5. ELV treatment
These are the appropriate measures for ELV treatment at regulated facilities with an environmental permit to treat ELVs.
1. ELV treatment must have a clear and defined benefit. You must fully understand, monitor, and optimise the ELV treatment process to make sure you treat ELV effectively and efficiently.
2. The treated output material must meet your expectations and be suitable for its intended disposal or recovery route, in line with applicable regulations.
3. You must identify and characterise emissions from the process and take appropriate measures to control them at source.
4. You must have up-to-date written details of your treatment activities and the control equipment you are using. This should include information about the characteristics of the ELVs you will treat and the ELV treatment processes. The written details should include:
- diagrams of the main site items where they have environmental relevance (for example, storage, tanks, treatment, and site design)
- details of depollution processes and physical treatment processes
- an equipment inventory listing site type and design parameters
- ELV types that you will treat
- a summary of operating and maintenance procedures
5. You must have up-to-date written details of the measures you will take during abnormal operating conditions to make sure you continue to comply with permit conditions. Abnormal operating conditions include:
- unexpected releases
- fire events
6. You need to consider physical hazards and include an assessment of the environmental risks and emissions from the site and processes. You also need to consider prevention and protective measures and process management, such as:
- working instructions
- staff training
- appropriate process control measures
- alarms
- site maintenance
- checks
- audits
- emergency procedures
7. You must accurately classify and code the ELVs. This should be carried out following the waste classification guidance.
8. You must not use a waste code for a single material fraction, such as plastic, unless the process is specifically aimed to produce that single fraction. Contamination by other materials must be negligible.
Typical waste codes used in the ELV sector are described in this table.
| List of Waste codes | Description |
|---|---|
| 13 01 11* or 13 01 12* or 13 01 13* | Hydraulic oils |
| 13 02 06* or 13 02 07* or 13 02 08* | Engine, gear, and lubricating oils |
| 13 05 03* | Interceptor sludges |
| 13 05 07* | Oily water from interceptor |
| 13 05 01* | Solid waste from interceptor |
| 13 07 01* | Fuel oil and diesel |
| 13 07 02* | Petrol |
| 13 07 03* | Other fuels, including mixed fuels from mis-fuelling |
| 14 06 01* | Air conditioning gas (R12 or R134a) |
| 14 06 02* | Air conditioning gas (HFO-1234yf) |
| 16 01 04* | End-of-life vehicles – undepolluted |
| 16 01 07* | Oil filters |
| 16 01 08* | Mercury containing components (tilt switches) |
| 16 01 11* | Brake pads containing asbestos (older ELVs) |
| 16 01 13* | Brake fluids |
| 16 01 14* | Antifreeze containing hazardous substances |
| 16 01 21* | Catalytic converter/ DPF units containing (RCF) |
| 16 06 01* | Lead acid batteries |
| 16 06 02* | Ni-Cd batteries |
| 16 01 03 | Tyres (no longer usable) |
| 16 01 10* | Explosive components (for example, airbags) |
(*) An asterisk at the end of a code means the waste is hazardous.
Check the full list of waste codes relevant to the ELV sector.
Minimising diffuse emissions from the process
9. You must minimise releasing diffuse emissions to air from activities which may create them, for example cutting, drilling, or grinding activities.
10. To track and control changes to processes, you must have a written procedure for proposing, considering, and approving changes to both:
- technical developments
- procedural or quality changes to the site and processes
Record keeping for all treatment residues
11. You must record in a suitable ELV tracking system:
- that an ELV has been treated
- what the treatment residues are and their weight
- what products (and the product weight) have been made from ELVs
1. The depollution sequence shown can be represented as 3 stages:
- preliminary activities
- removal of fluids and other items
- removal or deployment of air bags
2. After you have carried out each depollution operation, you must transfer the fluid or item you have removed to a suitable storage facility as soon as possible.
Preliminary activities
3. Before depollution, you must assess the vehicle for health and safety hazards. Hazards include glass, hypodermic needles and other biological contamination, or fire damage, which might affect the way in which its treatment should be handled.
4. You must check the vehicle for and remove any other foreign objects that might affect the way in which its treatment should be handled, such as gas cylinders and aerosols.
5. You must use the specific vehicle manufacturer’s guidance on depollution. If this is not available, then depollution information may be available on systems such as the international dismantling information system (IDIS). It is important to make sure you use the latest version of IDIS. You can check this on the IDIS website. Other sources of information may be available.
6. You must determine how many airbags are present in the vehicle and whether they have already been deployed or not. You must remove airbags that have not been deployed or depollute them ‘in situ’ (in their current position).
