GFML Executive Report

Environmental Legislation Consultation

Edmund Bright
0514618

Academic: Hilary Stone

08-01-2010
 GFML Environmental Legislation Consultation – Executive Report

1 Executive Summary
This report identifies the operations and key characteristics of GFML and
environmental legislation that is applicable to said operations. Other applicable
legislation that does not directly correspond to an operation conducted by GFML,
including noise and contamination, has also been identified and listed. Throughout
the report advice is given on how to reduce GFML’s environmental footprint.

2 Introduction
GFML manufacture parts for the Go Faster Sports car (Go Faster) which is sold in kit
form. GFML also sell spare parts including refurbished parts salvaged from end of
life vehicles (ELV’s). These parts include engines, gearboxes, fuels systems and
braking systems. The products GFML produce and supply are packaged and
shipped worldwide.

This report aims to identify and assess all the activities that GFML perform. It will
also identify, if any, environmental legislation that is applicable to the business
practice and advise on improvement of the processes identified.

3 GFML

3.1 The Company

a. Turnover of more than £2 million.
b. Produce more than 500 vehicles per annum.

3.2 GFML Operations

a. Manufacture components from metal billets and sheet by use of
machining operations.
b. Part assembly from components.
c. Accept End of Life Vehicles for depollution, reuse, recycling and
disposal.
d. Package components and distribute to customers.
e. Clean and refurbish used components for resale.
f. Paint new and refurbished components

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g. Dispose of hazardous and non-hazardous wastes.

h. Do not use ozone depleting substances such as Chlorofluorocarbons
(CFC’s) and Hydrochlorofluorocarbons (HCFC’s).
i. Do not conduct any welding onsite.

3.3 GFML Permitting & Registration Obligations

a. Environmental Permit, for operations including,
i. Treatment and Disposal of End of Life Vehicles.
ii. Storage and use of Solvents.
b. Register with Department for Business, Innovation and Skills (BIS) and
declare responsibility for production of the Go Faster.
c. Conduct an approved collection, treatment and disposal system for
disposal of End of Life Vehicles.
d. Register with Environmental Regulator for Producer Responsibility
Obligation as a packager of goods.

4 The Site & Surrounding Area

Go Faster Motors Ltd (GFML) is located in the Manor Royal Trading Estate (Manor
Royal), Crawley, West Sussex. The site consists of one substantial manufacturing
and assembly area with offices located in an adjacent building.

Manor Royal was established in 1950 for development of Industry in the area of
Crawley and is approximately 2 square miles. It currently consists of companies of
light industry and offices. The land of the surrounding area is residential to the East
and South with Gatwick Airport located to its North. The London-Brighton Railway
line is situated to the West with the M23 motorway located beyond that.

5 Executive Report

5.1 Product Compliance

GFML supply vehicles in kit form and therefore there are no emissions criteria that
the Go Faster must adhere to. However it is advisory to supply components that are
in accordance with Ministry of Transport tests.

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GFML are subject to the restrictions in the use heavy metals in accordance with “The
European End-of-Life Vehicles (ELV) Directive (2000/53/EC)” which is enforced by
“The End-of-Life Vehicles Regulations 2003 SI. 2635” and “The End-of-Life Vehicles
(Producer Responsibility) Regulations 2005 SI 263.” These regulations also state
that all rubber and plastic components on a vehicle, excluding tyres, must be part
marked for identification upon disposal. This ensures that the components are
disposed of appropriately upon disposal. Technical documents detailing these
components and their disposal must be kept for four years and produced if
requested by the Vehicle Certification Agency. This will reduce the environmental
impact in the disposal of GFML ELV’s and also help ensure GFML’s compliance with
the respective ELV directive and regulations in the future.

5.2 Manufacturing and Assembly

GFML conduct machining operations in the manufacturing of components for the Go
Faster. These machines will use lubricants that are classed as Hazardous when it
becomes waste. Although “The Control of Pollution (Oil Storage) (England)
Regulations 2001 SI 2954” may not apply, it is advised to adhere to these
regulations in the storage of the lubricants.

