National Hazardous Waste Management Plan

National Hazardous Waste
Management Plan
National Hazardous Waste Management

2014 – 2020 Plan
Environmental Protection Agency REGULATING IRELAND’S GREENHOUSE GAS
EMISSIONS
The Environmental Protection Agency (EPA) is a statutory
• Quantifying Ireland’s emissions of greenhouse gases in the
body responsible for protecting the environment in Ireland.
context of our Kyoto commitments.
We regulate and police activities that might otherwise
• Implementing the Emissions Trading Directive, involving
cause pollution. We ensure there is solid information on over 100 companies who are major generators of carbon
environmental trends so that necessary actions are taken. Our dioxide in Ireland.
priorities are protecting the Irish environment and ensuring
that development is sustainable. The EPA is an independent ENVIRONMENTAL RESEARCH AND DEVELOPMENT
public body established in July 1993 under the Environmental • Co-ordinating research on environmental issues (including
air and water quality, climate change, biodiversity,
Protection Agency Act, 1992. Its sponsor in Government is
environmental technologies).
the Department of the Environment, Community and Local
Government.
STRATEGIC ENVIRONMENTAL ASSESSMENT
• Assessing the impact of plans and programmes on the Irish
OUR RESPONSIBILITIES environment (such as waste management and development
plans).
LICENSING
We license the following to ensure that their emissions do not ENVIRONMENTAL PLANNING, EDUCATION AND
endanger human health or harm the environment: GUIDANCE
• waste facilities (e.g., landfills, incinerators, waste transfer • Providing guidance to the public and to industry on various
stations); environmental topics (including licence applications, waste
prevention and environmental regulations).
• large scale industrial activities (e.g., pharmaceutical
manufacturing, cement manufacturing, power plants); • Generating greater environmental awareness (through
environmental television programmes and primary and
• intensive agriculture;
secondary schools’ resource packs).
• the contained use and controlled release of Genetically
Modified Organisms (GMOs); PROACTIVE WASTE MANAGEMENT
• large petrol storage facilities; • Promoting waste prevention and minimisation projects
• waste water discharges; through the co-ordination of the National Waste Prevention
• dumping at sea. Programme, including input into the implementation of
Producer Responsibility Initiatives.
NATIONAL ENVIRONMENTAL ENFORCEMENT • Enforcing Regulations such as Waste Electrical and Electronic
• Conducting over 1200 audits and inspections of EPA licensed Equipment (WEEE) and Restriction of Hazardous Substances
facilities every year. (RoHS) and substances that deplete the ozone layer.
• Overseeing local authorities’ environmental protection • Developing a National Hazardous Waste Management Plan to
responsibilities in the areas of - air, noise, waste, waste- prevent and manage hazardous waste.
water and water quality.
MANAGEMENT AND STRUCTURE OF THE EPA
• Working with local authorities and the Gardaí to stamp out
illegal waste activity by co-ordinating a national enforcement
network, targeting offenders, conducting investigations and The organisation is managed by a full time Board, consisting
overseeing remediation. of a Director General and four Directors. The work of the EPA is
• Prosecuting those who flout environmental law and damage carried out across four offices:
the environment as a result of their actions.
• Office of Climate, Licensing, Research and Resource Use
MONITORING, ANALYSING AND REPORTING ON THE • Office of Environmental Enforcement
ENVIRONMENT • Office of Environmental Assessment
• Monitoring air quality and the quality of rivers, lakes, tidal • Office of Communications and Corporate Services
waters and ground waters; measuring water levels and river
flows. The EPA is assisted by an Advisory Committee of twelve
• Independent reporting to inform decision making by national members who meet several times a year to discuss issues of
and local government. concern and offer advice to the Board.

National
Hazardous Waste
Management Plan
2014 - 2020
ENVIRONMENTAL PROTECTION AGENCY

An Ghníomhaireacht um Chaomhnú Comhshaoil
PO Box 3000,
Johnstown Castle,
Co. Wexford, Ireland
T +353 53 916 0600

F +353 53 916 0699
E [email protected]
W www.epa.ie
LoCall 1890 33 55 99
© Environmental Protection Agency 2014

DISCLAIMER
This document does not purport to be and should not be considered a legal interpretation of the
legislation referred to herein.
Although every effort has been made to ensure the accuracy of the material contained in this
publication, complete accuracy cannot be guaranteed. Neither the Environmental Protection Agency
nor the author accepts any responsibility whatsoever for loss or damage occasioned, or claimed to have
been occasioned, in part or in full as a consequence of any person acting or refraining from acting,
as a result of a matter contained in this publication. All or part of this publication may be reproduced
without further permission, provided the source is acknowledged.
National Hazardous Waste Management Plan

2014 - 2020
ISBN 978-1-84095-542-2
Price: E20
Published by the Environmental Protection Agency, Ireland
PRINTED ON RECYCLED PAPER

Table of Contents
Preface vii
Executive summary viii
1. Introduction 1
1.1 What can, and cannot, be achieved by this revised Plan 2

1.2 Structure of this document 3
1.3 The objectives of this revised Plan 4
1.4 Strategic Environmental Assessment & Appropriate Assessment 4
1.5 Implementation of the Second Plan 6
2. Hazardous waste legislation 11
2.1 International - Basel Convention on the Control of Transboundary

Movements of Hazardous Wastes and their Disposal 11
2.2 EU legislation on hazardous waste 12
2.2.1 EU Waste Framework Directive 12
2.2.2 Other relevant EU legislation 13
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2.3 National legislation for hazardous waste 15
2.4 Classification of hazardous waste 18
2.5 Emerging issues and recommendations for future consideration 19
2.5.1 Replacement of Regional Waste Management Plans 19
2.5.2 Enforcement 19
2.5.3 Waste Electrical and Electronic Equipment (WEEE) 20
2.5.4 End of Life Vehicles 20
2.5.5 Ozone Depleting Substances / Fluorinated Greenhouse Gases 20
2.5.6 Green Public Procurement 21
2.5.7 Minamata Convention on Mercury 21
2.5.8 Unconventional Gas Exploration and Extraction 22
2.5.9 Recommended changes 22
3. The national hazardous waste profile 24
3.1 Managed (reported) hazardous waste 24

3.1.1 Management of hazardous waste 24
3.1.2 Hazardous waste treatment in Ireland 27
3.1.3 Hazardous waste imported for treatment 31
3.1.4 Hazardous waste exported for treatment 32
3.2 Industrial hazardous waste generation 36
3.3 Unreported hazardous waste 37
National Hazardous Waste Management Plan 2014 - 2020
3.4 Contaminated soil 38

3.5 Extractive waste 38
3.6 Radioactive waste 39
3.7 Enforcement – some key challenges concerning hazardous waste 39
3.7.1 Waste oils 40
3.7.2 Diesel fuel laundering 40
3.7.3 Waste Electrical and Electronic Equipment (WEEE) and Metal Theft 40
3.7.4 End of life vehicles 41
4. Prevention of hazardous waste 42
4.1 Definition of prevention 42

4.2 Approach to prevention 42
4.2.1 Role of research and innovation in prevention 45
4.3 Prevention plans for prioritised sectors 45
4.4 Implementation 58
4.4.1 Qualitative or product-based prevention 58
4.4.2 Role of the National Waste Prevention Programme 59
4.4.3 Local implementation of the prevention plan 59
iv |
4.5 Potential for all-island co-operation 60
5. Unreported hazardous waste 61
5.1 The current situation 61

5.1.1 Commercial hazardous waste collection 61
5.1.2 Civic amenity sites (recycling centres) 62
5.1.3 Retail take-back 62
5.1.4 Mobile collection services 62
5.2 Recommendations for the improved collection of hazardous waste 63
5.2.1 Commercial collection at source 63
5.2.2 Civic amenity sites and recycling centres 66
5.2.3 Producer responsibility and retailer take-back 70
6. Treatment of hazardous waste 73
6.1 The current situation 73

6.1.1 Hazardous Waste Projections 77
6.2 Self-sufficiency versus export of hazardous waste 77
6.3 Options proposed as alternative treatment techniques 79
6.4 Management of solvents and other wastes currently exported for -
thermal treatment 80
6.5 Landfill of hazardous waste 85
6.6 Physico-chemical treatment 88

6.7 Difficult wastes 90

6.8 Waste industry business development support 91
6.9 Potential for all-island co-operation 91
7. Legacy issues 93
7.1 Closed landfills 93

7.2 Contaminated soil 94
7.2.1 Options for management of contaminated soil in Ireland 97
7.3 Harbour sediments 98
7.4 Extractive waste from historical sites 98
8. Implementation 99
8.1 Summary of recommended actions and responsibilities 100

8.2 Resource requirements for the revised Plan 104
8.3 Consequences of not implementing the revised Plan 104
8.4 Objectives, targets and indicators 105
8.5 Reporting schedule 109
APPENDIX A - List of submissions 110

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APPENDIX B - Hazardous waste generation and treatment data 111
APPENDIX C - Hazardous waste facilities 115
APPENDIX D - Alternative hazardous waste treatment techniques 119
APPENDIX E - Radioactive waste 122
APPENDIX F - Estimated unreported waste 124

vi |

Preface
This revised National Hazardous Waste Management Plan, for the Republic of Ireland, is prepared by the
Environmental Protection Agency in accordance with Section 26 of the Waste Management Act 1996
as amended. The first such Plan was published in 2001 and was replaced by a second Plan published in
2008. This third Plan is a revision of the second Plan and will cover a period of six years from the date
of publication (2014 - 2020).
This revised Plan sets out the priority actions that should be undertaken within the lifetime of the
Plan in relation to: the prevention of hazardous waste; improved collection rates for certain categories
of hazardous waste; steps that are required to improve Ireland’s self-sufficiency in hazardous waste
management and the continued identification and regulation of legacy issues (e.g. identification, risk
assessment and regularisation of historic unregulated waste disposal sites). The key to achieving the
revised Plan’s objectives is effective implementation. A number of recommendations are made in the
revised Plan. Section 26(5) of the Waste Management Act 1996 as amended states the relationship
between the revised Plan and public bodies:
“A Minister of the Government, a local authority and any other public authority in whom
are vested functions by or under any enactment in relation to the protection of the
environment shall have regard to, and in so far as it is considered by the Minister of the
Government, local authority or other public authority to be appropriate to do so, shall take
measures to implement or otherwise give effect to, recommendation[s] contained in the | vii
hazardous waste management plan.”
Furthermore, the 2012 Government Policy on Waste Management1 states:
“The National Hazardous Waste Management Plan is a strategic level document designed
to provide overall direction to policy and decision makers involved in the prevention and
management of hazardous waste. All of the plan’s recommendations are designed to
reduce the environmental impact of hazardous waste. Local authorities are obliged to take
these recommendations into account when they review their own waste management
plans.”
A summary of the revised Plan’s recommendations is provided in the Executive Summary and is detailed
in Chapter 8, which includes the nomination of responsible public authorities. All relevant public
bodies as well as any other stakeholders and the public were invited to participate in the consultation
period on the Proposed Revised Plan in 2013. A full Strategic Environmental Assessment (SEA) was
carried out during the second Plan’s development. Following SEA screening (report available at www.
hazardouswaste.ie), it is considered that the modifications to the second plan do not need to be
subjected to further SEA processes. The original SEA Targets and Indicators have been retained, where
relevant, in the updated revised Plan. Appropriate Assessment screening of the revised Plan has also
been undertaken (report available at www.hazardouswaste.ie). The revised Plan has been screened out
for Appropriate Assessment, however, any specific plan or project proposals relating to or arising out
of the recommendations in the revised Plan will need to be subjected to the Appropriate Assessment
processes at the level of the more detailed sectoral plans and ultimately at individual project level, in
accordance with the relevant legislation.
1 A Resource Opportunity - Waste Management Policy in Ireland - Department of the Environment, Community and Local
Government July 2012
Executive summary
The Environmental Protection Agency (EPA) has prepared this revised National Hazardous Waste
Management Plan for the Republic of Ireland covering a six-year period from the date of publication.
This third Plan is a revision of the National Hazardous Waste Management Plan 2008 - 2012 and sets
out the priorities to be pursued over the next six years and beyond to improve the management of
hazardous waste, taking into account the progress made since the previous plan and the waste policy
and legislative changes that have occurred since the previous plan was published.
The objectives of the revised Plan are:
1. To prevent and reduce the generation of hazardous waste by industry and society
generally;
2. To maximise the collection of hazardous waste with a view to reducing the

environmental and health impacts of any unregulated waste;
3. To strive for increased self-sufficiency in the management of hazardous waste and

to minimise hazardous waste export;
4. To minimise the environmental, health, social and economic impacts of hazardous

viii | waste generation and management.
This revised Plan is made under Section 26 of the Waste Management Act 1996 as amended. A full
Strategic Environmental Assessment (SEA) was carried out during the second Plan’s development.
Following SEA screening, it is considered that the modifications to the previous plan do not need to
be subjected to further SEA processes. The original SEA Targets and Indicators, where relevant, have
been retained in the updated revised Plan. The SEA of the second plan and the SEA screening report
of the revised Plan are available at www.hazardouswaste.ie. Appropriate Assessment screening of the
revised Plan has also been undertaken (report available at www.hazardouswaste.ie). The revised Plan
has been screened out for Appropriate Assessment, however, any specific plan or project proposals
relating to or arising out of the recommendations in the revised Plan will need to be subjected to the
Appropriate Assessment processes at the level of the more detailed sectoral plans and ultimately at
individual project level, in accordance with the relevant legislation.
Hazardous waste generation and management
Waste is classified as being hazardous when it displays one or more of the hazardous properties listed in
the Second Schedule of the Waste Management Act as amended2 (e.g. explosive, oxidizing, flammable,
irritant, harmful, toxic, carcinogenic). The relevant property or properties are determined by testing or,
where applicable, concentration-based criteria.
The EPA National Waste Reports provide data on Ireland’s waste generation and management including
hazardous waste. The largest quantity of hazardous waste is generated by Irish industry and includes
such materials as industrial solvents, waste oils, industrial sludges and chemical wastes. Households,
2 European Communities (Waste Directive) Regulations 2011 (S.I. 126 of 2011)

small businesses, farms and the healthcare and construction sectors also generate quantities of
hazardous waste including batteries, electrical equipment, healthcare risk waste, solvent-based paint
and varnish waste, sheep dip and fluorescent lamps.
The overall quantity of hazardous waste managed in 2011 (most recent data) was 287,376 tonnes,
representing a <1% reduction on that reported for 2009 (Table 1). In 2011, 67,772 tonnes of hazardous
waste was treated on-site of generation at Integrated Pollution Prevention and Control (IPPC) licensed
facilities, with 98,838 tonnes treated off-site in Ireland by a network of authorised hazardous waste
treatment facilities (Table 1). In the same year, 149,037 tonnes of hazardous waste was exported for
treatment and disposal abroad, mostly for thermal treatment (incineration and use as fuel), but also for
metal recovery, solvent recovery and landfill. This represents a <1% reduction on the volume exported
in 2009.
Table 1 Summary of hazardous waste management, 2006-2011 (excluding contaminated soil) 3 4 5
Category 2006 2007 2008 2009 2010 2011

3
On-site at industry (t) 88,409 82,732 72,038 74,668 76,655 67,772
4
Off-site in Ireland (t) 60,872 91,240 113,839 89,992 93,048 98,838
Exported (t) 134,904 147,542 157,207 150,395 143,180 149,037

| ix
5
Total (t) 284,184 304,941 319,098 289,910 287,874 287,376
Source: National Waste Report 2011 (see current web version, http://www.epa.ie/pubs/reports/waste/stats)
Figure 1 illustrates the long-term trend in the location of treatment of hazardous waste. It shows that
the on-site treatment of hazardous waste decreased from 2010 to 2011. The off-site treatment of
hazardous waste in Ireland has steadily increased over the years, although it is down from a peak in
2008. The export of hazardous waste has become the established outlet for roughly half of all Irish
hazardous waste. Please see Figure 6 for destinations (2011), all of which are EU Member States.
3 “On-site at industry” refers to hazardous waste recovered or disposed of on-site at the industrial facility where it was
generated, under EPA licence.
4 “Off-site in Ireland” refers to waste sent to EPA licensed commercial hazardous waste treatment facilities for recovery or
disposal.
5 In 2011 a reported 28,270 t of hazardous waste was blended at facilities in Ireland prior to export as a waste for further
treatment (27,058 t reported as exported for use as fuel in cement kilns, a further 1,212 t hazardous waste was blended
prior to export for incineration abroad). These quantities are correctly counted in both the treated “off-site in Ireland”
row and the “exported” row. However, they have been discounted in the total row to avoid double counting in the total
amount of hazardous waste managed. Similar discounting also took place in the “total” figure relating to 2007, 2008,
2009 and 2010 to avoid double counting in the total amount of hazardous waste managed.
180000
160000
140000
120000
Off-site in Ireland
(t)
100000
On-site at Industry
80000
60000 Export
40000
20000
0
2006 2007 2008 2009 2010 2011
Year
Figure 1 Trends in the location of hazardous waste treatment, 2006-2011
x | With the reduction in building/development activity, the volume of contaminated soil managed declined
from 493,107 tonnes in 2008 to 17,297 tonnes in 2011. In 2011, 10,203 tonnes of contaminated soil
was exported for treatment, with the remainder treated at a single facility in Ireland. This is in stark
contrast to 2008, when 449,574 tonnes of soil was exported for treatment and 43,533 tonnes was
treated domestically.
The revised Plan makes 27 recommendations (see Chapter 8), dealing with:
➤➤ prevention of hazardous waste;
➤➤ collection of hazardous waste and the enforcement of hazardous waste regulations;
➤➤ moving towards self-sufficiency in hazardous waste management;
➤➤ regulatory aspects;
➤➤ legacy issues;
➤➤ north-south cooperation;
➤➤ guidance and awareness; and
➤➤ plan implementation.
A summary of these recommendations is presented below.

Prevention
Prevention projects to reduce the generation of hazardous waste in certain priority sectors (pharmachem,
agriculture, healthcare, households, publishing & printing and transport) should continue to be led by
the EPA under the National Waste Prevention Programme. Prevention initiatives should be incorporated
into Regional Waste Management Plans and the Green Public Procurement Action Plan should provide
for the substitution and reduction in use of hazardous materials. Waste characterisation studies of
certain waste streams are also recommended to evaluate the reduction of the hazardous content of
such wastes.
Collection
A comprehensive and accessible network of local drop-off facilities for householders and small businesses
is recommended to tackle the problem of “unreported” hazardous waste. Enforcement activities should
continue to focus on issues such as unauthorised burning of waste oil in order to increase collection and
prevent environmental pollution. The potential for producer responsibility obligations for a number of
hazardous waste streams should be given priority consideration.
Self-sufficiency
The objective of moving towards increased self-sufficiency and minimising exports continues to be
recommended, where it is strategically/environmentally advisable, and technically and economically | xi
feasible. If Ireland were to become self-sufficient, suitable hazardous waste treatment options would
be required.
Regulatory
Consolidation of waste legislation and cooperation in enforcement is recommended. A review of

waste licensing/permitting legislation is recommended in order to establish a proportionate regulatory
mechanism, including relief, to facilitate collection, transport and temporary storage of certain hazardous
wastes from small sources pending proper treatment.
Legacy issues
Old waste disposal sites, especially those that to a significant extent may have involved the disposal
of hazardous waste, should continue to be managed (i.e. identified, risk assessed and regularised) in
accordance with the Code of Practice drawn up by the EPA’s Office of Environmental Enforcement and
relevant legislation, where required.
North-south cooperation
The revised Plan recommends that any proposals for hazardous waste recovery/disposal infrastructure
should take all-island considerations into account for capacity planning purposes. Cooperation between
appropriate authorities on both sides of the border concerning hazardous waste management issues
should be explored.
Guidance and awareness
A key aspect of proper hazardous waste management is guidance and awareness. During implementation
of the second Plan, the EPA developed prevention resources for certain sectors. Such resources should
continue to be disseminated (e.g. the Green Healthcare Programme). Local authorities and relevant
sectoral organisations should also avail of appropriate media (e.g. social media) to inform the public and
small businesses of hazardous waste collection services.
Implementation
It is important to note that policy makers, regulators, product producers, importers, generators and
holders of hazardous waste all play a vital role in ensuring that the generation of such materials is
minimised, and the materials are collected and treated correctly in accordance with the waste hierarchy.
Each of the 27 recommendations in the revised Plan has a responsible body or bodies identified.
The principal implementing bodies are the Department of the Environment, Community and Local
Government, the Environmental Protection Agency, and the local authorities, along with facility
operators and holders of hazardous waste.
Targets and indicators have been included in the revised Plan to allow for monitoring its implementation
(management indicators) and any environmental effects of this (environmental indicators). The EPA will
xii | also devise sectoral and waste stream specific indicators in the early part of the revised Plan period to
help monitor implementation of the revised Plan’s objectives.
The EPA will carry out a mid-term review of the revised Plan’s implementation using data from the
National Waste Reports and with the input of the National Waste Prevention Committee.
Introduction
1. Introduction
Waste is classified as being hazardous when it displays one or more of the hazardous properties listed
in Annex III of the Waste Framework Directive (e.g. explosive, oxidizing, flammable, irritant, harmful,
toxic, carcinogenic). The relevant property or properties are determined by property testing or, where
applicable, concentration-based criteria.
The Directive has been transposed into national legislation by the European Communities (Waste
Directive) Regulations, 2011 (S.I. No. 126 of 2011). Industry is the largest generator of hazardous waste
in Ireland, giving rise to hazardous waste materials such as industrial solvents, sludges, oils and other
hazardous chemicals. Households, small businesses, farms and the healthcare and construction sectors
also generate substantial quantities of hazardous waste such as lead-acid batteries, waste electrical and
electronic equipment, healthcare risk waste, solvent-based paints and varnishes, pesticides, waste oils
and asbestos.
This revised National Hazardous Waste Management Plan (hereafter referred to as the “revised Plan”) sets
out the priorities to be pursued over the next number of years to continually improve the management
of hazardous waste in the Republic of Ireland. The revised Plan has been prepared in accordance with
Section 26 of the Waste Management Act 1996 as amended. The Environmental Protection Agency
(EPA) is required to develop a National Hazardous Waste Management Plan that has regard to:
➤➤ the prevention and minimisation of hazardous waste;

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➤➤ the recovery of hazardous waste;
➤➤ the collection and movement of hazardous waste; and
➤➤ the disposal of such hazardous waste as cannot be prevented or recovered.
The Plan must be evaluated at least once every six years. The first National Hazardous Waste Management
Plan was published by the EPA in 2001. In 2008 it was extensively reviewed and revised subject to
Strategic Environmental Assessment (SEA), and replaced by a second Plan. A third Proposed Revised
Plan was prepared and a period of public consultation on the Proposed Revised Plan was carried out
between October and December 2013. A total of 21 submissions were received (refer to Appendix A).
A summary of the principal issues raised and a compendium of submissions and responses is available
at www.hazardouswaste.ie. This third revised Plan updates the second Plan with new data while leaving
its principal components in place. The revised Plan continues to recommend a number of activities that
are ongoing under the previous Plan, and includes updated recommendations to ensure that the Plan
continues to be relevant for the next 6 years and beyond.
1.1 What can, and cannot, be achieved by this revised Plan

The National Hazardous Waste Management Plan makes recommendations, in accordance with Section
26(2) of the Waste Management Act 1996 as amended, for actions and infrastructure that the EPA
considers necessary and appropriate to achieve the stated plan objectives. The recommendations are
based on an analysis of statistical data and the policy and business environment surrounding hazardous
waste management. However, two significant public policy constraints were taken into account in
preparing this revised Plan.
First, current government policy indicates that large-scale public investment in hazardous waste
infrastructure will not be made. The hazardous waste industry in Ireland is entirely owned and operated
by the private sector. No public authorities are involved in the commercial collection of hazardous
waste, the provision of storage facilities or the treatment of hazardous waste. The only exception is
the provision of civic amenity sites by local authorities for the deposit of small quantities of household
hazardous waste. A recommendation in the revised Plan at variance with this general policy concerns
the possible public provision of hazardous waste treatment6 capacity (e.g. landfill capacity). This is
indicated in the revised Plan as a clear strategic need in order for hazardous waste to be treated in
Ireland and export to be reduced.
Second, the EPA, the public sector generally and the revised Plan can only seek to influence, but
cannot control, private sector investment decisions. Therefore, options for private sector investment
2 | are presented solely as options and the revised Plan does not seek to carry out a detailed evaluation of
the actual economic feasibility of any such potential investments. Any proposals for hazardous waste
management infrastructure would however be expected to have regard to the revised Plan and describe
how its overarching objectives would be met.
Additionally, in order to be granted an industrial emissions licence, a waste licence or a permit,

operators must demonstrate, among other things, that environmental pollution will not be caused by
the operation of any proposed facility.
The revised Plan can seek to have some influence over the implementation by public bodies of its
recommendations, as provided for in Section 26(5) of the Waste Management Act 1996 as amended.
Local authorities have taken steps in recent years to improve the collection of household hazardous
waste (e.g. civic amenity sites, mobile collection). Further investment by local authorities in household
hazardous waste collection facilities, coupled with prevention, enforcement and awareness activities,
is important to help meet the revised Plan’s objectives. It is essential that local authorities receive the
funding, resources and policy support required to enable them to implement these recommendations.
Other, less capital- and resource-intensive, activities are proposed, and it is considered reasonable to
presume that such recommendations can and will be implemented in a timely manner. It is important
to note that product producers, importers, generators and holders of hazardous waste have a vital
role to play in ensuring that the generation of such materials is minimised and that these materials are
collected and treated correctly in accordance with the waste hierarchy.
The EPA, through this revised Plan, continues to encourage the development and introduction of new
and innovative technologies and techniques for treating hazardous waste where they meet legislative,
regulatory, policy and Best Available Techniques (BAT) criteria.
6 “Treatment” means recovery or disposal operations, including preparation prior to recovery or disposal (EU Waste
Framework Directive 2008/98/EC).
Introduction
1.2 Structure of this document

The structure of the revised Plan generally follows the layout of the previous plan, as outlined in Figure
2. The first three chapters provide an introductory overview of the revised Plan. Relevant international,
EU, and national legislation and policy influencing the management of hazardous waste is outlined,
and a profile of the generation and management of hazardous waste in Ireland for a number of years
up to and including 2011, for which data are currently publicly available, is discussed. Chapter 4 focuses
on the area of waste prevention and, similar to the previous plan, continues to target key sectors in the
area of hazardous waste prevention.
Chapter 5 describes hazardous waste that is considered to be unreported or uncollected, and hazardous
waste issues that have been presenting certain challenges in recent times.
Chapter 6 describes the current situation with regard to principal hazardous waste treatment options
used for hazardous waste generated from Ireland, options for alternative treatment technologies and
other key issues for consideration. Chapter 7 provides an update on legacy issues with a focus on closed
landfills and contaminated soil in addition to information on extractive waste from historical sites and
contaminated sediments. Finally, Chapter 8 outlines key actions and associated responsibilities for the
implementation of recommendations arising from this National Hazardous Waste Management Plan.
| 3
Chapter 1
Introduction
Chapter 2
Legislation
Chapter 3
Hazardous Waste Profile
Chapter 4
National
Prevention
Hazardous
Waste Chapter 5
Management Unreported Hazardous Waste
Plan
Chapter 6
Treatment
Chapter 7
Legacy Issues
Chapter 8
Plan Implementation
Figure 2 Structure of the revised National Hazardous Waste Management Plan

1.3 The objectives of this revised Plan

Section 26 of the Waste Management Act 1996 as amended, sets out the overarching objectives for
the National Hazardous Waste Management Plan. In this context, the following objectives are included
as priorities for the revised Plan period:
1. To prevent and reduce the generation of hazardous waste by industry and society generally;
2. To maximise the collection of hazardous waste with a view to reducing the environmental
and health impacts of any unregulated waste;
3. To strive for increased self-sufficiency in the management of hazardous waste and to

minimise hazardous waste export;
4. To minimise the environmental, health, social and economic impacts of hazardous waste
generation and management.
Any actions relating to or arising out of any of the recommendations in the revised National Hazardous
Waste Management Plan should comply fully with all relevant EU and national legislation.
1.4 Strategic Environmental Assessment & Appropriate

Assessment
4 | A full SEA was conducted concurrent with the development of the second Plan in 2008. This fulfilled
the requirements of the SEA Directive (2001/42/EC)7 and the European Communities (Environmental
Assessment of Certain Plans and Programmes) Regulations 2004, S.I. No. 435 of 2004. Best practice
and relevant published guidance were followed throughout the process. Figure 3 shows the principal
steps in carrying out SEA.
Environmental Second
Background Plan
assessment in consultation -
research and Scoping Initial public Environmental completion
tandem with Environmental
statutory SEA Stage consultation Report and SEA
Plan Report and
consultation statement
development Proposed Plan
Figure 3 Summary of Strategic Environmental Assessment stages
In 2011, an Implementation Report was published on the second Plan as part of the monitoring step
in SEA. This evaluation indicated that no unforeseen adverse effects on the environment had become
evident arising from the implementation of the second Plan. It was concluded that the original SEA was
soundly based. It was noted from the EPA National Waste Report 2010, published in 2012, that hazardous
waste volumes are static or declining. In accordance with Article 9 of the European Communities
(Environmental Assessment of Certain Plans and Programmes) Regulations 2004 (S.I. No. 435 of 2004)
as amended, the EPA must decide if modifications to the National Hazardous Waste Management Plan
2008-2012 would or would not be likely to have significant effects on the environment, taking account
of relevant criteria set out in the Regulations. Following SEA screening and consultation with the relevant
SEA Environmental Authorities, it is considered that SEA of the modifications to the second plan is not
required. Further information is available at www.hazardouswaste.ie. The original SEA Targets and
Indicators have been retained in the revised Plan, where relevant, and a further Implementation/SEA
Monitoring Report will be completed during the next implementation period.
7 Directive 2001/42/EC of the European Parliament and of the Council of 27 June 2001 on the assessment of the effects
of certain plans and programmes on the environment, OJ L 197, 21.7.2001, pp. 30–37
Introduction
The revised Plan has also been screened for Appropriate Assessment in accordance with Article 6(3) of
the Habitats Directive8 and Part 5 of the European Communities (Birds and Natural Habitats) Regulations
2011 (S.I. No. 477 of 2011). The Appropriate Assessment screening report is available at www.
hazardouswaste.ie. The revised Plan has been screened out for Appropriate Assessment, however, any
specific plan or project proposals relating to or arising out of the recommendations in the revised Plan
will need to be subjected to the Appropriate Assessment processes at the level of the more detailed
sectoral plans and ultimately at individual project level, in accordance with the relevant legislation.
| 5
8 Council Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora
1.5 Implementation of the Second Plan

The second Plan (2008-2012) set out a number of recommendations for the prevention, collection and
treatment of hazardous waste. A report9 on the second Plan’s implementation was prepared in 2011.
The findings of this report are summarised in the following Tables 2-5.
Table 2 Were the second Plan’s objectives achieved?
Objective Comments
To reduce the generation of hazardous waste by Amounts of hazardous waste generally and in
industry and society generally industry are static or declining.
To minimise unreported hazardous waste with a Levels of unreported hazardous waste are likely
view to reducing the environmental impact of this to have declined due to impact of economic
unregulated waste stream downturn, WEEE, Batteries, ELV regulations and
CAS, garages and farm initiatives. New estimates
needed to confirm this trend.
To strive for increased self-sufficiency in the Levels of exported waste have stayed steady while
management of hazardous waste and to reduce the proportion of hazardous waste being treated
hazardous waste export in Ireland is slowly declining.
To minimise the environmental, social and economic EPA licensing/enforcement is minimising emissions
impacts of hazardous waste generation and in relation to licensed sites. Waste segregation
6 | management and CAS collections have increased, as has the
collection of batteries, ELV and WEEE waste.
However, data on the direct impacts of hazardous
wastes are not readily available.
Colour key:
Objective is being achieved
Objective is not being achieved
Objective is being partly achieved, or no change
Only indirect (input) data on the objective is available
Table 3 Were the second Plan’s recommendations implemented?
Implementation Status Number of Percentage of 29

Recommendations Recommendations
Recommendation is being implemented 18 62%
Recommendation implementation is in progress 6 21%
Only limited information on the implementation 4 14%

of the recommendation is available
Recommendation has not yet been implemented 1 3%
9 National Hazardous Waste Management Plan (2008-2012) Implementation Report 2011 (www.hazardouswaste.ie)
Introduction
Table 4 Were the second Plan’s targets achieved?
Target Comments
Initiate and implement hazardous waste prevention Incorporated into the National Waste Prevention
projects Programme (NWPP)
Reduce the generation of hazardous waste Incorporated into NWPP

relative to production at targeted, participating or
reporting organisations or sectors
Minimise the generation of unreported hazardous Updated data on unreported hazardous waste is
waste not currently available
Increase the deposit of household and small Data suggests increase in household hazardous
business hazardous waste at civic amenity sites; waste is being collected including WEEE, Batteries
other static collection points; and mobile services. and at CAS
Establish new producer responsibility obligations Not yet progressed due to Department of the
Environment’s resources being directed at
implementing WEEE, Batteries, ELV and other
existing schemes. The programme for government
states that consideration will be given to the
extension of Producer Responsibility Initiatives.
Increase on-site treatment of hazardous waste The evidence is that manufacturers prefer to let | 7
generated at IPPC-licensed facilities specialist external companies deal with hazardous
waste
Increase off-site treatment of hazardous waste in Hazardous waste volume treated off-site in 2009
Ireland up 48% compared to 2006
Reduce export of hazardous waste While volume exported is fairly stable, the
proportion of hazardous arisings has increased
from 48% in 2006 to 52% in 2009
Identify, assess and remediate as necessary all sites Identification and assessment process has been
where hazardous waste to a significant extent was started, but completing remediation will be
disposed of in the past lengthy and expensive
Colour key:
Target is being achieved
Target is not being achieved
Target is being partly achieved, or no change
Only indirect (input) data on the target is available
Table 5 Were the SEA environmental targets achieved?10
Target Comments
Minimise exceedances of emission limits to water Between 2008 and 2011, 31 ELV exceedances
and air from licensed hazardous waste facilities were noted among 15 IPPC/Waste licensees
(handling significant amounts of hazardous waste)
whose files were examined. 13 other licensees had
no ELV exceedances noted10.
Legacy hazardous waste disposal sites to be Code of Practice published and Tier 1 Risk
managed in accordance with Code of Practice Assessments are underway.
In the vicinity of hazardous waste incinerators, no All samples well below EU action and limit values
increase in dioxin levels in ambient environment
Maximise the generation of energy from renewable Amounts of hazardous waste used for energy
sources recovery (R1) increasing but half of this is via
export.
Minimise distance travelled by hazardous waste Data on tonnes-kilometres is not available to
determine whether target actually achieved.
However, export figures are fairly stable.
Minimise export of hazardous waste and move Levels of exported waste have stayed fairly steady
towards self-sufficiency while the proportion of hazardous waste being
treated in Ireland is slowly declining.
Minimise the generation of unreported hazardous Updated data on unreported hazardous waste is
8 | waste not currently available.
Increase the in situ treatment of contaminated soil Nine IPPC companies are treating historically
contaminated sites in-situ, however, there are no
estimates of the volumes of soil involved.
Increase the treatment of contaminated soil in Large quantities generated 2004 and 2008 were
Ireland largely exported for treatment.
Develop any new hazardous waste facilities on No specific information is available in relation to
previously used land or brownfield sites this target.
Avoid loss or damage to designated sites from No specific information is available in relation to
siting of hazardous waste facilities this target.
Minimise major incidents of unauthorised disposal Apart from occasional reports of diesel laundering
of hazardous waste residue, no other major incidents have been
identified.
Minimise complaints relating to hazardous waste Between 2008 and 2011, 74 complaints were made
facilities against 15 IPPC/Waste licensees (handling significant
quantities of hazardous waste) whose files were
examined. 13 other licensees received no complaints.
Colour key:
Target is being achieved
Target is not being achieved
Target is being partly achieved, or no change
Only indirect (input) data on the target is available
10 Please refer to Section 5 of National Hazardous Waste Management Plan (2008-2012) Implementation Report 2011
(www.hazardouswaste.ie) for further information on follow-up actions to non-compliances.
Introduction
The EPA, principally through the National Waste Prevention Programme (marketed as BeGreen), pursued
the following hazardous waste related projects during the implementation period of the second Plan
2008-2012 and a number of activities are ongoing:
➤➤ Household hazardous waste prevention was addressed through the Green Home project
(www.greenhome.ie), based in part on materials developed by the Local Authority Prevention
Demonstration (LAPD) programme;
➤➤ An Economic Study of Solvent Recycling & Treatment in Ireland was completed and communicated
to the Pharmachem sectoral representative group;
➤➤ A study was completed on a National Difficult Waste Facility (including hazardous waste landfill)
involving inter-Departmental/Agency consultation;
➤➤ A draft Code of Practice/Guidance Document for Civic Amenity Sites handling hazardous waste
including training resources was developed and circulated to key stakeholders for comment at the
end of 2013;
➤➤ A limited Farm Hazardous Waste study was undertaken to try to identify and quantify the types and
quantities of hazardous wastes generated on farms;
➤➤ The EPA and the Department of Agriculture, Food and the Marine (DAFM) jointly researched
and prepared the 7 Steps: Good Practice Guide for Empty Pesticide Containers and a supporting
technical background document. The Guide provides information on triple rinsing of pesticide
containers. Only triple rinsed pesticide containers managed in accordance with the Guide can be | 9
classified as non-hazardous wastes. The Guide was widely distributed to the farming community
and was made available at over 200 bring-centres for farm plastics recycling operated by the Irish
Farm Film Producers Group (IFFPG)11. Technical support was provided for the development of a
collection scheme for triple-rinsed farm plastics;
➤➤ The EPA and DAFM carried out joint inspections of the bring-centres in 2012 and 2013 to provide
technical support to IFFPG and Farm Plastics Recycling Limited (FPR Ltd) in their collection and
recovery of pesticide containers and to raise awareness among the farming community about the
importance of triple rinsing;
➤➤ A Green Healthcare programme (www.greenhealthcare.ie) which includes a focus on healthcare

hazardous waste was established;
➤➤ A Garages Best Practice Guidance was prepared in 2010 and widely distributed to the sector;
➤➤ Work continued on the implementation of Polychlorinated Biphenyls and Persistent Organic