7. You should, where possible, deploy air bags in situ using suitable equipment and that anyone deploying airbags must have attended a suitable training course.
8. You must remove the starting, lighting, ignition (SLI) battery to prevent an accidental electrical discharge before the fuel tank is depolluted. If the vehicle is electric powered or a hybrid vehicle, then refer to manufacturer’s instructions.
9. You should either remove the fuel, oil filler and other caps or open them to allow fluids to drain more easily.
10. You should set heater controls to maximum heat to make sure that the coolant in the heater unit can be drained. You should set the heater controls at the position which would provide the maximum amount of heat.
11. Removing wheels or tyres is not a depollution requirement (you are required to remove lead balancing weights). Removing the wheels and tyres will improve access to brakes and shock absorbers for depollution.
12. When removing tyres from rims, you may be able to reduce the operatives’ exposure to dust by deflating the tyre first. You can do this by either removing the valve, or by piercing the sidewall with a suitable tool if the tyre is not intended for reuse or retreading.
13. Remove balance weights from all wheels including the spare wheel, and place in a suitable storage container for recycling.
14. Prepare electric or hybrid vehicles for treatment. These vehicles contain a high voltage electrical system. There are dismantling requirements for the high voltage system before you can treat the vehicle as a normal ELV.
15. It is important you recognise and understand the high voltage electrical system and its specifications in order to safely handle the ELV. Electric or hybrid vehicle batteries that have not been discharged carry a significant risk of electric shock. They may also be an environmental hazard if their contents are accidentally released. Electric vehicles may contain other energy storage devices, such as capacitors, which may have to be discharged separately to the isolation of the battery. Even when disconnected and isolated it may be possible to generate electricity for example by turning the wheels or towing the vehicle.
16. You must make safe electric or hybrid vehicle batteries. You can normally do this by removing the safety cut-off plug. However, as vehicles have different designs you must refer to the manufacturer’s data sheet or other competent data source.
17. When dismantling any electric or hybrid components from the vehicle you must use the utmost care. Hybrid components may present significant risk due to their highly energetic properties and the nature of the materials they contain. Hybrid components should only be disassembled by suitably qualified personnel. You must comply with the important safety warnings listed in the manufacturer’s instructions, in IDIS, or in other competent data sources.
1. You must store removed fluids of differing types (for example, oils or water-based) in separate containers in a bunded storage area before carrying out specialist recovery or disposal.
2. You will need separate containers for:
- fuels (petrol and diesel separate)
- oils (lubricating, transmission, power steering and shock absorber oils together)
- water based coolant and screen wash (together)
- diesel exhaust fluid (DEF), for example AdBlue (separate)
- hydraulic fluids, for example brake and clutch fluids (together)
3. You must place the ELV on a support frame or lifting device to allow easy access below the vehicle before you can carry out a number of operations. Although you could get access to the underneath of a vehicle by placing it above a pit, there are health and safety issues with this approach. In particular, this would be the possible build-up of fuel vapour in the pit (and risk of explosion or fire) during the depollution procedure. Other risks include those associated with working in a confined space and working and falls from height.
4. You should also take care to avoid any vapour build up in floor mounted drip trays. The Dangerous Substances and Explosive Atmospheres Regulations (DSEAR) provides advice on avoiding explosive atmospheres.
The first activity you must carry out is to start draining the engine oil. You can carry out other activities in parallel, but the engine oil can typically take 20 minutes to reach the point where you can no longer see any oil draining.
5. You should carry out depollution activities using equipment which has been specifically designed for a depollution operation. Using such equipment will make sure that you can achieve a high level of depollution in a relatively short time frame.
6. You must also follow the instructions provided with any commercial equipment you use to make sure that you achieve this high level of depollution.
7. After depollution, you must plug all gravity-drained holes to prevent any residual leakage. You can either do this with their own drain plug or with a suitable plastic bung.
Engine oil
8. Engine oil is gravity-drained by removing the drain plug at the bottom of the sump and collecting the oil. If you do not use commercially available equipment to collect the oil, you should use a suitable container which has a minimum volume of 10 litres.
9. You must allow the oil to drain from the engine for a minimum of 20 minutes, or until you can no longer see any oil draining.
10. You must remove the oil filter. You should do this by using a suitable spanner or tool which does not puncture the oil filter during removal. You must treat the oil filter to remove residual oil. You can do this by crushing the filter and recovering the oil. Alternatively, you can send the oil filters to a suitable treatment facility using leakproof transit packaging. If the oil filter is crushed using a crusher designed and manufactured to remove the residual oil content to below 0.1%, then the oil filter will be classified as non-hazardous waste and can be placed back into the vehicle.
