Noor Jahan Majeed – Waste Management Lead1

Jan 2014

Identification & Classification

How do you identify waste as hazardous??

� Health Risk – Toxic, corrosive, harmful, Irritant

� Fire & Explosion Hazard – Explosive, oxidizing, flammable

� Effects to environment - pollutes air, toxic to living organisms, contaminates

waterways, catastrophic effect to flora & fauna

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Classification

It is the responsibility of the waste generator to classify his waste in accordance

with the First Schedule (Reg 2) of the Environmental Quality Act 1974 (Scheduled

Waste) Regulations 2005

Please refer to the SMEP Waste Consignment Note for the guide to classifying

waste commonly generated in SMEP operation.

Compliance (responsibility of waste generators)

In accordance with SMEP Waste Management Procedure

Notification of the generation of scheduled waste

• Immediately notify the Waste Management Unit (LSB) of any waste not listed in the SMEP Waste Consignment

Disposal of scheduled waste

• Shall transfer waste to Labuan Supply Base for temporary storage prior to final disposal

• As far as possible, the SW shall be rendered innocuous prior to disposal

Temporary storage at site

• Ensure proper storage – preferably under shed, or at least covered with canvas to avoid water ingress from

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• Ensure proper storage – preferably under shed, or at least covered with canvas to avoid water ingress from

rain. Waste containers to be placed inside a secondary containment (e.g., a drip pan)

• Signage to indicate storage area, available spill kit, emergency equipment

• Ensure containers are compatible with the waste, durable and which are able to prevent spillage or leakage

which could harm people/pollute the environment

• Incompatible SW shall be stored in separate containers and placed in separate secondary containment

• Avoid using rusting drums as it may not withstand

• Containers shall always be closed during storage, except when it is necessary to add or remove the waste

• Storage area shall be designed, constructed and maintained adequately

• Quantity of SW accummulatively shall not exceed 20 m/t or 180 days (whichever lower) at any one time.

NOTENOTENOTENOTE:::: It is recommended that waste generator sets 160 days as the guide so as to allow buffer forany re-work to ensure compliance / over-due date for disposal.

Compliance (responsibility of waste generators)…..(contd)

Labeling

• Date when the waste are first generated, name, address and telephone no. of the generator shall be

clearly labeled on the containers

NOTENOTENOTENOTE: For labels ordered via eMerlin, the name, address & telephone no. of generator is alreadypre-printed. Pls refer to Slide no. 11 for reference.

• Symbol of hazards shall be as stipulated in the Environmental Quality Act (e.g., symbol for flammable

waste must be in red colour. Photocopy/printed label is allowed provided the symbol is in black and

white).

• Hazard symbol shall be within a 4” x 4” (10cm x 10cm) frame

• No person is allowed to alter the markings and labels

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Packing

• Shall be properly packed – preferably as follows:-- Liquid waste in bung-holed drums/containers, solid/semi-solid waste in clamp-lid drums- Waste container to be palletised @ 4 drs/pallet of 44” x 44” x 4” gap height. This is to facilitate disposal

of the waste into 20fter shipping containers.- Where the waste is sludge, it will be 3 drs/pallet (due to the weight)

Inventory of scheduled waste

• Shall be accurate and up-to-date in accordance with the 5th Sch for a period of up to three (3) years fromthe date the waste is generated.

Transportation of waste

• All waste being transported from source to LSB shall be accompanied with the SMEP Waste Consignment

Note (COG) & relevant MSDS, in dual languages (English & BM)

• Information on the waste COG shall be correctly declared

Compliance (responsibility of waste generators)…..(contd)

Conduct of training

Every waste generator shall ensure that all his employees involved in the identification,

handling, labelling, transportation, storage and spillage or discharge response of SW attend

training programme� Formal training/course conducted by DOE� In-house awareness training/on-the-job training

Additional requirementWaste generator is to provide a valid/relevant account no(s) to the Waste Management Team for thecost of transportation and disposal of waste.

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Where/when in doubt, please contact the Waste Management Team inLabuan Supply Base :

o Noor Jahan (ext-465), oro Juliana Paitin (ext-537)

Non-complianceAny non-compliance against the afore-mentioned requirements will be regarded as an

incident reportable in Fountain.