5.3 End of Life Vehicles (ELV)

Upon receipt of an ELV staff at GFML must conduct administrative checks on the
vehicle to ensure its legitimacy. On confirmation of legitimacy the previous owner is
issued with a certificate of destruction and the DVLA notified with reference to “The
End-of-Life Vehicles Regulations 2003 SI. 2635.” These regulations as well as “The
End-of-Life Vehicles (Producer Responsibility) Regulations 2005 SI 263” require
vehicle manufacturers to establish approved systems, free of charge for the
consumer, for collection, treatment and disposal of ELV’s. GFML must register
responsibility for the vehicle components produced and issue dismantling information
and any information with regards to reuse and recycling of components that may be
appropriate.

“The End-of-Life Vehicles (Producer Responsibility) Regulations 2005 SI 263” also

defines targets of depollution and recycling, reuse and recovery for Approved
Treatment Facilities. Before 31 December 2014 85% by weight of the vehicle must

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be recovered and reused and 80% to be reused and recycled. These targets
increase to 95% and 85% respectively from 1 January 2015.

“The European End-of-Life Vehicles (ELV) Directive (2000/53/EC)” requires ELV’s

and their components to be stored and depolluted to a specified standard. The area
in which the ELV’s are stored must have a secondary containment system (SCS) so
that any hazardous materials from the ELV cannot enter the ground. The directive
also states which components are hazardous and require removal. Any components
containing mercury or other heavy metals must be removed and stored appropriately
for disposal. 98% of all fluids in the ELV must also be removed; this can be ensured
by using a depollution unit. The depollution unit will also store the appropriate fluids
separately in storage tanks. It is advisory to log the quantities of fluids removed from
an ELV to aid proof of compliance with depollution measures. The oil filter, wheel
balancing weights and catalytic convertor must also be removed and treated and
disposed of in an approved manner.

GFML must comply with the conditions stipulated by the Environmental Permit
issued by the Environmental Agency.

5.4 Refurbishment & Painting

GFML use solvents and solvent based products in their refurbishment of used parts
as well as in the paints used for painting components. “The Volatile Organic
Compounds in Paints, Varnishes and Vehicle Refinishing Products Regulations 2005
SI 2773” sets limits to control the level of volatile organic compounds present in
these at grams/litre. Elements of good practice and ventilation control should be
introduced to reduce harm to employees and the environment.

“The Control of Substances Hazardous to Health Regulations 2002 SI 2677” and its
amendments stipulate measures of control for the use and exposure of dangerous
chemicals including employer and employee responsibilities.

GFML should keep records of the quantity and source of products containing
solvents, where it was stored and how much of the solvents have been returned to
waste. Material safety data sheets should also be requested on delivery of products.
This will aid GFML understanding how solvent products should be stored and help
identify sources of spillage. The material safety data sheets will give guidance in
resolving spillages and the dangers imposed to the environment and employees.

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It is advised that the solvents used by GFML are stored with respect to “The Control
of Pollution (Oil Storage) (England) Regulations 2001 SI 2954” and “The Control of
Substances Hazardous to Health Regulations 2002 SI 2677”, this will reduce the
likelihood of land or water contamination and aid in the resolution of any spillages.

5.5 Waste Electrical & Electronic Equipment (WEEE)

The “Waste Electrical and Electronic Equipment Regulations 2006 SI 3289” requires
electronic equipment to be depolluted, reused or recycled where possible. This will
include electrical equipment from ELV’s, lights and any other electrical equipment
from offices. Any WEEE must be assessed for hazardous properties and if found to
contain any disposed of appropriately as identified in 5.6.1.

As a distributor of WEEE as components in the Go Faster, GFML must operate a

take back scheme so that the individuals can return any EEE as WEEE. Records
must also be kept to show how much WEEE is returned to GFML.

5.6 Waste Storage & Disposal

5.6.1 Hazardous and Special

GFML must identify hazardous and special wastes with respect to the “List of
Wastes (England) Regulations, Statutory Instrument 2005, No. 895” and its
amendments.

All hazardous liquid waste produced by GFML should be stored in accordance with
“The Control of Pollution (Oil Storage) (England) Regulations 2001 SI 2954” and
“The Control of Substances Hazardous to Health Regulations 2002 SI 2677.” This
stipulates that the liquids are to be stored in appropriate containers and in an area of
the site that has an SCS that will retain 110% of the fluids of the largest container or
25% of all containers, whichever is largest. This minimises the likelihood of spillages
and reduces the potential for hazardous liquids entering the ground or water. The
regulations will also protect the employees from harm and will also ensure that
GFML staff are aware of the dangers imposed.