Pollutants Regulations including the preparation of a National Implementation Plan for the Stockholm
Convention on Persistent Organic Pollutants which was published in 2012 (see www.pops.ie);
➤➤ EPA staff in co-operation with other statutory bodies continued the enforcement and/or monitoring
of Waste Electronic & Electrical Equipment (WEEE), Restriction of Hazardous Substances (in
EEE), Solvents, Deco-paints, Packaging (Essential Requirements), Ozone Depleting Substances,
Fluorinated Greenhouse Gases, Batteries and End-of-Life Vehicles Regulations; and
➤➤ EPA licensing and enforcement (through the EPA Office of Environmental Enforcement) of IPPC
and waste sectors continued to control hazardous waste arisings and treatment in the incumbent
sectors.
11 A copy of the Guide and supporting technical background paper is available at www.epa.ie/pubs/advice/waste/farm.
It is apparent that good progress has been made in Ireland during the second Plan’s implementation
period in relation to a number of its recommendations, objectives and targets, and generally in the
management of hazardous waste. It is also apparent, however, that more progress needs to be made
in some key areas such as the establishment of producer responsibility obligations for certain hazardous
wastes and in achieving greater self-sufficiency in managing Ireland’s hazardous waste. More remains
to be done, particularly in relation to hazardous waste prevention, product/service eco-design, the
collection of a greater proportion of products containing hazardous materials at end of life and self-
sufficiency in relation to treatment. The issues remain a significant challenge for society given the
number of players and the globalised economic, market and societal influences involved. Since the
publication of the previous plan, Ireland has experienced a significant economic downturn which, while
reducing the quantity of hazardous waste arising, has inevitably impacted on resources to help achieve
the previous plan’s objectives. Pressure will continue to come both from within the country where we
seek to ensure our green image and externally from EU policy. The recently published proposal of the
EU Commission for the 7th Environment Action Programme12 states:
“Hazardous waste will need to be managed so as to minimise significant adverse effects

on human health and the environment, as agreed at the Rio+20 Summit. To achieve
this, market-based instruments that privilege prevention, recycling and re-use should be
applied much more systematically across the EU. Barriers facing recycling activities in the
EU internal market should be removed and existing prevention, re-use, recycling, recovery
and landfill diversion targets reviewed so as to move towards a ‘circular’ economy, with a
10 | cascading use of resources and residual waste close to zero.”
12 European Commission COM(2012) 710 final “Living well within the limits of our planet” - Proposal for a general Union
Environment Action Programme
Hazardous waste legislation
2. Hazardous waste legislation

The management of hazardous waste is governed by comprehensive legislation. The legislation principally
originates in EU directives and regulations and is implemented in Ireland by the Waste Management Act
1996 as amended, related statutory instruments, and other acts. This chapter provides a listing of the
principal EU13 and Irish14 statutes governing:
(a) requirements to prevent hazardous waste and restrict the use of hazardous
substances in products;
(b) the management of hazardous waste that is generated; and
(c) regulation of the waste management and brokerage industries.
2.1 International - Basel Convention on the Control of

Transboundary Movements of Hazardous Wastes and their
Disposal
The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their
Disposal is a global environmental agreement on hazardous and other wastes. The Basel Convention
entered into force in May 1992. Its main principles are to: | 11
➤➤ reduce and minimise the generation of hazardous waste;
➤➤ reduce transboundary movements of hazardous wastes to a minimum consistent with

environmentally sound management; and
➤➤ treat and dispose of hazardous wastes as close as possible to their source of generation.
Ireland is a Party to the Basel Convention which entered into force for Ireland in 1994. In 1995, Decision
III/1 (the export ban amendment) was adopted prohibiting transboundary movements of hazardous
wastes from Parties listed in Annex VII of the Basel Convention to all other countries (Annex VII includes
all OECD member countries, the EU and Liechtenstein). To date the export ban amendment has yet to
enter into force due to the insufficient number of ratifications. However, it has been transposed by a
number of OECD countries (the EU Member States) into their national legislation.
Regulation (EC) No. 1013/2006 of the European Parliament and of the Council of 14 June 2006 on
shipments of waste (also referred to as the Transfrontier Shipment (TFS) Regulation) and its amendments
address the requirements of the Basel Convention on transboundary movement of wastes. In Ireland the
Waste Management (Shipments of Waste) Regulations 2007 (S.I. No. 419 of 2007) and amendments
address the administrative provisions to implement the EU TFS Regulation. All transfrontier shipments of
hazardous waste originating in any local authority area in the State that are subject to the prior written
notification procedures must be notified to and through Dublin City Council at the National TFS Office,
which was established to implement and enforce the 2007 Regulations.
13 European legislation can be downloaded at http://eur-lex.europa.eu

14 Irish legislation is available at www.irishstatutebook.ie.
2.2 EU legislation on hazardous waste

2.2.1 EU Waste Framework Directive
Waste management at EU level is regulated by the Waste Framework Directive (2008/98/EC)15. The
Directive lays down measures to protect the environment and human health by preventing or reducing
the adverse impacts due to the generation and management of waste. This revised Directive streamlines
EU waste legislation by replacing three existing directives: the previous Waste Framework Directive
75/442/EC, the Hazardous Waste Directive 91/689/EC and the Waste Oils Directive 75/439/EC.
The Directive updates the waste hierarchy, outlining the following in order of priority:
➤➤ Prevention – including reducing hazardous materials content in products;
➤➤ Preparing for re-use;
➤➤ Recycling;
➤➤ Other recovery, e.g. energy recovery; and
➤➤ Disposal.
In its previous form, the Waste Framework Directive required Member States to take steps to
12 | encourage waste prevention. The revised Directive outlines an updated hierarchy which should act as
a priority order and reinforces waste prevention at the top of the hierarchy. When applying the waste
hierarchy, Member States have to take measures to encourage the options that deliver the best overall
environmental outcome.
In relation to hazardous waste, requirements under the Directive include the establishment, revision
and reviewing of hazardous waste management plans, inspections of hazardous waste facilities, record
keeping, hazardous waste classification, banning of the mixing of hazardous waste, packaging and
labelling requirements.
Other key issues of relevance addressed in the revised Directive include:
➤➤ Extended producer responsibility - Member States have powers to introduce new producer
responsibility measures to increase levels of recycling, re-use and waste prevention;
➤➤ Waste prevention plans - Waste prevention plans are required to be drawn up by 12 December
2013;
➤➤ Energy recovery - energy-efficient incineration facilities dedicated to the processing of municipal

solid waste will be able to be classed as “recovery” rather than “disposal” operations, moving them
up the waste hierarchy;
➤➤ End of waste criteria - by which a material which is recovered or recycled from waste can be
deemed to be no longer a waste;
➤➤ By-products - the Directive provides clearer distinction between by-products and waste and sets
out conditions to be met for which material can be deemed to be a by-product.
15 Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and repealing
certain Directives
2.2.2 Other relevant EU legislation
The following EU Directives and Regulations are of relevance to the National Hazardous Waste
Management Plan and in the prevention (principally by restriction of hazardous substances) and
management of hazardous waste generally:
➤➤ Industrial Emissions Directive16 - which sets out the licensing procedures and criteria for
certain industrial activities. Licences make specific provision for the prevention of waste
and for its proper management. The Directive revises and merges seven separate existing
Directives related to industrial emissions into a single Directive, including the Integrated
Pollution Prevention and Control (IPPC) Directive (2008/1/EC), Volatile Organic Compounds
(VOC) Solvents Directive (99/13/EC), Waste Incineration Directive (2000/76/EC), Large
Combustion Plants (LCP) Directive (2001/80/EC) and Titanium Dioxide Directives (78/176/
EEC, 82/883/EEC and 92/112/EEC) on waste from the titanium dioxide industry.
➤➤ Decorative Paints Directive17 - which limits the solvent content of several classes of paint
product. A scheme using Inspection Contractors is in place to monitor vehicle refinishing
activities including disposal of VOC-containing wastes.
➤➤ The PCB (polychlorinated biphenyls) Directive18 - requiring the disposal of PCBs and the
environmentally sound decontamination or disposal of PCB-containing equipment.
➤➤ The WEEE (Waste Electrical and Electronic Equipment) Directive19 - imposing a producer
responsibility obligation in respect of WEEE management, several categories of which are | 13
classified as hazardous waste.
➤➤ The RoHS (Restriction of Hazardous Substances) Directive20 - restricting the use of

lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls (PBB) and
polybrominated diphenyl ethers (PBDE) in new electrical and electronic equipment.
➤➤ The Classification, Labelling and Packaging of Substances and Mixtures Regulation21 - which
uses internationally agreed classification criteria and labelling elements in order to facilitate
trade and to contribute towards global efforts to protect humans and the environment from
hazardous effects of chemicals.
➤➤ The End-of-Life Vehicles Directive22 - obligations with regard to the restriction of use of
certain hazardous substances in vehicles and the collection, treatment, re-use and recovery
of end-of-life vehicles.
16 Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions
17 Directive 2004/42/CE of the European Parliament and of the Council of 21 April 2004 on the limitation of emissions
of volatile organic compounds due to the use of organic solvents in certain paints and varnishes and vehicle refinishing
products and amending Directive 1999/13/EC
18 Council Directive 96/59/EC of 16 September 1996 on the disposal of polychlorinated biphenyls and polychlorinated
terphenyls (PCB/PCT)
19 Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on waste electrical and electronic
equipment (WEEE)
20 Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of
certain hazardous substances in electrical and electronic equipment (recast)
21 Regulation (EC) No. 1272/2008 of the European Parliament and of the Council of 16 December 2008 on classification,
labelling and packaging of substances and mixtures
22 Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of-life vehicles
➤➤ The Batteries Directive23 - obligations with regard to the restriction of use of certain hazardous
substances in batteries and accumulators, collection, treatment and recycling of batteries.
➤➤ The Packaging Directive24 - restricts the aggregate concentration of heavy metals (lead,
cadmium, mercury and hexavalent chromium) in packaging. Packaging essential requirements
are set out such that packaging is so manufactured that the presence of noxious and other
hazardous substances and materials as constituents of the packaging material or of any of
the packaging components is minimised with regard to their presence in emissions, ash or
leachate when packaging or packaging residues from management operations or packaging
waste are incinerated or landfilled.
➤➤ The Transfrontier Shipment of Waste Regulation25 - as discussed above - imposes controls on

the import, export and transit of waste, including hazardous waste.
➤➤ The Animal Remedies Directive26 - putting in place appropriate collection systems for
veterinary medicinal products that are unused or expired.
➤➤ The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACh)

Regulation27 - applies to the identification of the properties of chemicals, the provision of
safety information and calls for progressive substitution of dangerous chemicals as suitable
alternatives are identified.
➤➤ The Port Reception Facilities Directive28 - applies to all ships, including fishing vessels and
recreational craft, and aims to reduce the discharge of ship-generated waste and cargo
14 | residues into the sea by improving the availability and use of port reception facilities.
➤➤ The Ozone Depleting Substances Regulation29 - prohibits and restricts the use of “controlled
substances” that have the potential to deplete the ozone layer, including inter alia
chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), halons, methyl bromide
and carbon tetrachloride.
➤➤ The Fluorinated Greenhouse Gas Regulation30 - regulates the containment and handling of
fluorinated greenhouse gases (f-gases), such as hydrofluorocarbons (HFCs), perfluorocarbons
(PFCs) and sulphur hexafluoride. The European Commission published a proposal for a
revised F-gas Regulation in November 2012, with the view to phasing down the supply
of bulk HFCs, and introducing additional prohibitions on certain products and equipment.
23 Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006 on batteries and
accumulators and waste batteries and accumulators and repealing Directive 91/157/EEC
24 European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste
25 Regulation (EC) No. 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste
26 Directive 2001/82/EC of the European Parliament and of the Council of 6 November 2001 on the Community code
relating to veterinary medicinal products
27 Regulation (EC) No. 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency,
amending Directive 1999/45/EC and repealing Council Regulation (EEC) No. 793/93 and Commission Regulation (EC)
No. 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and
2000/21/EC. Regulation (EC) No. 552/2009 of 22 June 2009 amending Regulation (EC) No. 1907/2006 of the European
Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as
regards Annex XVII
28 Directive 2000/59/EC of the European Parliament and of the Council of 27 November 2000 on port reception facilities
for ship-generated waste and cargo residues
29 Regulation (EC) No. 1005/2009 of the European Parliament and of the Council of 16 September 2009 on substances that
deplete the ozone layer (Regulation (EC) No. 2037/2000 was repealed)
30 Regulation (EC) No. 842/2006 of the European Parliament and of the Council of 17 May 2006 on certain fluorinated
greenhouse gases
There is an increased focus in the proposed revision on global warming potential (GWP),
with more onerous controls proposed for those f-gases with high GWP. This regulation31 is
now published and will apply from 1 January 2015.
➤➤ The Persistent Organic Pollutants (POPs) Regulation32 - sets out the requirements for the
prohibition, management, monitoring and control of persistent organic pollutants including
persistent organic pollutants in wastes.
➤➤ Pollutant Release and Transfer Register (PRTR) Regulation33 - sets out the requirements for a
European Pollutant Release and Transfer Register.
➤➤ Mercury Export Ban & Storage Regulation34 - sets out the requirement concerning the
banning of exports of metallic mercury and certain mercury compounds and mixtures and
the safe storage of metallic mercury.
➤➤ Extractive Industries Waste Directive35 concerns the management of waste from the
extractive industries.
➤➤ The EU Animal By-Products Regulations (Regulation (EC) No. 1069/2009 & Commission
Regulation (EC) No. 142/2011) lay down the rules concerning animal by-products including
disposal requirements.
➤➤ Sustainable Use of Pesticides Directive36 - concerns closer monitoring, increased training and
information for users as well as specific measures for the use of these substances.
| 15
2.3 National legislation for hazardous waste
The Waste Management Act 1996 as amended provides the legislative framework for waste and
hazardous waste management in Ireland. The transposition of EU waste directives is enacted for the
most part through enabling provisions included within the Act. The Environmental Protection Agency
Act 1992 provides the framework for several other EPA functions, including the issuing of licences for
certain industrial activities.
The following regulations contribute to the governance of the production and management of
hazardous waste:
➤➤ European Communities (Waste Directive) Regulations, S.I. No. 126 of 2011 - transpose
Directive 2008/98/EC on waste. These Regulations also formalise the concepts of “by-
product” and “end-of-waste” in Irish law. Waste Transfer Station (WTS) operators who
send materials off-site as non-waste must ensure that the requirements of Regulations 27
and/or 28 are met.
31 Regulation (EU) No. 517/2014 of the European Parliament and of the Council of 16 April 2014 on fluorinated greenhouse
gases and repealing Regulation (EC) No 842/2006
32 Regulation (EC) No. 850/2004 of the European Parliament and of the Council of 29 April 2004 on persistent organic
pollutants and amending Directive 79/117/EEC
33 Regulation (EC) No. 166/2006 of the European Parliament and of the Council of 18 January 2006 concerning the
establishment of a European Pollutant Release and Transfer Register and amending Council Directives 91/689/EEC and
96/61/EC
34 Regulation (EC) No. 1102/2008 of the European Parliament and of the Council of 22 October 2008 on the banning of
exports of metallic mercury and certain mercury compounds and mixtures and the safe storage of metallic mercury
35 Directive 2006/21/EC of the European Parliament and of the Council of 15 March 2006 on the management of waste
from extractive industries and amending Directive 2004/35/EC
36 Directive 2009/128/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for
Community action to achieve the sustainable use of pesticides
➤➤ Waste Management (Hazardous Waste) Regulations, S.I. No. 163 of 1998 - make certain
provisions including for the supply of batteries, the reporting of certain PCB-contaminated
equipment and the management and disposal of polychlorinated biphenyls (PCBs) and PCB-
containing wastes and waste asbestos.
➤➤ European Union (Industrial Emissions) Regulations, S.I. No. 138 of 2013, Environmental
Protection Agency (Industrial Emissions) (Licensing) Regulations, S.I. No. 137 of 2013,
European Union (Waste Incineration Plants & Waste Co-incineration Plants) Regulations,
S.I. No. 148 of 2013, European Union (Large Combustion Plants) Regulations, S.I. No. 566
of 2012, European Union (Installations and Activities using Organic Solvents) Regulations,
S.I. No. 565 of 2012 - provide for the issuing and enforcement of licences by the EPA for
Industrial Emission Directive activities.
➤➤ Waste Management (Licensing) Regulations, S.I. No. 395 of 2004 - provide for the issuing
and enforcement of waste licences by the EPA.
➤➤ European Communities (Shipments of Hazardous Waste exclusively within Ireland)

Regulations, S.I. No. 324 of 2011 - The control of hazardous waste shipments is now fully
consolidated under the National Transfrontier Shipment Office. Exports of waste from the
State have been centrally controlled by the National Transfrontier Shipment Office since
1 July 2007 and a new electronic tracking system introduced on 1 January 2012 ensures
that all hazardous waste movements within the State are also brought under one national
authority, thus further consolidating and strengthening controls on such waste movements,
16 | while also delivering administrative efficiencies. The above regulations also revoke Parts V
and VI of the Waste Management (Hazardous Waste) Regulations, S.I. No. 163 of 1998.
➤➤ Waste Management (Shipments of Waste) Regulations, S.I. No. 419 of 2007 - streamline the
administration of Regulation (EC) No. 1013/2006 on the shipment of waste and nominate
Dublin City Council as sole competent authority in respect of the export into, import from
and transit of waste through Ireland.
➤➤ Waste Management (Registration of Brokers and Dealers) Regulations, S.I. No. 113 of 2008
- regulate waste contractors who arrange shipment of waste.
➤➤ Waste Management (Planning) Regulations, S.I. No. 137 of 1997 - provide for, in part,
the relationship between the National Hazardous Waste Management Plans and local and
regional waste management plans.
➤➤ Waste Management (Facility Permit and Registration) Regulations, S.I. No. 821 of 2007,
Waste Management (Facility Permit and Registration) (Amendment) Regulations, S.I No. 86
of 2008 - provide for the issuing and enforcement of waste facility permits and certificates
of registration for prescribed activities.
➤➤ Waste Management (Collection Permit) Regulations, S.I. No. 820 of 2007 - provide for the
issuing and enforcement of waste collection permits. The National Waste Collection Permit
Office (operated by Offaly County Council) has responsibility for the issuing of collection
permits.
➤➤ European Union (Waste Electrical and Electronic Equipment) Regulations 2014, S.I. No. 149 of
2014 give effect to the provisions of Directive 2012/19/EU on waste electrical and electronic
equipment. European Union (Restriction of Certain Hazardous Substances in Electrical and
Electronic Equipment) Regulations, S.I. No. 513 of 2012, transpose the provisions of the
RoHS Directive in Ireland.
➤➤ Waste Management (End of Life Vehicles) Regulations, S.I. No. 282 of 2006 - are designed
to implement the provisions of the End of Life Vehicles Directive in Ireland.
➤➤ European Communities (Metallic Mercury Waste) Regulations, S.I. No 72 of 2013 - bring into
force specific criteria for the storage of metallic mercury considered as waste.
➤➤ Control of Substances that Deplete the Ozone Layer Regulations, S.I. No. 465 of 2011 - make
provisions for the full and effective implementation of Regulation (EC) No. 1005/2009 on
substances that deplete the ozone layer.
➤➤ Fluorinated Greenhouse Gas Regulations, S.I. No. 279 of 2011 - make provisions for the
full and effective implementation of Regulation (EC) No. 842/2006 on certain fluorinated
greenhouse gases.
➤➤ Environmental Protection Agency Act 1992 (Fluorinated Greenhouse Gas) Regulations, S.I.
No. 278 of 2011 - designate the EPA as the competent authority for the implementation of
Regulation (EC) No. 842/2006 on certain fluorinated greenhouse gases.
➤➤ European Union (Installations and Activities Using Organic Solvents) Regulations, S.I. No. 565
of 2012 & European Union (Paints, Varnishes, Vehicle Refinishing Products and Activities)
Regulations, S.I. No. 564 of 2012 - govern installations and activities using organic solvents,
such as vehicle refinishers and dry cleaners, for the purpose of preventing or limiting
emissions of volatile organic compounds.
➤➤ The Waste Management (Packaging) Regulations, S.I. No. 798 of 2007 – give effect to the
| 17
Packaging and Packaging Waste Directive.
➤➤ European Communities (Animal Remedies) (No. 2) Regulations, S.I. No. 786 of 2007 – set
out obligations concerning unused or expired animal remedies.
➤➤ Animal Remedies Regulations, S.I. No. 734 of 2005 - a registered veterinary practitioner
or pharmacist is required to have in place a system whereby farmers can return an animal
remedy that is unused or expired. They are also obliged to make farmers aware of these
return arrangements.
➤➤ European Communities (Port Reception Facilities for Ship-generated Waste and Cargo
Residues) Regulations, S.I. No. 117 of 2003 - oblige harbour masters and port authorities to
prepare waste management plans for the management of ship-generated waste and cargo
residues at Irish ports and harbours.
➤➤ Waste Management (Batteries and Accumulators) Regulations, S.I. No. 268 of 2008 –
implement the Batteries Directive in Ireland. The European Union (Batteries and Accumulators)
(Amendment) Regulations, S.I. No. 529 of 2012 amend the Waste Management (Batteries
and Accumulators) Regulations 2008 as amended and are intended to give effect to
Commission Decision 2009/603/EC establishing requirements for registration of producers
of batteries and accumulators in accordance with Directive 2006/66/EC on batteries and
accumulators and waste batteries and accumulators.
➤➤ Waste Management (Certification of Historic Unlicensed Waste Disposal and Recovery

Activity) Regulations, S.I. No. 524 of 2008 - provide primarily for the certification of historic
unlicensed local authority waste disposal sites in operation between 1977 and 1996.
➤➤ Waste Management (Management of Waste from the Extractive Industries) Regulations, S.I.
No. 566 of 2009 - provide for measures on the management of waste from the extractive
industries.
➤➤ Persistent Organic Pollutants Regulations, S.I. No. 235 of 2010 – give effect to the EU POPs
Regulation in Ireland designating the EPA as the competent authority for their implementation
and also outlining the roles of other public bodies concerned.
➤➤ European Communities (Sustainable Use of Pesticides) Regulations, S.I. No. 155 of 2012 –
give effect to the Directive concerning measures to achieve the sustainable use of pesticides.
➤➤ European Communities (Transmissible Spongiform Encephalopathies and Animal By-

Products) Regulations, S.I. No. 252 of 2008, as amended, and the Diseases of Animals
Act 1966 (Transmissible Spongiform Encephalopathies) (Fertilizers and Soil Improvers) Order
2008, S. I. No. 253 of 2008 – give further effect to the EU Animal By-Products Regulations.
➤➤ Regulation of Retail Pharmacy Businesses Regulations, S.I. No. 488 of 2008 – a pharmacy
may accept return medicines for proper disposal.
2.4 Classification of hazardous waste

Waste producers are required to classify their waste as either hazardous or non-hazardous. On
completion of the classification, the correct European Waste Catalogue (EWC) code must be assigned
18 | from the List of Waste (LoW)37 (waste marked with an asterisk (*) is considered as a hazardous waste,
pursuant to the relevant legislation). Assessing waste as hazardous or non-hazardous is a multi-stage
process, and the EPA has developed a paper tool38 (updated in 2012) for the identification of the
hazardous components of waste. This provides producers of waste with a procedure, based on up-to-
date standards and information, for the identification and categorisation of the hazardous components
of waste.
The LoW provides a harmonised, non-exhaustive waste list and it is divided into 20 chapters which
must be used in order of precedence. The LoW codes reflect either the origin of the waste from a
particular sector or the type of waste. A waste producer may classify its activities in several chapters of
the catalogue. For instance, a car manufacturer may find its wastes listed in chapters 12 (wastes from
shaping and surface treatment of metals), 11 (inorganic wastes containing metals from metal treatment
and the coating of metals) and 8 (wastes from the use of coatings), depending on the different process
steps.
Within the LoW, waste can be categorised into the following:
➤➤ hazardous, known as “absolute” hazardous entries
➤➤ non-hazardous, known as “absolute” non-hazardous entries, and
➤➤ wastes that may be hazardous or non-hazardous, known as “mirror” hazardous and

“mirror” non-hazardous entries.
The “mirror entries” on the LoW allow for certain wastes to be classified as hazardous or non-hazardous
waste depending on the presence of dangerous substances at certain concentrations. The following
example illustrates how mirror entries are presented:
37 European Waste Catalogue and Hazardous Waste List – Valid from 1 January 2002, EPA, 2002
38 Available for download at http://www.epa.ie/waste/hazardous/class
17 05 03* soil and stones containing dangerous substances
17 05 04 soil and stones other than those mentioned in 17 05 03
The presence of dangerous substances in a waste could imply a hazardous waste classification. The
waste producer may look to demonstrate through compositional analysis that the substances are present
in concentrations not exceeding prescribed threshold values. The results of the compositional testing
must be populated into the amended paper tool on the identification of the hazardous components of
waste.
Currently, a review of the LoW and of the hazardous properties is being carried out by the European
Commission which will lead to amendments to the catalogue.
2.5 Emerging issues and recommendations for future

consideration
There are a number of changes that will take effect within the revised Plan period as a result of recent or
expected legislative amendments, in addition to some areas that may have implications for hazardous
waste management, some of which are described below:
2.5.1 Replacement of Regional Waste Management Plans

| 19
The Government’s new waste policy, A Resource Opportunity – Waste Management Policy in Ireland,
which was published in July 2012, provides for a reduction in the number of existing waste management
regions from ten to no more than three. The development of waste management plans and the
formation of regions for such purposes remains a matter for local authorities under Part II of the Waste
Management Act as amended.
The local authorities have now formed three non-hazardous waste management planning regions –
the Connacht-Ulster Region (lead authority Mayo County Council), the Eastern-Midland Region (lead
authority Dublin City Council) and the Southern Region (lead authority a consortium of Limerick County
Council and Tipperary County Council). The National Coordination Committee on Replacement Waste
Management Plans has been established and the local authorities are now beginning the process of
development of replacement Plans. In the meantime, the existing plans will remain applicable until the
new plans have been put in place.
2.5.2 Enforcement
National Waste Policy39 indicated that a review of the respective waste regulation and enforcement
roles of the EPA and local authorities will be completed by the end of 2013. This was to have a particular
focus on dealing with serious criminal offenders and the need for more intelligence-led and coordinated
multi-agency enforcement, aimed at ensuring targeted, timely and effective enforcement outcomes. This
review is at an advanced stage at the time of writing (refer also to Section 3.7 for further information).
39 A Resource Opportunity - Waste Management Policy in Ireland - Department of the Environment, Community and Local
Government, July 2012
2.5.3 Waste Electrical and Electronic Equipment (WEEE)
The recast of the Waste Electrical and Electronic Equipment (WEEE) Directive was published in July
201240. Some of the more challenging aspects of the recast are the collection targets, set at 45% in
2016 and 65%41 from 2019, based on the average weight of electrical and electronic equipment placed
on the market in the previous 3 years.
The recast of the WEEE Directive also obliges Member States to prioritise preparation for re-use at the
earliest stages of WEEE take-back, separate WEEE for re-use and enable access to refurbishment centres.
The transposition of the WEEE recast should assist in creating the correct regulatory environment to
support the development of re-use in Ireland. Transposed national regulations42 came into effect in
March 2014.
2.5.4 End of Life Vehicles
The End of Life Vehicles (ELV) Directive targets are in place since January 2006, and higher targets will
come into effect from January 2015. Ireland is failing to meet the ELV Directive targets which have been
effective since January 2006. Preliminary data for 2011 indicate that a re-use/recovery rate of 79% and
a reuse/recycling rate of 77% were achieved against targets of 85% and 80% respectively.
The Department of the Environment, Community and Local Government (DECLG) is currently considering
20 | a number of measures aimed to address difficulties concerning ELVs and new regulatory structures are
expected to be in place by 2015.
2.5.5 Ozone Depleting Substances / Fluorinated Greenhouse Gases
While the use of virgin HCFC (e.g. R22) in the maintenance of refrigeration and air conditioning equipment
has been prohibited since 1 January 2010, the use of recycled and reclaimed R22 can continue until 31
December 2014. In 2012/2013, the EPA commissioned a study into the nature and extent of remaining
R22 installed in Ireland, through a stakeholder survey and consultation exercise. The findings from the
study indicated that awareness of the forthcoming final phase out of R22 was variable across and within
sectors. A proposed awareness plan was developed as part of the study and elements of this plan will
be implemented by the EPA, as resources allow.
In addition to the approaching deadline for HCFCs, the deadline for the use of halon in certain critical
use applications is also approaching. Airports and airfields have availed of a critical use exemption under
the ODS regulation (EU Regulation (EC) No. 1005/2009 as amended) for the use of halon in crash rescue
vehicles and in hangars and maintenance areas. This critical use application will cease on 31 December
2016. All airports in Ireland have been formally informed by the EPA of the approaching deadline.
As the deadlines for the prohibition of HCFCs and halons approach and pass, the quantities of waste
HCFC gas and waste halons requiring management, both of which are designated as hazardous waste,
are expected to increase.
40 Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on waste electrical and electronic
equipment
41 Member States can choose an alternative target of 85% of WEEE generated.
42 European Union (Waste Electrical and Electronic Equipment) Regulations 2014 (S.I. No. 149 of 2014)
A dedicated webpage has been created on the EPA website to provide stakeholders with information
on the approaching phase-out, and final prohibition dates can be found at:
http://www.epa.ie/air/airenforcement/ozone/r22andhaloncriticalusephase-out
2.5.6 Green Public Procurement
The 2012 DECLG publications, Green Tenders - An Action Plan on Green Procurement and Our
Sustainable Future - A Framework for Sustainable Development for Ireland, establish the clear vision
and place of Green Public Procurement (GPP) in future national governance arrangements. Given the
scale of public procurement across all Irish Government Departments and Agencies, GPP is recognised
as an important policy instrument in promoting the development and expansion of markets for green
products and services. This can be achieved by including green criteria into procurement procedures by
which contracting authorities can support and promote greener production processes, greener products
and greener services. GPP is a core strand of driving sustainability, promoting resource efficiency, and
progressing circular economy ambitions.
The GPP Action Plan Implementation Group comprising Governmental bodies and agencies has been
tasked with drawing up terms of reference for further ongoing research into GPP methodologies,
target-setting and effective implementation, evaluation and monitoring. The Office of Public Works
(OPW) at the time of writing is developing specific GPP guidance relating to the construction sector in
particular. | 21
The EPA is currently developing guidance on specifying “green” credentials in procurement and

reviewing tenders with such commitments. Following public tender and award in 2013, the project
to develop this guidance has recently commenced and the overall expected project outcome will be a
practical guidance document to assist the wider public sector to include green criteria into tendering
procedures as a sustainable means of procuring goods and services.
2.5.7 Minamata Convention on Mercury
Mercury is a global pollutant that can cross international borders through long-range transport in the
atmosphere and is highly toxic to humans, ecosystems and wildlife.
To address this issue, the UNEP Governing Council in 2009 agreed to take international action on
mercury through the elaboration of a legally binding instrument to reduce risks to human health and
the environment posed by mercury.
In January 2013, governments agreed on a new global legally binding multilateral environmental
agreement to address all aspects of the mercury life-cycle, including wastes, storage and emissions.
The text to the Convention has been adopted (October 2013). The Convention is expected to enter into
force 90 days after the deposit of the fiftieth instrument of ratification, expected to be in 2017 or 2018.
This new multilateral environmental agreement is called the “Minamata Convention on Mercury”.
2.5.8 Unconventional Gas Exploration and Extraction
Unconventional Gas Exploration and Extraction (UGEE) is an emerging issue in Ireland, in particular with
regard to the use of hydraulic fracturing (“fracking”) technology. At present there is no UGEE project/
operation underway that has reached either the exploratory or commercial drilling stage.
The EPA is commissioning a 24-month programme of research (commencing in 2014) on UGEE in

collaboration with the Department of Communications, Energy and Natural Resources (DCENR) and the
Northern Ireland Environment Agency, with the principal aim of furthering the understanding of the
potential impacts on the environment and human health from UGEE projects/operations. This research
will also consider waste aspects associated with UGEE. The EPA along with other authorities such as the
Commission for Energy Regulation, DCENR and local authorities will have roles in regulating any UGEE
projects/operations, should such activity commence after the completion of the research programme.
2.5.9 Recommended changes
Similar to the previous plan, it is recommended that the need for a consolidated set of regulations
be kept under review to consolidate certain provisions of existing regulations and to provide for new
obligations. Any new regulations should at least replace the articles of the existing Waste Management
(Hazardous Waste) Regulations (S.I. No. 163 of 1998) that remain relevant. The following should also
be considered:
22 |
➤➤ At present, the transport of very small quantities of hazardous waste must be covered by a collection
permit and this creates barriers to the commercial collection of certain very small hazardous waste
streams (e.g. home-administered medical waste). The collection permit system should provide for
a reasonable and proportional level of regulation for essential and approved small-scale services,
consistent with the provisions of Article 24 of the Waste Framework Directive.
➤➤ With requirements under waste legislation to hold a waste licence for the storage of waste pending
onward treatment, certain outlets (such as veterinary practices/pharmacies) may be reluctant to
take back certain wastes from customers under take-back schemes. To encourage take-back
of hazardous wastes from certain sources, it is recommended that a review of waste licensing
legislation be carried out to establish an appropriate and proportionate regulatory mechanism, or
relief, to facilitate the take-back of certain hazardous wastes from smaller sources (e.g. unused or
expired animal remedies and human medicines).
➤➤ In relation to the management of farm hazardous waste, the current farm plastic recovery and
recycling scheme operated by Irish Farm Films Producers Group Ltd (IFFPG) should be examined
and utilised to provide a mechanism whereby farmers can bring their hazardous wastes to these
national bring centres for management and disposal. IFFPG is currently the sole approved body
for the purpose of operating a compliance scheme for the recovery of farm plastic waste43. IFFPG
collects both at the farmyard and at over 200 bring-centres across the country. To provide for
a more holistic approach to farm waste management, IFFPG in association with agri-supply and
farming sectors in 2010 established Farm Plastics Recycling Ltd to provide a service to farmers to
recycle fertiliser bags, seed bags, netting and twine and empty pesticide containers. Options, such
as the successful farm plastics recovery scheme operated by IFFPG and relevant legislation, should
be evaluated in order to examine the feasibility of enabling farmers who use the bring-centres to
bring other hazardous and non-hazardous farm wastes such as waste oils, paints and batteries for
43 Farm plastics are defined as sheeting, bale wrap or bale bags which are suitable for use for the conservation of fodder.
disposal/recovery. This is also relevant to the Producer Responsibility Initiative (PRI) Review currently
being undertaken by the DECLG which is examining the feasibility of additional PRI schemes for
a number of wastes including certain hazardous waste streams. The outcome of the 2013 farm
hazardous waste collection pilot research initiative should also inform any future long-term action
in this area44.
| 23
44 Interim report available at

http://www.epa.ie/pubs/reports/waste/haz/pilotfarmhazardouswastebringcentresin2013interimreport.html
3. The national hazardous waste profile