11. Once drained, you should replace the sump plugs, or other bungs to prevent further dripping.
Gearboxes
12. If a manual gearbox has a drain plug, you can gravity-drain it by removing the drain plug and collecting the oil in a suitable container which has a minimum volume of 5 litres. You must allow the oil to drain for a minimum of 10 minutes until you can no longer see any oil draining.
13. You must drain gearboxes which do not have a drain plug by drilling or piercing a suitably sized hole in the bottom of the gearbox and collecting the oil.
14. You must drain automatic gearbox oil from both the gearbox and the torque converter. These may be combined in a single unit, but the torque converter on some types of gearboxes is separate from the main gearbox unit. The procedure for draining these is the same as for a manual gearbox.
Rear differential
15. The procedure for draining a rear differential is the same as for a manual gearbox. You can:
- drill those that do not have a drain plug
- loosen and prise open the differential flange (if rear wheeled drive)
- use suction equipment
Power steering
16. If the ELV has power steering, you must extract fluid from both the reservoir and the connecting hose. You remove fluid by piercing the hose and sucking out the fluid, or by cutting it at the lowest point and allowing the fluid to gravity drain.
Brake fluid
17. All ELVs contain brake fluid. You can remove brake fluid with commercial equipment using both pressure and suction on the reservoir, pipes, and cylinder.
18. You should allow a drainage time of 10 minutes. There should be no visible fluid left in the reservoir and no visible further drainage following removal of suction equipment.
Clutch fluid
19. Virtually all modern cars have cable clutches and so do not contain any hydraulic clutch fluid. Some older cars may have hydraulic clutches. You can use equipment similar to that used to extract brake fluid from the brake reservoir to extract fluid from the clutch reservoir and slave cylinder.
Coolant (antifreeze)
20. You can gravity drain coolant and collect the liquid in a suitable container with a minimum volume of 10 litres. Commercial equipment allows you to drain from any reservoir or to drain from the bottom into a container.
21. You should allow a drainage time of 10 minutes, until you can no longer see any coolant draining.
Screen washing fluid
22. You remove screen washing fluid by sucking it from the reservoir, or by draining it from below. You can either use commercially available equipment or other suitable suction equipment.
23. If you use suction equipment, you must inspect the reservoir to check that it has been completely emptied. If a vehicle has more than one reservoir, then you must drain all reservoirs.
24. You should drain the reservoirs until you can no longer see any fluid there.
Fuel tank (not LPG)
25. The Health and Safety Executive (HSE) has provided guidance for operators on safe recovery of petrol from end of life vehicles.
You can remove fuel by suction or siphoning it from the tank with a tube that enters the tank through the fuel filling pipe. However, this procedure is unlikely to achieve the required level of depollution and you should only use it where no other method is available.
26. To make sure you achieve the required level of depollution you should pierce or drill a hole into the lowest point of the fuel tank and use suction to remove the fuel.
27. Drills or piercing tools should be made of suitable non-sparking material and pneumatically powered. There must be an earthing connection between the vehicle and the extraction equipment. Commercially available equipment should meet these requirements. You must only use intrinsically safe equipment for fuel removal. All equipment must be ATEX Directive compliant.
28. You should drain the fuel tank until you can no longer see any fluid in the (see through) extraction tubing.
Suspension system – shock absorbers
29. The most efficient way to drain the fluid from the shock absorber is whilst it is in situ and attached to the vehicle. To achieve the required level of depollution, you must remove the fluid from both the inner and outer cylinders of the shock absorber.
30. The equipment designed for fluid or oil-based shock absorbers may be suitable for safely removing the gas from gas suspension systems. You must confirm this with the manufacturer of the equipment before you use it for this purpose. You must follow any additional safety requirements or other instructions provided by the manufacturer.
Sealed suspension systems
31. There is commercially available equipment for both removing and recharging these sealed suspension systems and you can use this to drain them. Alternatively, you can gravity-drain them in about 20 to 25 minutes. You should carry out these procedures until you can no longer see any fluid.
Air conditioning refrigerant
32. Not removing the air conditioning gas from ELVs would breach your environmental permit and the requirement of the ELV Directive. This Directive sets out minimum standards for dismantling and recycling ELVs and includes the requirement to remove the air conditioning gas.
There are 3 types of gas found in vehicle air conditioning systems:
- R12
- R134a
- HFO-1234yf (2,3,3,3-Tetrafluoropropene)
33. Although the same equipment can be used to extract R12, R134a and HFO-1234yf they must not be mixed. Systems using HFO-1234yf need different connectors to those used for R12 and R134a so operators should have both sets.