Temporary storage at site

Temporary scheduled waste storage area

Shed

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Bunded

Concrete floor

Operational control:• A restricted area; only

authorised person(s) areallowed to access/manage thearea;

• Stored by compatibility. In theabsence of concrete/bundedarea – drip pans can be used

• Must be inventorised;

• MSDS & safety signs

• Spill kits, emergency

equipment;

• Emergency response plan

Packing & labeling

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Preferred packing

Open-top / clamp-lid drums packed @ 3 drums /

pallet

Size : 44” x 44” x 4”

Bung-holed drums 4

Size : 44” x 44” x 4”

Bung-holed plastic drums 4

Size : 44” x 44” x 4”

Preferred packing…..(cont’d)

For open-top / clamp-lid drums, to ensure the bolt faces

DOWN, not up

TENORM waste

Drums were not palletised, sent loose inside

the open-top cargo tray

TENORM contaminated waste & scheduled

waste packed on to the same pallet

No certificate of transportation provided

Focal point in LSB

o Tirilos Jaibol, FUI/C/OL

Labeling

Size is 4” x 4” sq (10cm x 10cm)

Clear legible label affixed on EACHcontainer/drum

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Fixed data

Declaration of Scheduled Waste

Scheduled waste to be transferred to the temporary storage area (chemical

warehouse) must comply with the following requirement:-

• Use the SMEP Waste COG & declare with correct information

• Attached CSDS, where available

• Waste is packed in durable container affixed with appropriate hazard label

NOTE

Empty drums

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Empty drums

- Means drums which have been flushed clean & dripped dry of any residual

Contaminated container (drums)

- Means drums/containers with residual- Empty chemical drums, paint containers, lub pails are classified as Contaminated

Containers – not empty drums, etc

Difference between product labels & schedule waste labels

Product hazard label

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Scheduled waste label containswaste code & description, date ofgeneration, name & address ofgenerators

Waste inventory template

*c Method

(A) Actual Oty store (m/t)

(B) Actual Oty

Disposed(m/t)

(A-B) Balance B/F (store)

*d Place

102 USED BATTERY(LEAD)

Type of waste

Date disposed

SCHEDULED/ TENORM WASTE INVENTORY RECORD

LOCATION: Piasau Camp

*a Date Cog. Reference*b WG

(Point of Generation)

Estimated Qty R'cd (m/t)

SW Code

Name of Waste

Waste handling

Balance in storage

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103 USED BATTERY(NICKLE)

110 e-WASTE

305 USED OIL

Non-compliance

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Poor management of waste

Contaminated waste mixed with office waste

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Used/empty paint thin mixed with scrap metal

E-Waste – not segregated, no hazard label

Poor management of waste

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Non-compliance label

Wrong classification of wasteActual content: Oily rags/cloths

This is not a waste hazardlabel

Poor management of waste

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Wrong classification of waste

Strapping tension too tight – may puncture

drum & cause leaks/spills

o Waste declared as Used oil – actual content is

waste of thinner

o Date of generation written as 9-Oct-2013, but

condition of drums suggested that it is more than 6

months overdue

Poor packing & labeling

• Avoid using rusting/bulging drums which may notbe able to withstand normal handling &transportation

• Poorly strapped using manila rope – should usemetal strapping

• More than 1 label being affixed – only 1 label perdrum/container

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Illegible labels – more than 1labels

Poor packing & labeling…..(cont’d)

Rusting/bulging drums

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Leak being plugged with piece of cotton rag

Labeling

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It shall be the responsibility of the waste generators to correctly identify andclassify their waste according to the hazardous nature of their waste.

Examples of scheduled waste hazard Labels

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SW CODE HAZARDOUS (SCHEDULED) WASTE

SW 305 Spent lubricating oil

SW 309 Oil & water mixture

SW 417 Waste Thinner

SW 418 Discarded paints

SW 429 Discarded or off-spec chemicals (liquid)

SW CODE HAZARDOUS (SCHEDULED) WASTE

SW 408 Contaminated soil, debris or matter resulting from cleaning-up of a spill of chemical, mineral oil or SW

SW 409 Contaminated empty drums/containers

SW 410 Rags, plastics, filters or papers contaminated with SW

SW 418 Discarded paints

SW 429 Discarded or off-spec chemicals (Solid)

Examples of scheduled waste hazard Labels…..(cont’d)

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SW CODE HAZARDOUS (SCHEDULED) WASTE

SW 429 Discarded or off-spec chemicals (liquid)

SW 327 Spent Glycol

SW CODE HAZARDOUS (SCHEDULED) WASTE

SW 109 Waste Containing Hg or its compound

SW 110 E-Waste, include spent fluorescent tubes

SW 201 Asbestos wastes

Examples of scheduled waste hazard Labels…..(cont’d)

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SW CODE HAZARDOUS (SCHEDULED) WASTE

SW 404 Clinical waste

SW CODE HAZARDOUS (SCHEDULED) WASTE

SW 311 Oily sludge include waste of SOBM

SW 421 Mixture of scheduled wastes

SW 422 Mixture of scheduled wastes & non-scheduled wastes (including cooking oil)

NOTEWaste generators can affix more than 1 hazard symbol (if necessary), but there shall be onlyONE waste code to be used/displayed on the drum/container.

Transferring of waste from source to LSB

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It shall be the responsibility of the waste generators to correctly identify andclassify their waste according to the hazardous nature of their waste.

Thank y

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