Information on hazardous waste generation and management presented in this chapter is categorised
as managed and generated hazardous waste (Sections 3.1 & 3.2), unreported hazardous waste (Section
3.3) and contaminated soil (arising as a legacy waste, Section 3.4). The source of all data presented in
this chapter is the EPA National Waste Report45 series, unless otherwise indicated. Further information
is also provided on extractive waste (Section 3.5) and radioactive waste (Section 3.6). Section 3.7
provides information on enforcement and some key challenges concerning hazardous waste.
3.1 Managed (reported) hazardous waste

A complete statistical dataset on reported hazardous waste management and generation has been
prepared every year and biennially respectively by the EPA for the National Waste Report. Information
on the management of hazardous waste in 2011 was mainly compiled from the National Waste Report,
which in turn obtains relevant data as follows:
➤➤ Data on the import and export of hazardous waste for treatment as provided by the National
Transfrontier Shipment Office (NTFSO), Dublin.
➤➤ Data on the treatment of hazardous waste off-site at commercial facilities in Ireland is also
obtained by way of the hazardous waste treatment survey, which is sent to facilities that are
licensed by the EPA or permitted by the local authorities to treat hazardous wastes.
24 |
➤➤ Data on the treatment of hazardous waste on-site at the industry where it was generated
(which occurs under EPA licence at companies mainly in the pharmachem sector) were
obtained from Pollutant Release and Transfer Registers (PRTR) and Annual Environmental
Reports (AER).
There is a diverse range of hazardous wastes arising, each requiring different and often specialist
treatment. For the purpose of guidance and awareness and continuous monitoring of hazardous waste
management in Ireland, the EPA will prepare up-to-date factsheets on each of the main hazardous
waste streams which will include information concerning the management of such waste streams. This
will be carried out in the early part of the revised Plan period and made available on the EPA website
(www.hazardouswaste.ie). The EPA will also prepare and make available key hazardous waste data
indicators concerning the management of hazardous waste at regular intervals.
3.1.1 Management of hazardous waste

The largest quantity of hazardous waste is generated by Irish industry and includes such materials
as industrial solvents, waste oils, industrial sludges and other chemical wastes. Households, small
businesses, farms and the healthcare and construction sectors also generate quantities of hazardous
waste including batteries, electrical equipment, healthcare risk waste, solvent-based paint and varnish
waste, sheep dip and fluorescent lamps.
Table 6 provides some overall statistics in relation to the management of hazardous waste generated
by Irish industry and society.
45 National Waste Reports for the years 1995, 1998 and 2001 to 2011 are available at http://www.epa.ie/pubs/reports/
waste/stats
The national hazardous waste profile
Table 6 Summary of hazardous waste management, 2006-2011 (excluding contaminated soil)
Category 2006 2007 2008 2009 2010 2011

46
On-site at industry (t) 88,409 82,732 72,038 74,668 76,655 67,772
47
Off-site in Ireland (t) 60,872 91,240 113,839 89,992 93,048 98,838
Exported (t) 134,904 147,542 157,207 150,395 143,180 149,037

48
Total (t) 284,184 304,941 319,098 289,910 287,874 287,376
Source: National Waste Report 2011 (see current web version http://www.epa.ie/pubs/reports/waste/stats/)46 47 48
The overall quantity of hazardous waste managed in Ireland in 2011 was 287,376 tonnes, a <1%
reduction on that reported for 2009 (Table 6). To put this in context each year in the EU, 2.7 billion
tonnes of waste are produced, of which 98 million tonnes is hazardous49.
In 2011, 67,772 tonnes of hazardous waste was treated on-site of generation at IPPC-licensed facilities
with 98,838 tonnes treated off-site in Ireland by a network of authorised hazardous waste treatment
facilities. In the same year, 149,037 tonnes of hazardous waste was exported for treatment and disposal
abroad, mostly for thermal treatment (incineration and use as fuel), but also for metal recovery, solvent
recovery and landfill.
| 25
Figure 4 illustrates the long-term trend in the location of treatment of hazardous waste. In recent years
it shows that the on-site treatment of hazardous waste decreased from 2010 to 2011. The off-site
treatment of hazardous waste in Ireland has steadily increased over the years, although it is down from
a peak in 2008. The export of hazardous waste has become the established outlet for roughly half of
all Irish hazardous waste, although volumes have declined since a peak in 2008.
46 “On-site at industry” refers to hazardous waste recovered or disposed on-site at the industrial facility where it was
generated, under an EPA licence.
47 “Off-site in Ireland” refers to waste sent to EPA licensed commercial hazardous waste treatment facilities for recovery or
disposal.
48 In 2011 a reported 28,270 t of hazardous waste was blended at facilities in Ireland prior to export as a waste for further
treatment (27,058 t reported as exported for use as fuel in cement kilns, a further 1,212 t hazardous waste was blended
prior to export for incineration abroad). These quantities are correctly counted in both the treated “off-site in Ireland”
row and the “exported” row. However, they have been discounted in the total row to avoid double counting in the total
amount of hazardous waste managed. Similar discounting also took place in the “total” figures relating to 2007, 2008,
2009 and 2010 to avoid double counting in the total amount of hazardous waste managed.
49 Source: European Commission COM(2012) 710 final “Living well within the limits of our planet” - Proposal for a general
Union Environment Action Programme
180000
160000
140000
120000
(t)
Off-site in Ireland
100000
On-site at Industry
80000
60000 Export
40000
20000
0
2006 2007 2008 2009 2010 2011
Year
Figure 4 Trends in the location of hazardous waste treatment, 2006-2011
26 |
Figure 5 illustrates the trend between 2006 and 2011 in the recovery and disposal of hazardous waste
generated in Ireland. While there has been a reduction in both recovery and disposal of hazardous
waste on-site at industry, the overall trend shows a move towards waste recovery, with significant
increases in the quantity of hazardous waste sent for recovery both off-site in Ireland and abroad. In
general terms there has been an overall decline in the quantity of waste sent for disposal.
120000
100000
80000
Off-site in Ireland
(t)
60000
On-site at Industry
40000 Export
20000
0
2006 2011 2006 2011
Disposal Disposal Recovery Recovery
Year (Recovery / Disposal)
Figure 5 Trends in the recovery and disposal of hazardous waste treatment, 2006-2011
3.1.2 Hazardous waste treatment in Ireland
The reported quantity of hazardous waste treated in Ireland in 2011 was 166,610 tonnes (Table 7),
which is an increase of 1% since 2009. Although there was a decrease in the treatment of hazardous
waste on-site at industry in 2011 (decreased by 9% on 2009 tonnage to 67,772 tonnes), there was an
increase in the treatment of hazardous waste off-site at commercial facilities in Ireland (increased by
10% on 2009 tonnage to 98,838 tonnes).
The increase in the treatment of hazardous waste off-site at commercial facilities in Ireland was largely
attributable to an increase in the treatment of waste oils and solvents.
Table 7 Location of hazardous waste treatment in Ireland, 2011 (excluding contaminated soil) 50 51
Category 50
On-site at Off-site in
51
Total
industry (t) Ireland (t) (t)
Solvents 34,354 16,898 51,252

Solvents (halogenated, where specified) 6,176 631 6,807
Oil waste (mineral oil) 180 38,092 38,272
Industrial hazardous waste (other) 4,722 3,046 7,768
Salts and saltcake 20,079 4 20,083
| 27
Healthcare risk waste 9,036 9,036
Oily sludges 45 3,464 3,509
Equipment (electrical, electronic, mechanical) 7,404 7,404
Chemical waste (other) 120 120
Paint, ink and varnish waste (including packaging) 1,358 1,358
Acid and alkali waste 3,777 3,777
Aqueous washing liquids and mother liquors (07 __ 01*) 1,852 11,937 13,789
Solid wastes from MFSU of pharmaceuticals (07 05 13*) 295 295
Sludges and filter cakes 0.2 132 132
Packaging (contaminated or containing residues) 25 2,068 2,093
Photographic chemical waste 95 95
Metal- and heavy metal-containing waste 8 8
Absorbents, wiping cloths etc. (EWC 15 02 02) 30 2 32
Fluorescent lamps 260 260
Oil filters 7 7
Laboratory and general chemical waste 13 59 72
Thermal treatment and combustion residues 438 438
Municipal hazardous waste (other) 4 4
Totals 67,772 98,838 166,610
Source: 2011 National Waste Report (see current web version)
50 “On-site at industry” refers to hazardous waste recovered or disposed on-site at the industrial facility where it was
generated, under EPA licence.
51 “Off-site in Ireland” refers to waste sent to EPA-licensed commercial hazardous waste treatment facilities in Ireland for
recovery or disposal.
A wide range of techniques were used to treat hazardous waste in Ireland in 2011 (Table 8).
Table 8 Methods of treatment of hazardous waste in Ireland in 2011 (excluding contaminated soil) 52 53 54
Recovery / Disposal or recovery activity On-site at Off-site in Total

Disposal Code52 industry (t) Ireland (t) (t)
D1 Landfill 20,079 20,079
D8 Biological treatment 1,655 1,655
D9 Physico-chemical treatment 122 25,959 26,081
D10 Incineration 12,615 12,615
Sub-total disposal 34,471 25,959 60,430
R1 Use as fuel 11,012 11,012
R2 Solvent recovery 21,770 27,97853 49,748
R3 Organic substance recovery 294 61 355
R4 Metal recovery 369 369
R3/R4 Combination of R3 and R4 1,522 1,522

28 |
R5 Inorganic substance recovery 5,842 5,842
R4/R5 Combination of R4 and R5 346 346
R9 Oil recovery 180 21,217 21,397
R4/R9 Combination of R4 and R9 1,562 1,562
R9/D9 Combination of R9 and D9 12,911 12,911
R10 Landspreading 45 45
D13/R12 Combination of D13 and R12 1,07154 1,071
Sub-total recovery 33,301 72,877 106,180
Total 67,772 98,838 166,610

Source: 2011 National Waste Report (see current web version)
In 2011, 20 IPPC-licensed facilities operated on-site treatment facilities treating 67,772 tonnes of
hazardous waste (Table 9). EPA licensed operations are regulated and monitored by the EPA’s Office of
Environmental Enforcement in accordance with licence conditions. In the interest of reducing transport
emissions and the export of hazardous waste, the promotion of on-site treatment of hazardous waste is
recommended, primarily in the pharmachem sector, where this is technically and economically feasible
and permissible by licence conditions.
52 See Appendix B for list of recovery and disposal operations.

53 This figure is made up of 26,895 t (solvent waste blended prior to its export as waste for use as fuel in cement kilns) plus
a further 609 t of waste solvent which was recovered and sold as product. The remaining 474 t of hazardous wastes
went abroad for incineration.
54 This 1,071 t represents the blending and storage of mixed solvents and aqueous liquids prior to their export for use as
fuel as well as incineration.
Table 9 Treatment of hazardous waste on-site at IPPC-licensed facilities in 2011 (excluding

contaminated soil)
Facility name IPPC Reg. Waste type Recovery/ Quantity

No. Disposal treated
code (t)
Arran Chemical Co Ltd P0110-02 Solvents R2 763
Astellas Ireland Co. Ltd P0007-03 Solvents D10 616
Aqueous washing liquids D10 1,400

and mother liquors
(07__01*)
Aughinish Alumina Ltd P0035-04 Salts and salt cake D1 20,079
BASF Ireland Ltd P0052-02 Other industrial hazardous R1 4,720

waste
Phillips 66 Bantry Bay Terminals P0419-01 Oil waste (mineral oil) R9 180
Eli Lilly P0009-03 Solvents D10 2,944
Solvents (Halogenated D10 68

where specified)
| 29
Galmoy Mines Ltd P0517-01 Oily sludges R10 45
Irish Industrial Explosives Ltd P0055-01 Other industrial hazardous D10 2

waste
Mallinckrodt Medical Imaging P0050-02 Solvents R2 6,347

Ireland
Solvents D8 306
Solvents (Halogenated D8 <0.1

where specified)

where specified)
Merck Sharp & Dohme P0011-04 Solvents D8 1,061
R2 1,820
Merck Millipore Ltd P0571-02 Solvents R2 1,380
cont’d
cont’d

code (t)
Novartis Ringaskiddy Ltd P0006-03 Other industrial hazardous D10 <0.1

waste
Packaging (contaminates or D10 25

containing residues)
Sludges and filter cakes D10 0.2
Solvents D10 <0.1
D8 284
R1 1,756
R2 4,102
Absorbents, Wiping cloths D10 30
Aq. washing liquids and D10 452

mother liquors (07__01*)
Solid wastes from MFSU D10 2

30 | of pharmaceuticals (07 05
13*)
Laboratory and general D10 13

chemical waste
Pfizer Ireland Pharmaceuticals P0013-04 Solvents R2 1,130
Pfizer Cork Ltd P0136-04 Solvents R2 2,724
Solvents R1 13
Roche Ireland Ltd P0012-04 Solvents R1 2,415
Solvents (Halogenated R1 958

where specified)
Schering-Plough (Ireland) P0015-05 Solvents R1 1,151
Smithkline Beecham (Cork) Ltd P0004-03 Solvents D10 2,417
R2 161

where specified)
Swords Laboratories P0014-04 Solvents D8 1.3
R2 580

where specified)
cont’d
cont’d

code (t)
Bristol Myers Squibb Cruiserath P0552-02 Solvents R2 1,213
Solvents (Halogenated D10 4,639

where specified)
D8 2.5
R2 154
Temmler Ireland Ltd P0813-02 Solvents R2 1,172
Solid wastes from MFSU R3 294

of pharmaceuticals (07 05
13*)
Total:

67,772
Source: National Waste Report (see current web version)55
3.1.3 Hazardous waste imported for treatment
In 2011 2,622 tonnes of oil-related waste was imported for recovery at commercial hazardous waste | 31
treatment facilities in the State (Table 10).
Table 10 Origin of hazardous wastes for recovery, 2011
Country of export Waste description Disposal or Total

Recovery imports (t)
code55
UK (excluding Northern Waste oils/water, hydrocarbons/water R9 318

Ireland) mixtures, emulsions for composition.
Northern Ireland Waste oil R9 1,096
Waste oil-mineral bases, chlorinated hydraulic R9 1,208

oils, mineral based chlorinated engine, gear
and lubricating oils.
Total 2,622
Source: National Waste Report (see current web version)
55 See Appendix B for a descriptive list of recovery and disposal operations.

3.1.4 Hazardous waste exported for treatment
Hazardous waste was mainly exported to a number of EU countries for treatment in 2011 (Figure 6).
Four EU countries (United Kingdom, Belgium, Germany and France) accepted approximately 92% of
these exports.
32 |
Figure 6 EU destination countries of exported hazardous waste, 2011
Exports amounted to 149,037 tonnes in 2011, consisting of a wide range of categories (Table 11).
There continues to be an increase in the export of lead acid batteries, which increased by 4% in
2011 compared to 2010. Although the tonnage of other batteries (small, non-lead acid) exported has
decreased when compared to 2010 levels, the overall tonnage of batteries exported has increased by
28% when compared to 2009 levels. This reflects the increased collection of batteries under the Waste
Management (Batteries and Accumulators) Regulations (S.I. No. 268 of 2008), which came into effect
in September 2008.
The quantity of WEEE exported increased by 108% in 2011 compared to 2009. A reported 28,270
tonnes of hazardous waste was blended at EPA licensed hazardous waste treatment facilities in Ireland
in 2011, prior to being exported as a waste for use as fuel in cement kilns and incineration abroad. The
quantity of solvents exported in 2011 increased by 2% compared to 2009.
Table 11 Categories of exported hazardous waste, 2007-2011 (reported from TFS data sets and
categorised by EPA) 56
Category Exported (t)
2007 2008 2009 2010 2011
Solvents 48,671 58,611 52,370 48,682 52,243
Solvents (halogenated, where specified) 6,743 8,693 4,540 1,893 6,079
Oil waste (mineral oil) 617 230 2,443 2,363 633
Industrial hazardous waste (other) 33,854 33,154 11,927 5,124 7,027
Healthcare risk waste 478 728 734 712 692
Oily sludges 7 107 94 45 30
Lead-acid batteries 10,565 11,050 11,832 14,805 15,374
Equipment (electrical, electronic, mechanical) 6,423 7,386 8,410 11,897 17,493
Chemical waste (other) 4,091 3,559 3,701 7,780 9,305
Paint, ink and varnish waste (including packaging) 2,805 4,843 4,834 5,459 4,713
| 33
Acid and alkali waste 2,384 2,917 2,578 1,556 1,558
Asbestos waste 6,168 7,007 14,068 9,512 7,001
Aqueous washing liquids and mother liquors (07 10,747 5,278 10,647 12,637 9,616
__ 01*)
Solid wastes from MFSU of pharmaceuticals (07 05 3,790 2,534 1,956 3,982 4,881
13*)
Sludges and filter cakes 5,036 6,057 3,834 3,663 3,006
Batteries (small, non-lead acid) 328 228 223 136 4656
Packaging (contaminated or containing residues) 785 746 664 867 777
Photographic chemical waste 680 650 432 221 284
Oil filters 640 1,092 741 739 654
Construction and demolition waste (hazardous) 82 137 12,892 9,137 3,236
Metal and heavy metal containing waste 42 71 69 181 83
Agricultural hazardous waste 72
Absorbents, wiping cloths etc. (EWC 15 02 02*) 1,894 1,373 661 596 939
cont’d
56 This is a low volume compared to previous years however typically batteries are stockpiled prior to export. Approx. 600
tonnes of portables was collected by the compliance schemes during 2011.
cont’d
Category Exported (t)
2007 2008 2009 2010 2011
Fluorescent lamps 116 56 74 58 119
Pesticides, herbicides 71 71 56 30 47
Laboratory and general chemical waste 332 193 485 548 677
Salts and saltcake 2 1
Thermal treatment and combustion residues 32 428 59 89 1,977
Medicines 1 3
Municipal hazardous waste (other) 89 437 537
Polychlorinated biphenyls 71 1 29 8
Total 147,542 157,202 150,397 143,179 149,037
Source: National Waste Report 2011 (see current web version)
Approximately 68% of exported hazardous waste was recovered, with the balance being disposed
34 | (Table 12).
Table 12 Disposal and recovery of exported hazardous waste, 2011 57
Disposal (D) or recovery (R) code57 Exported (t)
D1 2,801
D1/D5 3,027
D10 35,569
D12 6
D14 24
D5 2,147
D8 1,999
D8/D9 527
D9 966
Sub-total hazardous waste exported for disposal 47,065
R1 28,182
R1, R3 60
R1, R3, R4 770
cont’d
57 See Appendix B for a descriptive list of recovery and disposal operations.
cont’d
Disposal (D) or recovery (R) code57 Exported (t)
R1, R3, R5 164
R1, R4 1,897
R1, R4, R5 283
R1, R5 23
R1, R9 25
R12 6,068
R13 2,191
R2 15,721
R2, R3 4,025
R3 3,651
R3, R4 4,482
R3, R5 54
R4 28,590 | 35
R4, R5 112
R5 4,426
R6 1,014
R8 1
R9 233
Sub-total hazardous waste exported for recovery 101,972
Total hazardous waste exported for treatment 149,037

Table 13 provides a further breakdown of the destination and fate of exported hazardous waste in
2011.
Table 13 Destination and treatment of hazardous waste exports, excluding contaminated soil, 2011
Destination Disposal (t) Recovery (t) Total exports (t)
Belgium 11,475 26,937 38,412
Germany 21,261 9,747 31,008
Denmark 1,748 1,748
Finland 457 457
France 882 6,217 7,099
Italy 1 1
Netherlands 684 6,064 6,747
Poland 298 298
UK 10,560 48,771 59,330
USA 73 73
36 |
Sweden 3,865 3,865
Overall totals 47,065 101,972 149,037
3.2 Industrial hazardous waste generation

In terms of the manufacturing sector, generation of industrial hazardous waste is dominated by the
“pharmaceutical and chemical” (“pharmachem”) industry sector, with large contributions also from the
manufacture of basic metals and metal products. Table 14 shows industrial hazardous waste generation
by the manufacturing sector in 2010.
It should be noted that this dataset is presented here to illustrate and compare the estimated scale
of hazardous waste generation by the manufacturing sectors only. Note that the methodology for
the collection of 2010 waste generation data differed from previous years. Estimations are based on
data provided in annual returns from EPA licensed operators, supplemented by a sample survey of a
population of enterprises drawn from the business register by the Central Statistics Office (CSO). The
figures are estimated using both data sources.
Table 14 Generation of hazardous waste by industrial manufacturing sectors, 2010 58 59
NACE NACE Sector Total (t) of

Division58 hazardous waste
generated59
10_12 Manufacture of food products, beverages and tobacco products 1,381
13_15 Manufacture of textiles, wearing apparel and leather and related 145
products
16 Manufacture of wood and of products of wood and cork, except 769

furniture; manufacture of articles of straw and plaiting materials
17_18 Manufacture of paper and paper products, printing and 1,427

reproduction of recorded media
19 Manufacture of coke and refined petroleum products 698
20_22 Manufacture of coke and refined petroleum products, manufacture 189,342

of basic pharmaceutical products and pharmaceutical preparations
and manufacture of rubber and plastic products
23 Manufacture of other non-metallic mineral products 8,932
24_25 Manufacture of basic metals, manufacture of fabricated metal 92,054 | 37

products, except machinery and equipment
26_30 Manufacture of computer, electronic and optical products, 17,756

manufacture of electrical equipment, manufacture of machinery
and equipment n.e.c., manufacture of motor vehicles, trailers and
semi-trailers, manufacture of other transport equipment
31_33 Manufacture of furniture, other manufacturing, repair and 25,430

installation of machinery and equipment
Total 337,934
3.3 Unreported hazardous waste

By definition, the undocumented fate of unreported hazardous waste means that it has the potential
to have a greater environmental impact than reported hazardous waste. By the same token, providing
accurate estimates of unreported hazardous waste is very difficult. Some unreported waste may end
up in general domestic or commercial waste, or it may be disposed of in an uncontrolled manner by
burning, burying or discharge to sewer, water or surface ground.
Chapter 5 further details the issues around unreported waste and makes recommendations for improved
collection of hazardous waste.
58 Note: a comprehensive review of the assignment of the different NACE Codes is due to be carried out in advance of the
next reporting of waste generation figures.
59 Total estimated generation of hazardous waste within a sector, based on data reported by companies within that sector,
scaled up on the basis of a factor describing hazardous waste generated per employee in the sector as a whole.
3.4 Contaminated soil

Table 15 outlines the trends in the management of contaminated soil and export between 2006
and 2011. This includes contaminated soil treated off-site in Ireland at commercial hazardous waste
treatment facilities and contaminated soil that was exported for treatment. The data do not reflect any
contaminated soil that was treated in situ at its point of generation. There was a 13% increase in the
treatment of contaminated soil off-site in Ireland in 2011 compared with that in 2010. All reported off-
site treatment in Ireland took place at Enva Ireland Ltd’s Portlaoise facility (EPA Waste Licence Register No.
W0184-01). All reported exports of contaminated soils in 2011 were to Germany, accounting for 59%
of the total managed. There was an increase in the reported export of contaminated soil from 2,590
tonnes in 2010 to 10,203 tonnes in 2011; however, the overall tonnage of contaminated soil managed
is still significantly down on pre-2009 data, reflecting the reduction in brownfield development/re-
development projects during the economic downturn.
Table 15 Reported off-site management of contaminated soil, 2006-201160
2006 2007 2008 2009 2010 2011
Off-site in 36,872(R) 60 44,221(R) 2 (D) 12,428 (R) 6,260 (R) 7,094 (R)
Ireland (t) 43,531 (R)
Exported 370,032 143,906 449,574 476 2,590 10,203

38 | (total) (t)
Germany 341,158 (D) 126,859 (D) 285,028 (D) 7 (D) 2,590 (D) 10,203 (D)
135,980 (R)
28,570 (R) 14,919 (R)
Netherlands 305 (R) 2,128 (R) 12,655 (D) 469 (R)
15,911 (R)
Total
reported (t) 406,904 188,127 493,107 12,904 8,850 17,297
3.5 Extractive waste

Extractive waste, also known as mining and quarry waste, is controlled under a specific EU Directive
(2006/21/EC) 61. The Extractive Waste Directive arranges for the management of such waste via a schema
(e.g., for assessment, permitting, management, closure) separate to the EU Waste Framework Directive
(98/2008/EC). However certain matters such as definition of hazardous waste are cross-referenced to
the Waste Framework Directive, this latter Directive which sets out the authorities for the preparation
of this Hazardous Waste Management Plan. Any operational extractive waste facility in the state that
involves management (including disposal) of hazardous fractions of extractive waste is controlled by the
EPA through the Industrial Emissions and Waste licensing systems and is therefore accommodated in the
statistics presented herein. Such extractive waste management facilities are dedicated to the mineral
60 R is predominantly recovery or recycling; D is predominantly disposal.

61 http://ec.europa.eu/environment/waste/mining
processing site (and handle only extractive waste), i.e. the waste is not a burden on the national waste
infrastructure - it is managed as a site-specific issue. Indeed, in recognition of this, the Extractive Waste
Directive requires operators of such facilities to prepare dedicated waste management plans to include
such matters as prevention, selection, design, operation, monitoring, public participation, closure &
aftercare, and financial provision. There are no new mining activities currently in the national planning
or EPA licence consent processes. Extractive waste from historical sites is described under Chapter 7.
3.6 Radioactive waste

Although it is strictly speaking outside the legally mandated scope of the National Hazardous Waste
Management Plan62, Appendix E provides information on the issue of radioactive waste. The Radiological
Protection Institute of Ireland (RPII) has reiterated that there is a deficit in the provision of services to
ensure the collection and management of radioactive waste. In particular the RPII identifies issues with
legacy radioactive waste (sources that were in use since before the early 1990s and have now reached
the end of their useful life). As detailed in Appendix E, substantial progress has been made in this area
since the last Plan was published in 2008. In a report commissioned by the EPA under the previous
National Hazardous Waste Management Plan in relation to aspects of a national Difficult Waste Facility
(including hazardous waste), administrative and structural synergies were identified in the co-storage
of this waste stream with certain hazardous waste streams63.
3.7 Enforcement – some key challenges concerning hazardous

waste | 39
Environmental regulators in Ireland are responsible for in excess of 500 environmental protection
functions contained within over 100 pieces of legislation. The EPA is responsible for regulating over 200
waste activities (e.g. landfills/waste transfer stations) and 500 industrial activities that have significant
polluting potential. Local authorities control the collection and movement of waste in their functional
areas and regulate smaller industrial waste and wastewater activities as well as controlling diffuse
sources of pollution.
The Government’s Waste Management Policy, A Resource Opportunity, contained a commitment to

complete a review of the respective regulatory and enforcement roles of the Environmental Protection
Agency and local authorities by the end of 2013. In early 2013, the DECLG established a group to
carry out that review by examining current enforcement structures, identify the existing strengths and
weaknesses and make recommendations for the future. The group comprises of representatives from
local authorities, the regional waste management offices, the EPA, the National Transfrontier Shipment
Office (NTFSO), the National Waste Collection Permit Office (NWCPO) and An Garda Síochána. The
group has met on several occasions to date and a final outcome is expected in 2014.
In recent years there have been challenges for enforcement in the area of hazardous waste, some of
which are highlighted below:
62 See section 3 of the Waste Management Acts 1996 as amended.

63 http://www.epa.ie/pubs/reports/waste/haz/nationaldifficultwastefacilitystudy.html
3.7.1 Waste oils
The unauthorised use of waste oil in burners for space heating is a problem which continues to exist.
The burning of waste oil falls under the scope of the Industrial Emissions Directive (Directive 2010/75/
EU). The operation of, for example, used oil burners, requires a licence from the EPA for Hazardous
Waste Incineration. It is an offence to burn waste oil in the absence of a valid licence. The unauthorised
combustion of waste oils in burners/energy units has the potential to cause harm to the environment
and human health.
The EPA and local authorities have engaged in enforcement and awareness activities in this regard (e.g.
targeted inspections and awareness via national and sector advertisements (e.g. car garages)). See EPA
smart garage guide:
http://www.epa.ie/pubs/reports/waste/wpp/Smart%20Garage%20Guide%202010%20small.pdf))
Such enforcement and awareness activities should continue over the next revised Plan period.
The pork contamination incident in Ireland in 2008 also highlights the risk that PCB contaminated
oil that is not managed properly can potentially pose to the environment and public health, as well
as its economic impacts. Available evidence suggested that the incident occurred as a result of PCB
contaminated fuel being used in an oil-fired burner used to dry animal feed.
40 | 3.7.2 Diesel fuel laundering
There has been a dramatic increase in recent times in diesel laundering waste dumping incidents. The
scale of the dumping incidents can vary from one container to up to 45 intermediate bulk containers
(IBCs) 64. Laundering has been uncovered particularly in border counties such as Monaghan, Donegal
and Louth, with laundered fuel seized in many areas, e.g. Galway, Athlone and Dublin.
Typically waste associated with these illegal activities, such as sulphuric acid wash, contaminated
absorbent and bleaching earth sludge, has been exported to hazardous waste treatment facilities, at
significant cost, in either Holland or Germany for treatment.
Local authorities have had to take measures to protect watercourses and to temporarily turn off public
water supplies/monitor private wells due to dumping close to private dwellings. The waste is a significant
health and safety risk because of its acidic nature. Also roads can be left in a very dangerous/slippery
condition and must often be cleaned due to the risk of traffic accidents.
3.7.3 Waste Electrical and Electronic Equipment (WEEE) and Metal

Theft
In line with a global trend, metal theft has become a problem in Ireland in recent years, due to increasing
metal prices. Many economic sectors have experienced losses as a result of this trend and in some cases,
such theft can lead to environmental pollution such as oil spillage, as well as health and safety concerns
in the case of electrical cable and equipment.
64 Each IBC container can hold approximately 1,000 litres/1 tonne of waste.
The metal theft issue can only be tackled on a multi-stakeholder basis, and to this end, An Garda
Síochána has established the Metal Theft Stakeholder Forum, which involves affected business and
economic sectors as well as the EPA and local authorities. In February 2013, An Garda Síochána
launched the Metal Theft Crime Prevention and Reduction Plan, which aims to deliver crime prevention
and reduction policies/measures to combat the problem of metal theft.
WEEE has become part of the metal theft issue, due to the high metal content of large household
appliances in particular. Automotive batteries are similarly attractive due to the high lead content. The
high value of metal can be attractive to person(s)/groups seeking an alternative means of managing
WEEE, other than via the established routes through the WEEE compliance schemes. These situations
are referred to as WEEE leakage, where the WEEE is “leaking” from the established management
routes. The WEEE compliance schemes participate in the Metal Theft Stakeholder Forum described
above. The EPA is also working with An Garda Síochána to develop awareness material for parties
concerned by metal theft/WEEE leakage issues.
3.7.4 End of life vehicles
Directive 2000/53/EC, the End of Life Vehicle (ELV) Directive, sets targets for re-use/recovery and re-
use/recycling from January 2006, with higher targets coming into effect from January 2015. Ireland
is currently failing to meet the ELV Directive targets which have been in place since January 2006.
Preliminary data for 2011 indicate that a re-use/recovery rate of 79% and a re-use/recycling rate of
77% were achieved against targets of 85% and 80% respectively. | 41
Urgent action is needed to increase re-use/recovery/recycling of ELV materials, and the DECLG will be
engaging with producers and other stakeholders in this regard. The increases in the landfill levy and the
removal of the exemption from the landfill levy for shredder residue are likely to encourage the recovery
of shredder residue and therefore increase ELV recovery rates over time.
The EPA, working closely with local authorities, has prioritised the issue of unauthorised car scrapyards65
during 2011/2012, resulting in the number of illegal sites falling from 157 to less than 10 in 2013 – a
reduction of greater than 90%. A number of multi-agency actions took place during the period, often
overcoming difficult operational obstacles.
65 This is an aspect of the 2005 ECJ waste case against Ireland and it is a national priority to have the illegal sites dealt with
so that, among other reasons, legitimate operators are not undermined.
4. Prevention of hazardous waste

The data presented in Chapter 3 profile the generation and management of hazardous waste by Irish
industry and society generally. As outlined in Chapter 1, there are challenges to be met in relation to this
diverse hazardous waste stream: prevention, collection and self-sufficiency in treatment. This chapter
outlines a programme for hazardous waste prevention that promotes the reduction in the generation
of hazardous waste in targeted sectors of industry and society. These elements should be incorporated
in the next National Waste Prevention Programme, which is being led by the EPA.
4.1 Definition of prevention

