3. ELV pre-acceptance, acceptance and tracking
These are the appropriate measures for ELV pre-acceptance, acceptance and tracking at regulated facilities with an environmental permit to store and treat ELVs. These measures are designed to make sure operators only receive ELVs they can safely store, depollute, and dismantle.
1. In all cases you must reassess the information required at pre-acceptance on an annual basis. The information required and the assessment made at the pre-acceptance stage is to make sure you:
- only accept ELVs that are suitable for the site
- avoid accumulating ELVs
- have enough storage and treatment capacity
2. You must implement ELV pre-acceptance procedures so that you know enough about ELVs before they arrive at your facility. You need to do this to assess and confirm the ELVs are technically and legally suitable for your facility and processes. Your procedures must follow a risk-based approach, considering:
- the source and nature of the ELV
- its hazardous properties, for example, whether it is a combustion vehicle or electric end of life vehicle (EELV)
- potential risks to the environment (for example, from fire)
3. You must get the following information in writing when you agree to accept an ELV:
- details of the ELV holder, including name, address and contact details
- the specific source of the ELV
- a description of the ELV including its composition and quantity
- the List of Waste codes (European Waste Catalogue (EWC) code)
If the ELV has already been depolluted, you should request evidence to show this has been done. A certificate of destruction (COD), a visual check, declaration or some other evidence may help to confirm that depollution has been carried out.
4. You must consider whether any of the specific ELVs you are permitted to receive have properties that can pose unacceptable risks to the site or process. For example, damaged batteries can present a chemical, electric shock and fire risk.
5. You should establish a list of these ELVs and procedures for managing the risks they pose.
6. You must keep pre-acceptance records for at least 3 years in a suitable ELV tracking system following receipt of the ELV .
7. You must reassess the information required at pre-acceptance if the ELV received does not conform to the pre-acceptance information.
1. You must implement ELV acceptance procedures to check that the ELV received matches the information you obtained during pre-acceptance. This is to confirm that the waste is as expected and that you are permitted to accept it.
2. If not, you must confirm that you can accept it as a non-conforming waste, or you must reject it. If you are rejecting an undepolluted ELV, you must follow the guidance on the procedure for rejecting hazardous loads.
3. Your procedures should be documented and auditable and must follow a risk-based approach, considering the ELVs’:
- source, nature, and age
- hazardous properties
- potential to contain persistent organic pollutants (POPs)
- potential risks to process or occupational safety, and to the environment (for example, from odour and other emissions)
- previous holders and your knowledge about them
4. If you have not received any pre-acceptance information, you must assess the load to make sure it is technically (and legally) suitable for the site. Your checks and assessment must be risk-based considering, for example, the:
- hazardous properties of the ELV
- risks posed by the ELV in terms of process safety, occupational safety, and environmental impact
Storage areas
5. All relevant storage areas (quarantine, reception and general) and treatment processes in your facility must have the physical capacity needed for the ELVs you receive. You must not receive ELVs if this capacity is not available. The amount of ELVs you receive must also comply with storage limits in your permit.
6. The ELV offloading, reception, treatment and quarantine areas must have impermeable surfaces with a sealed drainage system. This system must collect all surface water run‑off and channel it to a blind sump unless you can lawfully discharge it in another way.
ELVs and treatment areas should be stored under cover to prevent ingress of rain and surface water.
You should keep clean surface water from roofs separate from contaminated waters.
7. You must clearly designate a materials reception area (or areas). Staff controlling the inspection, reception and validation of materials at the installation must be trained in their respective roles.
Waste acceptance
8. You must assess the weight of each load of ELVs on arrival to confirm the quantities against the accompanying paperwork. This is unless you have alternative reliable systems (for example, based on established data). You must record the weight in a suitable ELV tracking system.
9. You must check and validate all transfer documentation and resolve discrepancies before you accept the ELVs. If you believe the classification and description of the incoming ELVs is incorrect or incomplete, then you must address this with the customer during ELV acceptance. You must record any non-conformances. If you have assessed the ELVs as acceptable for on site storage or treatment, you must document this.
10. You must have clear criteria that you use to reject non-conforming ELVs. You must also have a written procedure for recording, reporting, and tracking non-conforming ELVs, including notifying the relevant customer or ELV producer to prevent reoccurrence.
Baling ELVs or components
11. If you are baling ELVs, you must make sure they are fully depolluted before baling.
Quarantine storage
12. You must establish quarantine areas for materials that are prohibited, awaiting full inspection, or awaiting testing or removal.
13. Quarantine storage must be for a maximum of 14 working days. For some limited and specific cases (for example, gas cylinders) you can extend the quarantine storage time if the Environment Agency agrees.
14. You must have written procedures for dealing with waste held in quarantine, and a maximum storage volume.
15. Quarantine storage must be separate from all other storage and clearly marked as a quarantine area.
16. You must identify and isolate gas cylinders and other prohibited items to remove them from the ELV stream. You must store gas cylinders in locked cages. Where possible, you must send prohibited items back to the appropriate owner.
1. You should use an electronic tracking system to hold up-to-date information about the available capacity of the ELV. This includes in the quarantine, reception, general and bulk storage and treatment areas of your facility. If you do not have an electronic system, you still need to hold the equivalent level of information. You should use a pre-booking system to make sure you have enough waste storage and treatment capacity for the incoming ELVs.
2. Your ELV tracking system must hold all the information generated during:
- pre-acceptance
- acceptance
- non-conformance or rejection
- storage
- repackaging
- treatment
- removal off site
This information must be readily accessible.
3. You must create records and update them to reflect deliveries, on site treatment, and despatches.
4. Your tracking system will also operate as a ELV inventory and stock control system. It must include this information as a minimum:
- the date the ELV arrived on site
- the original producer’s details (or unique identifier)
- a unique reference number
- ELV pre-acceptance and acceptance information
- the intended treatment or recycling route
- accurate records of the nature and quantity of ELVs held on site, including all hazards – you should identify the primary hazards
- where the ELV are physically located on site
5. The tracking system must be able to report:
- the total quantity of ELVs present on site at any one time
- a breakdown by type of the ELV quantities you are storing pending treatment or transfer
- the quantity of ELVs on site compared with the limits authorised by your permit
- the length of time the ELVs have been on site
- the quantity of ELV product materials on site at any one time, and where applicable, details of any non-conformances and rejections
6. You must store back-up copies of computer records off site. Records must be readily accessible in an emergency.
7. You must hold acceptance records for a minimum of 2 years after you have treated the ELVs or removed them off site. You may have to keep some records for longer if they are required for other purposes, for example, hazardous ELV consignment notes.