Are scrap iron filings stained with waste cutting fluid classified as hazardous waste?

April 22, 2022

The "Hazardous Waste Exemption Management List" clarifies that the honing, grinding, and grinding processes of the metal products machining industry, as well as oily metal scraps that are hazardous wastes generated in the process of machining with cutting oil or cutting fluid, code 900-200-08, 900-006-09, the utilization process that meets certain exemption conditions may not be managed as hazardous waste.

Case: A company was placed on file and punished for the open storage of scrap iron filings contaminated with cutting fluid
Law enforcement officers of Quanzhou Hui'an Ecological Environment Bureau conduct daily inspections of a machinery manufacturing plant located in Huidong Industrial Zone, Hui'an County. After investigation, the machinery manufacturing plant is mainly engaged in the production of petrochemical machinery equipment and accessories, and has gone through the EIA approval procedures and the project completion environmental protection independent acceptance. At the time of on-site inspection, the factory's mechanical parts manufacturing workshop was in production. The main production process flow was: steel plate, profile → shearing machine cutting → drilling machine, punching machine, milling machine processing → welding → finished product, among which the milling machine processing process needs to add cutting fluid processing, The production process will produce iron filings contaminated with cutting fluid. At the scene, law enforcement officers found that these scrap iron filings contaminated with cutting fluid were stored in the open air on the cement floor on the northeast side of the factory, and were not stored in accordance with environmental protection standards.

Cutting Fluid Hazardous Waste

Scrap iron scraps contaminated with cutting fluid are generated during the production process of the milling machine

Oil Hazardous Waste

Scrap iron scraps contaminated with cutting fluid are piled up in the open air

"National Hazardous Waste List (2021 Edition)" clearly lists "oil/water, hydrocarbon/water mixture or emulsion produced during machining with cutting oil or cutting fluid" as HW09 hazardous waste, and the hazardous characteristic is toxicity. At the same time, according to the "General Principles of Hazardous Waste Identification Standards" (GB5085.7-2019), "hazardous wastes with one or two hazardous properties of toxicity and infectivity are mixed with other substances, resulting in the diffusion of hazardous properties into other substances. Solid wastes are hazardous wastes”, and oily metal chips produced during machining with cutting oils or cutting fluids are hazardous wastes. According to the hazardous waste exemption management list stipulated in the "National Hazardous Waste Catalogue (2021 Edition)", it is pointed out that the above-mentioned oily metal scraps are pressed, filtered, filtered and degreasing until they are left to stand without leakage and then packed into briquette for metal smelting. According to the management of hazardous waste, the collection, transportation and disposal of the above-mentioned oily metal scraps other than the utilization link should be strictly managed according to the hazardous waste management. According to the "Hazardous Waste Storage Pollution Control Standards", hazardous waste producers should build special hazardous waste storage facilities, and hazardous waste piles should be protected from wind, rain, and sun, and warning signs should be set up as required.

Legal Analysis
In response to the environmental violations in the factory, law enforcement officers immediately conducted a comprehensive investigation and evidence collection of the factory, and filed a case for investigation and punishment in accordance with the law. The behavior of the factory violated the provisions of Article 81, paragraph 2, of the "Law of the People's Republic of China on the Prevention and Control of Environmental Pollution by Solid Waste". Item (6) of Article 12, and with reference to the "Fujian Province Ecological Environment Administrative Punishment Rules and Benchmarks (Trial)", an administrative decision was made to order the factory to make corrections and impose a fine of 111,300 yuan.

Author:

Mr. James

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