Paper manufacturing waste and hazardous substances
Waste and hazardous substances from businesses in the paper and cardboard industry can cause pollution if they are not dealt with correctly. The paper industry includes paper and paperboard manufacturers, and businesses that produce paper and paperboard products. It also includes businesses that carry out finishing activities, such as coating, covering, laminating and embossing paper or cardboard.
You must comply with waste legislation such as your duty of care when you dispose of wastes. Waste materials produced by paper manufacturing businesses might include trim and off-cuts, off-specification products, packaging, inks, coatings and office equipment. You may also use hazardous substances such as solvents and chemicals. Using hazardous substances efficiently can help you reduce waste, minimise costs and meet legal requirements.
This guide explains your responsibilities for dealing with waste and hazardous substances, including hazardous waste, waste electrical and electronic equipment, wastewater, oil and fuel, chemicals and solvents.
Paper manufacturing waste responsibilities
You are responsible for ensuring that controlled waste you produce, store, treat, transport or dispose of does not harm the environment. This is called your duty of care.
Controlled waste is commercial, industrial and household waste, and may include hazardous waste, agricultural, construction and demolition waste.
Types of paper manufacturing waste
Waste materials produced by paper and cardboard businesses include:
- off-specification products
- trim and off-cuts
- waste pulp and wood chips
- staples, paper clips, plastic, wire or other contaminants
- used packaging
- waste oil, lubricants and fuel
- containers containing chemical residues
- residues or unusable chemical products, such as solvents, adhesives, coatings, inks, varnishes and biocides
- sludges, eg from cooling tanks and effluent treatment plants
- office or kitchen equipment
- pollution containment equipment that has been used on spills
Check if you need a permit, licence or exemption
You must have a pollution prevention control (PPC) permit, waste management licence or registered waste exemption from the Northern Ireland Environment Agency (NIEA) to use, store, collect, treat, recover, dismantle, recycle, burn or otherwise dispose of waste.
In some cases you may not need to register an exemption but you will still need to comply with the terms of an exemption. For example, you can usually store your own waste where it was produced temporarily, while you wait for it to be removed from your site.
Apply the waste management hierarchy
You must apply the waste management hierarchy when you transfer waste. This means you must consider reusing or recycling your waste before deciding to dispose of it.
If you have a waste management licence for an operation which generates waste, you will have to apply the waste management hierarchy. This will be a condition of new waste management licences, and will be added to existing licences when they are reviewed.
Use authorised businesses to deal with your waste
If your waste is collected by a waste carrier, broker or dealer you must check that they are registered or exempt from registration. Ask to see their certificate of registration or a certified copy. If you do not check and keep proof of this you could be held responsible if your waste is disposed of illegally, for example by fly-tipping - see how to check your waste is dealt with correctly.
If you take your own waste to another site you must check that the site has the appropriate PPC permit, waste management licence or registered exemption for your type of waste.
Check if you need to register as a waste carrier
You can transport most waste produced by your own business directly to an authorised waste management site or recycling facility without being registered.
You must register with NIEA as a waste carrier if you transport:
- construction and demolition waste produced by your own business
- any waste produced by another business
See our guide on waste carriers, brokers and dealers.
Use waste transfer notes
You must have a waste transfer note (WTN) for every load of waste you pass on or accept. WTNs must be completed and signed by both the person sending the waste and the person receiving the waste. You must keep copies of all your WTNs for at least two years.
Pre-treat waste for landfill
You must make sure that your waste is treated before it goes to a landfill site. This applies to most types of waste. You can either treat your waste yourself or make sure that a later holder of the waste will treat it before they send it to a landfill site - see sending waste to landfill.
Follow hazardous waste controls
You must check if you have hazardous waste that may be harmful to human health or the environment. Most businesses produce some hazardous waste, such as fluorescent tubes and some types of batteries, computer monitors and paints.
You must comply with additional legal requirements for hazardous waste - see hazardous waste responsibilities for paper and cardboard producers.
Prevent pollution from spills of waste
You must ensure that you don't cause pollution when you store and transport your waste. Separate different waste materials and store them in covered, waterproof containers with clear labels.
