Who will help the enforcers?

Who will help the enforcers?

Who will help the enforcers? It’s not all about offshore accounts.

Who will help the enforcers? It’s not all about offshore accounts.

Payment by cash for scrap metal and ignoring the spirit and the letter of waste licensing law. How local authority, police, HMRC and the Environment Agency are trapped in budget cutting inaction.

Recycling scrap metal and regulation of the waste industry are linked in many different ways. The question of who forces the enforcers apply to both.

Take the issue of a hazardous contaminated scrap steel drum.

Stage 1 : the producer does not declare the hazard contained in the drum either at all, or incorrectly.

Stage 2 : the recycling facility is not licensed for hazardous waste in the first place, or for processing any hazardous waste. The site therefore carries out no pre-acceptance checks. The site does no sampling or inspection. Wastes produced from such sites can only therefore be describing their wastes for onward disposal inadequately.

Stage 3 : the undeclared hazard, not inspected and unprocessed is delivered to a scrap metal recycling facility.

Stage 4 : the scrap recycling facility ignores the NO payment in cash provision in the Scrap Metal Dealers Act, giving an incentive and therefore encouraging customers to generate material without correctly declared paperwork.

contact details

For further information about our dedicated reconditioning and recycling services, or to arrange a meeting with our team to discuss a solution for your residual requirements for waste management and packaging recycling, a member of our dedicated customer service team can be contacted by calling: 0161 848 0976

Email enquiries can be sent to us at: sales@prdservices.co.uk

You can see in this mythical scenario the local authority, relying on the police to enforce the Scrap Metal Dealers Act, is at best in a weak position. (https://www.letsrecycle.com/news/latest-news/bmra-fears-scrap-metal-dealers-act-is-weakening/) The licensing regime has no paperwork trail to inspect. HMRC miss on VAT and possibly income tax also. What is on the face of it some cash generation to avoid tax, can easily lead to significant environmental legislation violation.

We are all responsible to help the enforcers by preparing correct paperwork, identifying companies and individuals who are operating outside regulation, be it Environmental or tax. Take a look around over the next couple of weeks and see if you can help the enforcers force greater compliance. The Environment and the country need all responsible businesses to stand up for plain common sense.


Who will help the enforcers?

WM3: What You Need To Know

In July WM3, or Waste Management 3, came into force. This is the latest technical guidance provided by the Environmental Agency on how to both assess and clarify waste, building on the previous, no outdated guidance provided in WM2.

In many ways a clarification of existing regulations, it has however placed more onerous expectations on producers of waste, particularly in relation to HP14(FORMERLY H14).

The classification of HP 14 is clarified with H code or Risk Phase equations making it particularly difficult for mixtures of materials and some compounds to achieve non-hazardous by HP14 status. This is particularly true of effluents and filter cakes, the standard fare of many industrial and chemical processes.

This will inevitably lead to increase assessment and analysis costs for companies and potentially restrict the opportunities for waste brokers.

Controversy is also the case with the continued declaration of 15.01.10 contaminated packaging as this is an absolute hazard, meaning large quantities of hazardous waste are being consigned to facilities only licensed to receive non-hazardous wastes. Add to this the regular stories of containers emptied to industry standards as empty 15.01.10 containers yet reported to contain several per cent or up to 40 litres of product mean that there is considerable scope for incorrect or under declaration of hazardous waste streams.

Only bona fide hazardous waste facilities are licensed and capable of receiving these with site chemist, infrastructure and appropriate NSDS assessment and method statements.

Packaging Reuse are one such company, for further details regarding how we can meet your hazardous waste requirements, in line with the current legislation, to aid the clarifications of waste stream. It is now more vital than ever to have a team helping handle such issues as:

  • Assisting in identification and analysis of waste in a cost effective manner.
  • Network all hazardous disposal options from Cemfuel, high temperature incineration, TFS and treatment.
  • Identify product and packaging costs properly as part of the overall waste cost:
  • Waste disposal costs:
  • Cost of packaging
  • Cost of manufacturing on raw materials and/or product
  • Cost of disposal
  • Packaging Reuse’s USP is to quantify all three of these costs.

In order to discuss the compliance of your waste stream with WM3, a member of our customer service team can be contacted by calling: 0161 848 0976.

Email enquiries can be sent to us at: sales@prdservices.co.uk


Steel Drums

For the duration of the twentieth century, the steel drum has been effectively used as a means of providing the carriage of liquids. With industries as diverse as hazardous chemicals and foodstuffs, utilising the steel drum as their primary transportation method of choice.

This popularity can be attributed to the fact that the Steel Drum can be safely moved by a single person- due to the fact it is round in shape and can, therefore, be rolled. Due to the fact that the steel drum is incredibly strong, especially compared with other transportation methods, it is considered by many to be the safest transportation method, making steel drums incredibly popular for the movement of hazardous waste.

But what other benefits do steel drums provide?

  •  Safety: due to the strength of steel, these drums can offer unparalleled levels of protection from fire, rupture and leakage.
  •  Durability: The ability to recondition and recycle steel drums offer potentially unlimited levels of reusage.
  • Stackability: Steel drums can be easily and effectively stacked to facilitate effective storage and enable effective transportation, irrespective of environment based factors.


Steel drums differ from other industrial packaging materials in one key way. This is the fact that once a steel drum has been correctly reconditioned, it meets the same legal and safety requirements of a brand new steel drum.

Additionally, steel drums offer high levels of re-use expectations, providing significant financial savings for your business, presently a simple yet effective means of increasing its cost efficiency.


When a steel drum has come to the end of its life it can be effectively recycled. Scrap drums are first segregated, before being processed and made into scrap metal. Due to the fact that it is both magnetic and incredibly strong, steel drums are especially suited to being recycled.

Furthermore, to ensure that scrap resulting from steel drums contributes towards meeting both recovery and recycling obligations, the British Metals Foundation, the British Foundry Association and UK Steel Association, have co-signed an agreement with the Environmental Agency to recognise the retrieval of both commercial and industrial scrap.

Packaging Reuse offer a dedicated steel drum recycling and reconditioning service, this includes the reconditioning of steel drums that have contained hazardous waste in a way which is compliant with the new WM3 requirements.

For further information, a member of our customer service team can be contacted by calling: 0161 848 0976

Email enquiries can be sent to us at: sales@prdservices.co.uk