Prevention is at the top of the waste hierarchy, and represents the preferred policy approach to materials
management and an alternative to the wastage of materials or resources. The prevention of waste is
preferable to its generation and to the monetary and environmental costs incurred as a result of its
generation. A new and revitalised approach to prevention is taken in the revised Waste Framework
Directive.
“Prevention” means measures taken before a substance, material or product has become waste, that
reduce:
42 |
a) the quantity of waste, including through the re-use of products or the extension of
life span of products;
b) the adverse impacts of the generated waste on the environment and human health;
or
c) the content of harmful substances in materials and products.
The revised definition clearly incorporates the principle of reducing the “hazardous properties” of waste
(or qualitative prevention) as a means of preventing environmental pollution or damage to human
health.
4.2 Approach to prevention

Effective waste prevention addresses the root causes and sources of waste, and is not typically
concerned with waste management per se. Therefore, techniques for preventing waste should look
at industrial processes, material inputs and products in a way that links them to wasted resources or
inputs (i.e. waste). A problem for prevention is that any mention of the word “waste” causes people to
immediately think about waste recycling and disposal, and not to consider the material and cost savings
that can accrue from a real preventive approach to resource efficiency.
Prevention of hazardous waste
PREVENT
REDUCE
REUSE
RECYCLE
ENERGY RECOVERY
DISPOSE
Figure 7 The waste hierarchy, highlighting prevention of waste as the preferred option
There are two dimensions to “prevention”. The first is the avoidance of the generation of waste in the
first place (e.g. by reducing material intensity). This, as noted above, is the purest form of prevention. | 43
The second is that if waste cannot be avoided, then prevention measures should ensure the elimination
of harmful substances or compounds that present an environmental burden or interfere with the
preparation for re-use and recycling of the waste. Application of eco-design across the entire life cycle
of a product – from the extraction of raw materials to production, distribution and utilisation, all the
way to re-use, recycling and disposal - can prevent or reduce hazardous waste arisings. As well as
addressing issues of energy consumption and the responsible use of resources, eco-design needs to
address user behaviour, product durability and reparability.
Prevention will continue to be a priority for the six year period of the revised Plan to progress the
cultural change that makes businesses look again at resource efficiency in order to bring about a step
change in the material intensity and hazardous properties of waste in Irish industry, and in society
in general. Prioritised sectors will again be targeted in order to examine their material usage and
waste generation profiles and to propose solutions. With expert knowledge, insights and technical and
financial supports, industry can be encouraged to bring about the changes necessary to satisfy this
paradigm for environmentally efficient industrial production.
The prevention of waste is always preferable to the generation of waste from two points of view. First,
if a waste is not generated, it will have no opportunity to cause adverse human health or environmental
impacts. Second, the holder of the waste does not have to pay for its management. The latter would
appear to present a compelling case for businesses to prevent waste. However the slow adoption
of preventive measures, even when their benefits are well proven and well known, demonstrates
that achieving prevention is as much a socio-economic and psychological problem as a technical
one. Consequently, if we really wish to promote and continue to achieve waste prevention, a mix of
cumulative, integrated policy measures is required. This chapter sets out the continued approach to
promoting and achieving the prevention of hazardous waste.
In considering the scope for prevention, the existing waste management status of a sector and the
degree to which the sector itself can make changes that will achieve prevention are important. There is
an “evolutionary pathway” whereby a sector may improve its waste management initially by achieving
compliance and effectively segregating wastes, thereby minimising the quantity of hazardous waste
generated for disposal. However, improvement may stop at this point and not progress further to
embrace prevention (as opposed to recycling) unless there are external drivers for this continuous
improvement. The proposed approach will encourage improved segregation by generators of hazardous
waste, allow them to identify the scale and origins of individual waste streams, and draw their attention
to the more significant elements of their wastage where improvement is possible (and should also
bring about cost savings). Figure 8 illustrates the division of emphasis in this two-phase approach
to achieving prevention: firstly concentrating on improvements in general waste management and
secondly identifying opportunities for prevention.
Any hazardous waste prevention activities outlined in this chapter will be considered as part of the
implementation of the next National Waste Prevention Programme66 (NWPP). The NWPP is broad in
its scope, and other opportunities to engage with sectors not mentioned in this chapter should be
explored. The NWPP satisfies the new obligation in the revised Waste Framework Directive for Member
States to prepare prevention plans that set out the State’s waste prevention objectives. Article 29 of
the revised directive states that “the aim of such objectives and [prevention] measures shall be to break
the link between economic growth and the environmental impacts associated with the generation of
waste”.
44 |
Unreported Segregation Prevention of waste

and Compliance and and
unmanaged recycling resource efficiency
Figure 8 The “evolutionary pathway” to prevention of waste and resource efficiency
The third cycle of the EPA’s NWPP runs from 2014 to 2020 with the overarching objective to stimulate
resource efficient behaviours and break the link between economic growth and environmental impact.
More specifically, the NWPP will work to:
➤➤ Reduce wasteful consumption of material, water and energy resources by changing behaviours in
businesses, households and the public sector;
➤➤ Enhance competiveness and reduce business costs by delivering programmes that stimulate resource
efficiency and the circular economy;
➤➤ Support sustainable growth and employment in the green economy - including re-use enterprises;
➤➤ Minimise generation of hazardous wastes through efficient practices and use of safer alternatives;
66 The National Waste Prevention Programme was established in 2004 and is led by the Environmental Protection Agency.
A portfolio of projects has been developed including the Green Business Initiative, comprised of the greenbusiness.ie free
advisory service for improved business efficiency and the Green Hospitality Award for sustainable practices in the hotel
and related sectors. See www.nwpp.ie for more information.
➤➤ Manage hazardous substances in products through efficient regulation;
➤➤ Inform and influence evidence-based decision-making by compiling and publishing high quality
data on waste.
4.2.1 Role of research and innovation in prevention
Both in line with the above advocacy objective and because of their role in funding research the EPA
and the DECLG have participated in the Research Prioritisation Exercise convened by the Department of
Jobs, Enterprise and Innovation. The 2011 report67 of the National Research Prioritisation Steering Group
recommends 14 areas of opportunity, as well as underpinning technologies and infrastructure to support
these priority areas, which should receive the majority of competitive public investment in Science,
Technology and Innovation (STI) over the coming 5 years. The report also recognises the critical role of
research for policy making and the fundamental role of research for knowledge. The recommendations
in the report were adopted by Government in 2012. Action plans have been developed for each of the
prioritisation areas as part of the ongoing implementation of the recommendations.
The Prioritisation Action Plans for the areas of Manufacturing Competitiveness and for Processing
Technologies highlight the need for resource efficiency but research in many of the other priority areas
(e.g. Medical Devices, Therapeutics, Diagnostics) should also address the issue of potential hazardous
waste arisings and how to avoid them. In this way a forward-looking cohort of new industries will be
built that are capable of meeting current and future regulatory requirements, while also protecting the | 45
valuable natural assets in our environment.
4.3 Prevention plans for prioritised sectors

Following on from the previous plan, six priority sectors, as listed in Table 16, have been identified
for continuous engagement on hazardous waste prevention. The priority list will remain flexible, with
addition or deletion of sectors as further study, information or opportunities might dictate during the
revised Plan period.
Table 16 Six priority sectors for hazardous waste prevention
Sector Typical hazardous wastes
Pharmachem Solvents, other industrial hazardous waste
Agriculture Waste oils, oily wastes, paints, pesticides, animal healthcare wastes
Healthcare Healthcare hazardous waste (e.g. dressings, contaminated medical

products and other general hazardous waste)
Households Paint, pesticides, pharmaceuticals, batteries, fluorescent tubes
Publishing & Printing Ink and varnish waste
Transport Waste oils, oily sludge, lead acid batteries
67 http://www.djei.ie/publications/science/2012/research_prioritisation.pdf
The general tools outlined in Table 17, originally developed for the previous National Hazardous Waste
Management Plan, should continue to be used, as appropriate, in engaging with the sectors identified
as a priority for continued action on hazardous waste prevention activities. The sectoral approach
should remain flexible and able to respond to specific sectoral needs and opportunities that may arise
during implementation.
Table 17 General toolbox for sectoral engagement on waste prevention and resource use minimisation
Tool Approach
Engagement with A review and advisory (steering) group could be established for each sector
the sector with membership drawn from sectoral representative, regulatory and other
organisations. The sectoral representatives would serve as a two-way conduit for
communications. Broad agreement should be sought on all proposed initiatives,
though it should be recognised that consensus may not always be possible.
Engagement Companies should be supported through site visits to determine the origins of
with individual good (or poor) performance. Detailed company-specific assessments should
organisations be carried out with specific reports generated for the company. The aim of the
visits would be to identify transferable practices and technologies (or pitfalls),
subject to commercial confidentiality, and to generate financial or environmental
returns for companies. These visits should be clearly distinct from inspection
or audit visits and should be intended to support and assist companies. Data
should be used to contribute to sectoral performance comparisons.
46 |
Performance Detailed waste information is available from annual environmental reports
comparison and (from EPA licensed companies) and general waste statistics. Company-specific
benchmarking data can be extracted and analysed for comparison, review of trends and
identification of significant improvement (or deterioration) on a company and
sectoral basis. A report should be published for the sector highlighting general
trends. Examples of good performance should be published as case studies.
Data should be analysed for best practice benchmarks that can be applied
sector-wide. Commercially sensitive company-specific information should be
kept confidential except where it is already publicly available and/or subject to
legislation on freedom of information.
Environmental Many industrial facilities are subject to EPA licensing. There are explicit
objectives and requirements for prevention to be addressed in licences through a set of
targets environmental objectives and targets. Licensees are obliged to ensure that
these targets are challenging and are addressed. A review of the objectives
and targets developed by licensees within a sector will illustrate the level of
ambition within the sector for achieving the objectives/targets concerned. If
the objectives and targets are adequately challenging, they can be used to set
sectoral benchmarks. Where sectors are not covered by EPA licences, alternative
sources of benchmarking information should be sought.
Research New research and case studies on best environmental practice, technologies
dissemination and and techniques should be disseminated within each sector. Funding should
studies also be available for once-off sector-specific research that may be required.
Funding to third-level institutes is also necessary in order to develop waste and
resource management modules, and industry-led research projects so as to
ensure availability of appropriately educated graduates in the areas of resource
efficiency and waste management.
Financial support Grant-aid to assist in material and equipment investment may be appropriate
for certain sectors and may prove catalytic in driving innovation, efficiency and
better environmental performance.
Pharmaceutical and chemical industry - sectoral prevention plan

(to be read in conjunction with Table 17)
Background: This sector is very important to Ireland’s economy. Current manufacturing processes are
dominated by the use of organic solvents, which in turn become the single largest hazardous waste
stream in Ireland, much of which is recovered or recycled. There is a trend towards a greater proportion
of products being manufactured by biotechnology routes, avoiding the use of organic solvents.
Nevertheless, manufacture by chemical routes will continue to be important. The sector is likely to
continue to seek more efficient manufacturing routes of its own accord (e.g. fewer steps, alternative
or no organic solvents, continuous processing, green chemistry), but the changing nature of individual
products and the associated synthesis routes means that predicting the inherent trend in waste arisings is
uncertain. The sector should continue to be facilitated and guided in its efforts to improve.
An Economic Study on Solvent Recycling and Treatment has been completed and there has been
engagement between the EPA and the sector in this regard.
Tool Approach
Engagement with PharmaChemical Ireland is the main representative body for the sector.
the sector Notwithstanding the fact that EPA licences are facility and company specific,
sectoral co-operation should continue to be encouraged and facilitated. Sectoral
agreements may be appropriate and their use should be explored. The EPA
should maintain engagement with the sector to examine issues concerning the
treatment of solvent in Ireland and explore acceptable solutions to promote
solvent recycling and recovery.
Engagement The pharmachem sector is technically highly competent. Engagement with | 47
with individual companies should take place through equally experienced and competent
companies personnel.
Performance Detailed waste generation information is readily available from annual

comparison and environmental reports prepared by companies in the sector and provided to the
benchmarking EPA. These reports are publicly available. Data are also presented and analysed
in National Waste Reports. The annual Responsible Care report, published by
PharmaChemical Ireland, demonstrates the extent of waste prevention and
reduction by the sector.
Environmental Most companies in this sector are licensed by the EPA. Detailed information on
objectives and any individual company’s environmental objectives and targets is readily and
targets publicly available. The data should be extracted, analysed and published annually.
The sector’s level of ambition in environmental objectives and targets should be
analysed.
Tool Approach
Research The annual Responsible Care report, published by PharmaChemical Ireland,

dissemination and demonstrates the extent of waste prevention being carried out by the sector.
once-off studies The National Waste Prevention Programme will work with the Responsible Care
initiative and seek to intensify the “reinvestment” of this and other relevant
research back into the sector.
Research and technological development efforts could continue to be directed

to areas such as improved synthesis pathways (e.g. fewer steps, improved
specificity, less hazardous solvents), continuous processing, improved recovery
and enhanced process monitoring and control. The use of “environmental
technologies” should be supported, but in the context of prevention, with an
emphasis on avoidance, reduction and recovery.
Financial support Any financial support to this sector will be small in relation to the sector’s
invested capital and turnover. A research and innovation fund should be made
available, with support from the sector, to assist technological innovations,
examples of which are given above. Ongoing support should be provided for
training and education of staff in the sector.
48 |
Prevention - Green Enterprise
(formerly Cleaner Greener Production Programme (CGPP))
Cleaner Production is the application of integrated

preventive environmental strategies to processes, products
and services to increase overall efficiency and reduce risks to
humans and the environment. Using resources more
efficiently has clear environmental and economic benefits for
companies and organisations: it improves productivity,
reduces costs and enhances competitiveness. Between 2008
and 2012, 24 different projects were funded under the
CGPP Green Enterprise programme, across sectors such as
food, IT, services and manufacturing. In total more than 50
companies and organisations were involved in these projects.
Taking into consideration client and franchise roll-outs of the
projects, these projects are now being implemented in
almost 1,600 sites across Ireland. By way of example in terms
of hazardous waste, in the case of one company, Tech
Group, dry-ice cleaning of tools reduced hazardous waste
from aerosols by 70%, saving €35,000.
Agriculture - sectoral prevention plan

Background: There are 139,860 farms in Ireland with the average farm being 32.7 hectares however
42% of farms are less than 20 hectares. The agricultural sector is geographically dispersed and the
main farming enterprises are dairying, beef, sheep, tillage, pigs, poultry and intensive horticulture. The
main hazardous waste streams generated by these enterprises include waste oils, wastes containing
residues of oils and greases, waste paints, unused or de-registered agrochemicals, chemical and biocide
containers, animal health wastes and aerosol cans. The type and diversity of the waste generated
and the geographical distribution of farms in Ireland presents a challenge for waste collection and
subsequent management. Animal health care wastes also present a biosecurity risk.
Since 2007, the EPA has collaborated and engaged with various stakeholders in this sector to facilitate
and provide a mechanism whereby farmers can dispose of these wastes in an appropriate manner. The
EPA and Department of Agriculture, Food and the Marine (DAFM) prepared and published guidance
specific to triple rinsed pesticide containers. These wastes are being recovered through Farm Plastics
Recycling Ltd. In 2013, IFFPG, European Recycling Platform Ireland (ERP Ireland) and WEEE Ireland
operated co-collection bring centres for farmers across the country where farmers were able to bring
waste electronic and electrical equipment with their farm plastics for recycling. A review of these joint
operations will be undertaken. Farmers did avail of the service and also commented that it would be
useful if the centres should cater for additional hazardous wastes that they have on their farms. The
wastes identified included waste oils, filters, oil drums, grease gun tubes, de-regulated pesticides, old
paints and animal health care wastes. Refer also to Section 5.2.1.2 regarding a recent farm hazardous
waste collection pilot scheme.
Tool Approach | 49
Engagement with The EPA will continue to engage and work with key stakeholders including the
the sector IFFPG, Teagasc, DAFM, DECLG, Irish Medicines Board and relevant farming
organisations and trade associations. Waste specific targeted campaigns should
be considered to deal with stockpiling and legacy issues of hazardous wastes
on farms. Existing farm extension/advisory programmes should be utilised to
exchange information on waste prevention and minimisation. The EPA will also
be engaging in a Smart Farming programme (http://www.smartfarming.ie),
which is to look at resource use and efficiency on all farms across all sectors
and highlight “top tips” in relation to resource efficiencies including waste
minimisation.
Engagement See above.

with individual
companies
Performance The development of farm type (tillage, dairy, horticultural, intensive pig, etc.)
comparison and specific hazardous waste benchmarks may, for example, be explored having
benchmarking regard to national and international experience as may be available.
Tool Approach
Environmental The objectives for this sector is to move from current uncertainties in relation
objectives and to the types and quantities of wastes being generated on farms and stockpiling
targets of such wastes towards segregation and recycling opportunities to prevention
as part of resource efficiency. The EPA will be funding work to develop more
accurate waste generation models for this sector. Collaboration will continue
with relevant stakeholders to implement waste specific initiatives to assist
the sector to manage hazardous waste in a manner which contributes to the
branding of Irish agriculture as clean and green. Smart Farming is an initiative
which highlights ways that farmers can reduce their bills and maximise output
through better resource management. Part of the initiative is a guide that
provides top-tips to farmers on how to save money on feed, fertiliser, energy
and water bills and prevent waste.
Research Research and develop a waste model to estimate the quantities of hazardous
dissemination and and non-hazardous wastes on farms. Produce guidance for farmers on
once-off studies hazardous waste prevention and disposal to be disseminated through the
Smart Farming programme. Sheep dip is a hazardous waste and should not
be landspread in the absence of a waste licence. A study, undertaken by the
EPA in consultation with relevant stakeholders, to evaluate and recommend an
appropriate regulatory mechanism and relevant guidance for the management
and disposal of spent sheep dip will be carried out during the revised Plan
period. This will include a life cycle analysis of currently available treatment
options for spent sheep dip. The Smart Farming Programme and existing farm
extension advisory programme will be used to disseminate guidance on the
50 | management and minimisation of farm hazardous waste.
Financial support Financial supports to farm and farm advisory bodies should be considered where
necessary.
Prevention Case Study - Farming the Environment
This guide, published in 2008, gives farmers a number of specific easy actions they can take to
reduce their costs by reducing consumption of water and energy, and preventing waste, which
in turn reduces environmental impacts. The guide was developed by Monaghan County
Council in association with County Monaghan Irish Farmers Association under the EPA’s
National Waste Prevention Programme.
Healthcare - sectoral prevention plan

Background: The healthcare sector is predominantly publicly owned, though with important and
large private facilities and small practices. A different approach is likely to be demanded by either side
of the sector, though cost savings are likely to prove an attractive driver across the sector. A relatively
small proportion of healthcare waste is classified as hazardous waste, but it is a waste stream of major
concern from environmental, occupational health and safety and public health concerns. Infection
control nurses advise on segregation of infectious risk waste and sharps, and poor segregation can result
in unnecessarily high waste management costs being incurred. Infection control remains the overriding
priority in the healthcare sector.
The cost of healthcare risk waste treatment or export is relatively high, and there is scope for reducing
the costs of the management of healthcare risk waste through appropriate waste segregation at ward
level. By seeking to reduce the extent of this hazardous waste stream and diverting non-hazardous
waste for recycling, where possible, opportunities for hazardous waste prevention are likely to become
apparent.
Tool Approach
Engagement with The principal focus at national level is with the Health Service Executive (HSE).
the sector Considerable work is on-going in relation to promoting best practice waste
management within the HSE. The HSE has updated guidelines on segregation,
packaging and storage for healthcare risk waste in 2010 and also produced a
Waste Management Awareness Handbook for HSE employees in 2012. The EPA
NWPP is engaging with this sector through the Green Healthcare Programme
| 51
(www.greenhealthcare.ie). It is important to engage also with private facilities
and the small-scale private sector of general practitioners, dentists and others.
Sectoral cooperation should be explored in trying to achieve specified targets.
Engagement Evidence from recent EPA-funded projects suggests that there is scope for
with individual obtaining greater value for money for individual facilities. Engagement with
organisations individual facilities should focus around advising on waste management and
reduction plans, with a focus on recycling in the first instance and moving on to
examining waste generation overall. Good waste management control is most
effective at the level of individual facilities and requires day-to-day intervention of
motivated and cost-conscious local healthcare managers. This work should build
on the HSE’s existing awareness-raising, training and good practice monitoring
projects. Considering the size of this sector there are benefits in actively
disseminating the results and guidance arising from case studies under the Green
Healthcare Programme.
Performance A small number of case studies (e.g. from the Green Healthcare Programme)
comparison and provide initial benchmarking data in relation to waste and hazardous waste
benchmarking generation, segregation and costs. International benchmarks may also be useful
in this sector. Individual facilities should be encouraged to measure their own
performance for comparison against sectoral benchmarks.
Tool Approach
Environmental A combined top-down and bottom-up approach is most appropriate for this
objectives and sector, with national benchmarks being set by the HSE or Department of Health,
targets and hospital type specific targets put in place for local healthcare managers and
budget-holders.
Research Recent EPA-funded research has shown that raising awareness and taking simple
dissemination and steps can bring about major improvements in waste management and reduced
once-off studies waste management costs. The dissemination of case studies and relevant
guidelines within the sector (e.g. Green Healthcare Programme) should be
ongoing through proactive site visits and regional Green Healthcare seminars.
Financial support The sector should be supported in responding to new environmental green public
procurement criteria and for training and education of staff in the sector. The HSE
is the largest public procurer of goods and services.
Prevention Case Study - Green Healthcare Programme
The Green Healthcare Programme has produced three

52 |
‘How To’ Guides, showing hospital staff how they can
carry out waste prevention and resource efficiency
activities themselves. The guides outline a step-by-step
approach to all the required activities, providing clear
assistance to hospital staff on how to save money and
resources. For example, a Best Practice Guide has been
produced on Healthcare Risk Waste Reduction.
Households - sectoral prevention plan

Background: Households individually produce a small amount of hazardous waste, but this is often
“unreported”, possibly being mixed with general household waste or discharged to drain. Householders
may be unaware generally of the hazardous waste they produce or how it should be managed. While
the implementation of the waste electrical and electronic equipment (WEEE) and batteries regulations
have greatly improved the situation, a more concerted effort is required to fully engage with the general
public on its generation and management of hazardous waste.
A wide range of hazardous product wastes are generated in households, for example: fluorescent
(energy-saving) bulbs, solvent (VOC)-based paint and varnish, paint thinners, medicines, some batteries,
some WEEE, leftover garden pesticides and herbicides, waste oil and other DIY vehicle servicing waste.
Both compliance schemes have run special collection days and events for the collection of WEEE and
batteries.
The EPA NWPP is engaging with householders through the Green Home initiative (www.greenhome.ie ).
Tool Approach
Engagement with While there is no representative body per se for the household sector, there are
the sector certain programmes aimed generally at householders. The EPA is supporting
An Taisce’s Green Home initiative. This is building on the successful Green
Schools programme and seeks to take the environmental sustainability message
into communities. Local authorities’ general waste awareness and education
activities are also key to making householders aware of hazardous waste and
informing them of good practices and local facilities. The EPA-funded Local | 53
Authority Prevention Network (LAPN) programme is building capacity in local
authorities in the waste prevention and resource efficiency fields.
Engagement with This will be achieved principally through such mechanisms as those mentioned
individuals above.
Performance In 2011, 0.43 kg of household hazardous waste per capita was collected. This
comparison and has increased from 0.16 kg per capita in 2006, which demonstrates a significant
benchmarking improvement in collection rates during the previous plan period. This should
serve as a benchmark on household activities, though improved collection
should increase this number. Periodic household waste characterisation studies,
commissioned by the EPA or local authorities, will provide information on the
disposal of hazardous waste in waste and recycling bins. A national municipal
waste characterisation study will be repeated periodically.
Environmental The focus for engagement with householders should continue to be on

objectives and improving collection rates and reducing the inappropriate disposal of household
targets hazardous waste. The disposal of household hazardous waste in waste and
recycling bins should be expected to decrease as: (a) information and awareness
campaigns take effect; (b) more and better local facilities and collection services
are made available; and (c) the influence and effect of free take-back of WEEE
(including fluorescent lamps) and batteries continue to grow.
Tool Approach
Research An important factor in the prevention of household hazardous waste is

dissemination and to provide information on “green products” and alternatives to the use of
once-off studies hazardous cleaning, decoration and garden products. The promotion and use of
eco-labels and other information mechanisms should be explored.
Financial support The EPA NWPP should continue to support An Taisce’s Green Home project and
local authorities through the Local Authority Prevention Network. A funding or
grant-aid mechanism should be made available to support other projects aimed
at the prevention of household waste and resource efficiency in households.
Producers of batteries are required to fund public information campaigns on
the collection, treatment and recycling of batteries. Similar funding mechanisms
could be considered for future PRIs.
Prevention Case Study -

A Householders’ Guide to Hazardous Waste Prevention
This booklet, published in 2010, contains tips and advice for

householders on the correct use and disposal of everyday
54 |
hazardous products. The information in this guide was
prepared by the Regional Waste Management Office
(RWMO) for Limerick, Clare and Kerry, working on waste
prevention by participating in the Local Authority Prevention
Network (LAPN) and working in partnership with the region’s
local authorities. In 2013, Local Authorities, via the LAPN,
held workshops with Tidy Towns groups on household
hazardous waste aspects (e.g. bring and swap leftover
products, correct handling and disposal of this waste and
advice on non-hazardous alternatives).
Publishing and printing industry - sectoral prevention plan

Background: The use of inks based on organic solvents leads to hazardous waste arising in this sector.
Waste ink, containers, cleaning rags and solvents associated with cleaning are generated. The sector
includes manufacturers of inks as well as consumers of ink, i.e. the printers. These operations vary in
scale from local print shops for advertising leaflets, to newspaper printers and packaging suppliers.
Minor improvements are likely to be possible for smaller operations, with the potential for major
improvements, for example in the types of ink used, arising from partnership arrangements between
ink suppliers and ink users. Major changes have occurred in this sector with the move towards digital
systems. The EPA has supported several projects to investigate the use of non-organic-solvent inks.
The trend of waste generation is uncertain, but the lessons already learned should be widely applied.
Case studies under the Cleaner Greener Production Programme which demonstrate good practice and
improved efficiencies are available on www.greenbusiness.ie. See also information overleaf on a best
practice guide due to be published under a Green Print and Packaging Initiative 2012-2013, which was
funded by the EPA.
Tool Approach
Engagement The Irish Printing Federation is the main representative body for the sector. Sectoral
with the sector co-operation should continue to be encouraged and facilitated. Mentors and
champions should be sought from the larger EPA licensed operations and from
progressive smaller operations.
Sectoral agreements may be appropriate and their use should be explored.
Engagement This sector is specialised, and experienced personnel should be sought to engage with | 55
with individual individual companies. Priority should be given to the larger, licensed operations and
companies good practice demonstration should be provided to smaller operations that perhaps
do not have the technical and financial resources to seek assistance in production and
environmental efficiencies.
An appropriate regulatory system should be considered for smaller unlicensed

operations on foot of outcomes from sectoral engagement. This could be used to
drive environmental efficiencies and obtain monitoring information.
Performance Detailed waste generation information is readily available from annual environmental
comparison reports prepared by EPA licensed companies in the sector. These reports are publicly
and available. The data should be extracted, analysed and published annually. Many
benchmarking operators are not licensed and other means of obtaining statistical information will
be required. The data should be normalised against production data to ensure valid
comparisons are made.
Environmental The larger companies in this sector are licensed by the EPA. Detailed information
objectives and on individual company’s environmental objectives and targets is readily and publicly
targets available. The data should be extracted, analysed and published annually. The sector’s
level of ambition in environmental objectives and targets should be analysed.
Tool Approach
Research Experience gained from case studies, available via www.greenbusiness.ie, and the
dissemination best practice guide due to be published under a Green Print and Packaging Initiative
and once-off 2012-2013 should be disseminated across the sector.
studies
The public sector commissions a significant proportion of the output from this sector.
Environmental considerations should be included in green public procurement criteria,
in particular the specification of inks.
Financial The sector should be supported in responding to environmental criteria in green

support public procurement and for training and education of staff in the sector.
Prevention Case Study -

Resource Efficiency in the Irish Print and Packaging Sector
This best practice guide, to be published in 2014, aims to

help the Irish Printing and Printed Packaging sector to save
money, use resources more efficiently and improve
56 | environmental performance. The booklet provides tips on
organising a resource efficiency programme, potential cost
RESOURCE EFFICIENCY
savings from raw material usage and reduction, waste IN THE IRISH PRINT & PACKAGING SECTOR
management including tips for minimising hazardous waste

and associated disposal costs, energy efficiency and water
management hints and information on green procurement
and eco-labels. The booklet is designed to help a wide range
of companies across the sector and points out how many
printing companies have saved significant costs through
resource efficiency measures.
Transport industry - sectoral prevention plan

Background: This sector includes road, rail, ship and air transport. As well as cars serviced by garages,
it includes major fleet operators (e.g. An Post, Eircom, ESB, Bus Éireann, Dublin Bus, Iarnród Éireann),
distribution companies, public service vehicles, visiting ships and aircraft. Hazardous waste is associated
with the maintenance of these vehicles, typically being the replacement of spent or contaminated
fluids and cleaning of parts. The scope for prevention is limited, though condition-based maintenance
(based on distance travelled rather than time, for example) could be applicable for fleet operators and
alternative paints relevant to repainting. The European Union (Installations and Activities Using Organic
Solvents) Regulations (S.I. No. 565 of 2012) and European Union (Paints, Varnishes, Vehicle Refinishing
Products and Activities) Regulations (S.I. No. 564 of 2012) govern installations and activities using
organic solvents, such as vehicle refinishers for the purpose of preventing or limiting emissions of volatile
organic compounds.
Proper collection, segregation, reporting and general environmentally sound management presents the
greatest potential to improve performance in this sector and identify future actions for prevention. In
2010, the EPA published a Smart Garage Guide which is aimed at promoting best environmental practice
in garages. This guidance is applicable to the transport sector as it covers energy efficiency, waste
management (including management of waste oils, mixed fuels, brake fluids and antifreeze, batteries,
WEEE and aerosols) and water management.
Tool Approach
Engagement with There are numerous large transport companies, fleet operators and garages
the sector within the sector. Sectoral engagement should be encouraged and facilitated.
| 57
Engagement The priority for this sector is to ensure compliance with existing waste
with individual management legislation. For example, the unauthorised use of waste oil in
companies burners for space heating in car garages has been reported. There should be
continued engagement in enforcement and awareness activities in this regard
(e.g. targeted inspections and awareness via national and sector advertisements
(e.g. car garages)). As compliance levels increase and information begins to
feed back from enforcement studies and campaigns, greater opportunities
should arise for engagement with the sector on preventive approaches and
encouraging good environmental practices (e.g. further dissemination of the
Smart Garage Guide). Contact should be made with larger operators to explore
best practice measures that can be centrally disseminated and replicated in
smaller operations.
Performance As data become available, through dedicated studies, it may be possible to set
comparison and benchmarks objectively for certain classes of activity in the sector.
benchmarking
Environmental The sector is not highly regulated and data are not generally available. As data
objectives and become available, it may be possible to set environmental objectives and targets
targets for the sector as a whole or for certain activities or operations.
Research A best performance study should be undertaken to identify the actual range
dissemination and of performance with regard to materials use and waste management actually
once-off studies occurring within the sector, the benchmarks that are achieved, associated best
practices and opportunities for improvements and cost savings. These outcomes
and real case studies should be disseminated across the sector.
Guidance on record keeping and provision of waste data to regulatory

authorities, as required under existing legislation, should be provided (e.g. Smart
Garage Guide). Sectoral level data are key to planning for greater environmental
efficiencies and preventive approaches.
Financial support The sector should be supported in responding to new developments and for
training and education of staff in the sector.
4.4 Implementation
4.4.1 Qualitative or product-based prevention
Hazardous waste may also be prevented by reducing the “hazardousness” or hazardous components/
ingredients in products during design and production. The revised Waste Framework Directive includes
within its definition of actions for prevention “the content of harmful substances in materials and
products”. There are already a range of regulations in place that control the content of hazardous
materials in specified products or articles (see Chapter 2). These include regulations on the Restriction
of Hazardous Substances (in electrical & electronic equipment), Persistent Organic Pollutants (POPs),
Packaging (Essential Requirements), Batteries & Accumulators and Decorative Paints. Other legislation
controlling the impact of products that may become hazardous (or environmentally harmful) wastes after
use includes End of Life Vehicles (ELVs), Polychlorinated Biphenyls (PCBs), POPs, Solvents (incorporated
into the Industrial Emissions Directive), Ozone Depleting Substances (ODS) and Fluorinated Greenhouse
Gas (F-gas) Regulations. Enforcement and compliance with these regulations will reduce the health
and environmental impacts of these potentially hazardous and harmful substances. The EU REACH
(Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation should also reduce
hazardous materials and products over time. Relevant public bodies should continue to cooperate in
enforcement activities concerning product-based pollution prevention.
58 |
Prevention Case Study - Batteries & Accumulators
In 2006 the EU adopted legislation which sought to make batteries and accumulators less
harmful to the environment. The Batteries Directive includes a specific ban on batteries and
accumulators containing mercury and cadmium, but an exemption was provided for batteries
for cordless power tools and button cells containing low levels of mercury. There has been a
recent agreement on lifting an exemption on a ban of the use of cadmium in cordless power
tools and mercury (low levels) in button cells. The main benefits of the agreement will be:
Substantial reduction in the amount of cadmium annually brought into the
European economy and used in everyday products and a corresponding reduction in
the risk of cadmium releases into the environment;
Reduction in the intentional world extraction of cadmium from primary resources by
more than 10%;
Reduction in the environmental impact from the use of mercury and the risks
associated with mercury being released into the environment given that button cells,
due to their size are often inappropriately disposed of in municipal waste; and
Acceleration of the switch to the manufacture of mercury-free batteries.
It is recommended that within the revised Plan period, a waste characterisation study, commissioned
by the EPA via the NWPP, be carried out to profile hazardous waste arisings from smaller sources (e.g.
households and SMEs) to determine if product-based legislation is having its desired effect and the
hazardousness of related waste streams is reducing.
4.4.2 Role of the National Waste Prevention Programme
The EPA’s NWPP leads and co-ordinates a wide range of

prevention initiatives. The NWPP, through the Cleaner
Greener Production Programme, has provided financial
support to Irish-based businesses to “green” their processes and to produce products/services in
an environmentally friendly manner. This links well with Enterprise Ireland’s Green Offer initiative
for Irish-based manufacturers68. The EPA has recently rebranded the CGPP as the “Green Enterprise
Programme” and applications are currently being assessed for the seventh tranche of funding.
The EPA NWPP also supports environmentally improved services through the Green Healthcare initiative
(with particular regard to hazardous waste streams) and the Green Hospitality Programme.
The NWPP should continue to be a priority for the State and should co-ordinate the principal prevention
initiatives outlined in this revised Plan, and create opportunities for engagement at the sectoral and
enterprise level. It will be critical that sectoral representatives and individual organisations actively
engage with the programme. Prevention is a long-term initiative that, quick initial gains aside, may take | 59
some time to register success at the sectoral or national level.
4.4.3 Local implementation of the prevention plan
Local authorities should continue to provide the necessary out-reach

to industry and small businesses and communities in their functional
areas from the NWPP. Prevention forms an important part of all local
and regional waste management plans, and these provisions should
be implemented in full, especially in relation to hazardous waste. Such
supports to local businesses will also enhance their viability to safeguard existing employment and to
create new jobs. Local authorities are currently supported by the NWPP via the Local Authority
Prevention Network (LAPN) 69. Many local authorities have been grant-aided to demonstrate
prevention and resource efficiency in their own offices, in airports, shopping centres, communities,
farms, construction sites and local businesses. The work done by these local authorities has
demonstrated that considerable progress can be made when staff are dedicated solely to waste
prevention projects. These local authorities in turn help other local authorities implement waste
prevention initiatives and a well-functioning network has formed, co-ordinated by the EPA and other
participating (expert) organisations.
68 See http://www.enterprise-ireland.com/en/Productivity/Build-a-green-sustainable-Business
69 The LAPN programme is an initiative of the National Waste Prevention Programme administered by the EPA and funded
by the Department of the Environment, Community and Local Government from the Environment Fund.
The network has two key ingredients:
(1) a network core, including a resource rich website (http://localprevention.ie), to keep

members informed, co-ordinate information sharing, operate working groups,
organise meetings and conferences, and run training courses; and
(2) access to project-based grant-aid, to support projects and provide local authorities
with the financial means to allocate staff to prevention projects.
The benefits of providing the two elements of LAPN are considerable – (1) a network of trained,
motivated and professional prevention officers providing services and advice to their own organisations,
local business and communities on waste prevention and environmental sustainability, and (2) senior
local authority management interested and engaged in waste prevention.
Prevention and Business Development Officers should continue to be empowered to assist local
business, industry and public sector organisations to develop preventive approaches to all their activities
as well as promoting waste prevention in their local communities. Prevention officers should also be
empowered to form internal green teams with relevant colleagues to ensure that local authorities’ own
internal activities and practices demonstrate best environmental practice in relation to prevention of
hazardous waste in particular.
60 | 4.5 Potential for all-island co-operation

