Legal Requirements

 POSTING 1: Legal requirements to consider in the project 

  

To begin with, we will explain who we believe is the holder of this waste. Here the waste holder of metal cans is the owner of the site where they are. Indeed, as the EU waste framework says the: “‘waste holder’ means the waste producer or the natural or legal person who is in possession of the waste”. So, unfortunately, our client is the waste holder. It’s therefore their responsibility to treat the waste from the site. 

However, in the case of our Infected sharps, by law, private doctors and medical centres are responsible for their waste for life. But as it is on our buyer's site, he becomes responsible for it too. 

 

 

We have found different types of waste on the site and we are going to identify where our waste fits in the hierarchy. 

As the waste hierarchy shows us, those metals cans should have been recycled and not dumped. Indeed, the waste hierarchy aims to reduce the quantity of waste produce. In order to do this, the first idea is to prevent waste creation, then we can reuse and after we can recycle like with our metal can, or recover. Finally, when there is no other choice, we can dispose of the waste. 

Infected sharps have to be collected separately with other waste carrying diseases and treated to avoid contamination. Disposal of this king of waste is not allowed because infected materials as waste have a large impact on animals and human health, and on the environment. Hospital creating these wastes are responsible for sorting and placing them in a puncture proof container, labelled “Hazardous waste”, with the “Biological Waste” sign, date and source of waste generation. Oil paints can be recycled, the solvent from the paint is extracted and recovered so it can be used in recycled paint. 

Concerning the t-shirt, it should not have been thrown away. These fabrics should be recycled in order to give them a second life and also a wooden table can be reused, or material (wood) can be repurposed. 

 

 

Once prioritised, we tried to answer the questions that arose about the planning of the site remediation. 

To treat these types of waste, we need to take care of every step. First, we need to move these types of waste to the corresponding treatment centres. So, to do this we can ask a private company. But we need to be sure that those types of waste are not dangerous and that there is no danger for the worker to take them off, then all the waste must be clearly identified.  

About dangerous types of waste found on the site such as infected sharps and oil paint there are special restrictions. They need to be labelled and their dangerousness must be indicated. Dangerous waste must be transported separately from other types of waste. It’s not legal to mix different types of waste. Once the transporter comes to pick-up dangerous waste, they must give us a shipping slip, so then we know where our waste is. The owner of the waste is responsible for the end of life of the waste even if he entrusts it to an intermediary. That’s why the shipping slip is really important. 

Concerning the paint, since it has been dumped on the site and is classified as hazardous waste it must be disposed of in the correct manner. The waste must be appropriately labelled and classified so it can be dealt with in a specific way. It must be collected to be stored and treated to prevent damage to the environment.  In Finland, there are hazardous waste collection points where the waste should be taken. In Mikkeli this is ‘Metsä-Sairila waste management centre’. The labelling should Include the manufacturer, the name of the product, a product identification number and the chemical constituents. 

During, the remediation we also need to protect the environment around the pollution site and to avoid additional contamination. We also need to take care of the water around the site, and protect the biodiversity.  

 

 

Then our team asked questions based on the different waste and renovation plan to come. Indeed, before the renovation plan can be built, a permit from the building control department will have to be obtained and the processing time for the permit is about 21 days. A waste management inspector may be hired, which entails additional costs.  

The application must be signed by the site owners and a qualified designer. Building permit drawings must be submitted with the application (two sets of drawings). A site and soil survey must be carried out.  

As neither the wooden table, the cotton T-shirt nor the metal cans are considered hazardous waste, no special permit is required. They can be recycled by the municipality at no extra cost. Metal cans are part of the packaging waste, Suomen Pakkauskierrätys RINKI Oy is responsible for recycling the packaging waste. The T-shirt found at the site was dirty and unusable, so it cannot be recycled. It is therefore considered mixed waste and is diverted to energy recovery in Mikkeli. The wooden table would be reused by the customer or recycled in a centre.  

Permits for hazardous waste disposal are granted at Metsä-Sairila Waste Management Centre in accordance with the Waste Management Act, and the paint will therefore be transported and disposed of there.  

 

 

As a result of these questions, we were able to determine an action plan. The first step of the renovation plan is to identify the waste present on the site. This part is quite cheap because it can be done by our Team. It can be done in one working day by a team of 5 people. Then we have to evaluate the risks linked to the waste found, for the environment including water, soil, animals, and define the way of transportation in water, soil and air. One week is needed to list the components of each waste and assessing the characteristics of them.  

After evaluating the risks for each contaminant, protection has to be set up according to waste. Time and cost depend on the harmfulness of the contaminants. The tools needed can now be set up on the site. Time and cost depend on the tools, which depend on the contaminants. 

Once the tools have been put in place and a risk assessment study has been carried out, a specialist company will have to be called in to remove the waste on site. Due to the size of the area (0.5 km2), the company's estimated time for removal is a few weeks. The cost of this labour is estimated according to the volume of waste to be removed.  

However, as we have hazardous waste, we have to call a company specialising in hazardous waste treatment because the first company only takes care of recyclable waste. When we called the town hall, they gave us the name of a company that specialises in dealing with hazardous waste. This company will intervene as soon as the collection of recyclable waste has been completed. This is also an additional cost to be taken into account and the intervention is estimated to take between 5 and 10 days as the volume of hazardous objects is not large. 

Another issue to consider is water. If the risk assessment reveals that the water is contaminated, another company will have to be called in to deal with the problem, which can take a long time... This will result in additional costs. 

Finally, once all these issues have been resolved, we would like to carry out a new risk assessment to see if the site is safe and no longer polluted. 

Our approximation for the costs is between €2000-7000.