Prepare a pollution incident response plan. Ensure accidental spills can be contained. Keep spill kits at your site and portable spill kits in vehicles used to transport waste materials - see pollution incident prevention at paper and cardboard production sites.
Good practice in paper manufacturing
You can save money and help the environment by reducing the amount of waste you produce.
Keep lightweight material covered so that it does not blow about your site or cause a nuisance to your neighbours.
Paper manufacturing hazardous waste responsibilities
Your business is likely to produce some hazardous waste, which is harmful to human health or the environment. This waste may be flammable, corrosive, or ecotoxic - toxic to people or the environment.
Examples of hazardous waste from paper manufacturing
Hazardous waste produced by paper and cardboard businesses includes:
- residues or unusable chemical products, such as solvents, adhesives, coatings, inks, varnishes and biocides
- containers that include chemical residues
- sludges, eg from cooling tanks and effluent treatment plants
- waste oil, lubricants and fuel
- some office equipment, including computer monitors and laptops that contain cathode ray tubes
- kitchen equipment containing ozone-depleting substances, eg fridges and vending machines
- fluorescent tubes and energy saving light bulbs
- pollution containment equipment that has been used on hazardous material spills
Identify hazardous waste
If the waste you produce has hazardous properties, you may need to deal with it as hazardous waste. You will find information that can help you make this decision on safety data sheets and product labels. Safety data sheets contain information about substances, including how to store, use and dispose of them safely.
If you intend to discard containers, you must assess whether they are hazardous waste. Containers may need to be classified as hazardous waste if they contain residues of hazardous or dangerous substances or materials. If the residue is hazardous, the whole container will be hazardous waste.
Use and keep copies of paperwork
If your business produces hazardous waste, you must:
- use consignment notes whenever the waste is moved to another location, and keep copies for three years
- keep copies of return to producer forms for three years (these are records of what has happened to your waste)
- notify NIEA at least 72 hours and not more than one month before the waste is moved
- comply with your duty of care for waste
Store hazardous waste safely
You must check if the waste you store is hazardous waste before you store it.
You must store hazardous waste securely and separately from all other waste materials. You must use containers that are sealed, labelled, covered and waterproof.
If you store hazardous waste you may need to comply with the conditions of a waste exemption or you may need a waste management licence.
Transport hazardous waste safely
You can currently carry your own hazardous waste without registering as a waste carrier, unless it is construction or demolition waste. You must still complete a consignment note. However, you will have to register with NIEA as a lower tier waste carrier before 31 December 2013 if you normally and regularly carry your own business waste.
If you carry hazardous waste produced by other businesses, or your own construction or demolition waste, you must usually register as an upper tier waste carrier. If you had a waste carrier certificate before 8 April 2011, it will be classified as an upper tier registration. When your certificate is due to be renewed it will be replaced with an upper tier certificate - see waste carriers, brokers and dealers.
If you pass your waste to someone else to transport for you, you must ensure that they are registered or exempt.
Dispose of hazardous waste correctly
You must ensure that your hazardous waste is disposed of and treated at an appropriate facility. You should recover and recycle your hazardous waste wherever possible.
Look for alternative materials and practices that do not produce, or produce less, hazardous waste.
Provide written instructions for storing and disposing of each type of hazardous waste produced on your premises. Ensure that all employees and contractors follow these instructions.
Paper manufacturing WEEE obligations
Your business is likely to use electrical and electronic equipment such as monitoring and control equipment for production processes. You may also use electrical and electronic equipment in your office or kitchen areas, including computers, telephones, printers, fluorescent light tubes, kettles, fridges and vending machines.
Waste electrical and electronic equipment (WEEE) is the fastest growing type of waste in the UK. You must handle and store it correctly and ensure that it is treated, recycled or disposed of at an authorised facility. Where possible you should reuse WEEE.
Deal with WEEE correctly
Your business must store, collect, treat, recycle and dispose of WEEE separately from other waste.
You must get and keep proof that you gave your WEEE to an authorised waste management company, and that they treated and disposed of it without harming the environment.
You may be able to use a free take-back scheme for WEEE funded by the equipment manufacturer.
If your business manufactures, rebrands, imports, distributes or sells electrical or electronic equipment you may have to comply with additional requirements under the WEEE Regulations.