The industrial profile and consumption patterns in Northern Ireland are not markedly different to those
in the Republic of Ireland, though some key differences exist. The potential for cross-border initiatives
in hazardous waste prevention was a recommendation in the previous plan. This recommendation is
still valid in that the DECLG should seek to establish, with the appropriate Northern Ireland authorities,
a North-South co-operative group working on hazardous waste issues.
Northern Ireland authorities have, for example, expressed interest in replicating the Green Home
programme in their jurisdiction. The production of benchmarking data, sectoral studies and household
hazardous waste prevention guides may have relevance in both jurisdictions and common issues should
be identified and communicated, thus ensuring that enterprises and individuals north and south have
access to the best available information, guidance and tools.
Unreported hazardous waste
5. Unreported hazardous waste

The previous plan attempted to illustrate the potential scale of unreported hazardous waste and
indicated that, in 2006, an estimated 29,888 tonnes of hazardous waste were potentially classified
as unreported (10% of the volume managed). Some improved data are presented in Appendix F
including updated estimates but definitive estimates are elusive or difficult to quantify. The issue of
unreported hazardous waste should continue to be addressed during the implementation period of
this revised Plan. The problem of unreported waste can be exacerbated by a lack of collection facilities
for hazardous waste from a diverse range of sources, mostly small scale, including households, small
businesses and farms. The challenge and particular priority for the revised Plan is to maximise the
collection of hazardous waste. The solution to this problem is centred on providing comprehensive
collection services and infrastructure, supported for some waste streams by producer responsibility
obligations where considered feasible. The availability of these services and facilities needs to be widely
and systematically publicised. There must also be consistent inspection of hazardous waste producers/
holders and appropriate enforcement actions taken, as necessary. The objective is to ensure that a high
proportion of hazardous waste and its appropriate management are duly reported. The remainder of
this chapter outlines some options for implementing solutions.
5.1 The current situation

Any generator or holder of hazardous waste has four main legal choices of service at present, depending
on the scale and nature of the waste generated: | 61
➤➤ commercial hazardous waste collection (at source), mainly serving industrial and certain commercial
customers, where waste is taken to a treatment facility in Ireland, is directly exported or is stored
temporarily at an authorised transfer station;
➤➤ civic amenity sites, designed to accept small quantities of waste from householders and, in limited
circumstances, small businesses;
➤➤ retail take-back, limited at present largely to waste electrical and electronic equipment (WEEE),
batteries/accumulators and End-of-Life Vehicles (the latter in the form of free deposit at authorised
treatment facilities); and,
➤➤ mobile and periodic drop-off services provided by local authorities or compliance bodies (e.g.
WEEE, batteries, farm plastics) and serving communities on an occasional basis.
5.1.1 Commercial hazardous waste collection

The private hazardous waste industry plays a key role in serving Irish industry and commerce. It enables
the proper movement, off-site treatment and/or preparation of hazardous waste for export and is
available at commercial cost to industry. However, this full commercial cost is often prohibitive to smaller
industry and commerce, especially where smaller quantities of hazardous waste are generated - often
infrequently - and unit costs are very high. There is a need to provide for the collection of small quantities
of hazardous waste from businesses, farmers, and commercial and public sector organisations that are
not currently served, for whatever reason, by existing commercial services.
5.1.2 Civic amenity sites (recycling centres)
A network of 113 civic amenity sites was operated by local authorities and the private sector in 2011. All
34 local authority areas are served by at least one facility that will accept WEEE with 43 also accepting
waste batteries and waste oils, 41 also accepting waste paints/varnish and 17 also accepting general
household hazardous waste. For other household hazardous wastes, a deposit service is not generally
available. Most of the facilities do not accept similar hazardous waste from small businesses, despite
the fact that the nature and quantity of the waste is more or less the same as that of household
hazardous waste. There is a need to develop this static collection network, where feasible, to ensure
that householders and small businesses can dispose of a full range of hazardous wastes. Apart from
waste supported by compliance schemes, there may be a case for levying a charge for such services.
It should be noted that national regulations70 allow household hazardous waste to be accepted under
a Certificate of Registration for storage at a civic amenity facility, recycling centre or central collection
point pending onward transport and submission to recovery at an authorised facility.
5.1.3 Retail take-back
Retail take-back is a useful method of collecting small quantities of hazardous waste from the public.
Retailers will generally, and understandably, provide this service only when legally obliged to do so. At
present, retail take-back obligations exist solely for WEEE and waste batteries. The model for WEEE has
worked especially well to date, and suggestions for its replication for a range of hazardous wastes are
62 | further detailed below. Some pharmacists will take back unused medicines, and the HSE has funded
unused medicine take-back schemes in several areas in partnership with the relevant local authorities.
However, there is no legal obligation on pharmacists to take back medicines and this means the service,
although well subscribed by the public, is not widely available. In 2011, the Pharmaceutical Society of
Ireland established guidelines71 on the sourcing, storage and disposal of medicinal products within a
retail pharmacy business to facilitate compliance with the Regulation of Retail Pharmacy Businesses
Regulations 2008. Section 3.1.6 of the guidelines on patient counselling outlines that patients should
be facilitated and encouraged to return unwanted or expired medicinal products to the pharmacy for
disposal.72 Furthermore, pharmacists should inform patients that it is not appropriate to dispose of
waste medicinal products in their household waste or through the mains water drainage system.
5.1.4 Mobile collection services
A contract mobile collection service has been availed of by local authorities for use by the public. In
2011, 71 tonnes of hazardous waste was reported as being collected (the largest waste streams collected
being waste paint and varnish, household hazardous waste). The service typically involves a hazardous
waste collection vehicle parking in a public place, such as a shopping centre car park, for a period of
some hours, and accepting hazardous waste from members of the public. The service is advertised
locally in advance. This is an expensive service for local authorities to provide, but it engenders publicity
and awareness of hazardous waste collection and is a useful complement to permanently available
static facilities such as civic amenity sites.
70 Class No. 1 of Third Schedule: Part II of Waste Management (Facility Permit And Registration) (Amendment) Regulations
2008
71 Available at http://www.thepsi.ie/Libraries/Publications/Guidelines_on_the_Sourcing_Storage_and_Disposal_of_
Medicinal_Products.sflb.ashx
72 See also EU Guidelines of 7 March 2013 on Good Distribution Practice of Medicinal Products for Human Use (2013/C
68/01).
Special collection events have also been undertaken by the compliance bodies for WEEE/Batteries
(WEEE Ireland and ERP Ireland) and for farm plastics including triple-rinsed pesticide containers (Farm
Plastics Recycling Ltd in partnership with the Irish Farm Films Producers’ Group (IFFPG)) throughout the
country. In 2011, 250 events73 were held by WEEE Ireland (3,241 tonnes collected) and by ERP Ireland
(404 tonnes collected) and up to 200 events per year are conducted by IFFPG (15 and 17.5 tonnes
collected in 2010 and 2011, respectively).
In summer of 2013, IFFPG, ERP Ireland and WEEE Ireland operated a pilot co-collection service for
farmers across the country. Farmers were able to bring WEEE and batteries with their farm plastics for
recycling.
5.2 Recommendations for the improved collection of

hazardous waste
Similar to the previous plan, solutions are recommended below that focus on the small-scale hazardous
waste streams that arise at small businesses, households, farms, local healthcare services and other
sources. Other hazardous waste streams not specifically identified below may also need to be addressed
via one or more of the identified routes. To improve collection of unreported hazardous waste, funding
via producer responsibility initiatives should be considered where feasible, in order to support civic
amenity and mobile collection services, in addition to guidance and awareness activities. It should be
noted that producers of hazardous waste have legal obligations to ensure the proper management of
hazardous waste. | 63
5.2.1 Commercial collection at source
As discussed above, hazardous waste collection services are provided at source by an existing network
of brokers, hauliers and transfer stations. The waste industry is operating in a competitive environment
and therefore focuses only on waste streams that offer a commercial return. However, there are
situations where the collection of small-scale unreported hazardous waste is best done by commercial
services offered at source. Policy, economic or enforcement drivers will be required to ensure that this
happens. The following sources of hazardous waste continue to be priorities for action:
➤➤ garages and other locations where vehicles are serviced or dismantled;
➤➤ farms;
➤➤ ports and harbours; and
➤➤ healthcare risk waste from individual households.
It is also considered that opportunities for improved hazardous waste management exist to facilitate
local or sectoral industry to act co-operatively in their management of hazardous waste and engagement
with the waste industry. Other sectors are dealt with in a more general manner in Section 5.2.1.6.
73 Special events include inter alia: special collections days, events and island collections.
5.2.1.1 Garages and other vehicle service and dismantling locations74
Waste oils from the servicing of vehicles are currently collected from the majority of garages, although
in winter the unauthorised combustion of waste oil in space heaters is reported to be significant and a
growing problem. The supply of cleaning solvent and associated equipment for cleaning machine or
engine parts and spray guns, and the collection of spent solvent, is also a readily available commercial
service. Although services are available for other hazardous waste streams such as oil filters, lead acid
batteries and cleaning rags, these may not always enter the permitted hazardous waste management
routes. The key to improved hazardous waste management at garages is continued information and
awareness, and enforcement.
Guidance & Awareness - Smart Garage Guide
In 2010, the EPA published the Smart Garage Guide which is

aimed at promoting best environmental practice in garages.
It outlines the different ways in which operators can save
resources and money through making small changes in their
day to day operations including in areas such as hazardous
waste management.
64 |
5.2.1.2 Farms
An affordable and accessible farm waste collection system is necessary for a range of farm hazardous
wastes including animal and plant protection product containers, unused or out-of-date animal health
medicines and pesticides, waste oils, oil filters, empty cartridges (e.g. grease guns), aerosols, WEEE,
paints, batteries and other hazardous farm wastes.
A farm hazardous waste collection pilot project to inform such a collection system was carried out
in November 2013, which focused on the collection of hazardous farm wastes such as animal and
plant protection product containers, unused or out-of-date animal health medicines and pesticides,
waste oils, oil filters, empty cartridges (e.g. grease guns), aerosols, WEEE, paints, batteries and other
74 This sector is well served by several commercial waste collectors and treatment facilities.
hazardous farm wastes75. The project, involving six bring centres, was a collaborative effort between
the EPA, Pesticide Control Division of Department of Agriculture, Food and the Marine, Teagasc, six
local authorities, Rilta Environmental Ltd (a hazardous waste contractor), WEEE Ireland and European
Recycling Platform Ireland (ERP Ireland). The aim of the joint initiative was to research the need for
a national farm hazardous waste collection scheme; characterise farm hazardous waste; identify and
estimate types and quantities of de-regulated pesticides remaining on farms; pool resources and
collective expertise between the various agencies and departments, facilitate the removal of hazardous
wastes from farms and ensure their recovery/disposal is managed in accordance with national and
European waste legislation. The pilot project was very successful in terms of the positive uptake from
the farming community and ultimately removing hazardous waste from farms, with an estimated
94,472 kg of farm hazardous waste and 22,228 kg of WEEE and batteries collected at the six pilot
bring centres.
As outlined previously, a pilot co-collection project took place with IFFPG and the two WEEE compliance
schemes during the summer of 2013, and the feedback on the success of these initiatives should inform
any future initiatives.
National regulations76 provide for the return of unused or expired animal remedies to the point of
purchase. However, there may be legislative barriers such as waste licensing requirements that may
discourage such take-back. Teagasc in association with Veterinary Ireland has prepared a booklet77
for farmers on the safe use of livestock medicines for cattle and sheep farms, including disposal of
medicines/materials. | 65
Recent enacted legislation concerning the sustainable use of pesticides78 includes new requirements
concerning retailers and distributors, the use of pesticides by professionals and amateurs, registration,
inspections, record keeping, and training and awareness on their correct use and application.
5.2.1.3 Ports and harbours
The European Communities (Port Reception Facilities for Ship-generated Waste and Cargo Residues)
Regulations, S.I. No. 117 of 2003, oblige harbour masters and port authorities to prepare waste
management plans for the management of ship-generated waste and cargo residues at Irish ports
and harbours. There should be continued information and awareness and enforcement to ensure
appropriate hazardous waste management at ports and harbours.
5.2.1.4 Healthcare risk waste from small sources
Considerable efforts are on-going on the part of the Health Service Executive (HSE) to ensure that
healthcare non-risk waste and healthcare risk waste are properly managed in a cost-effective manner.
The Green Healthcare Programme (www.greenhealthcare.ie) which became fully operational in 2010
is an initiative by the EPA under the National Waste Prevention Programme and aims to prevent waste
and reduce costs. As the HSE is the largest public service in the State, there is scope to disseminate the
information and guidance from the Green Healthcare Programme to all HSE employees, as appropriate.
This forms a recommendation in this revised Plan.
75 Interim report available at http://www.epa.ie/pubs/reports/waste/haz/

pilotfarmhazardouswastebringcentresin2013interimreport.html
76 European Communities (Animal Remedies) (No. 2) Regulations, S.I. No. 786 of 2007
77 Available at http://www.teagasc.ie/publications/2003/vetleaflet.pdf
78 European Communities (Sustainable Use of Pesticides) Regulations, S.I. No. 155 of 2012
There still remain issues that have been identified in relation to the management of small quantities
of healthcare risk waste, arising particularly through self-administration of medicines and healthcare
procedures carried out in the home. The HSE should continue to ensure that adequate and suitable
systems are in place to manage healthcare waste generated within HSE facilities and services for which
the HSE is responsible. There may still be a case for a producer responsibility initiative in this area (and
consideration should be given in the context of the recently established review of existing producer
responsibility initiatives) whereby producers of medical products facilitate safe take-back of used
materials, where possible, including from self-administering patients in the home.
5.2.1.5 Industrial estates and commercial clusters
As mentioned in Section 4.4.3, many local authorities have been grant-aided via the Local Authority
Prevention Network (LAPN) to demonstrate prevention and resource efficiency in their own offices, in
airports, shopping centres, communities, farms, construction sites and local businesses. Considerable
efforts have been made in recent years by LAPN in relation to the prevention and correct management
of hazardous waste. Local authorities should continue to work with local industry and commerce
(whether on a geographical or a sectoral basis) to seek commercially favourable hazardous waste
collection solutions for industry. There may be opportunities at the planning stage for new commercial
or industrial areas to provide centralised or co-ordinated approaches to waste and particularly hazardous
waste management. Local authority Business Development Officers should be empowered to assist
66 | industries to club together to create networks and get collective deals on waste services to the benefit
of all parties, generator and service provider alike.
5.2.1.6 Other sectors
A large number of other sectors (e.g. construction, industrial, retail, private healthcare) are sources of
unreported hazardous waste and predominantly use commercial waste companies to collect hazardous
waste at source. Local authorities should focus enforcement efforts to ensure that all generators of
hazardous waste are managing hazardous waste in accordance with their statutory obligations. The
Network for Ireland’s Environmental Compliance and Enforcement (NIECE) may be an appropriate
means of co-ordinating concerted actions, procedures and protocols.
5.2.2 Civic amenity sites and recycling centres

As outlined previously, 0.43 kg of household hazardous waste per capita was collected in 2011. This has
increased from 0.16 kg per capita in 2006, which demonstrates a significant improvement in collection
rates during the previous plan period and measures that local authorities have taken to provide collection
facilities for household hazardous waste.
Local authorities should be adequately resourced by the DECLG to provide directly or via private
enterprise for the collection of a full range of hazardous waste at civic amenity sites from households
and small local businesses in their functional areas where this is considered feasible. It is recognised that
resources are lacking, however finance could be raised from producer responsibility initiatives and other
policy initiatives (e.g. export levy) to help pay for this infrastructure.
In recent times conditions have been included in waste licences (e.g. Corranure Landfill, Licence
no. W0077-04) whereby hazardous waste of a similar nature to household hazardous waste may
be accepted at the civic amenity facility from business customers and other non-household sources,
including farms.
Small businesses could be charged equitable not-for-profit rates for this service. To avoid abuse,
businesses could be subject to caps or quotas on the amount of hazardous waste that can be deposited
per company in a defined period79. Misuse of this service could be made an offence under potentially
revised hazardous waste regulations, and this should be kept under review. Innovative means of
facilitating business use and payment, for example through pre-registration of waste delivery via a
secure internet site, could minimise abuse of the service while making the service convenient and
economical for businesses and allowing them to track their own deposits.
The EPA is progressing the development of a code of practice/guidance document on the minimum
operational and environmental standards for accepting hazardous waste at civic amenity sites and on
the types of hazardous waste that a civic amenity site would be expected to accept.
As part of the development of the code of practice/guidance, the EPA sponsored a pilot training course
for civic amenity site staff. The code of practice/guidance document will be completed in the near
future and disseminated to local authorities and civic amenity operators.
| 67
Collective approach by local authorities
There is now an opportunity for the recently configured three waste management regions to plan
for the provision of civic amenity site services to householders and businesses where deficiencies are
identified. The role of planning authorities is also important. Planning authorities and An Bord Pleanala
are required to ensure that such measures as are reasonably necessary are taken to secure appropriate
provision for the management of waste within developments, including the provision of facilities for the
storage, separation and collection of such waste.80
A certain level of consistency in services from civic amenity sites, particularly to businesses, is considered
desirable. Sharing of information within a region (e.g. through shared on-line pre-registration services)
on business use of facilities could minimise businesses “shopping around” civic amenity sites. Collective
tendering by local authorities for contracts to manage the deposited waste from several civic amenity
sites would reduce unit costs to local authorities and service providers alike.
79 The reason for this proposal is to ensure that businesses that generate large quantities of hazardous waste only use
commercial collection sources and do not overburden the local authority system.
80 Section 26 of Protection of the Environmental Act 2003 amends the Waste Management Act (WMA) 1996 by inserting
this requirement under Section 22 (10D) of the WMA 1996.
Asbestos
There is still a lack of appropriate facilities for the acceptance of waste asbestos in Ireland. This revised
Plan continues to recommend that a network of collection and transfer facilities be established to
capture the small-scale arisings from DIY and small contracting jobs. Without such facilities, substantial
quantities of asbestos waste may be managed illegally, due to either ignorance of legal obligations or
the high cost of employing specialist contractors for small jobs.
Consideration should be given for local authorities to be resourced and then directed by the DECLG
to provide at least one transfer station or other appropriate facility for small quantities of asbestos in
each local authority area. A possible solution is to use the existing civic amenity site network, wherever
suitable. Where local authority-owned sites are not available or suitable, it may be possible for local
authorities to contract authorised private sector waste facilities to accept asbestos on their behalf. The
development of this network would be expected to provide reassurance that there is no reason for
illegal or “backyard” disposal or accumulation of asbestos. This issue should be taken into account
during the development of the replacement regional waste management plans.
Existing guidance on asbestos is available at: http://www.epa.ie/waste/hazardous/asbestos.
Information to householders and small businesses

68 |
In 2010 an information booklet on household hazardous waste was prepared by the Regional Waste
Management Office (RWMO) for Limerick, Clare and Kerry and contains tips and advice for householders
on the correct use and disposal of everyday hazardous household waste. This booklet is available at:
http://www.epa.ie/pubs/reports/waste/wpp/ahouseholdersguidetohazardouswasteprevention.html
Legislative requirements to ensure hazardous household waste is not mixed with non-hazardous
household waste are a driver for improved management of household hazardous waste. For example,
in July 2013, Dublin City Council introduced byelaws81 that include a requirement to exclude hazardous
waste from household waste collections and to dispose of it at an approved facility.
Householders and small businesses should continue to be informed through ongoing information
campaigns, conducted by or on behalf of local authorities, of the hazardous waste collection services
available in their areas.
Practical guidelines on the segregation and storage of hazardous waste at households and business
should be provided. Central co-ordination of information campaigns, particularly the use of social
media (e.g. Twitter, Facebook), may be appropriate. Finance could be raised from producer responsibility
initiatives to help pay for information campaigns.
81 Dublin City Council (Storage, Presentation and Collection of Household and Commercial Waste) Bye Laws 2013
Recycling Centre / Civic Amenity Centre Information
Repak has developed a search facility and mobile phone app to help you find out where your
local recycling facility including facilities that accept household hazardous waste is located.
| 69
Source: www.repak.ie
Mobile collection services for householders
Local authorities should continue to avail of contract mobile collection services, where available, both
to raise awareness about household hazardous waste and to fill geographical gaps in static facilities’
service provision, and should be considered in the context of geographical areas that are remote or
distant from civic amenity sites. Mobile collection services can be used to highlight seasonal wastes, for
example the collection of surplus garden chemicals or lawnmower waste oils at the beginning or end
of summer. Mobile collection services are expensive, and should only be deployed strategically to meet
specific needs and objectives. They should not be considered solely as an alternative to a permanent
civic amenity site accepting a full range of household and similar hazardous waste.
Implementation timetable
Public authorities should continue to progress the development of a comprehensive hazardous waste
collection network and information awareness for householders and small business within the lifetime
of this revised Plan, i.e. over the next six years. Public authorities should continue to progress the
implementation of the recommendations outlined in this section (see also Chapter 8) and provide
information to the EPA at regular intervals on progress on their implementation during the revised Plan
period.
5.2.3 Producer responsibility and retailer take-back
Producer responsibility is based on the principle that producers82 of products take financial responsibility
for the collection and management of their products at end-of-life. It is an economic means for
producers to maximise the collection and recovery of products at their end-of-life. It can also lead to
better life-cycle management of hazardous materials. Producer responsibility obligations have become
a mandatory requirement for a number of waste and hazardous waste streams - packaging waste, farm
plastics, WEEE, end-of-life vehicles and batteries - see Table 18. Both packaging and WEEE collection
and recycling rates have increased as a result of the respective producer responsibility initiatives. The
collection of WEEE and waste batteries has been particularly successful in a very short time for many
reasons, not least of which is the free take-back obligation imposed on retailers.
Table 18 Existing producer responsibility obligations for hazardous waste
Material Collection route(s) Funding model
Waste electrical and electronic Retail/producer take-back or no- Collection and recycling costs
equipment (WEEE) (introduced less-convenient alternative to be borne by producers
2005)
Civic amenity sites
End-of-life vehicles (introduced Free-of-charge delivery at Producers are ultimately liable

2006) authorised treatment facilities for full cost of treatment
70 |
(ATFs)
Animal remedies (introduced 2005) Retail (veterinary/pharmacy/co- None established

op) take-back
Batteries Retail take-back Collection and recycling costs

(introduced September 2008) to be borne by producers
Civic amenity sites
Proposed models of producer responsibility vary depending on the waste stream and the purpose
of imposing the obligation. In certain cases the waste stream may be prohibitively expensive for
local authorities to manage at civic amenity sites. Alternatively, retail take-back as part of producer
responsibility may be an appropriate means of improving collection rates. Some particular advantages
of retail take-back include:
➤➤ Potential for high public participation and awareness rates due to the frequent use of retail
outlets;
➤➤ a new-for-old pattern of consumption could become the norm;
➤➤ deposit-refund mechanisms are suited to retail take-back models and may be suitable for
some materials;
➤➤ additional car-based trips to civic amenity sites can be avoided;
➤➤ producers and industry can employ reverse logistics in the retail supply chain83; and
82 Generally defined in producer responsibility legislation as manufacturers or importers – being the persons who place
goods on the Irish market at the top of the supply chain.
83 Reverse logistics means transporting end-of-life goods on vehicles on their return journey after they have delivered new
goods to the retailer.
➤➤ producers take full responsibility for the waste, in theory stimulating redesign of products,
packaging and supply chains to minimise costs to producers and customers, thus reducing
environmental impacts.
However, not all hazardous wastes are suited to retail take-back. For example, liquid hazardous wastes
or hazardous waste in powder form could present a risk to retail staff and consumers. Retail take-
back obligations must take account of health, safety and environmental concerns in the storage and
management of hazardous waste in retail outlets, particularly small outlets.
The previous plan recommended the consideration of producer responsibility obligations for several
additional hazardous waste streams, including the following:
➤➤ Human medicines
➤➤ Farm animal medicines
➤➤ Waste oil
➤➤ Oil filters
➤➤ Paint and paint containers
➤➤ Pesticides and herbicides (household)
➤➤ Ink and ink containers from publishing

| 71
In 2012 the DECLG commenced a wide ranging review of existing producer responsibility agreements
currently in operation in Ireland which is also examining the feasibility of the introduction of additional
producer responsibility initiatives for waste streams, including hazardous wastes. The review is required to
have particular regard to those waste streams recommended in the previous National Hazardous Waste
Management Plan (2008-2012) as suitable for further evaluation as possible producer responsibility
initiatives. The report of this review is expected to be published in 2014.
This revised Plan recommends that the DECLG complete the examination of potential producer
responsibility obligations concerning the above hazardous waste streams and progress the establishment
of producer responsibility initiatives for such waste streams, where feasible. In particular there is a need
for a nationwide take-back scheme for unused or expired human medicines considering the widespread
consumption of medicines, the likely uptake of this service (refer to Section 5.1.3) and the potential for
the prevention of environmental pollution. Industry buy-in will be important for the success of producer
responsibility initiatives, and producers should be involved at an early stage in any new initiatives.
With changes in EU directives (new WEEE Recast) and associated targets, it is likely that the producer
responsibility landscape will be more complex in the future and compliance schemes will need to
work more closely together and examine synergies to help achieve overarching national objectives.
Future arrangements with compliance schemes will be focusing on corporate governance, flexibility
and cooperation to respond to new policy direction and operational instructions, which could have
relevance in the future in terms of hazardous waste.
A producer responsibility initiative in an area such as hazardous farm wastes could be funded by levies
on producers and/or importers of relevant products that generate the hazardous wastes. The service
could comprise a network of mobile and/or static facilities at convenient locations such as co-ops,
marts, and civic amenity sites. Expansion of the existing farm plastics recycling scheme could also
provide such a mechanism. This would in effect offer the farming community a one-stop-shop to
manage a range of hazardous wastes helping to promote more sustainable farming in Ireland. The
feedback of the success of the current pilot co-collection project that took place with IFFPG and the two
WEEE compliance schemes during the summer of 2013 in addition to the above-mentioned pilot project
on farm hazardous waste collection should be used to inform any potential producer responsibility
initiative in this area.
72 |
Treatment of hazardous waste
6. Treatment of hazardous waste

The treatment84 of Irish hazardous waste generally takes place under regulated and controlled
conditions. Currently almost half of this treatment takes place abroad, in other EU Member States for
the most part. The EU Waste Framework Directive requires that a policy of national self-sufficiency in
disposal installations be adopted by Member States where this is possible on the grounds of strategic
need and conformance with the proximity principle. Hazardous waste destined for recovery is subject
to an open and competitive waste market in the EU (i.e., not subject to the Proximity Principle85). This
chapter sets out options for the provision of hazardous waste treatment services in Ireland in order to
reduce exports.
It should be noted that it is not the intention of this revised Plan to nominate specific technologies to
be employed for treating specific wastes. Specific technologies are however identified and discussed
in this chapter. The promotion of some technologies (namely combustion in cement kilns and landfill
(of certain wastes where no other option is available)) should be facilitated in the interest of reducing
exports by using existing infrastructure, provided they can be correctly operated to protect human
health and the environment. However, more than one treatment option is usually available for a given
waste stream, and no realistic proposal for hazardous waste treatment in Ireland should be excluded
on foot of this revised Plan. Any proposal will of course require a waste licence or permit before
operations can begin, and this will ensure that operational facilities operate in a manner that represents
BAT86 and will not cause environmental pollution. Preparation of regional waste management plans
should consider treatment options that are highlighted in this Plan and take measures to plan for such | 73
treatment, where considered strategically advisable, and economically and technically feasible, in order
to help improve Ireland’s self-sufficiency in hazardous waste treatment.
6.1 The current situation

Almost half (47%) of Irish hazardous waste (not including contaminated soil) was exported for
treatment abroad in 2011. Some 22% was treated on-site of generation, for the most part at IPPC-
licensed facilities. The remaining 31% was treated at authorised hazardous waste facilities in Ireland.
Figure 1 shows the trend in the location of hazardous waste treatment since 2006. The figure shows
no significant change in the volumes treated on site of generation at commercial facilities in Ireland over
the years. Export trends show an overall increase in hazardous waste treatment.
Table 19 shows the headline treatment techniques used for Irish hazardous waste – both in Ireland and
abroad for the years 2008 and 2011. The data show that thermal treatment technologies, incineration
and use as fuel, dominate the export column. Solvent recycling is also important, as is metal recovery.
84 “Treatment” means recovery or disposal operations, including preparation prior to recovery or disposal (EU Waste
Framework Directive 2008/98/EC).
85 Please refer to Article 16 of EU Waste Framework Directive 2008/98/EC.
86 BAT means “best available technique” and forms the basis for EPA licensing of facilities. Techniques or technologies
must meet BAT criteria published periodically by the EPA.
Table 19 Comparison of treatment technologies employed for Irish hazardous waste 87
Hazardous waste treatment 2008 2011

category or technology87
Treated in Treated Treated in Treated
Ireland (t) abroad (t) Ireland (t) abroad (t)
Incineration (D10) 20,897 on-site 40,505 12,615 on-site 35,569
Use as fuel (R1) 12,312 on-site 21,714 11,012 on-site 28,182

23,986 off-site
Solvent recycling (R2) 23,506 on-site 33,078 21,770 on-site 19,746

7,374 off-site 27,978 off-site
Metal recovery (R4) 1,727 off-site 23,760 369 off-site 28,702
Physico-chemical treatment 322 on-site 1,792 122 on-site 966

(D9) 27,131 off-site 25,929 off-site
Landfill (D1, D5) 12,559 on-site 21,992 20,079 on-site 7,975

7,462 off-site
Inorganic material recovery (R5) 6,030 off-site 2,596 5,842 off-site 4,426
Acid/base regeneration (R6) 0 1,543 0 1,014

74 |
Organic substance recovery (non- 379 on-site 6,618 294 on-site 8,187
solvent) (R3) 13,562 off-site 61 off-site
Oil recovery (R9) 250 on-site 0 180 on-site 233

Other (e.g., D8, D13/R12) 1,813 on-site 3,609 1,700 on-site 14,037
4,531 off-site
72,038 on-site 67,772 on-site

Totals 185,877 total 157,207 166,610 total 149,037
343,084 315,647
Table 20 builds on this data and provides an overview of the principal waste types exported for the
various treatment options. It is likely that some hazardous waste that is exported could be treated,
or at least pre-treated, at existing indigenous facilities – for example solvents, electrical equipment,
photochemicals, acid/alkali waste (subject to licence and waste acceptance restrictions at existing
facilities). Increasing quantities of Irish waste are exported for use as fuel. This predominantly means
the combustion of waste solvent in cement kilns or other combustion plant. Cement kilns currently in
operation in the Republic of Ireland (4) and Northern Ireland (2) could potentially use certain hazardous
wastes as a fuel substitute for fossil fuels. One kiln has recently commenced using solvent wastes for
this purpose, having had its IPPC licence amended to permit the change. Not all operations would
necessarily be suitable or available to use waste as fuel.
87 Refer to Annexes I and II of EU Waste Framework Directive 2008/98/EC for disposal and recovery operations.
Table 20 List of dominant waste streams exported for various treatment techniques
Hazardous waste 2009 2010 2011

treatment category or
technology Principal waste Principal waste Principal waste types
types exported types exported exported
Incineration (D10) Aqueous washing Chemical waste Aqueous washing liquids and
liquids and mother (20%) mother liquors (12%)
liquors (29%)
Solvents (20%) Aqueous washing Solvents (25%)

liquids and mother
liquors (33%)
Halogenated solvents Solvents (20%) Halogenated solvents (13%)

(12%)
Other industrial waste Solid wastes Other industrial waste (21%)

(21%) 1 containing
dangerous
substances (11%)
Paint, Ink & Varnish Solid wastes containing

(5%) dangerous substances (13%)
| 75
Chemical waste (22%) Packaging Chemical waste (22%)
(contaminates 2%)
Use as fuel (R1) Solvents (98%) Solvents (86%) Solvents (81%)
Other industrial waste Aqueous washing Aqueous washing liquids and

(2%) liquids and mother mother liquors (13%)
liquors (8%)
Paint, ink, varnish

waste (4%)
Solvent recycling (R2) Solvents (95%) Solvents (93%) Solvents (95%)
Paint, ink and varnish Halogenated Halogenated solvents (5%)

(1%) solvents (6%)
Other industrial waste

(1%)
Metal recovery (R4) Batteries (63%) Batteries (lead-acid, Batteries (lead-acid, vehicle
vehicle 59%) 52%)
Other industrial waste Equipment Other industrial waste (4%)

(6%) (electrical,
electronic,
mechanical 29%)
Equipment (electrical, Chemical waste Equipment (electrical,

electronic, mechanical (2%) electronic, mechanical 37%)
28%)
Sludges and filter

cakes (3%)
cont’d
cont’d
Hazardous waste 2009 2010 2011

treatment category or
technology Principal waste Principal waste Principal waste types
types exported types exported exported
Physico-chemical Acid / Alkali waste Sludges and filter Sludges and filter cakes
treatment (D9) (47%) cakes (51%) (43%)
Paint, ink & varnish Paint, ink & varnish Thermal treatment and
(32%) (32%) combustion residues (22%)
Other industrial Acids and alkaline Acids and alkaline waste

waste (12%) waste (11%) (16%)
Absorbents, wiping cloths

etc. (12%)
Landfill (D1, D5) Asbestos (93%) Asbestos (99%) Asbestos (76%)
Sludges and filter Construction and Other industrial waste (11%)

cakes (6%) demolition waste
(<1%)
Inorganic material Equipment (electrical, Equipment Thermal treatment and

recovery (R5) electronic, mechanical (electrical, combustion residues (39%)
76 | 33%) electronic,
mechanical 31%)
Construction and Other industrial Equipment (electrical,

demolition waste waste (27%) electronic, mechanical 29%)
(27%)
Other industrial waste Construction and Other industrial waste (16%)

