Hazardous Waste – a brief overview

Hazardous WasteThe WEEE Directive

In addition to the rules covering the transfer of all redundant  IT equipment, the current WEEE (Waste Electrical and Electronic Equipment Directive) regulations mandate the way that hazardous waste must be treated by businesses / institutions and their third party recyclers. 

What is Hazardous waste?

Clearly, there are many types of waste which are classified as hazardous, including some which are not normally discussed in polite society!  However, from the standpoint of redundant IT equipment the most common items are old style CRT monitors and TVs (which contain a quantity of mercury), as well as lead acid containing UPS batteries.  

Am I required to do anything?

The bad news:

For those unfamiliar with the regulations, the current situation is that any site (one postal address) which produces more than 500kg of hazardous waste* within a rolling year must be registered as a Producer of Hazardous Waste before breaking this threshold.  

The good news:

The online registration process (which covers one year) is straightforward and not costly.

*Please note that the weight is of the assets containing the hazardous substances, and not just the weight of the hazardous materials themselves! 


If you are aware that some of your redundant assets are classified as hazardous, then to avoid falling foul of the regulations, you may wish to use the following checklist when dealing with a recycler:

  • Are they licensed as a Waste Carrier and/or Broker?
  • Are their premises registered on the Hazardous Waste Register? 
  • Do they understand (and more importantly abide by) the current regulations?
  • Do they have procedures in place to ensure the safe recycling of these items?
  • If YES to the above, do their procedures include a policy of 0% to landfill?
  • When applicable in the past, have they issued you with the required Hazardous Waste Consignment  Note?

If you would like further clarification on any of the above and it relates to IT Equipment, then please feel free to contact us and we will do our best to help/advise

Large fine imposed for loss of personal data

The importance of securing data was highlighted recently when the ICO (Information Commissioner’s Office) imposed a fine of £150K on Glasgow City Council for a number of data security breaches.  These breaches most importantly included the loss of two laptops with unsecured data which included the bank account details of over 6,000 people, and other personal data relating to  more than 20,000 individuals.

Although the unfortunate loss of this data was caused by a lack of effective encryption and then the subsequent theft of the two laptops in question, it does also highlight the need for organisations to insist on certificated data destruction when PCs, servers and laptops become redundant within their organisation.  

The Duty of care: waste transfer note

We are often asked about the ‘Duty of care: waste transfer note’ which is often referred to as just the ‘WTN’.  The main points to note as a producer are that:

  1. All parties handling electrical waste have a responsibility to ensure that it is correctly handled and processed.  
  2. It is a legal requirement for a WTN to be issued when WEEE (Waste Electrical and Electronic Equipment) transfers from one organisation to another.
  3. Once the WTN is signed by the waste producer, the responsibility for the correct handling and processing of the waste assets moves to the collector.  If the collector then sends some of this waste (because it can’t be re-used for its original purpose) so that the recovery of plastics, precious metals and so on can take place, then once again a waste transfer is taking place and therefore another WTN is required.  
  4. The primary reason (there were other considerations) for the introduction of this legal document was to combat flytipping. 
  5. The current guidelines (May 2013) from the Environment Agency are that these notes should be kept by the waste producer for a minimum of two years.
  6. At this time (May 2013) WTNs are generally paper based.  However, there is an initiative under way for a more centralised electronic system (edoc) to be available in the future.