See our guide on waste electrical and electronic equipment (WEEE).
You must comply with your duty of care responsibilities when dealing with WEEE - see waste responsibilities for paper and cardboard producers.
If your WEEE contains hazardous substances, you will need to treat it as hazardous waste. This includes fluorescent light tubes and televisions that contain cathode ray tubes - see hazardous waste responsibilities for paper and cardboard producers.
If your WEEE contains radioactive materials you will need to comply with additional requirements - see radioactive substances certificates and exemptions for paper and cardboard producers.
Paper manufacturing wastewater treatment responsibilities
Your paper and cardboard production business may treat water or liquid effluents on site, for example using an effluent treatment plant.
Water pollution incidents involving dyes and suspended solids are the most common complaint downstream of paper mills. Make sure that you treat and remove colour from any wash waters before you discharge them to the environment.
Check if you need authorisation to discharge wastewater
Before you discharge wastewater to surface waters or groundwater, you must have authorisation from the Northern Ireland Environment Agency. Your wastewater may be contaminated with a wide range of organic water-soluble pulp components. You will need to treat effluent extensively before you can discharge it to surface waters or groundwater.
Before you discharge wastewater to a sewer, you must get permission from NI Water. You may need to pre-treat your effluent before you discharge it to the sewer.
You must comply with all of the conditions in your authorisation or you may be prosecuted and fined or sent to prison.
If you have an effluent treatment plant you must manage it carefully to comply with the conditions of your authorisation. For example, you may need to monitor and stay within specified limits for the main components of your discharges, such as flow rate, pH, temperature, suspended solids, or chemical oxygen demand. These requirements and limits will be explained in your authorisation.
Comply with waste sludge and screening responsibilities
Materials discarded from your effluent treatment plant, such as sludges and screenings, are classed as waste. You must comply with your duty of care responsibilities when dealing with these and other waste - see waste responsibilities for paper and cardboard producers.
You may need to deal with some sludges and screenings as hazardous waste - see hazardous waste responsibilities for paper and cardboard producers.
Review your chemical use
If you use biocides for system cleaning, slime control and in de-foamers, consider using biodegradable biocides that degrade quickly, such as guanidine and isothiazolones.
Avoid using chlorine-containing bleaches or chlorine-bleached pulps. Bleaching chemicals react with organics and place a considerable load on water treatment systems.
Don't overdose water with water treatment chemicals, especially those containing halogens, eg chlorine and bromine. Use chlorine dioxide in place of halogenated disinfectants for high organic loads.
Use dyes with solid pigments where they can be treated by clarification.
See the page on raw material use in paper and cardboard production.
Manage your effluent treatment plant correctly
Make sure that your systems are designed so that effluent cannot bypass the treatment plant.
If you make a change to your process, always consider the effect this will have on your treatment plant. Effluent treatment plants are designed for specific processes, depending on the quality and quantity of the effluent. For example, if you implement water minimisation measures the concentration of your effluent will increase.
If you carry out batch processes, you should manage your effluent carefully to avoid discharging large quantities to the treatment plant at one time. These 'shock loads' could affect the treatment plant's performance.
If there are a lot of coloured fines during de-inking, consider using dissolved air flotation (DAF) or membrane technology. You can use DAF as a primary effluent treatment, as well as in the de-inking process.
Balancing tanks can help to mix and standardise your effluent. Sludges with poor settlement characteristics (bulking) can be treated by stabilising fluctuations in effluent pH, flow, load and tank conditions and by maintaining your plant regularly.
Treat effluents containing suspended solids separately. This will prevent problems in biological treatment plants.
Cover containers to prevent emissions and odour from chemicals and sludge.
Monitor and maintain your treatment plant
Monitor your effluent plant regularly to make sure it is operating effectively. You could use turbidity meters to monitor effluent quality continuously.
Check your sewerage and effluent disposal costs. Establish a baseline and investigate when costs deviate from it. This could save you money.
Employ suitably qualified engineers to make sure the treatment plant is designed to produce the required quality of effluent and that it will operate effectively.
Minimise the amount of sludge you produce
Reduce the volume of sludge you produce by using dewatering presses or centrifuges. For example, use centrifuges to separate fines in white water and recover reusable material in your production process.