(29%) Demolition waste
(26%)
Sludges and filter Batteries (lead acid, 11%)

cakes (12%)
Acid/base regeneration Acid and alkali waste Acid and alkali Acid and alkali waste (87%)
(R6) (100%) waste (87%)
Chemical waste Chemical waste (13%)

(8%)
Organic substance Construction and Construction and Construction and demolition

recovery (R3) demolition waste demolition waste waste (74%)
(77%) (99%)
Paint, ink & varnish Equipment (electrical,

(10%) electronic, mechanical 18%)
Equipment (electrical, Solvents (4%)

electronic, mechanical
9%)
1
This is principally process waste from the pharmachem sector.
6.1.1 Hazardous Waste Projections
In terms of projections of hazardous waste generation, Curtis et al (2009) 88 provide a summary of

ISus baseline scenario projections for waste generation including for hazardous waste generation.
Projections up to 2025-2030 for hazardous waste generation are presented in Table 21. The study
indicates that with a projection of increased levels of hazardous waste in the future the sustainability
associated with shipping these materials abroad for treatment needs to be reassessed.
Table 21 Waste arisings as observed and projected for hazardous waste
2010 2010- 2015- 2020- 2025- 2010- 2015- 2020- 2025-

2015 2020 2025 2030 2015 2020 2025 2030
Baseline projection Baseline projection
Million tonnes per year Change per year, %
0.29 0.32 0.43 0.53 0.62 6.6 5 3.3 3.3
6.2 Self-sufficiency versus export of hazardous waste

The data above show that significant quantities of hazardous waste are exported for treatment to
other European countries. Broadly speaking, this export of waste takes place in a currently stable | 77
marketplace. Article 16 (1) of the Waste Framework Directive (2008/98/EC) states that:
“Member States shall take appropriate measures, in cooperation with other Member
States where this is necessary or advisable, to establish an integrated and adequate
network of waste disposal installations…taking into account best available techniques.”
Given this principle established in European law, and considering the data presented in Section 6.1, it
is recommended that Ireland should strive for greater self-sufficiency in hazardous waste management
where it is strategically advisable and where it is technically89 and economically90 feasible.
This recommendation is in line with several objectives. It recognises the proximity principle established
in the Waste Framework Directive (see above) and it seeks to maximise the re-use and recovery
potential of, for example, materials, precious metal and secondary fuels, through provision of a range
of local treatment options where practical. There are ancillary environmental benefits deriving from
self-sufficiency. Firstly international transport of hazardous waste is minimised (eliminating associated
risks, and avoiding transport related greenhouse gas emissions). Secondly, it increases availability of
recovery and disposal outlets for hazardous waste if problems arise in the export agreements for
hazardous treatment in other Member States. However, it is recognised that hazardous waste destined
for recovery is subject to an open and competitive waste market in the EU, and Ireland is also unlikely to
achieve complete self-sufficiency given the range of specialist treatments that are required for certain
hazardous waste streams. Indeed, Article 16 (4) of the Waste Framework Directive (2008/98) states
that:
88 Curtis, J., Pentecost, A., Lyons, S., Morgenroth, E., di Cosmo, V. (2009) Towards a Green Net National Product for Ireland.
STRIVE Report Series No.103
89 Technical feasibility means that a project must be able to obtain a waste licence and other relevant authorisations to
proceed. It must therefore meet or exceed BAT (best available technique) and must be efficacious in the treatment of
waste while not causing environmental pollution.
90 Economic feasibility means that a project must provide an economic return.
“The principles of proximity and self-sufficiency shall not mean that each Member State
has to possess the full range of final recovery facilities within that Member State”
Policies of enforced self-sufficiency have been abandoned in other Member States as a result of pressures
exerted by the open and competitive waste market in the European Union. The recommendation to
strive for greater self-sufficiency is intended to maximise the treatment and disposal of hazardous
waste in Ireland, where strategically advisable, and economically and technically feasible, with policy,
environmental and availability-of-outlet benefits.
The export of some major categories of hazardous waste decreased in 2011 compared to 2009, as
shown in Figure 9. There was no significant change in the export of waste solvents from 2009 to 2011.
Nevertheless, there are options for the treatment of waste solvents in Ireland that are further explored
below. The decline in the reported export of asbestos waste is particularly notable. Exports decreased
by approximately 50% from a total of 14,068 tonnes in 2009 to 7,001 tonnes in 2011. This reduction
may be due to a decline in construction and demolition (C&D) activities. Similarly the reported export
of C&D waste reduced from 12,892 tonnes in 2009 to 3,236 tonnes in 2011. There was a significant
increase in the export of batteries (lead acid) from 11,832 tonnes in 2009 to 15,374 tonnes in 2011.
60000
78 | 50000 Exported 2009
40000 Exported 2011

Tonnes
30000
20000
10000
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Figure 9 Export of some major hazardous waste streams, 2009 and 2011
Based on the data presented in this chapter and in Chapter 3, three overarching strategic needs have
been identified for action if additional hazardous waste is to be treated in Ireland and export is to be
reduced:
➤➤ expansion of recovery and treatment capacity in Ireland for waste that does not need thermal
treatment or landfill – generally referred to as physico-chemical treatment – see Section 6.6;
➤➤ addressing the deficit in thermal treatment capacity in Ireland (i.e. use as fuel, co-incineration
or incineration) for Irish hazardous waste currently being exported (e.g. solvents) – see
Section 6.4; and
➤➤ securing of long-term disposal arrangements for hazardous waste streams not suitable for
thermal treatment or recovery.
It should be clearly understood that while this revised Plan can set out options and make
recommendations, based on waste data and environmental criteria, and on the need for treatment
facilities for hazardous waste (for the purpose of reducing export of hazardous waste), infrastructure is
however provided by private organisations or through public private partnerships. Consideration should
be given to co-location of hazardous waste treatment at existing waste facilities or brownfield sites for
the purposes of sustainability and land-use planning. Any proposals for hazardous waste treatment will
of course be subject to their own planning and licensing/permitting processes including the assessment
of environmental impacts.
In order to facilitate an on-going understanding of hazardous waste treatment capacity needs, the EPA
will prepare and maintain, in consultation with various stakeholders an inventory of national hazardous
waste recovery and disposal capacity.
| 79
6.3 Options proposed as alternative treatment techniques
A number of alternative treatment methods are available for several different hazardous waste streams,
including such techniques as:
o alkaline hydrolysis o advanced oxidation
o ball milling o molten slag
o base catalysed dechlorination o ‘PCB Gone’
o catalytic treatment o plasma arc technologies
o ‘Cerox’ o ‘Silver II’
o gasification o solvated electron technology
o gas-phase chemical reduction o steam detoxification
o molten metal o supercritical water oxidation
o molten salt o thermal desorption
A brief technical description of these technologies is provided in Appendix D. There are clear possibilities
for the use of some of these technologies for the treatment of hazardous waste in Ireland. The revised
Plan supports the provision of such technologies where technically and economically feasible. Some
of these alternatives are niche-market treatment options (often for such wastes as persistent organic
pollutants or chlorinated chemicals). Some are in development or have not yet been commercially
proven. In many cases, their application is technically limited and adequate supplies of waste would
be needed to justify investment. To help the development of realistic alternatives, the revised Plan
continues to support the following:
➤➤ research grants should be made available, where possible, through the EPA research
programme, or from other suitable sources, to develop hazardous waste and waste treatment
technologies from conceptual to laboratory and pilot scales; and
➤➤ supports, where possible, should be available for the commercial development of treatment
capacity.
Any proposals for alternative technologies would need to be evaluated on the basis of BAT. The potential
for increased import of hazardous waste into Ireland to supply alternative or niche processes should be
addressed by policy-makers if the need arises, taking into account BAT and potential impacts on the
environment and human health.
As alternative treatment techniques are commercially established, training and up-skilling of regulators
should be supported with the assistance of industry and associated research institutes (e.g. via
Continuous Professional Development).
6.4 Management of solvents and other wastes currently

exported for thermal treatment
For several categories of hazardous waste, thermal treatment (whether in a dedicated incinerator or in
a cement kiln) is a commonly used treatment technology. Some relevant data are summarised in Table
22. The locations of treatment (on-site, off-site or abroad) for some categories of hazardous waste are
80 | shown against the relevant treatment classification used. Data on use as fuel (R1) and incineration (D10)
are shown. For the purposes of comparison, solvent recycling (R2) is also shown.
Table 22 shows that a total of 66,973 tonnes of hazardous waste was exported for thermal treatment
(use as fuel and incineration) in 2011. Some 35,568 tonnes was exported for incineration and 31,405
tonnes for use as fuel. There is a considerable increase in waste exported for use of fuel since 2010,
when a total 17,334 tonnes was exported for similar treatment. There was a significant decrease in
the on-site incineration of hazardous waste when comparing 2011 to 2009 figures. There has been a
decrease in the treatment of “other” industrial hazardous waste, comprising aqueous-based and solid
wastes. All of these wastes are generated predominantly by the pharmachem sector. The revised Plan
period should see waste prevention from the pharmaceutical industry mainly as a result of the increased
use of water-based biotechnology in drug manufacture and reduced step/continuous loop processes
underpinned by economic incentives.
It is a recommended objective of this revised Plan to reduce export and increase indigenous (including
on-site) treatment of hazardous waste, where strategically/environmentally advisable, and economically
and technically feasible. To achieve this objective, capacity is required in accordance with the waste
hierarchy for solvent treatment in Ireland - solvent recycling (R2), use instead of fossil fuel at existing
appropriate sites (e.g. at existing pharmachem facilities, in existing cement kilns) (R1), in purpose built
incinerators (D10), and/or alternatives (as outlined in Section 6.3) as appropriate. Domestic capacity
could be provided in either of two locations: on-site of generation, or off-site at commercial facilities
in Ireland.
Table 22 Thermal treatment of waste solvents and other hazardous waste, 2009-2011 91
2009 2010 2011
On-site Off-site Export On-site Off-site Export On-site Off-site Export
Solvents (total shown, including halogenated solvents where these were specified)
Recycling 25,042 18,533 22,047 27,352 20,359 20,387 21,770 16,688 19,613
(R2) 91
Use as fuel 7,326 17,745 23,171 7,490 0 12,607 6,292 0 22,746

(R1)
Incineration 19,306 0 10,904 17,896 0 6,409 12,091 0 13,736

(D10)
Other industrial hazardous waste (mostly pharmachem sector – aqueous mother liquors, reaction
residues, solid wastes – often containing solvents but not as a principal constituent)
Use as fuel 3,273 0 586 4,159 0 237 4,720 0 458

(R1)
Incineration 3 0 7,274 3,917 0 734 2 0 1,262

(D10)
Chemical waste not otherwise specified (mostly organic and inorganic chemicals 16 05 07* and 16 05 | 81
08*)
Use as fuel 0 0 2,250 0 0 182 0 0 141

(R1)
Incineration 0 0 773 0 0 6,576 0 0 7,670

(D10)
All others (mostly waste oil, waste paint, absorbents and filter materials and contaminated packaging)
Use as fuel 0 0 5,341 0 0 4,308 0 0 8,060

(R1)
Incineration 2,069 0 15,131 338 0 18,682 521 0 12,900

(D10)
Sub-total - 10,599 17,745 31,348 11,649 0 17,334 11,012 0 31,405

Use as fuel
(R1)
Sub-total 21,378 0 34,082 22,151 0 32,401 12,614 0 35,568

Incineration
(D10)
Total (t) 31,977 17,745 65,430 33,800 0 49,735 23,626 0 66,973
(Note: Data extrapolated/estimated from National Waste Reports and associated data)
91 Solvent recycling (R2) is presented in this table not as a thermal treatment technique, but to illustrate the scale of solvent
recycling vis-à-vis thermal treatment (R1 + D10). (Note: R1 means use as fuel, i.e. recovery of heat/energy; R2 means
material recycling, e.g. by distillation; D10 means incineration).
With regard to on-site treatment of solvents, in 2011, fifteen IPPC-licensed companies employed solvent
distillation (to recycle solvents back into a process stream) or thermal treatment (to use as fuel or
dispose of solvent) – see Appendix B (Table 30). It is recommended that further opportunities for on-site
treatment of waste, particularly in the EPA licensed sector, be explored and that relevant EPA licensed
companies examine their processes for the potential to incorporate on-site solvent treatment techniques.
The promotion of this activity should be undertaken in parallel with the prevention initiatives proposed
for the pharmaceutical and chemical sector in Chapter 4.
For solvent waste that is transported off-site, there are two options: treatment in Ireland or treatment
abroad. A single waste treatment company, Soltec, is authorised to accept waste solvents for recycling
by distillation. One cement plant is licensed to burn solvent with an annual permitted capacity of 10,000
tonnes. Two facilities, Indaver Ireland, and Veolia Environmental Technical Solutions Ltd., blend waste
solvents to optimise their calorific value for subsequent use as fuel. The blended waste solvents are
currently transported abroad to cement kilns.
Overall, 36,482 tonnes of waste solvent was exported for incineration or use as fuel in 2011. This was an
increase from 34,075 tonnes in 2009. There is clearly a quantity of solvent waste that could be treated
commercially in Ireland. Subject to the application of the waste hierarchy, the options to achieve this
are as follows:
➤➤ recycling – i.e. distillation or other physico-chemical treatment resulting in a recycled solvent

suitable for re-use;
82 |
➤➤ co-incineration and energy recovery in cement kilns or electricity/heat generation facilities;
and
➤➤ incineration – i.e. combustion in dedicated incineration plant with recovery of energy.
The order of their presentation reflects the accepted waste hierarchy, namely that preference should
be given to recycling, recovery, and treating waste for disposal as close as possible to its place of
generation. The current use of the three options is reflected in Table 22.
Domestic solvent waste contractors generally operate a similar triage hierarchy for waste solvents.
Subject to the application of the waste hierarchy, waste solvent is directed to the most suitable
treatment option – recycling, use as fuel or incineration – depending on such factors as the nature of
the solvent, its level of contamination, the client’s requirements and relative costs. Waste solvents that
are unsuitable for either recycling or use as fuel are sent for incineration. It is noted that elements of
all three of these treatment options are in place in Ireland, as outlined above: (1) Considerable solvent
recycling is carried out at industrial facilities and at one commercial facility which are EPA licensed. (2)
Major solvent transfer facilities in Ireland are now equipped with solvent blending equipment. When
waste solvents are suitable for blending and for subsequent use as fuel in cement kilns, then they are
directed to this route, where the outlets are available. (3) On-site incineration is carried out at some EPA
licensed sites, and there remains a proposal for a hazardous waste incinerator at Ringaskiddy, Co. Cork.
Recycling
Authorised capacity for the recycling of solvents by distillation at one commercial facility92 (off-site of
generation) is 5,000 tonnes per annum, though less than 600 tonnes was treated in 2011. There may
be barriers to the economic feasibility of large-scale distillation or recycling of solvents in Ireland. The
principal barrier is the apparent limited market for recycled solvent in Ireland. Recycled solvent would
thus have to be exported to gain critical scale, probably to the United Kingdom. Given also that several
large-scale solvent recyclers already operate in Great Britain, investment in a new substantial recycling
facility in Ireland may be unattractive. Environmentally, the location of solvent recycling is neutral in
its effect. There is little difference between recycling solvent in Ireland and exporting the recycled
solvent on the one hand, and exporting waste solvent for recycling abroad on the other. The transport
distances remain substantially the same. An Economic Study of Solvent Recycling & Treatment in Ireland
was completed in 201093. The results of this study should help inform decision-makers as to whether
expansion of the commercial solvent recycling industry in Ireland should be actively promoted and
supported. Such promotion and support would require parallel efforts to market recycled solvent in
Ireland, and the assistance of the North/South Market Development Group may be appropriate in this
regard. It should be noted, however, that a solvent recycling industry in Ireland is likely to remain a niche
market and account for a relatively small proportion of solvent waste arisings.
Co-incineration
The total operational blending capacity in Ireland is reported to be 66,000 tonnes per annum though | 83
not all of this capacity is currently used. It is mainly exported, however, one cement plant was granted
an IPPC licence in 2012 to co-incinerate a number of waste types including solvents at the plant.
In the interest of promoting self-sufficiency and maximising fossil fuel substitution, it is recommended
that the combustion of blended solvent should be facilitated in Ireland, within the constraints of planning
requirements and EPA licensing, in preference to export. Indigenous cement kilns may be suitable users
of blended solvent, although power stations or other combustion plant may also be appropriate.
Incineration
Co-incineration of waste solvent cannot provide the whole solution to managing Irish waste solvents
or other waste streams suitable for or requiring thermal treatment. Co-incineration plants will only,
justifiably, seek to burn the best material with the optimal calorific value. The remaining wastes (see
Table 22), plus solvent waste unsuitable for blending and co-incineration, will still require an alternative
treatment. The most widely used alternative for these wastes is currently incineration in dedicated
facilities.
Incineration is a thermal treatment technology that provides flexibility in the management of combustible
hazardous waste. A wide range of hazardous wastes can be accepted – not only solvents, but also other
liquid and solid hazardous wastes such as those listed in Chapter 3 and summarised in Table 22.
Table 23 calculates the approximate quantity of hazardous waste that would still have been exported
for incineration in a given year even if all potentially recyclable waste solvent was to be diverted to
recycling or for use as fuel. The calculation is based on the total quantity of hazardous waste that
is exported for incineration (D10) minus the quantity of solvents that are exported for incineration
92 Soltec, waste licence register number W0115-01.

93 Available at http://www.epa.ie/pubs/reports/waste/haz/Solvents%20Economic%20Study%20Report.pdf
(D10). Table 23 shows that even with full diversion of all available waste solvent to recycling facilities
and for use as fuel, a remaining 21,832 tonnes of hazardous waste would still have been exported
for incineration in 2011. The equivalent calculations for 2009 and 2010 show some variability in the
quantity of waste potentially available for or requiring incineration after all possible recycling of solvent
or use of solvent as fuel has taken place.
Table 23 Calculation of quantity of hazardous waste potentially available for incineration in Ireland
2009 (t) 2010 (t) 2011 (t)
Total quantity of hazardous waste exported for incineration (D10) 34,082 32,401 35,568
Deduct the actual quantity of solvent exported for incineration -10, 904 -6,409 -13, 736
(D10) that may have the potential to be diverted for recycling or use
as fuel
Minimum potentially available for incineration in Ireland

that is currently incinerated abroad 23, 178 25,992 21, 832
Obviously it is difficult to predict how much hazardous waste will remain after, and even if, all suitable
material is diverted for recycling and use as a fuel. However, it is clear that diverting less solvent to
84 | recycling or for use as fuel in cement kilns or other combustion plant would leave greater quantities
sent for incineration, whether in Ireland or abroad. It should be noted that the export of this material is
currently taking place in a secure, competitive and available marketplace abroad. Irish waste is not likely
to be restricted from entering other Member States, although there are some policy barriers that exist
(e.g. UK disposal market94). It is therefore a matter for the private sector to judge whether investment
in an Irish hazardous waste incineration facility, or alternative treatment technologies, would make
commercial sense in the context of the evolving European market.
It is, however, evident from this analysis that there is a quantity of hazardous waste that is currently
exported for incineration for which incineration will remain the most likely management route. It must
therefore be concluded that, in combination with the blending of waste solvent for use in cement
kilns, and in the absence of alternative techniques that are capable of treating a wide range of diverse
waste streams, incineration will be needed in order for Ireland to move towards self-sufficiency in the
treatment of hazardous waste.
The proposed incineration facility for Ringaskiddy95 is authorised to treat up to 50,000 tonnes
of hazardous waste per annum. It is noted that a merchant incinerator operator has submitted an
application in 2012 to the EPA for a waste licence review to increase the capacity of their waste-to
energy plant from 200,000 tonnes per annum to 220,000 tonnes per annum and, in particular, to
accept up to 15,000 tonnes per annum of a number of hazardous waste types (e.g. paint tins, rags and
wipes contaminated with paints or oils) for treatment. This application is subject to a full environmental
assessment and industrial emissions licence determination process.
94 The UK Plan for Shipments of Waste prohibits most imports of waste for disposal from Ireland into Great Britain, but
allows for certain hazardous waste imports for disposal into Northern Ireland (and exports from Northern Ireland). There
are no restrictions on access to recovery or recycling markets. See Section 6.9 below.
95 Waste licence register number W0186-01.
6.5 Landfill of hazardous waste

Ireland currently has no dedicated hazardous waste landfill disposal facility. Table 24 shows the scale
of landfilling abroad of Irish hazardous waste in 2011. Asbestos is the single largest hazardous waste
stream that requires landfill disposal.
Table 24 also outlines the use of landfill for Irish hazardous waste abroad for the year 2010 and based
on both 2010 and 2011 figures indicates a current need for approximately 10,000-15,000 tonnes of
capacity per annum.
Table 24 Commercial landfilling of Irish hazardous waste (exported), 2010-2011
2010 (t) 2011 (t)
Asbestos 9,512 7,001
Hazardous construction and demolition waste 54 26
Solid wastes containing dangerous substances 2 2
Other industrial hazardous waste - 865
Sludges and filter cakes - 39

| 85
Metals and heavy metal containing wastes 19 41
Contaminated soil 216 5,098
Total 9,803 13,073
Total off-site landfill excluding contaminated soil 9,587 7,975
The landfilling of asbestos is subject to a unique set of criteria. As a “stabilised non-reactive hazardous
waste”, construction materials containing asbestos (EWC 17 06 05*) and other suitable asbestos waste
may be accepted at non-hazardous landfills, subject to a set of strict waste acceptance and waste
management criteria being followed96. For example, asbestos must be landfilled alone and separate to
the main body of non-hazardous waste, and it must be clearly marked on all site maps. A number of
licences were previously reviewed to allow asbestos to be accepted for disposal. However, there is no
facility currently operational for the acceptance of asbestos for disposal in Ireland.
The cost of exporting asbestos waste is prohibitive, particularly for small scale or DIY operators. This
is in all likelihood driving asbestos towards being unreported or illegally disposed. The generation of
asbestos is a legacy of construction materials used in the past and is linked to the rate of renovation,
demolition or extraction of asbestos from older buildings. The quantities shown in Table 24 represent
the current requirement for landfill capacity for reported asbestos waste. It is proposed that, in the
absence of a dedicated national facility and considering the prohibitive export costs for this stream,
additional capacity be provided at specialist cells in a limited number of existing non-hazardous landfills
96 As set out in article 6(c)(iii) of the Landfill Directive (1999/31/EC) and section 2.3.3 of the Annex to Council Decision
2003/33/EC.
to prevent illegal disposal of asbestos and to take account of increased promotion of legal collections
of asbestos97. Thus capacity for up to 20,000 tonnes of asbestos waste per annum is recommended for
capacity planning purposes.
Other than asbestos, a relatively small amount of hazardous waste (other than contaminated soil)
required disposal – approximately 75 tonnes in 2010 and 973 tonnes in 2011.
While landfill is the least favoured option on the waste hierarchy, it is recognised that for some non-
recoverable or non-combustible hazardous wastes it will need to be considered. Relying on the current
export model to address this need poses risks for long term availability of outlets. However, there
are considerable hurdles to be overcome prior to development of a hazardous waste landfill, from
a societal acceptance, regulatory and financial (liability) point of view. These hurdles should not be
underestimated when developing plans that may include the need for such infrastructure. These hurdles
must be weighed up against the uncertainty in the volumes of waste that are subject to landfill as the
only option. Where brownfield sites such as existing landfills are proposed for co-location of difficult
wastes such as asbestos some of these obstacles may be more easily overcome.
In July 2010, a study on the Technical and Economic Aspects of developing a National Difficult Waste
Facility (NaDWaF) was completed by SKM Enviros on behalf of the EPA98. This study looked at a range
of hazardous and difficult wastes (which because of their nature and physical properties pose problems
for disposal) including out of date unexploded marine distress flares and unused ordnance as well
86 | as radioactive sources. A range of management options were examined including landfill technical
containment and operational requirements. Site selection criteria, potential for co-location, all-island
perspectives and environmental issues arising were examined, and an economic appraisal and a socio-
economic assessment were also conducted.
This study projected growth tonnages for hazardous waste arisings potentially suitable for landfill in
Ireland and Northern Ireland and are aggregated on 6 year basis, 2008 – 2025, (including hazardous
contaminated soils).
97 In Chapter 5, a network of asbestos transfer stations operating from civic amenity sites is proposed. The availability of
drop-off facilities at equitable cost should minimise the illegal disposal or backyard accumulation of asbestos.
98 Report is available at http://www.epa.ie/pubs/reports/waste/haz/nationaldifficultwastefacilitystudy.html
Table 25 Hazardous Waste Arisings Potentially Suitable for Landfill, Ireland and Northern Ireland,
Aggregated on 6-year basis, 2008-2025 (as outlined in NaDWaF study). 99.
HAZARDOUS WASTE99, LANDFILLED NACE 2008 - 2014 - 2020 -

Unit: tonnes 2013 2019 2025
Average Average Average
Chemical production
07 05 11* 24 89 141 182
07 05 13* 156 246 318
16 11 05* 6 9 12
Non-metallic mineral production
10 11 13* 26 36 50 60
10 11 19* 1,527 2,131 2,524
12 01 14* 12 17 20
Metal prod. excl. machinery & transport equip.
01 03 07* 27-28 14,190 22,414 28,946

| 87
10 02 07* 43 68 88
10 10 07* 826 1,305 1,685
Electrical goods
06 04 05* 31-33 2,845 4,494 5,804
Construction
17 05 03* 45 142,642 179,121 195,723
17 06 01* 2,841 3,567 3,898
17 06 05* 11,882 14,921 16,304
17 09 03* 11 14 16
Services (excl. transport)
19 01 05* 50-55, 8 10 11
64-95
19 01 13* 29, 000 35,900 35, 900
19 03 04* 27 33 39
19 03 06* 1,124 1,373 1,621
19 08 06* 3 4 4
19 10 03* 9,266 11,321 13,371
cont’d
99 Refer to European Waste Catalogue for waste description (e.g. 17 05 03* refers to soil and stones containing dangerous
substances)
cont’d
HAZARDOUS WASTE99, LANDFILLED NACE 2008 - 2014 - 2020 -

Unit: tonnes 2013 2019 2025
Average Average Average
Predictions Model Sub-Total (Applying ESRI Growth

Factors) 216, 534 277, 139 306, 526
It is noted that an application for a licence review has been submitted to the EPA, which includes the
development of a hazardous waste facility for the engineered landfill of contaminated soil and fly-ash
containing dangerous substances (the application does not include asbestos disposal). This application
is subject to a full environmental assessment and industrial emissions licence determination process.
This revised Plan recommends that the DECLG keep under review the provision of hazardous waste
treatment capacity (e.g. hazardous waste landfill capacity), including at national or all-island level,
taking into account the above information including the findings from the NaDWaF study, and consider
the use of appropriate economic or other instruments to ensure any necessary capacity is provided for
disposal, either by the private or public sector.
Such instruments might include:
➤➤ policy directions or incentives for existing local authority or private sector landfill operators;
88 | ➤➤ a national contract or public private partnership; and/or
➤➤ an export levy.
Such instruments may provide additional incentive to potential investors in establishing the necessary
infrastructure for the treatment of hazardous waste. National policy or guidance to direct the control of
hazardous waste shipments (e.g. for disposal) should be developed in order to facilitate self-sufficiency
in hazardous waste treatment where this is technically, economically, strategically and environmentally
advisable.
6.6 Physico-chemical treatment

Physico-chemical treatment is used to treat hazardous liquid, solid and sludge waste. The principal
physico-chemical treatment100 operations are material conversion (e.g. neutralisation, oxidation and
reduction) and material separation (e.g. filtration, sedimentation, distillation and ion exchange).
Physico-chemical treatment plants can use many processes, some processes being common to several
treatments. Physico-chemical processes are a useful way of concentrating certain hazardous wastes or
transforming them into less problematic compounds (for further disposal or recycling).
A total of 25,959 tonnes of hazardous waste was treated off-site in Ireland in 2011 by physico-
chemical methods (in its strictest interpretation as disposal operation D9) at four facilities. In a broader
interpretation, all hazardous waste treatment facilities strictly speaking carry out “physico-chemical”
treatment processes in the sense that a waste is subjected to physical or chemical treatment processes
to concentrate or recover materials. These operations tend however to be classified according to
recovery codes (see Appendix B). An additional 966 tonnes was exported for disposal by physico-
chemical treatment. There are no major technical barriers for Irish facilities to increase their capacities or
100 The classification of “physico-chemical treatment” in the legislation as a disposal option is unhelpful. Many treatment
methods that are physical or chemical in nature actually result in waste being recycled – and many waste operators
describe their activities in this manner and take little cognisance of the fact that it is a disposal code. Thus physico-
chemical treatment will be discussed here as a catch-all classification for a range of disposal and recycling techniques,
including, for example: chemical neutralisation, mechanical material separation, solvent distillation and recycling (of
metal, organic or inorganic constituents).
to expand their processes to treat a wider range of waste streams. Some facilities are actually operating
below authorised and equipment capacity levels. However, there are other barriers to expansion: in
the form of low waste generation or poor collection rates (to justify investment) and lack of disposal
facilities for treatment residues. Much of the exported waste is sent to large-scale specialised physico-
chemical treatment centres in Germany and other countries. Smaller-scale Irish facilities could find it
difficult to compete on many waste streams with these larger continental operations.
There are several benefits to promoting increased physico-chemical treatment of hazardous waste
in Ireland. It is a relatively low cost (capital and operating) method of dealing with certain hazardous
wastes. Pre-treating or concentrating waste can reduce subsequent transport costs101. New or
expanded processes could provide employment and investment in companies operating in Ireland and
could contribute towards the creation of recycling markets in Ireland. Given that the barriers are less
technical and more economic in nature, the role of business development supports become important.
Considerable business supports are available from Enterprise Ireland (see Section 6.8) and county and
city enterprise boards (www.enterpriseboards.ie). It is important that the waste industry, particularly
small businesses, be actively supported by enterprise agencies to ensure it is in a position to exploit
opportunities to expand its treatment base and create new investment and employment. Provision of
capacity for the pre-treatment of the following hazardous waste streams is particularly recommended
(though business supports from enterprise agencies should not necessarily be confined to this non-
exhaustive list of wastes):
➤➤ paint and varnish waste – though not always hazardous waste, it is often mixed and difficult to
| 89
segregate;
➤➤ waste electrical and electronic equipment – preparation for re-use, dismantling and recycling
industries in Ireland should be allowed to continue their development and should be supported,
where possible;
➤➤ end-of-life vehicles – end-of-life vehicles regulations place obligations on producers (manufacturers

and importers) to establish and maintain a national collection system to facilitate the recovery and
treatment of end-of-life vehicles. The regulations also impose an obligation on registered vehicle
owners who intend to discard their vehicle as waste to deposit it at an authorised treatment facility
ensuring that depollution is carried out in an environmentally sound manner;
➤➤ oil filters – though often pre-treated (by separating oil, metal and other materials) when they
are collected, collection rates need to improve and greater capacity for their pre-treatment is
recommended;
➤➤ lead acid batteries (automotive and industrial) – large volumes of acid are exported with batteries,
adding to export weights and transport costs. The feasibility of draining batteries and neutralising
or recycling acid in Ireland should be explored, with consideration for the separation of lead, other
metals and plastic prior to recycling;
➤➤ acid and alkali waste – large quantities are exported. Existing treatment capacity is small scale and
there is probably scope for expansion. The feasibility of expanding treatment of this stream should
be explored.
101 For example, dismantling of WEEE and fluorescent lamps achieves this objective. Likewise, the separation of waste paint
from its containers and their squashing or shredding will reduce the amount of empty space in shipping containers. Lead
acid batteries are another example of this potential.
6.7 Difficult wastes

The term “difficult wastes” is commonly used to refer to wastes that by their nature and physical
properties pose problems for disposal and require special management to avoid nuisance and pollution
or where physical properties of the wastes create serious handling problems. These wastes may or may
not be hazardous. Wastes can also be considered difficult if there is no available treatment technology
to allow it to meet waste acceptance criteria limits or if the technology has not yet been commercially
proven. Difficult wastes include:
➤➤ out of date ordnance;
➤➤ marine flares;
➤➤ non-re-saleable seized/confiscated controlled substances;
➤➤ ship and cargo wastes;
➤➤ noxious weeds; and
➤➤ contaminated dredging spoils and harbour wastes.
The above-mentioned NaDWaF study also looked at management options for the above difficult wastes
and found that in most cases, such wastes would not require management via a hazardous waste
landfill facility. The study did however point out that a key waste arising requiring the introduction of
90 | a co-ordinated management policy are marine flares or time expired pyrotechnics (TEPs). The actual
arisings are not definitively known and there is lack of regulation dealing with the disposal of such
arisings. The manufacture, transport, sale and storage of explosives is regulated by various national and
local government bodies, but there is a fragmented approach in the destruction of TEPs.
The study indicates that one central facility would be impractical for the storage of TEPs as storage
facilities need to be close to the arisings. Also, the disposal of TEPs needs specialist knowledge (which
the military has) and this expertise would not normally reside in waste management companies. The
previous National Hazardous Waste Management Plan recommended that an appropriate agent of
the state be appointed for the management of TEPs. The NaDWaF study recommends that further
feasibility should be considered in the establishment of a network of small storage units, perhaps at
coastguard stations, with a view to collection and destruction being contracted to a suitable private
contractor. It is likely that shipment to a destruction facility in the UK may be the most viable option
as the volumes arising may be too low to warrant the investment in such a facility in Ireland. Another
option indicated in the study would be to consider the UK Maritime and Coastguard Agency storage
facility in Belfast as a main central facility where TEPs are delivered and stored prior to destruction at
a facility in England. This option could be explored as part of potential north-south cooperation as
recommended in this revised Plan.
6.8 Waste industry business development support

Given the competitive European environment in hazardous waste management and treatment, the role
of industrial development authorities is key in the development of indigenous companies involved in
hazardous waste management. Enterprise Ireland has a clear function in the development of business
opportunities for indigenous firms in Ireland and encourages and supports its clients along all stages of
the business development process to help them succeed in the global economic environment. Enterprise
Ireland clients are primarily manufacturing and internationally traded services companies employing
ten or more people. Enterprise Ireland’s focus is on five main areas of activity: achieving export sales;
investing in research and innovation; competing through productivity; starting up and scaling up; and
providing management development, strategy and advice. Enterprise Ireland has developed a range of
programmes and supports to suit the varying phases of company and business development from early
stage start-up companies to companies achieving annual sales of >€20m.
The main focus of Enterprise Ireland supports in the environmental sector relates to the commercialisation
and development of technologies, products and/or processes that have a commercial potential.
Enterprise Ireland provides feasibility and R&D support to companies that are operating in this sector.
Commercialisation funding and support for industry-led research projects are also available for research
projects based in third-level institutions. Details on supports available from Enterprise Ireland can be
found at www.enterprise-ireland.com. County and city enterprise boards102 provide many equivalent
supports to small businesses, including information services, grants for feasibility studies, financial
supports, “soft supports” such as mentoring and training, and other services such as “techcheck” | 91
which provides mentored assessments towards the effective use of technology (www.techcheck.ie).
Intertrade Ireland’s103 role includes the development and delivery of programmes to help companies
take advantage of the business opportunities available across the island of Ireland. It also supports
networks that enable businesses to share their experience and expertise, develop new products and
identify new markets.
6.9 Potential for all-island co-operation

