
waste
moved from one location to another (including asbestos produced by a
contractor at domestic premises). The only exception is when a householder
moves their own waste.
Consignment notes should always be checked for compliance, completeness
and correctness. For example look for:
 discrepancies in weights, dates and times
 issues with names and signatures
Receiving and storing
Unless it is bonded asbestos stored at a place controlled by the producer,
not undertaken as a waste management service2, the site receiving asbestos
waste must be permitted under the Environmental Permitting Regulations
(EPR):
 If the site has the capacity to store more than 50 tonnes of hazardous
waste (including asbestos), it must have an environmental permit to
undertake a listed activity under Schedule 1, Section 5.6 A(1)(a) of the
EPR.
 Sites storing less than 50 tonnes of hazardous waste require an
environmental permit for a waste operation.
The primary role of an asbestos removal contractor is to remove asbestos
which is being discarded or is required to be discarded. Asbestos removal
contractors are involved in providing a waste management service on behalf
of others. The Non Waste Framework Directive exemption for temporary
storage of waste at a site controlled by the producer does not apply to
asbestos removal contractors or the storage of unbonded asbestos.

Disposal at Guidance for the acceptance of asbestos in landfills for disposal can be
landfills found at: http://publications.environment-
agency.gov.uk/PDF/GEHO1110BTEW-E-E.pdf.

2
This would exclude asbestos removal companies - see Schedule 25 Part 3 Paragraph 3 for full
requirements.
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 Labelling

Suitable Asbestos waste bags and containers should be labelled with the asbestos
markings warning sign. Mark vehicles and packaging in accordance with the
regulations for the carriage of dangerous goods.

Storage standards

Pre- Asbestos wastes should be subject to rigorous pre-acceptance and

acceptance acceptance procedures. While the document ‘Guidance for the Recovery and
and Disposal of Hazardous and Non Hazardous Waste S5.063 was not written
acceptance with asbestos wastes in mind, some of the general principles of pre-
acceptance and acceptance are applicable. Some however are clearly not
applicable, such as the requirement for the operator to sample and analyse
asbestos wastes.
Asbestos waste should be coded appropriately by type according to the List
of Wastes Regulations (see Classification and coding) No further
assessment is required unless the waste is known to be contaminated with
other substances.
Acceptance procedures will not require e.g. a sample or the analysis of a
sample by the operator (as this has been done as part of the original
asbestos survey) or bags and wrapping to be opened.
Acceptance procedures will not require sampling and testing but will ensure
that:
(i) skips containing asbestos waste are sealed and secure upon arrival
and are not opened to verify contents or to add further materials.
(ii) other asbestos is appropriately packaged (see below). Damaged
packaging or incorrectly labelled asbestos should be remedied
immediately. Packaged asbestos must be deposited in a lockable
skip. Bags must not be opened.
(iii) an auditable record is made of non-conforming wastes.
On arrival at the site, asbestos should only be accepted when it is
appropriately packaged, as shown in the examples below.

3
see: http://www.environment-agency.gov.uk/business/sectors/39737.aspx
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 Pictures from HSE guidance EM9 Disposal of asbestos waste

Handling asbestos

Handling There are always risks associated with the transfer of asbestos waste. To
asbestos avoid the risk:
 Wherever possible deliver waste asbestos directly to landfill, this
minimises unnecessary double handing. A secure container must be
used.
 Where cement bonded asbestos is delivered direct to landfill it must be
stored in a secure skips. Wrapping of asbestos sheets would not be
required if the skip is lined and the sheets are covered with plastic
sheeting to minimise contamination of the skip and spread of asbestos in
loading, transporting and emptying of the skip.
 Store fibrous asbestos in the container double-bagged.
 Where cement bonded asbestos is not delivered direct to landfill and is
stored at a transfer station, introducing double handling, cement bonded
asbestos must be double-bagged or double-wrapped (if in large pieces).

Deposit asbestos waste at landfill with the minimum of handling either

manual or mechanical, see http://www.environment-
agency.gov.uk/static/documents/Business/RGN_LFD1_Landfills_(v2.0)_30_
March_2010.pdf.

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 Using transfer The function of an asbestos waste transfer station is to facilitate the transfer
stations of small amounts of appropriately packaged asbestos waste from delivery
vehicles such as small vans.
Such waste must be taken from the delivery vehicle and placed directly into a
lockable sealed skip. Handling bags should not compromise the bag or its
contents. Bags must not be opened. Repackaging must be limited to the
repair of damaged packaging only.
Larger quantities of asbestos in locked sealed skips can be delivered to
transfer stations. To prevent the release of fibres such skips however must
not be unloaded, added to or bulked up.

Safe storage at transfer stations

Guidelines Follow the guidelines below:

Item Guideline
1 Asbestos wastes must not be put into bays or transferred between
different skips or containers.
2 Make the deposit at a transfer station with the minimum of handling,
either manual or mechanical.
Loading shovels must not be used to move asbestos waste.
3 Keep skips secure and locked when asbestos wastes are not being
deposited in them.
4 Operators must have emergency procedures to deal with non-
conforming asbestos wastes that arrive at the facility.
Non-conformance includes wastes received that are not properly
contained in bags or skips, for example unwrapped asbestos sheets
and open skips.
Sites should also have the capability to deal appropriately with non-
conforming waste and spillages, for example from broken bags.
Records must be made of non-conforming wastes
5 Do not use a skip that has been used to store asbestos wastes for
non-asbestos uses, unless they are verified as clean. Otherwise the
skip must be fully decontaminated.
See http://www.hse.gov.uk/pubns/waste26.pdf for guidance.

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 Classification and coding

List of Waste Hazardous asbestos wastes can arise from a variety of sources and,
(LoW) codes therefore, may be described under a number of List of Waste (LoW) codes.
The most likely examples of hazardous asbestos wastes are set out in the
table below.
Coding and classification of hazardous wastes is described in technical guide
WM2 but usually if a waste listed in the table below contains more than 0.1%
asbestos it is hazardous4.
Where discreet, identifiable fragments of asbestos are found within a waste,
the asbestos and the other constituent of the waste should be considered as
a mixed waste, coded as two distinct wastes. Each of these should be coded
and classified individually in accordance with WM2.
The requirements of the Hazardous Waste Regulations apply to the
hazardous asbestos wastes listed in the table below.
Asbestos waste Relevant Hazardous LoW Codes and Descriptions
source
Asbestos – usually 17 06 01* insulation materials containing asbestos
fibrous and
insulation products
Asbestos – bonded 17 06 05* construction materials containing asbestos
or corrugated
Asbestos-lined 16 01 11* brake pads containing asbestos
brake shoes

Other asbestos 15 01 11* metallic packaging containing a dangerous

wastes solid porous matrix (for example asbestos) including
empty pressure containers
16 02 12* discarded equipment containing asbestos
16 02 15* hazardous components removed from
discarded equipment

4
A waste that contains less than 0.1% asbestos may still be hazardous where it has been deliberately
mixed to lower the concentration of asbestos.
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 Related documents

Links HSE Resources

 HSE Asbestos Homepage: http://www.hse.gov.uk/asbestos/index.htm
 HSE Asbestos Image gallery: http://www.hse.gov.uk/asbestos/gallery.htm
Work with materials containing asbestos
 Managing and working with asbestos Approved Code of Practice and
guidance: http://www.hse.gov.uk/pubns/priced/l143.pdf
 em9 Disposal of asbestos waste:
www.hse.gov.uk/pubns/guidance/em9.pdf
 Waste26 Managing health and safety in civic amenity sites:
http://www.hse.gov.uk/pubns/waste26.pdf

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