How to dispose and handle waste hydraulic oil, hoses & associated waste

There has been considerable uncertainty within the hydraulics industry regarding the

classification of various types of waste and how it should be processed in an

environmentally responsible and legally correct manner. This uncertainty has also led to

questions relating to the need or otherwise for Consignment Notes when transferring the

waste.

In our latest blog, we share advice recently published from the British Fluid Power Association on how these items should be dealt with.

WASTE HYDRAULIC OIL

Hydraulic oils are listed within The European Waste Catalogue (EWC) as ‘absolute

hazardous waste’. To ensure that the movement of waste hydraulic oil is traceable a

Consignment Note must be prepared before the waste oil is moved. A Consignment Note

must contain certain information concerning:

1. i) the nature of the waste
2. ii) a full description (including the EWC) code

iii) where, when and who generated the waste

1. iv) details of who the waste was consigned to

 WASTE HYDRAULIC HOSES, RAGS, SPILL PADS AND GRANULES

Where possible, the specific hydraulic oil being used should be identified and the Safety Data Sheets (SDS) checked to see if there is any indication that the oil contains hazardous substances. In a

maintenance and repair environment, this is not usually possible, so for standard hydraulic

applications the oil can be considered to be mineral oil-based and non-chlorinated, which

carries the EWC code of 13 01 10.

Additionally, because these hoses have residues of hydraulic oil which do not display any

hazardous properties, the correct code to use is 16 01 22 which is a (mirror) nonhazardous

waste.

Oily rags, spill pads and granules used in the clean-up and maintenance are classified

under 15 02 of the EWC. Similarly, because the oil does not have hazardous properties,

these wastes will also be classified as (mirror) non-hazardous: 15 02 03. There are two

considerations, however:

1. A need to act responsibly to minimise the amount of oil used in hydraulic hoses,

spill pads and granules, etc. and any environmental damage this waste oil could

produce.

2. The need to comply with The Environmental Protection Act 1990 [2], Section 34:

Waste Management – the Duty of Care, a Code of Practice regarding the transfer of

any controlled waste (see Appendix B).

NOTE 3: Used hydraulic hoses, rags, spill pads and granules are controlled waste under

this Code of Practice.

Also available from: http://www.eauc.org.uk/templates

Consequently, in simpler terms, waste hydraulic hoses, rags, spill pads and granules do

not require a Consignment Note for transport purposes, provided that they are handled

appropriately and disposed of in accordance with the Regulations above.

APPROPRIATE HANDLING, GOOD PRACTICE AND DRAINING OF USED HYDRAULIC HOSES

Oil should be drained from any hydraulic hoses before it is removed from site. It is not

considered good practice to drain oil into a container which is then poured back into the

hydraulic system as this can result in contamination.

In the event that such waste hydraulic oil is recovered and left at the customer’s site, the

service provider, as the producer of the waste, has an obligation under their Duty of Care

to take reasonable steps in ensuring that the oil will be handled appropriately. This will, at

least, include informing or reminding the customer of their obligations under WM3 to

ensure that the oil is disposed of in the appropriate manner.

In the event that the oil is to be transferred by the customer, they also need to be reminded

that they are obliged to do so with the appropriate Consignment documentation.

Such notification might be made in the form of a printed leaflet to be left at the site which

both informs the customer of their obligations and provides them with guidance on how to

meet their responsibilities under the relevant Regulations. Whilst this may not completely

remove the service provider from any responsibility for subsequent mis-handling of the oil

by the customer it will, at least, be seen as best practice and constitute reasonable efforts

to ensure that the customer is complying with the Regulations. Any service provider’s

paperwork associated with the customer signing to acknowledge completion of the work

may also contain similar provisions stipulating that as it is a hazardous waste, it will be

assumed that any oil left at the customer’s site will be disposed of in accordance with the

relevant Regulations.

TRANSFER OF NON-HAZARDOUS WASTE

Section 34 of the Environmental Protection Act stipulates that if any non-hazardous

controlled waste is transferred then a Waste Transfer Note is required. Someone who

carries out repair work is considered the producer of the waste. Hence, if the producer

removes any hose and associated waste from site it is not being transferred and a Waste

Transfer Note is not required.

OIL FILTERS/CARTRIDGES

Oil filters are classified under the end-of-life vehicle category 16 01 and specifically

16 01 07 which is classified as Absolute Hazardous (AH).

NOTE 6: The movement of any oil filter/cartridge needs to be traceable and a Consignment

Note is required.

SCOTLAND AND WALES

The Scottish Environmental Protection Agency (SEPA), operates independently from the

EA as do the other regulators for Northern Ireland and Wales. The Regulations controlling

the movement of hazardous (special) waste in Scotland are also slightly different.

The rules, however, governing the classification of waste are not different, being driven by

European Regulations. All four agencies contribute to a single piece of guidance on waste

classification (WM3). Classifying this waste, therefore, in any part of the UK using this

guidance will result in reaching the same conclusion.

The agreed classification applies UK-wide.