There are potential economies of scale to be achieved through full opening of the Northern Ireland and
Republic of Ireland waste markets. Certain companies already operate on an all-island basis and certain
hazardous waste streams currently move across the border, including waste oils, fluorescent lamps and
waste electrical and electronic equipment. All such movements are subject to the EU Regulation on the
transfrontier shipment of waste and companies must set aside administrative and financial resources to
satisfy the competent authorities in both jurisdictions. The UK Plan for Shipments of Waste104, which
came into force on 9 August 2007 (last updated in May 2012), allows “shipments of hazardous waste
[for disposal] between Northern Ireland and the Republic of Ireland, in either direction, provided that
such waste is both generated and disposed of within Northern Ireland or Ireland”. Shipments made
under this policy “are restricted to those destined for the following disposal operations:
➤➤ D5 specially engineered landfill (e.g. placement into lined discrete cells which are capped
and isolated from one another and the environment, etc.);
➤➤ D10 incineration on land; and
102 www.enterpriseboards.ie
103 www.intertradeireland.com
104 DEFRA, 2012. UK Plan for Shipments of Waste. (https://www.gov.uk/government/uploads/system/uploads/attachment_
data/file/69546/pb13770-waste-shipments.pdf)
➤➤ D9 physico-chemical treatment which results in final compounds or mixtures which are

discarded by means of any of the operations above.”
The provision of common all-island landfill capacity for hazardous waste, including asbestos waste for
example, is possible within UK policy and is not prohibited in Irish policy. Similarly, it is still possible
for all-island incineration and physico-chemical treatment capacity to be planned for and taken into
consideration by treatment operators. The DECLG should seek to further examine the potential for
joint north-south approaches and co-operation in the provision of all-island hazardous waste disposal
and treatment105 facilities as proposals arise, also taking into account recommendations outlined in the
abovementioned National Difficult Waste Facility study.
92 |
105 The Department of the Environment in Northern Ireland in its “Statement of Facility Needs” has indicated that over
20,000 tonnes of hazardous waste, including asbestos, requires landfill each year. Northern Ireland regulations state that
only pre-treated hazardous waste may be landfilled. The Statement of Facility Needs also indicated that disposal capacity
for around 2,500 tonnes of asbestos per annum should be provided in at least two locations in Northern Ireland. A
network of asbestos transfer stations is also recommended.
Legacy issues
7. Legacy issues
The following continue to be regarded as “legacy issues” in the context of hazardous waste:
➤➤ the legacy of historical waste disposal practices in a large number of old landfills, many
undocumented, around the country. While most of these old landfills would not be
expected to contain significant quantities of hazardous waste, an identification, assessment
and action-planning exercise is required to deal with them (Section 7.1); and
➤➤ soil and ground contamination is associated with a wide range of historical activities such as
coal gasification, land reclamation and filling stations (garages). “Contaminated soil” is that
material that requires treatment and management and is often dug up and removed from
the site during redevelopment (see Section 7.2).
Other legacy issues also described in this section include extractive waste from historical sites and
contaminated harbour sediments.
7.1 Closed landfills

Local authorities are obliged under Section 22(7)(h) of the Waste Management Act 1996 as amended
to identify sites at which waste disposal or recovery activities have been carried on, to assess those
sites and to take measures to prevent environmental pollution. In a related measure, Section 26(2)(c)
of the Act requires equivalent identification and assessment of sites at which waste disposal activities | 93
were carried out that to a significant extent involved hazardous waste. The Code of Practice for the
Environmental Risk Assessment for Unregulated Waste Disposal Sites was published by the EPA in
2007106 and includes guidance on identifying waste disposal and recovery sites, and sets out a risk-
based assessment procedure that should be applied to sites identified in accordance with Sections
22(7)(h) and 26(2)(c) of the Waste Management Act. A web-based system for local authorities to
provide registers for such sites (under Sections 22 and 26 of the Waste Management Act 1996) has
been rolled out by the EPA and updated in 2009.
Twenty-five sites have been identified as containing hazardous waste. Of these, sixteen are local
authority sites, five are privately owned, two are pre-1977 sites107 and two are illegal sites. The nature
and extent to which these and other landfill sites may have been used to dispose of hazardous waste
to a significant extent in the past will only become apparent following appropriate site investigations.
The Waste Management (Certification of Historic Unlicensed Waste Disposal and Recovery Activity)
Regulations 2008 (S.I. No. 524 of 2008) required the identification and registration of local authority
operated unlicensed sites by end-June 2009. Currently a total of 284 sites that fall under these
regulations are entered in the electronic register. Registration is to be followed by site risk assessments
and regularisation via an EPA authorisation system.
Once an application is made, the EPA assesses the adequacy of the risk assessment carried out. A
Certificate of Authorisation is then issued in due course, identifying whether any additional measures,
additional to those identified by the risk assessment, need to be addressed. This would be with a view
to protecting human health and the environment in line with the waste and groundwater directives.
106 http://www.epa.ie/pubs/advice/waste/waste/epa_cop_waste_disposal_sites.pdf
107 Pre Waste Framework Directive sites
To date, a number of historic unlicensed landfill sites have been subjected to Tier 1 Risk Assessment and
their risk level identified.
At the time of writing, 15 applications for Certificates of Authorisation are being considered by the EPA
and one has been granted. The EPA has estimated that considerable financial resources will be required,
over a long period of time, to apply full risk assessment and complete any necessary remedial actions
to these sites.
The DECLG is funding an ongoing pilot project on environmental risk assessment of legacy landfills.
Since this project commenced in 2009, approximately 40 site investigations have been completed.
The EPA has provided assistance by developing guidance to ensure site investigations are targeted and
avoid potential unnecessary and costly investigations. Overall, it is estimated that the application of this
guidance can result in savings in the range of 30%–45%. With nearly 300 sites, the potential saving to
the public purse could be up to €7m.
Any project proposals for landfill site remediation or associated works would require screening for
Appropriate Assessment and if necessary be subject to Appropriate Assessment prior to commencement
of any works, as such sites may impact on European Sites within the meaning of the European
Communities (Birds and Natural Habitats) Regulations 2011 (S.I. No. 477 of 2011).
7.2 Contaminated soil

94 |
Under Article 2.1 of the revised Waste Framework Directive, land including unexcavated soil is outside
the scope of the Directive and therefore contaminated land is subject to waste legislation only when it
is subject to disturbance by excavation.
Currently there is no specific legislation addressing contaminated land in Ireland and to date numerous
approaches to the problem, including the ad hoc application of standards and methodologies from
other countries, have been applied. Owners/occupiers of contaminated land still retain liability under,
inter alia, water pollution and health and safety legislation. A recent relevant legislative measure has
been the introduction of the European Communities (Environmental Liability) Regulations 2008108 which
came into force in Ireland on 1 April 2009. These regulations clearly assign rules on liability and when
remediation must be carried out, although these regulations do not apply retrospectively in that they
do not cover contaminated land that pre-dates this legislation. In 2011, the EPA published guidance109
on these regulations.
In February 2012 the European Commission published a policy report on the implementation of the
soil strategy and ongoing activities. The report provides an overview of the actions undertaken by the
European Commission to implement the strategy and presents current soil degradation trends both in
Europe and globally, as well as future challenges to ensure protection.
While contaminated soil is generated mainly in the redevelopment of former industrial sites, it is also
generated through fuel-oil and chemical spills and accidents and from the remediation of former waste
disposal sites. Figure 11 sets out the general routes and options for contaminated soil management. An
arbitrary distinction is drawn between recently contaminated soil and historically contaminated sites.
“New contamination” is that which typically arises from petrol or oil spills at service stations or domestic
houses as a result of poor facility management or equipment failure. In-situ remediation is sometimes
carried out. The alternative to on-site treatment is to remove contaminated soil for treatment off-site.
108 Statutory Instrument No. 547 of 2008

109 http://www.epa.ie/pubs/advice/general/Liability_Regulations%20Final%20August%202011.pdf
Legacy issues
One facility110 in Ireland is licensed to treat up to 40,000 tonnes of contaminated soil per annum. All
other off-site treatment currently takes place abroad. Soil is typically treated by some form of physical
treatment and it is then landfilled or re-used in a low grade application, depending on the quality of
the final treated soil.
Figure 10 illustrates the reported quantity and treatment location of contaminated soil removed
from development sites between 2004 and 2011. By far the trend shows a greater proportion of
contaminated soil that is removed from redevelopment sites is exported, however in recent years the
quantity of contaminated soil has dramatically decreased as a result of the economic downturn and the
consequential low level of development activity.
So-called “historical contamination” is typically associated with contamination by heavy metals,

polyaromatic hydrocarbons and other difficult chemicals. There are a limited number of such sites
in Ireland, mainly related to former industrial activities such as coal gasification, historic mine sites111,
tanneries and waste disposal sites. The management of contaminated soil at such sites is controlled
under planning and development legislation. A waste permit or licence is generally required where on-
site recovery or disposal activities are proposed.
IPPC activities that have given rise to contaminated land are captured under the EPA licensing regime112.
Past stimuli in Ireland for remediation and site improvements were driven by economic factors and the
high return on investment for urban sites. This has changed dramatically, and there is potential for a | 95
situation where in the short to medium term Ireland is left with a growing number of “orphan sites”
that pose a risk to the environment yet the original owners no longer have the incentive or the means
for remediation.
110 Enva Portlaoise, waste licence register number W0184-01.

111 Historic Mine Sites – Inventory and Risk Classification, Volume 1A, joint study carried out by the Environmental
Protection Agency and the Geological Survey of Ireland, 2009.
112 http://www.epa.ie/terminalfour/waste/index.jsp
The actual scale of future arisings is unknown, however, it is clear that the lack of treatment capacity in
Ireland to entirely manage this waste stream indicates a continued need to export significant quantities
of soil. If contaminated soil were to be treated in Ireland, treated soil would be potentially available as
an engineering resource for the same redevelopment works where it was generated.
500000
Exported
400000 Treated in Ireland

Tonnes
300000
200000
100000
96 |
0
2004 2005 2006 2007 2008 2009 2010 2011
Figure 10 Location of treatment of reported contaminated soil
Contaminated
Soil from ...
New Contamination Historic Contamination

(spills, accidents) (industrial sites, gasworks)
In-situ remediation (e.g. In-situ pre-treatment and

hyrdocarbon contamination processing (e.g. soil washing,
treated biologically) mechanical screening)
Ex-situ treatment
in Ireland or
abroad
Non-hazardous Non-hazardous
residue left Non-hazardous residue left
in place or residue in place or
removed removed
Figure 11 Overview of contaminated soil management routes and option

Legacy issues
In 2013 the EPA published Guidance on the Management of Contaminated Land and Groundwater
at EPA Licensed Sites113. This document sets out the EPA’s position in relation to the management of
contaminated land and groundwater at EPA licensed sites. The approach outlined may also be suitable
for the purposes of assessing Land Damage at sites under the Environmental Liability Regulations.
The principal aim in dealing with contaminated land and groundwater related issues is to secure the
protection of human health, water bodies (including groundwater) and the wider environment. The
risk based approach in this guidance is considered best practice for the assessment and remediation of
contaminated land and groundwater at EPA licensed sites.
7.2.1 Options for management of contaminated soil in Ireland
Given the apparent lack of sophistication in treatment methods used for contaminated soil, there would
appear to be no obvious technical barriers to providing more facilities for the commercial treatment of
contaminated soil in Ireland. The barriers are more likely to be logistical and economic, including:
➤➤ contaminated soil is often generated in large quantities from the redevelopment of city
docklands (Dublin in particular to date). It can be cost-effective to load the soil from such
locations directly onto ships for bulk export, avoiding extensive and relatively expensive road
transport;
➤➤ low gate fees for large consignments in established facilities abroad make it difficult for new
domestic facilities to compete;
| 97
➤➤ uncertainty in future arisings makes business planning difficult. There is a perception that
there is a limited number of contaminated sites in Ireland and this discourages investment in
contaminated soil treatment facilities.
The continued absence of a legislative requirement for a published register of contaminated sites
makes it difficult to plan ahead for contaminated soil treatment. Development of a public register of
contaminated sites, and a concerted programme to investigate and remediate these, may change the
outlook for developing treatment facilities in Ireland.
Local authorities could, where they have not already done so, take a pro-active approach in planning for
docklands redevelopment and other brownfield remediation by, for example, requiring the coordination
of contaminated soil management by developers. This could enable a single, if temporary, point of
treatment to be established with the appropriate environmental authorisations and controls to serve
the overall area in question. This would mean that treated soil is then available for engineering or other
uses, assuming adequate quality standards are achieved. Area and development plans that include the
redevelopment of docklands or other brownfield sites should take the management of contaminated soil
into consideration from this perspective. Plans should set an objective to avoid export where treatment
in Ireland is technically and economically feasible and where such treatment would not result in greater
emissions or other impacts being generated from transport. This objective is already disseminated to
planning and development authorities by the EPA in carrying out its role as environmental authority
under the Strategic Environmental Assessment Regulations.
113 http://www.epa.ie/pubs/advice/waste/contaminatedland/contaminatedland
Regional Planning Guidelines would appear to be a useful route to co-ordinate management of

environmental issues arising from brownfield and harbour management. The inclusion of a comprehensive
section dealing with contaminated land should be considered in future regional planning policy and
guidelines. Area and development plans must have regard to regional planning guidelines.
Where possible and environmentally acceptable, in-situ remediation should be considered in all relevant
projects. This has the potential to reduce the excavation, transport and replacement of soil.
Mobile plant provides a flexible mechanism for providing in-situ treatment and recycling of soil and
avoiding export. Mobile plant requires a waste licence under the Waste Management (Licensing)
Regulations, 2004, or a waste facility permit under the Waste Management (Facility Permit and
Registration) Regulations, 2007. The regulations require detailed assessments of treatment sites, and
this reportedly deters investment in equipment or the entry of Northern Ireland or overseas operators
to the Irish market. The result is that no mobile plant operates in Ireland. The use of mobile plant in
other jurisdictions could be examined with a view to considering new ways of regulating the activity in
a manner that does not cause environmental pollution.
7.3 Harbour sediments

Following the Foreshore and Dumping at Sea (Amendment) Act 2009, the EPA was designated the
competent authority for permitting Dumping at Sea from 15 February 2010. This function involves
98 | assessing applications for the offshore dumping of dredged material from ports and harbours.
Dumping is only allowable where suitable alternative methods of re-use, treatment or disposal of
the dredged material are not available. Before a Dumping at Sea Permit can be granted by the EPA,
dredged material must be well characterised and sediment samples analysed for a range of parameters
as described in the First Schedule to the Dumping at Sea Acts. In accordance with guidelines issued by
the OSPAR and London Conventions, Ireland has established upper and lower action levels for a range
of contaminants (metals, PCBs, PAHs, organochlorine pesticides, organotins). These data are used in
a weight-of-evidence assessment to determine the suitability of dredged material for disposal at sea.
Dredged material with contaminant concentrations exceeding the relevant upper action levels is classed
as heavily contaminated and generally regarded as unsuitable for unconfined dumping at sea.
7.4 Extractive waste from historical sites

The EU Extractive Waste Directive (2006/21/EC) requires Member States to prepare a National Inventory
of closed mine sites (operated in the last two centuries or so in Ireland’s case). The inventory is intended
for those historical sites which have the potential to cause, or are causing, risk to the environment or
human health. Some of the wastes in these historical facilities may have hazardous properties, though
would not be “Hazardous Waste” within the meaning of the EU Waste Framework Directive or this
revised Plan, because neither speaks to extractive activities closed before the coming into effect of the
1991 amendment of Waste Directive (Council Directive 91/156/EEC).
The EPA and the Geological Survey of Ireland collaborated in the preparation of a national inventory
of closed mine sites. This study, Historic Mine Sites – Inventory and Risk Classification, was published
in 2009114. Many of the data can be viewed and queried on EPA GIS Envision Historical Mines portal
http://gis.epa.ie/Envision, and related data are also available to download.
114 http://www.epa.ie/pubs/reports/land/mines
Implementation
8. Implementation
Implementation of this revised National Hazardous Waste Management Plan will require appropriate
financial and personnel resources to ensure that all recommendations in the Plan are acted upon by
the nominated bodies and within acceptable timescales. The principal implementation and monitoring
bodies for the revised Plan are as follows:
➤➤ The Department of the Environment, Community and Local Government should adopt a
policy leadership and sponsoring role for the Plan’s implementation by:
➤➤ making resources available for the Plan’s implementation;
➤➤ fulfilling specific implementation roles as identified in the Plan;
➤➤ making new regulations where necessary and appropriate; and
➤➤ ensuring other Government departments and public bodies fulfil their roles and responsibilities
identified in the Plan.
➤➤ The Environmental Protection Agency will promote and co-ordinate the Plan’s implementation,
and will continue to take responsibility for:
➤➤ chairing the National Waste Prevention Committee with oversight of the Plan’s
implementation; | 99
➤➤ fulfilling specific implementation roles as identified in the Plan; and
➤➤ monitoring and reporting on the Plan’s implementation.
➤➤ The National Waste Prevention Committee should continue to act as the principal stakeholder
oversight body for the Plan’s implementation, with responsibility for:
➤➤ enabling two-way communication with sectoral and stakeholder interests;
➤➤ participating on sub-groups that may be established for specific purposes, as may be decided
by the Committee; and
➤➤ providing review, feedback and comment on implementation reports prepared by the

Environmental Protection Agency.
➤➤ Local authorities’ participation is essential for promoting good hazardous waste management
practices and they are the subject of a considerable number of specific recommendations. They
should:
➤➤ ensure that regional waste management plans, as well as regional and area development
plans, take this Plan into account;
➤➤ fulfil their important role in providing small-scale collection services and generally raising
awareness in hazardous waste management; and
➤➤ engage with the Local Authority Prevention Network.

8.1 Summary of recommended actions and responsibilities

This summary of recommendations below, which arise from the analysis and considerations included in
the revised Plan, is not necessarily presented in the order in which they could or should be implemented.
Administrative arrangements
1. Local authorities should consider the information provided in this revised Plan and, in accordance
with Sections 22(8) and 26(6) of the Waste Management Act 1996 as amended, take relevant
recommendations of this revised Plan into account in their revision and implementation of
regional waste management plans, as well as regional planning guidelines and regional and area
development plans.
Responsible: Local authorities
2. Public bodies should be aware of this revised Plan and take its provisions and recommendations
into account in the execution of their environmental protection, industrial development and other
functions, with the objective of improving their own hazardous waste management and that of
their clients, customers or stakeholders.
Responsible: All public bodies

100 |
Prevention
3. Continuously engage with priority sectors (pharmachemical, health, agricultural, household,

publishing & printing and transport) and communities (e.g. via the Local Authority Prevention
Network) on hazardous waste prevention activities as detailed in the revised Plan.
Responsible: Environmental Protection Agency, local authorities and relevant sectoral organisations
4. Incorporate the prevention of the generation of hazardous waste into the National Waste Prevention
Programme and the implementation measures within the Regional Waste Management Plans.
Responsible: Environmental Protection Agency, local authorities
5. Engage with businesses towards achieving hazardous waste prevention, cleaner technology and
better compliance with regulation.
Responsible: Environmental Protection Agency, local authorities
6. In implementing the Green Public Procurement Action Plan provide for the substitution or reduction
in use of hazardous materials and products in public procurement (eco-design).
Responsible: All public bodies
7. Carry out waste characterisation studies, via the National Waste Prevention Programme, to profile
hazardous waste content of arisings from smaller sources (e.g. households and small business).
Responsible: Environmental Protection Agency

Implementation
8. With support from producer responsibility initiatives, carry out studies on relevant waste streams,
(e.g. packaging, WEEE), to determine if product-based legislation is having its desired effect and
the hazardousness of related waste streams is reducing.
Responsible: Environmental Protection Agency in collaboration with other

organisations (e.g. Producer Responsibility Initiative stakeholders)
9. Assist relevant Departments and Agencies to examine the feasibility of alternatives to the diesel
fuel marking system that can help eliminate illegal diesel laundering operations and prevent the
generation of hazardous waste and associated environmental clean-up costs arising from such
activities.
Responsible: Department of the Environment, Community and Local Government in

consultation with relevant stakeholders (e.g. Office of the Revenue Commissioners)
Collection of hazardous waste
10. (i) Plan and make provision for resourcing local authorities to develop adequate collection facilities
for small-scale quantities of hazardous waste from households and small businesses (e.g. at civic
amenity sites, mobile special collections). This could include resourcing through sectoral agreements
and the development of potential new producer responsibility obligations for certain hazardous
waste streams. | 101
(ii) Consider the establishment of a network of collection and transfer facilities to capture small-
scale quantities of legacy wastes (e.g. asbestos arisings from DIY and small contracting jobs) for
environmentally sound management, having regard to the “polluter pays” and “waste producer”
principles. Engage with stakeholders on the development of appropriate operational conditions for
such facilities.
Responsible: Department of the Environment, Community and

Local Government, local authorities
11. Continue to carry out awareness raising and enforcement to ensure improved hazardous waste
collection from small–scale hazardous waste streams (e.g. waste oils from garages).
Responsible: Relevant sectoral organisations, local authorities
12. Assessment and development of potential new producer responsibility obligations for certain
hazardous waste streams (e.g. a take-back scheme for unused or expired human medicines), on
foot of the recently established review of producer responsibility initiatives and detailed studies into
priority hazardous waste streams.
Responsible: Department of the Environment, Community and Local Government

13. Complete a farm hazardous waste collection pilot project and publish pilot project research findings
and recommendations.
Responsible: Environmental Protection Agency in collaboration with relevant bodies
Infrastructure and self-sufficiency
14. (i) Keep under review the provision and facilitation of hazardous waste treatment115 capacity and
make recommendations on the appropriate economic or other instruments necessary for such
capacity to be provided, either by the private or public sector.
(ii) Develop national policy or guidance to direct the control of hazardous waste shipments in order
to facilitate self-sufficiency in hazardous waste treatment where this is technically, economically,
strategically and environmentally advisable.

Local Government in consultation with relevant stakeholders
15. Prepare and maintain, in consultation with various stakeholders, an inventory of national hazardous
waste recovery and disposal capacity.
102 | Responsible: Environmental Protection Agency
Regulatory
16. Consolidate and reform existing regulations where appropriate, and make provision for new
hazardous waste regulations where the need becomes apparent during implementation of this
revised Plan.
17. Carry out a review of waste licensing and permitting legislation in order to establish a proportionate
regulatory mechanism, including relief, to facilitate collection, transport, take-back and temporary
storage of certain hazardous wastes arising from small sources.

Local Government in consultation with relevant stakeholders
18. Cooperate in enforcement activities concerning product based pollution prevention (e.g. Restriction
of Hazardous Substances in Electrical and Electronic Equipment, Persistent Organic Pollutants
(POPs)).
Responsible: Relevant public authorities
115 ‘Treatment’ means recovery or disposal operations, including preparation prior to recovery or disposal (EU Waste
Framework Directive 2008/98/EC)
Implementation
Legacy issues - Closed landfills
19. Identify, assess and, where necessary, remediate sites where hazardous waste was to a significant
extent disposed of in the past. This action should conform to the Code of Practice prepared by the
EPA’s Office of Environmental Enforcement.
Responsible: Local authorities
North-south initiatives
20. Seek to establish, with the appropriate Northern Ireland authorities, a North-South co-operative
group working on hazardous waste issues.
Guidance and awareness
21. Conduct regular awareness and information campaigns (e.g. via social media) to pro-actively
update and inform individuals and businesses of available hazardous waste collection services in
their areas, as well as their legal obligations. Provide and disseminate practical guidance on the
management of sectoral hazardous waste (e.g. household, commercial, farming).
| 103
Responsible: Local authorities and relevant public authorities and sectoral
organisations (e.g. Department of Agriculture, Food and the Marine)
22. Prepare up-to-date factsheets on each of the main hazardous waste streams including information
on appropriate management options for such waste streams.
23. Complete the code of practice/guidance document on the minimum operational and environmental
standards for accepting hazardous waste at civic amenity sites, and disseminate to local authorities
and civic amenity site operators.
24. Continue to promote awareness and guidance on the correct management of healthcare hazardous
waste (e.g. Green Healthcare Programme) to all HSE employees, as appropriate.
Responsible: Environmental Protection Agency, Health Service Executive
25. Carry out a study to evaluate and recommend an appropriate regulatory mechanism and relevant
guidance for the management and disposal of spent sheep dip.
Responsible: Environmental Protection Agency in

consultation with relevant stakeholders
Plan Implementation
26. Devise sectoral and waste stream specific indicators (e.g. industrial, farming, healthcare) to help
monitor implementation of the revised Plan’s objectives. Prepare and make available key hazardous
waste data indicators at regular intervals.
Responsible: Environmental Protection Agency in

consultation with relevant bodies
27. Periodically report on the progress on the revised Plan’s implementation.
8.2 Resource requirements for the revised Plan

There are two essential prerequisites to ensure that the revised Plan is implemented – sufficient staff
and financial resources. Recognising that Ireland is currently experiencing significant cutbacks in public
sector resources, the revised Plan has sought to set out recommendations that can realistically be
implemented over the plan period.
Public bodies should assess what resources they need to respond to the recommendations for action
104 | made in this revised Plan (as summarised in Section 8.1). Failure on the part of public bodies to allocate
resources to the revised Plan’s implementation will result in the revised Plan not being fully implemented.
8.3 Consequences of not implementing the revised Plan

Some of the consequences of not putting in place a programme to implement the revised National
Hazardous Waste Management Plan are as follows:
➤➤ many generators of hazardous waste will remain unaware of their obligations in respect of the
management of hazardous waste;
➤➤ levels of unreported hazardous waste will remain high and could grow;
➤➤ small businesses and households may not have full access to affordable collection services, resulting
in small-scale hazardous waste being disposed of with general refuse in landfills not designed or
licensed for hazardous waste;
➤➤ improvements and consistent high standards in civic amenity site storage of hazardous waste will
not materialise, resulting in potential for poor management of deposited materials;
➤➤ producers will not be made responsible for the proper management of hazardous waste resulting
from products placed by them on the market;
➤➤ knowledge will not be developed on available and optimal hazardous waste management routes in
Ireland to avoid large-scale export of waste for thermal treatment;
➤➤ hazardous waste treatment capacity (e.g. landfill) will remain unavailable, ensuring that large
quantities of asbestos waste in particular will continue to be exported or disposed of in an
unauthorised manner.
Implementation
8.4 Objectives, targets and indicators

Table 26 summarises the objectives that will be adopted for the revised National Hazardous Waste
Management Plan (see Section 1.3) and includes environmental objectives identified during the Strategic
Environmental Assessment (see Section 1.4). Table 27 and Table 28 summarise the targets and indicators
that will provide a means of measuring progress towards these objectives. Targets and indicators are
intended to allow for monitoring the implementation of the revised Plan (management indicators) and
monitoring any environmental effects of the revised Plan’s implementation (environmental indicators).
There are two principal mechanisms for reporting on the revised Plan’s implementation progress. The
National Waste Report will provide regular statistics on hazardous waste generation, treatment and
export. A mid-term review report on the implementation of the revised Plan will also be prepared – see
Section 8.5.
Table 26 Summary of revised Plan and environmental objectives
Summary of revised Plan objectives (see Section 1.3)
1 To prevent and reduce the generation of hazardous waste by industry and society generally.
2 To maximise the collection of hazardous waste with a view to reducing the environmental and
health impacts of any unregulated waste.
3 To strive for increased self-sufficiency in the management of hazardous waste and to minimise | 105
hazardous waste export.
4 To minimise the environmental, social and economic impacts of hazardous waste generation
and management.
Summary of environmental objectives

(from Chapter 7 of the Environmental Report - see Section 1.4 of this document)
1 To protect water quality (rivers, lakes, marine and groundwater) from hazardous waste
2 To protect air quality from hazardous waste and/or reduce air pollution or limit to levels that do
not damage the natural environment or human health
3 To minimise greenhouse gas emissions associated with hazardous waste management

(including transport)
4 To safeguard soil quality and quantity from hazardous waste and reduce soil contamination
5 To maximise use of material assets including the built environment, energy and raw materials
6 To minimise the export of hazardous waste for treatment and/or disposal and reduce emissions
due to transportation
7 To conserve and enhance biodiversity, including flora and fauna, and integrate biodiversity
considerations into actions relating to or arising out of any of the recommendations in the
National Hazardous Waste Management Plan
8 To protect human health from hazardous waste

Table 27 Revised Plan targets and indicators
Target for lifetime of Plan Indicator Data availability Frequency

and source in assessing
progress
Initiate and implement Scoping, commencement and EPA – National Annual

hazardous waste prevention progress reports for individual Waste Prevention
projects projects Programme
Reduce the generation of Reduction in hazardous EPA - all prevention Annual

hazardous waste relative waste generation relative projects will have
to production at targeted, to production at relevant, built-in quantitative
participating or reporting participating or targeted and qualitative
organisations or sectors. organisations or sectors. indicators
Influence positive behavioural Greater engagement by
change by supporting householders, communities
businesses, communities and and businesses in resource
householders to become more efficient behaviours (e.g.
resource efficient. through participation in EPA
BeGreen initiatives)
Minimise the generation of Estimation of unreported EPA - estimation Every 2 years

unreported hazardous waste hazardous waste will be made every
two years for the
106 |
National Waste
Report
Increase the deposit of Quantity of household and EPA - National Waste Annual
household and small business small business hazardous Report team
hazardous waste at waste deposited at static
facilities
o civic amenity sites;
Availability of collection/
o other static collection deposit services
points; and
o mobile services.
Increase collection of waste Quantity of waste oils EPA – National Waste Annual
oils from smaller sources (e.g. collected and treated at Report team
garages) hazardous waste facilities
Carry out farm hazardous Assessment and development Department of Annual

collection pilot project to inform of new producer responsibility the Environment,
producer responsibility initiatives obligations Community and
Local Government
Quantity of (hazardous) waste
collected on foot of producer EPA – National Waste
responsibility obligations Report team
Increase on-site treatment of Quantity of hazardous waste EPA – National Waste Annual
hazardous waste generated at treated at IPPC/IED licensed Report team
IPPC/IED licensed facilities facilities
cont’d
Implementation
cont’d
Target for lifetime of Plan Indicator Data availability Frequency

and source in assessing
progress
Increase off-site treatment of Quantity of hazardous EPA – National Waste Annual

hazardous waste in Ireland waste treated or landfilled at Report team
merchant facilities in Republic
of Ireland
Reduce export of hazardous Quantity of hazardous waste EPA – National Waste Annual
waste exported Report team
Quantity of contaminated soil

exported
Identify, assess and remediate Number of sites identified, EPA OEE – Code Every 2 years
as necessary all sites where assessed and remedial actions of Practice
hazardous waste to a significant undertaken implementation
extent was disposed of records
Table 28 Environmental targets and indicators
Target for lifetime of Ref to Indicator Data Frequency

plan environmental availability and in assessing | 107
objective source progress
(Table 26)
Minimise exceedances of Water Number of hazardous EPA OEE – licence Every 2

emission limits to water waste facilities in enforcement files years
and air from licensed Air breach of emission
hazardous waste facilities limits to surface
water, groundwater
and air
Legacy hazardous waste Water Number of legacy EPA OEE – Code Every 2
disposal sites to be disposal sites to which of Practice years
managed in accordance Soil Code of Practice is implementation
with Code of Practice applied records
No increase in dioxin levels Air Dioxin in cow’s milk EPA – monitoring When
in ambient environment of cow’s milk available
Human health
Maximise the generation Climate Quantity of hazardous EPA – National Annual

of energy from renewable waste managed via Waste Report
sources energy recovery (R1) team
cont’d
cont’d

plan environmental availability and in assessing
(Table 26)
Minimise distance Climate Tonne-kilometres EPA – to be Every 2

travelled by hazardous travelled by road and calculated from years
waste Transport sea best available
records (e.g.
facility records,
waste tracking
records, TFS)
(data not
currently
collected)
Minimise export of Transport Quantity of hazardous EPA – National Annual

hazardous waste and waste exported Waste Report
move towards self- Material assets team
sufficiency
Minimise the generation Human health Estimation of EPA - estimation Every 2

of unreported hazardous unreported hazardous will be made years
waste Soil waste every two years
108 |
for the National
Waste Report
Increase the treatment Soil Quantity of EPA – National Every 2

of contaminated soil in contaminated soil Waste Report years
Ireland Material assets treated in Ireland as and licence
a proportion of the enforcement files
total
Maximise the use of Material assets Area of new EPA – licensing Every 2
previously developed land hazardous waste files years
or brownfield sites for facilities on greenfield
appropriate developments and brownfield sites (data not
including hazardous waste currently
facilities collected)
Avoid loss or damage Bio-diversity Area of designated EPA – licensing Every 2

to designated sites from sites used by or files years
siting of hazardous waste proposed for
facilities development of
hazardous waste
facilities
cont’d
Implementation
cont’d

plan environmental availability and in assessing
(Table 26)
Minimise major incidents Human health Reports of large EPA – Every 2

of unauthorised disposal scale illegal disposal unauthorised years
of hazardous waste involving hazardous waste activities
waste (not including reports and
relatively small-scale information
fly-tipping) provided from
relevant bodies
(e.g. major
emergency
management
bodies)
Minimise complaints Human health Number of complaints EPA – licence Every 2

relating to hazardous received relating to enforcement files years
waste facilities hazardous waste
facilities
The above environmental targets and indicators are also important in helping to achieve environmental
goals set out in the EPA’s strategic plan for the period 2013-2015 including, for example, | 109
➤➤ Limiting and Adapting to Climate Change;
➤➤ Protected Water Resources;
➤➤ Protected Soil and Biodiversity;
➤➤ Sustainable Use of Resources.
8.5 Reporting schedule

With respect to the previous plan, an implementation report was published by the EPA in 2011 which
reviewed the Plan’s and SEA objectives and identified progress made in implementing recommendations
since its publication in 2008 up to mid-2011. This revised Plan provides further up-to-date information
regarding the management of hazardous waste in Ireland.
In relation to the revised Plan, the EPA will carry out a mid-term review and will report to the National
Waste Prevention Committee on the implementation of this plan, incorporating information from the
implementing bodies defined in this plan. The National Waste Report will present statistics on hazardous
waste treatment and progress relative to other targets.
APPENDIX A - List of submissions

Public consultation on the Proposed Revised Plan was carried out between 23rd October 2013 and
23 December 2013. A total of 21 submissions were received. Submissions were received from the
following:
Angela Hetherton
Animal and Plant Health Association
Cappagh Farmers Support Group
Cork Harbour Alliance for a Safe Environment
Department of the Environment, Community and Local Government
Dublin City Council/National Transfrontier Shipment Office
Dun Laoghaire - Rathdown County Council
Engineers Ireland
Health Service Executive
Indaver Ireland Ltd
Irish Doctors Environmental Association
Irish Medicines Board
Irish Waste Management Association
Monaghan County Council
Noel Duffy, Cork Institute of Technology
110 | Patel Tonra Environmental Solutions (on behalf of Murphy Environmental Hollywood Ltd)
Roscommon County Council
SRCL Ltd
Teresa Ryan-Feehan, Site Manager, Athlone Recycling Centre
Veolia Environmental Services Technical Solutions Ltd
A compendium of submissions and responses is available at www.hazardouswaste.ie.