Solid hazardous wastes such as those removed from ELV’s, Printer toner and
cartridges and fluorescent lighting tubes must also be stored in areas that minimise
risk to employees and the environment. It would be advisable to store said
components in the area where the Oils and Hazardous wastes are located. This will

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localise any potential sources of land contamination and thus increasing ease of
pollution identification and remediation.

The hazardous wastes produce by GFML must be collected and treated by an

approved hazardous waste carrier registered with the Environment Agency. All
hazardous wastes stored, collected and the consignments notes issued, that should
be retained and filed for three years, must be compliant with “The Hazardous Waste
(England and Wales) Regulations 2005 SI 894” and its amendments.

The batteries removed from ELV’s must be recycled by an Approved Battery

Treatment Operator in accordance with “The Waste Batteries and Accumulators
Regulations 2009 SI 890.” This process will meet the regulations that will come into
force on 01/01/2010 preventing automotive batteries to be sent to landfill or
incineration.

5.6.2 Metal
The depolluted ELV’s and other scrap metal produced by GFML should be recycled
by a registered scrap metal handler. There is no applicable legislation for the
recycling of the metal however any metal sent for recycling must be assessed for
hazardous properties, for example swarf produced from machining operations. The
“List of Wastes (England) Regulations, 2005 SI 895” and its amendments should be
referred to in the identification of potential hazardous wastes. If hazardous materials
are identified they must be either treated or stored appropriately and disposed of in
the correct manner. GFML must ensure that the waste metal is accompanied by a
waste transfer note in accordance with “The Environmental Protection (Duty of Care)
Regulations 1991 SI 2839” and that it is sent to an appropriate site for disposal.

5.6.3 General
GFML produce various types of municipal wastes however action should taken to
recycle the where possible. This will reduce the amount of waste being sent to
landfill, save GFML money and reduce its carbon footprint. All remaining waste
deemed non-hazardous is sent to landfill. GFML must ensure that the landfill site to
which this waste is delivered has an Environmental Permit and is suitable for the
types of waste being sent with respect to “Environmental Protection (Duty of Care)
Regulations 1991 SI 2839.”

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5.7 Packaging
GFML package their components for delivery and are therefore subject to “The
Packaging (Essential Requirements) Regulations 2003 SI 1941.” These regulations
put responsibility on the producer to minimise the packaging used and increase the
effectiveness of reuse and recycling of said packaging. GFML must keep records to
show that their packaging is in accordance with “The Packaging (Essential
Requirements) Regulations 2003 SI 1941” for a minimum of 4 years.

GFML uses more than 50 tonnes packaging a year and has a turnover of more than
£2 million and are therefore subject to “The Producer Responsibility Obligations
(Packaging Waste) Regulations 2007 SI 871.” The producer responsibility
obligations require GFML to recover and reuse certain amounts of their packaging
produced.

To reduce the level of packaging used GFML may reuse packaging from goods
bought by the company. This packaging will not be counted towards the total
distributed by GFML and therefore may reduce the amount of packaging that is
required to be recycled, reused and disposed of.

5.8 Other Applicable Legislation

1. “Water Resources Act 1991” – Sets legislation to conserve, manage and
control pollution of water resources.
2. Contaminated Land (England) Regulations 2006 SI 138 – Regulates
identification and remediation of contaminated land.
3. Environmental Damage (Prevention and Remediation) Regulations 2009 SI
153 – Regulation forcing polluters to remediate contamination.
4. Control of Major Accident Hazards Regulations (COMAH) 1999 SI 743 –
Requires users of dangerous materials to have accident prevention policy and
an onsite emergency plan.
5. Environmental Protection Act 1990 – Defines that noise emitted from
premises so as to be prejudicial to health or a nuisance is a statutory
nuisance
6. Clean Neighbourhoods and Environment Act 2005 – Introduces additional
noise controls to Environmental Protection Act 1990
7. Anti-social Behaviour Act 2003 – Empowers local authority to implement
controls over noisy premises.

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6 Bibliography
1. NetRegs. [Online] www.netregs.gov.uk.

2. Office of Public Sector Information. [Online] www.opsi.gov.uk.

3. Department of Environment Food and Rural Affairs. [Online] www.defra.gov.uk.

4. Vehicle Certification Agency. [Online] www.vca.gov.uk.

5. Wikipedia. [Online] www.wikipedia.com.

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