Reduce the load on your treatment plant by minimising your waste and monitoring the volume of water used by your business.
Recycle wastewater whenever possible to reduce the input and load on your water treatment systems. Reducing the water content of the sludge can reduce your waste management costs.
Use water efficiently
Save money on your effluent treatment costs and your water supply by using water more efficiently. You should recycle and reuse water within your process wherever possible.
Keep your wastewater streams separate. This will make it easier to reuse the water and also prevent large wastewater streams being contaminated with concentrated toxic streams.
See the page on water use responsibilities for paper and cardboard producers.
Paper manufacturing fuel and oil use responsibilities
You may use and store oil and fuel for equipment and vehicles on your paper and cardboard production site.
Leaks and spills cause pollution, so it is essential that you store and handle fuels and oil safely. Fuels include petrol, diesel, oil and liquid petroleum gas (LPG).
Store oil safely
If you store any kind of oil on your premises, you may need to comply with a number of regulations controlling its storage. This will depend on how much and what type of oil you store, the type of site you have and the containers you use.
Even if oil storage controls do not apply, you should still store your oils responsibly and consider meeting the requirements of the legislation. This can help you to prevent land and water pollution and avoid prosecution.
Find out if oil storage controls apply to your business.
Prevent major accidents
If you store or use dangerous substances, such as petroleum products or LPG, on your site, you may need to comply with the Control of Major Accident Hazards (COMAH) Regulations.
For example, if you store more than 2,500 tonnes of petroleum products, you must have a major accident prevention policy. If you store more than 25,000 tonnes of petroleum products you must also submit a safety report and prepare an on-site emergency plan.
Supervise all fuel deliveries to your site.
Clearly label all tanks with their contents and storage capacity. You should also label remote filling points. This will reduce the risk of overfilling and spills.
Use drip trays when you refuel mobile or temporary equipment, for example bowsers or generators, and at the fill point when refilling storage tanks. This may be a legal requirement - see storing oil.
Prevent water running off refuelling areas into surface water drains and general yard drainage by using drainage gullies, raised kerbs or appropriate falls. Drain this run-off via an oil separator. You may need permission from the Northern Ireland Environment Agency or Ni Water to discharge wastewater from your oil interceptor.
Ensure your oil separator is properly maintained and works effectively. If your oil separator doesn't work properly, you might cause pollution, and you could be prosecuted or fined.
Prevent drainage system incidents
Keep an up-to-date and accurate drainage plan of your site. This will help you identify the locations of all the drains and sewers and where they lead.
When making a discharge to a drain or sewer, always check you are connecting to the correct system. You should only discharge clean, uncontaminated surface water to the surface water drainage system.
Colour code your drainage system by painting manhole covers, gullies and grills using a recognised colour coding system - blue for surface water drains and red for foul water drains. This will help you to identify which system you are discharging to and where any spills will end up.
Install shut-off valves on your surface and foul water drainage lines so that you can isolate your site drainage if there is a major fuel spill.
Report any pollution incidents as soon as they happen to the NIEA Water Pollution Hotline on Tel 0800 80 70 60.
Paper manufacturing chemical and REACH responsibilities
Your specific business activities will determine what you have to do to comply with the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation. The requirements of REACH often have to be decided on a case-by-case basis. You need to be able to justify the actions that you take. To help you do this, you should document the reasons for your decisions, in case you are challenged.
You may use chemicals for a range of purposes, including paper production and cleaning. You must store and handle chemicals safely to avoid pollution incidents and health risks. Regularly review the hazardous substances you use, make sure you follow any restriction or controls placed on them and where possible use less harmful alternatives.
Does REACH apply to your paper manufacturing business?
The REACH Regulation aims to protect human health and the environment through the control of chemical substances.
If you use, supply or manufacture chemical substances, or import them from outside the European Union (EU), it is likely REACH will affect you in some way.
REACH applies to a wide range of chemical substances on their own, and in preparations or mixtures including coatings, paints, varnishes, inks or dyes and cleaning products. REACH also applies to chemical substances contained in finished products or articles, whether you are manufacturing or supplying them within the EU, or importing them from outside the EU.
Paper is classed as an article under the REACH Regulation.