APPENDIX B - Hazardous waste generation and treatment data
The following tables are contained in this appendix:
➤➤ Table 29 Indicators for hazardous waste generation and management
➤➤ Table 30 Treatment of hazardous waste on-site of generation at IPPC licensed facilities in 2011
Table 29 Indicators for hazardous waste generation and management
All data sourced from National Waste Reports (2006-2011)
Indicator 2006 (t) 2007 (t) 2008 (t) 2009 (t) 2010 (t) 2011 (t)
Industrial hazardous waste 88,409 82,732 72,038 74,668 76,655 67,772

treated on-site of generation
(predominantly at IPPC-licensed
facilities)
… recovered (t) 38,372 46,545 36,446 36,124 39,495 33,301

… disposed (t) 50,037 36,187 35,592 38,544 37,160 34,471
Hazardous waste treated off-site 60,872 91,240 113,839 89,992 93,549 98,838
in Ireland at authorised facilities
| 111
(not including contaminated soil)
… recovered (t) 26,976 52,452 79,245 68,145 59,152 72,877
… disposed (t) 33,896 38,791 34,594 21,848 34,437 25,959
Hazardous waste exported 134,904 147,542 157,207 150,395 143,180 149,037
(not including contaminated soil)
… for recovery 69,515 82,770 89,749 98,049 97,735 101,972
… for disposal 65,130 64,675 67,424 52,345 45,445 47,065
… for unspecified treatment 259
Unreported hazardous waste 26,024
(estimate)
Contaminated soil 406,904 188,127 493,107 12,904 8,850 17,297
… recovered in Ireland 36,872 44,241 43,531 12,428 6,260 7,094
… disposed in Ireland 2
Exported contaminated soil 370,032 143,906 449,574 476 2,590 10203
… recovered abroad 28,875 17,047 151,891 469
… disposed abroad 341,158 126,859 297,683 7 2,590 10,203
Industrial hazardous waste
generated
… reported (i.e. sample) 216,411 98,044
… projected (i.e. total) 271,755 250,311 Refer to

Section
3.2
Table 30 Treatment of hazardous waste on-site of generation at IPPC licensed facilities in 2011
Facility name IPPC Reg. Waste Type Recovery/ Quantity

Code in 2011
(tonnes)
Arran Chemical Co. Ltd P0110-02 Solvents R2 763
Astellas Ireland Co. Ltd P0007-03 Solvents D10 616
Aqueous washing liquids D10 1,400

and mother liquors
(07__01*)
Aughinish Alumina Ltd P0035-04 Salts and salt cake D1 20,079
BASF Ireland Limited/ P0052-02 Other industrial hazardous R1 4,720

International Detergent waste
Chemicals Ltd
Phillips 66 Bantry Bay Terminals P0419-01 Oil waste (mineral oil) R9 180
Eli Lilly P0009-03 Solvents D10 2,944

112 |
where specified)
Galmoy Mines Ltd P0517-01 Oily sludges R10 45
Irish Industrial Explosives Ltd P0055-01 Other industrial hazardous D10 2

waste
Mallinckrodt Medical Imaging P0050-02 Solvents R2 6347

Ireland
Solvents D8 306
Solvents (Halogenated D8 <0.1

where specified)

where specified)
Merck Sharp & Dohme P0011-04 Solvents D8 1,061
R2 1,820
Merck Millipore Ltd P0571-02 Solvents R2 1,380
cont’d
cont’d

Code in 2011
(tonnes)
Novartis Ringaskiddy Ltd P0006-03 Other industrial hazardous D10 <0.1

waste
Packaging (contaminates or D10 25

containing residues)
Sludges and filter cakes D10 0.2
Solvents D10 <0.1
D8 284
R1 1,756
R2 4,102
Absorbents, Wiping cloths D10 30
Aqueous washing liquids D10 452

and mother liquors
(07__01*)
| 113
Solid wastes from MFSU D10 2
13*)
Laboratory and general D10 13

chemical waste
Pfizer Ireland Pharmaceuticals P0013-04 Solvents R2 1,130
Pfizer Cork Ltd P0136-04 Solvents R2 2,724
Solvents R1 13
Roche Ireland Ltd P0012-04 Solvents R1 2,415

where specified)
Schering-Plough (Ireland) P0015-05 Solvents R1 1151
P0004-03 Solvents D10 2,417

Smithkline Beecham (Cork) Ltd
R2 161

where specified)
cont’d
cont’d

Code in 2011
(tonnes)
Swords Laboratories P0014-04 D8 1.3

R2 580
Solvents
R2 224
Solvents (Halogenated
where specified)
Bristol Myers Squibb Cruiserath P0552-02 Solvents R2 1,213

Solvents (Halogenated D10 4,639
where specified)
D8 2.5
R2 154
Temmler Ireland Ltd P0813-02 Solvents R2 1,172
Solid wastes from MFSU R3 294
13*)
114 | Total 67,772
Key to D/R codes116 :
D codes R codes
D1 Landfill R1 Use as a fuel
D4 Surface impoundment R2 Solvent recycling (reclamation/regeneration)
D5 Engineered landfill R3 Organic substance recycling (other than

solvent)
D8 Biological treatment R4 Metal recycling
D9 Physico-chemical treatment R5 Inorganic substance recycling/reclamation
D10 Incineration R6 Regeneration of acids and bases
D12 Permanent storage R8 Recovery of components from catalysts
D14 Repackaging prior to D1-D13 R9 Waste oil recycling
R12 Waste exchange prior to recovery
R13 Storage prior to recovery
116
116 Refer to Annexes I and II of EU Waste Framework Directive 2008/98/EC for disposal and recovery operations
Table 31 Licensed and permitted facilities for hazardous waste treatment and transfer117
Company name Licence or Treatment Hazardous waste operations Principal hazardous wastes authorised Status
Permit Reg. or transfer for treatment
Number facility
Rilta Environmental W0192-03 Transfer General chemical and other hazardous Oily sludges, waste oils, oil filters, Operational
Ltd and waste treatment and storage prior to photographic waste, contaminated soil,
treatment export contaminated drums, containers and IBCs,
WEEE
Soltec Ireland Ltd W0115-01 Transfer Solvent distillation and recycling Solvents distillation Operational
and
treatment
SRCL Ltd (formerly W0054-02 Transfer Healthcare risk waste treatment Healthcare risk waste Operational
Eco-Safe Systems and
Ltd.) treatment
Veolia W0050-02 Transfer General chemical and other hazardous Solvents blending and recycling Operational
and waste storage prior to export
treatment
APPENDIX C - Hazardous waste facilities
Enva - Portlaoise W0184-1 Transfer Oils and oil filters processing, Waste oils and sludges, contaminated soils Operational
and contaminated soils processing
treatment
Enva - Shannon W0041-01 Treatment General chemical waste treatment and Acid and alkali waste, photographic waste, Operational
and transfer storage prior to export industrial sludges, laboratory waste,
solvents blending, other industrial and
commercial chemical waste
Indaver - Dublin W0036-02 Transfer Waste transfer station and solvent Solvents blending Operational
Port and blending plant
treatment
cont’d
117 Please refer to http://www.epa.ie/terminalfour/waste/index.jsp for information on hazardous waste facility licences. Please also check with Local Authorities for facilities that are
permitted to accept certain hazardous wastes.
| 115
116 |
cont’d
Number facility
Safety Kleen W0099-01 Transfer Solvents and chemical waste storage See operations Operational
Ireland Ltd prior to export
Enva - Dublin W0196-01 Pre- Waste oil and oily sludges transfer Physical chemical treatment of aqueous Operational
treatment wastes and storage of packaged wastes on
and transfer site for onward recovery/disposal
Enva - Cork W0145-02 Pre- Storage of waste oils for onward See operations Operational
treatment recovery to Enva Portlaoise
and transfer
Rilta Environmental W0185-01 Treatment Processing waste transformers and See operations Operational
Ltd and transfer storage of waste fridges
SRCL Ltd W0055-02 Treatment Treatment of healthcare risk and related Healthcare risk waste Operational
and transfer waste
Irish Lamp WFP- Treatment Processing fluorescent lamps, treatment See operations Operational
Recycling KE-08-0348-01 and transfer of WEEE
KMK Metals W0113-04 Treatment Metal-rich wastes and sludges storage WEEE Operational
Recycling Ltd and transfer prior to export
Electronics WFP- Treatment WEEE treatment WEEE Operational

Recycling DC-09-0015-01
Hi-Volt Ireland Ltd W0267-01 Transfer Accepts waste batteries, waste Storage Operational
oil, waste oil filters, waste tyres,
contaminated soil
Rehab Recycle WPR033/2 Treatment WEEE treatment WEEE Operational
cont’d
cont’d
Number facility
Electrical Waste WFP- Transfer Accepts small WEEE and refrigeration WEEE Operational
Management Ltd DS-09-0012-01 equipment
The Recycling WFP/ Treatment Processing of CRTs and monitors WEEE Operational
Village MH/11/0005/01
Indaver Ireland W0186-01 Treatment Integrated waste management facility, Chemical waste including solvents Not
Limited - including incineration operational
Ringaskiddy
Further facilities (e.g. in Dublin City Council’s administrative area) that are also permitted to accept certain hazardous wastes include:
➤➤ Padraig Thornton Waste Disposal Ltd (WFP-DC-09-0005-01),
➤➤ The Hammond Land Metal Company Ltd (WFP-DC-09-0013-01),
➤➤ Summerhill Spares Ltd (WFP-DC-10-0018-01),
➤➤ Chevron Environmental Ltd (WFP-DC-09-0015-01),
➤➤ Tom Murphy Recovery & Towing Services Ltd (WFP-DC-11-0027-01),
➤➤ Rogers Recycling Ltd (WFP-DC-11-0030-01),
➤➤ Padraig Thornton Waste Disposal Ltd (WFP-DC-12-0033-01),
➤➤ Blancomet Recycling IE Ltd (WFP-DC-12-0034-01)

| 117
118 |
Figure 12 Hazardous waste licensed facilities in Ireland

APPENDIX D - Alternative hazardous waste treatment techniques
Table 32 Alternative hazardous waste treatment techniques
Technology Description Status Relevance in Ireland
Advanced This system involves advanced Established Ireland produces aqueous

oxidation oxidation treatment which can organic waste streams (e.g. from
include, for example, the treatment PharmaChem industry) and therefore
of aqueous organic wastes. This this is an available option.
system uses UV and oxidation to
destruct complex organic species in
aqueous waste and to render them
biodegradable.
Ball Milling Dry, solid and non-concentrated Emerging Ireland currently produces a limited
persistent organic pollutants amount of the relevant POPs waste
(POPs) are dehalogenated and and is therefore unlikely to be a
converted to a fine powder relevant location for the application
through mechanical and chemical of this technology at commercial
processes. scale.
Base BCD is a thermal process involving Established Ireland produces a limited amount of
Catalysed De- the removal of chlorine from PCB chlorinated solvents and is therefore
chlorination waste by the addition of a base unlikely to be a relevant location for
(BCD) and a catalyst. the application of this technology | 119
at commercial scale. Were it to
become available in EU countries it
could offer a treatment avenue for
chlorinated wastes from Ireland to
compete with incineration.
Catalytic Catalysts can convert hazardous Emerging Were the technology to become
Treatment waste into inert or safer material available at commercial scale in EU
using lower temperatures and countries it could offer a treatment
allowing for safer incineration. This avenue for chlorinated wastes from
technology is applicable to difficult Ireland to compete with incineration.
waste streams such as POPs and
chlorinated solvents.
Gasification Gasification is a process that Established Gasification is a proven technology
converts carbon based waste for treatment of several waste
streams under low pressure and streams.
high temperature in the absence of
oxygen into a gas product which
can be used to generate electricity
or steam.
cont’d
cont’d
Gas Phase The process involves the chemical Established The technology is costly to operate
Chemical reduction of organic compounds, and not cost-effective for low
Reduction such as PCBs, dioxins and POPs, by strength waste or small scale
(GPCR) hydrogen at 875°C to methane, operations. Given the high costs,
hydrogen chloride and small the technology is likely to be first
amounts of low molecular weight employed on difficult waste streams
hydrocarbons. such as POPs and chlorinated
solvents, of which Ireland currently
produces limited quantities. Were
the technology to become available
at commercial scale in EU countries
it could offer a treatment avenue for
chlorinated wastes from Ireland to
compete with incineration.
Molten Metal A molten metal bath causes the Emerging This process is applicable to
dissociation of the hazardous wastes which are in reasonably
waste into its elements, which homogeneous phases. Wastes
dissolve in the liquid metal comprising predominantly inert
solution. Adding co-reactants material such as soil cannot be
and/or controlling the operating treated. The technology is costly to
conditions can produce products of operate due to significant volumes
120 | commercial value. All waste types of off-gases that require treatment
with the exception of soil, sludges using conventional gas cleaning
and other solids with high mineral systems, which involve considerable
content. capital cost.
Molten Slag Waste is mixed with steelworks Promising This technology has not been
dust and fluxing agents, which is proven.
dried and then fed on to molten
iron in an electric arc smelter. The
metal oxides are reduced to metals
and the organic materials are
converted to their basic elements.
Molten Salt Molten Salt Oxidation is a thermal Established Generally, the cost of treatment
Oxidation treatment process for hazardous with this technology is relatively
(MSO) waste, which oxidises the organic high because of the high capital
material while retaining the cost of the equipment, the
inorganic material in the salt. labour requirements and the high
Organic liquids (high and low energy cost. Given high costs,
volatility) and other materials with the technology is likely to be first
a significant organic content. Inert employed on difficult waste streams
waste is not suitable for treatment such as POPs and chlorinated
in the molten salt system. solvents, of which Ireland produces
limited quantities.
PCB Gone The process reduces the Established The process is limited to transformer
concentration of PCB in oils. It is unlikely that the quantities
transformer oil by dechlorination. generated in Ireland will make a
facility cost-effective.
cont’d
cont’d
Plasma Arc The Plasma Arc process involves Established The technology is costly to operate
Technologies the use of high temperatures to (Plascon), and not cost-effective for low
(PACT / PWC / destroy feed material. Organic Emerging strength waste or small scale
Plascon) material is vaporised and (PWC), operations. Were the technology
decomposed by the heat and Transition to become available at commercial
then ionised by the air. Inorganic (Pact) scale in EU countries it could offer a
material is vitrified. treatment avenue for asbestos and
fly ash from Ireland to compete with
landfilling.
Supercritical SCWO destroys organic hazardous Emerging Due to the limitation in waste
Water waste at temperatures and accepted by the technology, it
Oxidation pressures above the waste’s is unlikely that the quantities
(SCWO) thermodynamic critical point. generated in Ireland will make a
Under these conditions the facility cost-effective.
water becomes fluid causing
the chlorinated hydrocarbons to
become soluble and the salts to
precipitate out. This technology is
limited to the treatment of waste
which is liquid or has a particle
size less than 200 μm and is most
applicable to wastes with an | 121
organic content of less than 20%.
Solvated The process involves mixing Emerging Ireland currently produces a limited
Electron anhydrous ammonia with the amount of the relevant POPs and is
Technology hazardous waste producing a therefore unlikely to be a relevant
solvated electron solution. The location for the application of this
solvated electrons bond to the technology at commercial scale.
ions of the contaminated material
neutralising the waste.
Steam High temperature steam (100 Promising Limited data available on this
Detoxifier -1500°C) is used to destroy waste. technology
Vent gases are carbon dioxide and
water. This technology is mainly
limited to the treatment of liquid or
aqueous wastes.
Thermal The process involves the physical Established This technology is relevant in
Desorption separation under temperature the Irish context as it can treat a
ranging from 90 to 650ºC wide range of contaminants and
of volatile and semi-volatile the system can be mobile. After
contaminants from soils, treatment, additional soil processing
sediments, slurries, and filter cakes. may be required.
Alkaline A metal hydroxide-based solution Established This technology is relevant in the
Hydrolysis reacts with contaminated bone Irish context as a localised solution
meal, animal-by-products, bovine to treat animal or human tissues.
risk material, hospital cytotoxic Processing capacity may be limited.
wastes to break down the major
constituent of cells and tissues.
CEROX and Mediated electro-chemical Promising No commercial experience of this
Silver II oxidation. technology
APPENDIX E - Radioactive waste

The Radiological Protection Institute of Ireland (RPII) is the Competent Authority in Ireland with
responsibility for, inter alia, the licensing and regulation of radioactive sources. Since the establishment
of the radiological licensing framework in 1977, the RPII (and its predecessor the Nuclear Energy Board)
has expressed concern at the lack of indigenous infrastructure to deal with radioactive waste arising
from the legitimate use of radioactive sources in Ireland.
Since the early 1990s licences for the custody and use of radioactive sources have only been granted
by the RPII where a “take-back” agreement has been entered into with the supplier. This policy was
adopted with a view to minimising the amount of radioactive waste to be managed in Ireland once
sources are no longer required. While this approach is not without some problems, it has worked
reasonably well in the intervening period. However, as radioactive sources had been in use or custody
in Ireland for many decades prior to the adoption of this policy, there are a significant number of legacy
sources that are of no further use and these remain without a return or disposal route in Ireland.
In October 2011, it was established that there were 3292 radioactive sources in Ireland held by 85
licensees with half-lives greater than ten years for which no further use was foreseen. Such sources
require significant management in terms of safety and security until a central waste storage facility is
established or a disposal route is identified. In addition, there were also other sources of less radiological
concern but with similar difficulties in terms of storage and disposal. These included technetium-99m
122 | generator cores held by hospitals (accumulated by nuclear medicine departments during the 1970s
and 1980s when no return route for these generators existed), small disused sources and thorium and
uranium compounds held by post-primary schools. While responsibility for radioactive sources clearly
rests with licensees, the safety and security of sources, particularly when they have a high radioactive
content and/or are no longer in use, give rise to a heightened level of concern. This concern is reflected
internationally where the potential for the diversion of such sources for malevolent purposes is now
under active consideration. In addition, some of the most lethal radiological accidents globally have
involved disused sources falling out of regulatory control and have resulted in the loss of life as well as
widespread radioactive contamination of the environment.
Ireland does not have a national storage facility to assist in the management and storage of radioactive
waste and disused sources as well as those that are occasionally discovered – the so called ‘orphan’ sources.
The RPII has long identified the lack of such a facility as a serious gap in the current waste management
infrastructure with potential implications for safety and security. In response to these concerns, in
December 2010 the Government adopted a national policy on radioactive waste management for
Ireland. Two of the key initiatives under this policy are the establishment of a centralised storage facility
for interim storage and management of radioactive waste and residual sources, and the roll out of a co-
ordinated and phased Inventory Reduction Programme to reduce the inventory of disused sources. The
Reduction Programme commenced in 2011 with lead State Agencies and Government departments
tasked with driving source disposal programmes within their respective sectors. Between 2011 and
2013 approximately 99% of all disused sources with half-lives greater than ten years were successfully
exported out of Ireland to disposal and recycling facilities in Europe and the USA. In addition, almost
5600 spent technetium-99m generator cores were also disposed of during 2012 and 2013. Figure
13, which shows the amount of disused sources held within the various sectors, clearly illustrates the
substantial progress made on this initiative since 2008.
The Government has also agreed an operational protocol for seized and orphan sources which sets out
responsibilities for RPII, Government departments and key stakeholders to ensure that these sources are
dealt with in a safe and secure manner.
However, with the transposition in August 2013 of the Euratom Waste Directive (Council Directive
2011/70/Euratom) into national legislation, it is no longer possible to export radioactive waste or
disused sources to overseas facilities for disposal. Instead, only material that can be recycled or reused
can be exported. In the absence of a national storage facility, this restriction on what can be exported
out of Ireland will create difficulties for any future seized, orphan or disused radioactive sources where
take back agreements are not honoured or are not deemed suitable for recycling or re-use, requiring
them to be safely managed within Ireland.
In line with Government policy enunciated in December 2010, the RPII reiterates its long held view that
a central radioactive waste storage facility be established as soon as possible in Ireland for the interim
storage and management of radioactive waste materials.
2500 Medical
Education
Radioactive Sources (no.)
2000 | 123
Industry (Private)
1500
State
1000
500
0
2006 2008 2011 2012 2013
Figure 13 Disused source inventory by sector (half-life >10 yr)

APPENDIX F - Estimated Unreported Waste

Table 33 Characteristics and estimated scale of unreported hazardous waste 118 119 120
Hazardous Characteristics Estimated Updated position

waste unreported (e.g. 2011 data,
category in 2006 where available)
(tonnes)
Paint and ink Unused or surplus paint and ink from 7,513 1,448 tonnes
packaging households, trade and industry. A poor collected at civic
collection infrastructure for householders amenity sites, 4,713
and the trade contributes to the problem. tonnes exported.
(Deco-paints Regulations reduce solvent
content and may reduce quantity of waste).
Small Certain waste portable (consumer) batteries 1,496119 2,096 tonnes portable
batteries118 and button cells are hazardous waste, such batteries placed on
as nickel-cadmium batteries and mercury market in 2011. 600
cells. During collection these are usually tonnes collected in
mixed with non-hazardous batteries such 2011.
as alkaline batteries, leading to hazardous
waste class.
124 | Spent sheep dip Sheep dips used to control ectoparasites 3,600 20,195 tonnes
in sheep are based on two main chemical generated per year
substances, organophosphates and (based on average
cypermethrin. Approx. 20,195 tonnes of over a three year
waste sheep dip is generated per annum in period. Data sourced
Ireland, 85% is organophosphate based, the from information
remaining 15% being cypermethrin. This provided by the Irish
waste sheep dip is currently landspread in Medicines Board).
accordance with guidance issued by the
DAFM under cross-compliance120.
Fluorescent Tubes and compact fluorescent lamps (CFLs 2,267 1,049 tonnes
lamps – low energy bulbs). (Fluorescent lamps placed on market;
contain mercury.) 392 tonnes lamps
collected, 119 tonnes
exported.
Waste oils Used engine and machine lubrication oil 2,000 328 tonnes waste
from garages, industry, DIY, maintenance, mineral oils & filters
etc. collected at civic
amenity sites, 633
tonnes waste oil
exported. 30 tonnes
oily sludges exported.
118 The Batteries Directive (2006/66/EC) provides three classes of batteries including portable batteries, automotive batteries
and industrial batteries
119 The figure indicated in the previous plan (5,361 tonnes) has been revised as more data are available for this year.
120 Department of Agriculture and Food. 2005. The Single Payment Scheme – Guide to Cross Compliance. Under cross-
compliance, inspections are carried out by the DAFM for compliance with the Ground Water Directive (Statutory
Management Requirement SMR 2) for the management of sheep dip.
Hazardous Characteristics Estimated Updated position
waste unreported (e.g. 2011 data,
category in 2006 where available)
(tonnes)
Oil filters Vehicle oil filters from the servicing of road 362 Civic amenity site
vehicles. collections as above,
654 tonnes exported.
Solvents From dry cleaners (perchlorethylene or 220 171 tonnes PERC

“perc”) and other small scale commercial imported, 100 tonnes
users. Solvent Regulations have much used in dry cleaning.
improved management of product and
waste.
Lead acid Originating from garages, farms, households 177 12,522 tonnes placed
batteries and other industrial applications. Lead is on market; 15,374
recovered from lead acid batteries for its tonnes exported
market value. as per Batteries
Regulations.
Dental Dental amalgam contains mercury. 0.5 International treaty on

amalgam the control of mercury
agreed in 2013.
Other A range of hazardous wastes can be put 4,890 201 tonnes collected
household in domestic bins and end up in landfill. For at civic amenity sites. | 125
hazardous example, household chemicals, garden
waste chemicals, cleaning agents, medicines and
other materials.
Other Comprising oily wastes, animal health care 3,218 UK Model/Eurostat

agricultural wastes, machinery waste, contaminated waste estimates
hazardous packaging, paints and batteries. based on 2010 data
waste (tonnes):
End-of-life machinery/
tractors: 4,077
Waste oils (engine
and hydraulic): 1,697
Batteries: 366
Waste metal oil
drums: 70
Animal healthcare
waste: 23
CFC containing waste
equipment: 8.
Other office A wide range of product wastes, batteries, 280 WEEE and Batteries
and commercial fluorescent lamps, printer inks and toner, Regulations have
waste cleaning agents, and other wastes. much improved
collection rates.
Total estimated generation of unreported hazardous 26,024 ?- Incomplete

waste tonnes Dataset
Unreported hazardous waste is estimated by a number of methodologies:
➤➤ Mass flow analysis: There is a direct relationship between the use of certain products and the
amount of hazardous waste that arises as a result of their use. Central Statistics Office data
on imports and exports, combined with data on indigenous production, allows estimates to
be made of the sale of certain products and hence the likely level of waste generation (e.g.
lubrication oil).
➤➤ Examination of hazardous waste arisings in other countries: For some sectors, no

comprehensive records exist in Ireland and quantities were estimated from factors derived
from international data.
➤➤ Other methodologies: Use is made of data from a wide variety of sources, and of specific
studies carried out on certain products or hazardous waste streams.
126 |
An Ghníomhaireacht um Chaomhnú Comhshaoil RIALÚ ASTUITHE GÁIS CEAPTHA TEASA NA
HÉIREANN
Is í an Gníomhaireacht um Chaomhnú Comhshaoil (EPA)
• Cainníochtú astuithe gáis ceaptha teasa na hÉireann i
comhlachta reachtúil a chosnaíonn an comhshaol do
gcomhthéacs ár dtiomantas Kyoto.
mhuintir na tíre go léir. Rialaímid agus déanaimid maoirsiú ar
• Cur i bhfeidhm na Treorach um Thrádáil Astuithe, a bhfuil
ghníomhaíochtaí a d’fhéadfadh truailliú a chruthú murach sin. baint aige le hos cionn 100 cuideachta atá ina mór-
Cinntímid go bhfuil eolas cruinn ann ar threochtaí comhshaoil ghineadóirí dé-ocsaíd charbóin in Éirinn.
ionas go nglactar aon chéim is gá. Is iad na príomh-nithe a
bhfuilimid gníomhach leo ná comhshaol na hÉireann a chosaint TAIGHDE AGUS FORBAIRT COMHSHAOIL
agus cinntiú go bhfuil forbairt inbhuanaithe. Is comhlacht • Taighde ar shaincheisteanna comhshaoil a chomhordú (cosúil
le caighdéan aeir agus uisce, athrú aeráide, bithéagsúlacht,
poiblí neamhspleách í an Ghníomhaireacht um Chaomhnú
teicneolaíochtaí comhshaoil).
Comhshaoil (EPA) a bunaíodh i mí Iúil 1993 faoin Acht fán
nGníomhaireacht um Chaomhnú Comhshaoil 1992. Ó thaobh an MEASÚNÚ STRAITÉISEACH COMHSHAOIL
Rialtais, is í an Roinn Comhshaoil, Pobal agus Rialtais Áitiúil. • Ag déanamh measúnú ar thionchar phleananna agus
chláracha ar chomhshaol na hÉireann (cosúil le pleananna
ÁR bhFREAGRACHTAÍ bainistíochta dramhaíola agus forbartha).
CEADÚNÚ PLEANÁIL, OIDEACHAS AGUS TREOIR CHOMHSHAOIL

• Bíonn ceadúnais á n-eisiúint againn i gcomhair na nithe seo • Treoir a thabhairt don phobal agus do thionscal ar cheisteanna
a leanas chun a chinntiú nach mbíonn astuithe uathu ag cur comhshaoil éagsúla (m.sh., iarratais ar cheadúnais, seachaint
sláinte an phobail ná an comhshaol i mbaol: dramhaíola agus rialacháin chomhshaoil).
• áiseanna dramhaíola (m.sh., líonadh talún, loisceoirí, • Eolas níos fearr ar an gcomhshaol a scaipeadh (trí
stáisiúin aistrithe dramhaíola); cláracha teilifíse comhshaoil agus pacáistí acmhainne do
• gníomhaíochtaí tionsclaíocha ar scála mór (m.sh., bhunscoileanna agus do mheánscoileanna).
déantúsaíocht cógaisíochta, déantúsaíocht stroighne,
stáisiúin chumhachta); BAINISTÍOCHT DRAMHAÍOLA FHORGHNÍOMHACH
• diantalmhaíocht; • Cur chun cinn seachaint agus laghdú dramhaíola trí
• úsáid faoi shrian agus scaoileadh smachtaithe Orgánach chomhordú An Chláir Náisiúnta um Chosc Dramhaíola, lena
Géinathraithe (GMO); n-áirítear cur i bhfeidhm na dTionscnamh Freagrachta
Táirgeoirí.
• mór-áiseanna stórais peitreail;
• Cur i bhfeidhm Rialachán ar nós na treoracha maidir le
• scardadh dramhuisce;
Trealamh Leictreach agus Leictreonach Caite agus le Srianadh
• dumpáil mara. Substaintí Guaiseacha agus substaintí a dhéanann ídiú ar an
gcrios ózóin.
FEIDHMIÚ COMHSHAOIL NÁISIÚNTA
• Plean Náisiúnta Bainistíochta um Dramhaíl Ghuaiseach a
• Stiúradh os cionn 2,000 iniúchadh agus cigireacht de fhorbairt chun dramhaíl ghuaiseach a sheachaint agus a
áiseanna a fuair ceadúnas ón nGníomhaireacht gach bliain. bhainistiú.
• Maoirsiú freagrachtaí cosanta comhshaoil údarás áitiúla thar
sé earnáil a er, fuaim, dramhaíl, dramhuisce agus caighdeán STRUCHTÚR NA GNÍOMHAIREACHTA
uisce.
• Obair le húdaráis áitiúla agus leis na Gardaí chun stop a chur Bunaíodh an Ghníomhaireacht i 1993 chun comhshaol na
le gníomhaíocht mhídhleathach dramhaíola trí comhordú a hÉireann a chosaint. Tá an eagraíocht á bhainistiú ag Bord
dhéanamh ar líonra forfheidhmithe náisiúnta, díriú isteach lánaimseartha, ar a bhfuil Príomhstiúrthóir agus ceithre
ar chiontóirí, stiúradh fiosrúcháin agus maoirsiú leigheas na Stiúrthóir. Tá obair na Gníomhaireachta ar siúl trí ceithre Oifig:
bhfadhbanna.
• An dlí a chur orthu siúd a bhriseann dlí comhshaoil agus • An Oifig Aeráide, Ceadúnaithe agus Úsáide Acmhainní
a dhéanann dochar don chomhshaol mar thoradh ar a • An Oifig um Fhorfheidhmiúchán Comhshaoil
ngníomhaíochtaí. • An Oifig um Measúnacht Comhshaoil
• An Oifig Cumarsáide agus Seirbhísí Corparáide
MONATÓIREACHT, ANAILÍS AGUS TUAIRISCIÚ AR AN
GCOMHSHAOL Tá Coiste Comhairleach ag an nGníomhaireacht le cabhrú léi. Tá
• Monatóireacht ar chaighdeán aeir agus caighdeáin dáréag ball air agus tagann siad le chéile cúpla uair in aghaidh
aibhneacha, locha, uiscí taoide agus uiscí talaimh; leibhéil na bliana le plé a dhéanamh ar cheisteanna ar ábhar imní iad
agus sruth aibhneacha a thomhas.
agus le comhairle a thabhairt don Bhord.
• Tuairisciú neamhspleách chun cabhrú le rialtais náisiúnta
agus áitiúla cinntí a dhéanamh.
ENVIRONMENTAL PROTECTION AGENCY
An Ghníomhaireacht um Chaomhnú Comhshaoil
Headquarters and South East Region

Environmental Protection Agency
PO Box 3000, Johnstown Castle Estate
County Wexford, Ireland
Bosca Poist 3000, Eastát Chaisleán Bhaile Sheáin
Contae Loch Garman, Éire
T: +353 53 916 0600
F: +353 53 916 0699
Seville Lodge, Callan Road, Kilkenny, Ireland

Cigireacht Réigiúnach, Lóiste Sevilla,
Bóthar Challainn, Cill Chainnigh, Éire
T: +353 56 779 6700
F: +353 56 779 6798
South/South West Region

Inniscarra, County Cork, Ireland
Inis Cara, Contae Chorcaí, Éire
T: +353 21 487 5540
F: +353 21 487 5545
East/North East Region

McCumiskey House, Richview
Clonskeagh Road, Dublin 14, Ireland
Teach Mhic Chumascaigh
Dea-Radharc, Bóthar Cluain Sceach
Baile Átha Cliath 14, Éire
T: +353 1 268 0100
F: +353 1 268 0199
The Glen, Monaghan, Ireland

Cigireacht Réigiúnach, An Gleann
Muineachán, Éire
T: +353 47 77600
F: +353 47 84987
West/North West Region

John Moore Road
Castlebar, County Mayo, Ireland
Bóthar Sheán de Mórdha
Caisleán an Bharraigh, Contae Mhaigh Eo, Éire
T: +353 94 904 8400
F: +353 94 902 1934
E: [email protected]
W: www.epa.ie
LoCall: 1890 33 55 99
© Environmental Protection Agency 2014

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National Hazardous Waste

National Hazardous Waste Management

ENVIRONMENTAL PROTECTION AGENCY

T +353 53 916 0600

© Environmental Protection Agency 2014

National Hazardous Waste Management Plan

Published by the Environmental Protection Agency, Ireland

PRINTED ON RECYCLED PAPER

Executive summary viii

1.1 What can, and cannot, be achieved by this revised Plan 2

2. Hazardous waste legislation 11

2.1 International - Basel Convention on the Control of Transboundary

3. The national hazardous waste profile 24

3.1 Managed (reported) hazardous waste 24

3.4 Contaminated soil 38

4. Prevention of hazardous waste 42

4.1 Definition of prevention 42

5. Unreported hazardous waste 61

5.1 The current situation 61

6. Treatment of hazardous waste 73

6.1 The current situation 73

6.7 Difficult wastes 90

7.1 Closed landfills 93

8.1 Summary of recommended actions and responsibilities 100

APPENDIX A - List of submissions 110

APPENDIX C - Hazardous waste facilities 115

APPENDIX D - Alternative hazardous waste treatment techniques 119

APPENDIX E - Radioactive waste 122

APPENDIX F - Estimated unreported waste 124

Furthermore, the 2012 Government Policy on Waste Management1 states:

The objectives of the revised Plan are:

2. To maximise the collection of hazardous waste with a view to reducing the

3. To strive for increased self-sufficiency in the management of hazardous waste and

4. To minimise the environmental, health, social and economic impacts of hazardous

Hazardous waste generation and management

2 European Communities (Waste Directive) Regulations 2011 (S.I. 126 of 2011)

Table 1 Summary of hazardous waste management, 2006-2011 (excluding contaminated soil) 3 4 5

Category 2006 2007 2008 2009 2010 2011

Exported (t) 134,904 147,542 157,207 150,395 143,180 149,037

Figure 1 Trends in the location of hazardous waste treatment, 2006-2011

➤➤ collection of hazardous waste and the enforcement of hazardous waste regulations;

➤➤ moving towards self-sufficiency in hazardous waste management;

➤➤ guidance and awareness; and

A summary of these recommendations is presented below.

Consolidation of waste legislation and cooperation in enforcement is recommended. A review of

Guidance and awareness

➤➤ the prevention and minimisation of hazardous waste;

➤➤ the collection and movement of hazardous waste; and

➤➤ the disposal of such hazardous waste as cannot be prevented or recovered.

1.1 What can, and cannot, be achieved by this revised Plan

Additionally, in order to be granted an industrial emissions licence, a waste licence or a permit,

1.2 Structure of this document

Figure 2 Structure of the revised National Hazardous Waste Management Plan

1.3 The objectives of this revised Plan

3. To strive for increased self-sufficiency in the management of hazardous waste and to

1.4 Strategic Environmental Assessment & Appropriate

Figure 3 Summary of Strategic Environmental Assessment stages

1.5 Implementation of the Second Plan

Table 2 Were the second Plan’s objectives achieved?