34. If you are using R134a air conditioning gas from ELVs to recharge air conditioning systems, then you should refer to Using R134a air conditioning gas from ELVs to recharge air conditioning systems: RPS 226.
35. You must remove air conditioning refrigerant gas using specialist equipment, and you must have separate collection cylinders for each type. Depollution and collection takes around 10 to 12 minutes (depending on the system and ambient air temperature).
36. Relevant operatives must be formally trained and hold a duly accredited certificate of competence. See the F-gases guidance.
AdBlue
AdBlue is a liquid containing urea which is widely used in catalytic reduction systems. AdBlue is injected into the vehicle exhaust gases to aid the breakdown of NOx emissions into nitrogen and water.
AdBlue is extremely polluting if it enters surface water or groundwater. AdBlue is soluble in water, so oil separators do not contain or remove it.
37. Any areas where you remove (or store) AdBlue from vehicles must have an impermeable surface and sealed drainage. It is also important that you store AdBlue in containers with valves and pipework specifically designed to store urea. This is because it contains ammonia which is corrosive to some metals, such as copper and its alloys.
LPG (liquid petroleum gas) tank
38. If it is feasible, you should run the engine to empty as much fuel as possible from the tank before you start to remove it. This will reduce the weight of the tank and the risk of vapour loss .
Alternatively, you can flare off residual LPG from the vehicle provided that you:
- remove the LPG from the vehicle fuel tank using a system specifically designed and manufactured for purging vehicle tanks of LPG and flaring off gas.
- purge and flare in a clearly identified, designated area of the site, away from combustible and flammable materials.
- detail the process and location for purging and flaring in your fire prevention plan
- carry out a DSEAR assessment and put measures in place to eliminate or control the risks
- clearly label the tanks you have removed from a vehicle to identify that they have been purged, and send them for recovery at a suitably permitted site
39. Even after running to empty the tank will still contain some residual gas vapour, so you must still follow the full removal procedure. Check the battery has been removed or isolated before you remove the tank.
The basic depollution procedure is as follows:
- turn off the isolating valve
- cut through or disconnect the connecting pipes
- cut through or remove the retaining clamps or straps
- remove the tank to safe storage
Refer to the guidance on the removal of LPG tanks.
40. You should quarantine the vehicle in an open area so the tank can be isolated and removed for emptying, purging and separate disposal by suitably qualified personnel. You should check the vehicle for gas leaks using proprietary detection equipment.
41. You should store removed tanks in the open air in appropriate racks or cages until qualified disposal agents can collect or treat them.
42. Because there are health and safety issues when removing, handling and storing LPG tanks, authorised treatment facilities (ATFs) should check HSE’s current guidance.
Switches containing mercury.
43. You must do a visual inspection of areas which contain this type of switch during the depollution procedure, but you only need to remove switches which are clearly identified as containing mercury.
Catalytic converters
Older ELVs may not possess a catalyst, but nearly all modern vehicles, particularly those registered since 1993, both petrol and diesel, will have a catalytic conversion unit in the exhaust system.
The removal of catalytic converters is not part of the depollution process. However, they are one of the higher value items on a vehicle and will be removed as part of the dismantling process in preparation for recycling activity.
You can identify the catalyst by a visual inspection of the exhaust system.
1. Remove the catalyst unit by cutting through the exhaust pipe, both in front of, and behind, the catalyst unit. Some vehicles may have more than one catalyst unit.
Batteries
2. You must remove or disconnect all batteries, with the terminals isolated, as soon as is practicable after the ELV arrives and before the ELV is stockpiled. This is to reduce the risk of fire and electric shock. If you have stored the batteries correctly in an upright position, it may not be necessary to isolate the terminals.
3. You must make safe electric or hybrid vehicle batteries. You can normally do this by removing the safety cut-off plug. However, as vehicles have different designs you must refer to the manufacturer’s data sheet or other competent data source.
4. Modern vehicles may have several smaller lithium-ion (Li-ion) batteries, for example in the infotainment and tracking systems. If not removed, these batteries can become damaged and pose a fire risk. IDIS provides information of the number and types of batteries in a particular make and model of ELV and where they are located.
5. You must store lead acid batteries upright in leak proof acid resistant containers. You must not use damaged containers. If the battery containers are not stored in a well-ventilated building the containers must have lids that prevent water ingress.
6. You must not store different types of batteries together, for example, lead acid batteries with other types of batteries removed from hybrid and electric ELVs. This is to reduce the risk of fire and explosion.
