1. Why do you need to make a hazardous waste ledger?
Article 78 of the Law of the People's Republic of China on the Prevention and Control of Environmental Pollution by Solid Wastes provides that "units that produce hazardous wastes shall, in accordance with the relevant provisions of the State, formulate hazardous waste management plans, establish hazardous waste management accounts, and truthfully record relevant information".
The Technical Guidelines for the Formulation of Hazardous Waste Management Plans and Management Ledgers further clarifies the overall requirements for the units that produce hazardous wastes to formulate hazardous waste management plans and management ledgers, declare hazardous waste related information, formulate hazardous waste management plans, formulate hazardous waste management ledgers and declare hazardous wastes.
This paper interprets the key points that need to be paid attention to in the formulation of hazardous waste ledgers.
Second, the division of management categories
According to factors such as the amount of hazardous waste generated and environmental risks, the management categories of units that produce hazardous waste are divided into the following three categories:
3. How to do a good job of hazardous waste ledger?
1. General principles
(1) The unit that produces hazardous waste shall establish a hazardous waste management ledger, implement the person responsible for the hazardous waste management ledger records, clarify the job responsibilities, and bear legal responsibility for the authenticity, accuracy and completeness of the hazardous waste management ledger.
(2) The unit that produces hazardous waste shall truthfully establish a hazardous waste management account for each link according to the dynamic flow direction of hazardous waste generation, storage, utilization, disposal and other links.
(3) Hazardous waste management ledger is divided into two forms: electronic management ledger and paper management ledger. Units that produce hazardous waste may record electronic management ledgers through the national hazardous waste information management system, the enterprise's self-built information management system or a third-party platform.
2. Frequency requirements
If it is contained in containers or packages after generation, it should be recorded according to each container and packaging; if it is transported to the storage site by pipeline or other means after generation, it shall be recorded on a daily basis; and in other special circumstances, the recording frequency shall be determined according to the law of hazardous waste generation.
3. Record the content
4. Record keeping
In principle, electronic files and paper files should be archived for more than 5 years, of which hazardous waste business units should keep ledger records for more than 10 years, and ledger records for the disposal of hazardous wastes in landfills should be kept permanently.
Fourth, the consequences of failing to record hazardous waste ledgers in accordance with the norms
1. Punishment basis of relevant laws and regulations
Article 112, Paragraph 1, Paragraphs 13 and 2 of the Law of the People's Republic of China on the Prevention and Control of Environmental Pollution by Solid Wastes stipulate that anyone who fails to establish a hazardous waste management ledger in accordance with the relevant provisions of the State and truthfully record it violates the provisions of this Law shall be ordered by the competent department of ecology and environment to make corrections, impose a fine, and confiscate illegal gains;
2. Punishment cases in recent years
On November 22, 2023, law enforcement officers inspected a machinery Co., Ltd. in Pidu District in accordance with the requirements of "double random", and found that the company was in normal production, and in the hazardous waste storage room set up by it, there were 9 waste guide rail oil drums and 17 waste cutting fluid drums, weighing a total of about 600 kg. In accordance with the provisions of the "Sichuan Provincial Ecological Environment Administrative Punishment Discretionary Standards", on February 6, 2024, the Chengdu Municipal Ecological Environment Bureau imposed an administrative penalty of 85,000 yuan on the company in accordance with the law.
On January 12, 2024, the Mudanjiang Municipal Bureau of Ecology and Environment conducted an investigation on Mudanjiang Fuyu Auto Parts Co., Ltd. and found that the unit carried out a maintenance of the production equipment at the beginning of 2024, producing about 160 kg of waste engine oil, but did not formulate a hazardous waste management plan in accordance with relevant regulations, nor did it declare a hazardous waste management account. The Mudanjiang Municipal Bureau of Ecology and Environment imposed a fine of RMB 100,000.00 (?100,000.00) on him in accordance with the Law of the People's Republic of China on the Prevention and Control of Environmental Pollution by Solid Waste.
5. Tips
Enterprises should strictly implement the relevant environmental management requirements put forward in the Law of the People's Republic of China on the Prevention and Control of Environmental Pollution by Solid Waste in their daily operations, further enhance their legal awareness and environmental awareness, and avoid unnecessary penalties due to non-standard hazardous waste ledger records or failure to truthfully record hazardous waste ledgers, which will affect the environmental credit of enterprises.
Source: Hazardous Waste Disposal Platform