Chemical users' requirements
You are a chemical user if as a part of your work you:
- use any chemicals or preparations
- use chemicals to formulate or blend preparations or mixtures
- use any chemicals, preparations or mixtures to produce articles
If you use a chemical substance, you must:
- identify and follow all appropriate safety measures identified by the chemical's safety data sheet
- use the substance within its safe exposure limits
- comply with any conditions of authorisation that have been placed on its use by REACH
- not use it in a way that is restricted by REACH
You should check that your suppliers register all the ways you use the chemicals they supply. If you have an unusual use for a substance, you should provide your suppliers with details of how you intend to use the chemical. This will allow them to include this information in their registration. If you do not want to tell your suppliers about your use for a chemical, you may have to carry out a chemical safety assessment for that substance, and submit your assessment directly to the European Chemicals Agency (ECHA).
You should make an inventory or list of chemical substances that your business uses, supplies, manufactures or imports. This will help you understand your responsibilities and the impact REACH will have on your business activities.
Substances of very high concern and restricted chemicals controls
REACH places controls on the supply and use of certain chemical substances on their own, in preparations or mixtures, or in articles. These apply to substances that can be particularly harmful to human health or the environment, for example those that are classified as persistent, bioaccumulative and toxic (PBT).
There are three groups of chemicals that are specifically controlled under REACH:
- the candidate list of substances of very high concern (SVHCs)
- Annex XIV substances - priority SVHCs that require an authorisation for their supply and use
- Annex XVII substances - particular chemicals with restrictions on their supply and use
If you supply or use a chemical substance, on its own, in preparations or mixtures or in articles, make sure that you meet any specific controls that apply to it.
Manufacturing, importing and distributing chemicals
If you manufacture, import or supply chemical substances there are additional REACH responsibilities that you must comply with - see registration, evaluation, authorisation and restriction of chemicals (REACH).
If you manufacture or import chemical substances, products or mixtures you must classify and label them correctly before you put them on the market.
Paper manufacturing solvent use responsibilities
Organic solvents are volatile organic compounds (VOCs), which are chemicals that easily vaporise at room temperature and may be harmful if inhaled. They are used in paper manufacturing and produce emissions that can harm the environment and human health. Solvents are present in many adhesives, inks and paper coatings.
You may use solvents in paper coating and finishing processes such as manufacturing wallpaper, manufacturing release papers, laminating paper or impregnating paper (eg with phenol or formaldehyde-based materials).
Check if you need a permit
If you use organic solvents, you may require a pollution prevention and control permit from the Northern Ireland Environment Agency (NIEA) or your local district council. If you have a permit you must comply with its conditions, which may require you to reduce or control your solvent emissions.
You will need a permit for solvent emissions if you use:
- more than 5 tonnes per year of a solvent-based product for coating paper
- more than 5 tonnes per year of a solvent-based adhesive
Prevent water pollution from solvents
You must not allow solvents to enter surface water drains, surface waters, the ground or groundwater. This causes pollution and you could be prosecuted.
If you intend to discharge solvents to the foul sewer, you must have an authorisation from NI Water.
Ozone-depleting substances (ODS) and fluorinated greenhouse gases (F-gases) in solvents
You must not use solvents containing ODS.
Solvents which contain F-gases that have a high potential to cause global warming are restricted. You must never allow F-gas solvents to vent directly to the air or be discharged directly into drains.
If you operate equipment that contains F-gas solvents you must ensure the solvents are recovered properly during servicing, maintenance and at the end of the equipment's life. This must be done by someone with the correct qualifications - see solvent cleaning: ODS and F-gas controls.
Good practice for solvent use
- replace solvent-based coatings and adhesives with water-based ones
- use abatement equipment to reduce the environmental impact of VOCs from carrier solvents and solvent-based coatings
- consider installing an integrated heat and VOC recovery system
- assess the quantity of formaldehyde, ammonia and VOCs produced by re-pulping broke (paper formed on the machine that is not usable), the papermaking drying sections and the coating section
- monitor the amount of volatile wood compounds you release with the process steam and use a cost-effective abatement process, eg a cyclone to remove dust that is carried along in the steam
- assess whether the release points at your premises are high enough - contact your local NIEA office or your district council for advice