7. Batteries should already be labelled to identify the battery chemistry. If there is no label present, get advice from the manufacturer or databases such as IDIS.
8. Li-ion batteries are found in electric and hybrid vehicles. They have several cells within the battery and be over 500 volts. High voltage Li-ion batteries can be located in various places within the car, for example in the floor or in the boot areas. Different systems discharge in different ways, so you must understand how to safely deactivate, discharge and remove the battery packs. There is some information on the Society of Motor Manufacturers and Traders (SMMT) website.
9. The Li-ion battery packs in electric vehicles are becoming increasingly large and heavy. Whatever method you use to remove and move this battery; you must avoid damaging it. The battery can be damaged by incorrect handling, for example moving the vehicle with a forklift truck. You will require specialised equipment such as supporting stands and tables to safely remove and transport them around the site.
10. You must also store Li-ion batteries separately to other battery types and store them securely to prevent water ingress and to prevent damage.
Further detail about the risks and hazards of working with electric and hybrid vehicles can be found on the HSE website.
Airbags
11. Under the ELV Directive, you must remove or deploy all pyrotechnic devices such as airbags or pyrotechnic seat belt pre-tensioners. This is because they are classed as explosive components.
12. Pyrotechnic devices are deployed either mechanically or electrically depending on vehicle type and year. You must assess every vehicle for airbag type and quantity, and any other pyrotechnic devices that may be present, so you can use a safe procedure.
13. You should get advice from the manufacturer if information is not provided in IDIS. If you are attempting to deploy pyrotechnics you need to be aware of the:
- different types of airbags and pyrotechnic devices contained in a vehicle
- method of deployment – mechanical or electrical
- health and safety issues regarding deployment, removal and disposal
14. Only appropriately trained personnel should carry out airbag deployment or removal.
15. Before you carry out any work on electrically deployed airbags, you should disable them by disconnecting the battery. After disconnecting the battery, you should allow a minimum period of 30 minutes before carrying out any work on the airbags. This is to allow any residual charge left in the system to dissipate.
16. Some vehicles have a supplementary battery back-up system. This will normally be indicated by a flashing LED on the steering wheel which shows that the airbag circuit is still active. Check IDIS for details of the battery location and how to disconnect it.
17. Undeployed air bags that are being removed must be stored correctly. Because they are classed as explosive devices, the storage facility must meet all the relevant regulations and requirements for storing explosive materials, including those relating to health and safety.
18. Many modern cars may have more than 10 air bags. Removing all the airbags would be a time-consuming process. The safest and most efficient way to do this is to deploy the airbags within the vehicle. If it is not possible to deploy the airbag within the vehicle, remove the airbag and deploy it immediately.
19. You should carry out airbag deployment outside in a secure non-hazardous area. If you deploy air bags in situ, you must make sure that neither the operator of the equipment, nor any other person, is within 10 metres of the vehicle when the air bags are detonated.
20. You must assess the level of noise produced during the deployment of air bags and you may need to discuss this with the local authority, particularly if the treatment facility is close to a residential area. Gases and particulates are generated during deployment of pyrotechnic devices. Once all devices have been deployed, you should open all doors to thoroughly ventilate the vehicle before re-entering it for any removal operations.
21. Once deployed, pyrotechnic devices are neutralised and can be left inside the vehicle. The explosives used in airbags (before deployment) are toxic and are hazardous to health. As they are sealed into the generator in manufacture, exposure to these chemicals during normal handling is highly unlikely. If a generator is split open, you must take extreme care. The HSE have guidance on the safe handling and storage of airbags.
Seatbelt pre-tensioners
ELVs that contain air bags may also contain seatbelt pre-tensioners. These are designed to pull the seat belt tight at the same time as the airbags are deployed, to clamp the seat belt wearer to the seat preventing them from gaining too much acceleration or twisting before they hit the airbag.
22. Pre-tensioners may contain explosive or have stored mechanical energy (a large spring) that is deployed mechanically or electrically. If they contain explosive devices, you must deploy them as part of the depollution procedure. You should get guidance from the manufacturer on how to identify, remove and deploy seat belt pre-tensioners if this is not in IDIS.
Asbestos
23. Some older ELVs may contain asbestos (for example, certain brake pad linings). Regulations require that you identify the location of any components that may contain asbestos.
24. You must do a visual inspection of the vehicle during the depollution procedure to identify if the ELV contains any notices indicating parts that contain asbestos.
25. If a visual inspection identifies components that contain asbestos you must remove them. When you remove the components that contain asbestos, your procedures must follow all health and safety guidelines relating to asbestos.