Issuance of permits for transboundary movement of waste. Permits for moving soil and construction and demolition waste

Transboundary movement of waste

Transboundary movement of waste is the transportation of waste from the territory of one state to the territory of neighboring countries or their transit. Transboundary movement of waste requires the participation of at least two states.

To carry out activities related to transboundary movement of waste, it is necessary to be legal entity those engaged in direct or transit transportation of waste from the Russian Federation, obtain a special permit, which can be issued for a one-time movement of waste or, if there is a contract, for a calendar year.

The permit is issued on the basis of:

• Resolution of the Government of the Russian Federation No. 442 regarding the movement of waste between states and territories. It should be noted that in 2016, this document Some clarifying additions have been made. A “Unit List of Wastes” was also defined, which are subject to restrictions on the movement of hazardous waste.
• On the territory of the Russian Federation there is also a separate provision on restrictions on waste transportation, which was approved by Decision of the Interstate Council of the EurAsEC No. 19 of November 27, 2009. The decision of the Customs Union Commission No. 132 dated November 27, 2009, which was amended on July 26, 2012, has the same force.

Together with instructions on the standard principle of drawing up the conclusion form, a separate format for a permit document was developed that regulates any movement of individual goods. This document is included in the Unified List of Goods that are subject to a ban or restriction on the movement of these goods within the states that are members of the Customs Union, working in collaboration with the EurAsEC and within trade relations with third countries.

The unified list was approved by decision of the Board of the Eurasian Economic Service No. 45 dated May 16, 2012.

The permit is issued by the authorized state body in the category of environmental management. The review period is about one month from the date of filing the application, accompanied by a full set of documents certified by a notary.

FSBI "FCAO" deals with issues of environmental safety and is always ready to assist in expert assessment documents required to obtain permission to cross-border movement waste.

When conducting research, it is indicated that goods transported under a cross-border permit are not subject to the scope of the Customs Union. All expert documents are issued in as soon as possible. Mutual cooperation with our organization is a guarantee that the business will be environmentally friendly. FSBI FCAO will prepare a package of documents necessary to obtain permission for transboundary movement of waste.

These permits are required by contractors to provide them to the Customer, usually in a closed form, to close payments for the disposal and removal of solid waste, especially, more often with coupons, to budget customers or city customers. To date, an open permit for the movement of solid waste is not required for submission to OATI. Now the procedure is reversed; to open a permit for the movement of construction and demolition waste, an open OATI order is required.

Permits for moving soil and removing construction and demolition waste are issued by the Moscow Department of Construction at the address: Moscow, st. Bolshaya Dmitrovka, 16, building 2.

Not all types of work require permits. As a rule, their presence is required for types of work where it is necessary to move large volumes of soil and construction waste. For facade work, reconstruction of utility networks, landscaping, where the volume of soil and waste does not exceed 50 m3, no permits are required and this waste is disposed of in the usual way, it is enough to conclude an agreement with a company that transports waste to landfills. In case of large volumes, you will need to obtain permits.

Permission to move soil

If your type of work requires a large volume of soil movement throughout Moscow, a mandatory permit is required. This is required in order to distribute traffic flows across the territory of Moscow and to maintain a favorable environmental situation, since soils have different hazard classes, and dumping toxic soils into clean landfills is prohibited by law. As well as dumping broken bricks and concrete in the nearest forest.

Receives a ground permit contractor. To do this, it is necessary to obtain the following design documentation from the customer:

1. Engineering and environmental report (sometimes called Sanitary and Epidemiological) with tables on the hazard class of soils.
2. Engineering-geological research with longitudinal sections by soil type
3. Construction permit
4. Estimate documentation (not needed in full, but only the part where the soil movement and cover are indicated)

Permit for movement of construction and demolition waste

If during the construction and demolition of an object you encounter construction waste that need to be disposed of, a waste transfer permit must be opened with the Department of Construction.

All types of waste that are planned for removal are listed in the Technological Regulations for Waste Management and are provided to the contractor by the customer (investor). There are situations when the Customer did not develop the Technical Regulations and coordinated them with the Construction Department. In this case, it is necessary to survey the structures, determine the volume and type of waste (concrete, brick, metal, glass, etc.), and then, based on the survey, develop a Technological Regulation and approve it with the Construction Department.

The Technical Regulations also indicate the types of waste, methods of disposal or processing, and a list of landfills to which certain types of waste can be removed.

The opening of a permit for the movement of construction and demolition waste is carried out by the contractor. To do this, you need to obtain from the customer next list project documentation:

1. Technological regulations for waste management.
2. Construction permit
3. Estimate documentation (not needed in full, but only the part where the movement of waste and the cover are indicated)

To obtain permission to move soil, you must submit a package of documents to the “One Window Service” of the Department of Construction and duplicate them electronically on a disk in PDF format.

The Stroyconsulting company offers you consulting services in the field of obtaining permits for the movement of soil and construction and demolition waste in the Moscow Construction Department.

Alexey Maslennikov

The movement of goods across the border is regulated by the Customs Code of the Russian Federation dated May 28, 2003 No. 61-FZ.

The main instruments for regulating foreign economic activity are customs duties on the import and export of goods, value added tax, excise tax and licensing. Value added tax and excise taxes are paid by participants in foreign economic activity when importing goods into the territory of the Russian Federation. When exporting goods, the exporter has the right to a refund of value added tax when taxed in accordance with Article 165 of the Tax Code. In fact, this right provides international practice for providing protection from double taxation of goods when moving across borders, the essence of which is that value added tax is paid only when goods are imported.

Government Decree No. 442 of July 17, 2003 “On transboundary movement of waste” establishes requirements for participants in transboundary (transit) movement of waste and introduces two lists of hazardous waste specified in Appendices 1 and 2.

Import into the territory of the Russian Federation of hazardous waste specified in Appendix No. 1 to the Rules for the purpose of their use and removal from the territory of the Russian Federation of hazardous waste specified in Appendices No. 1 and 2 to the Rules is carried out under a license issued in the prescribed manner by the Ministry economic development and trade of the Russian Federation on the basis of permission from the Ministry natural resources of the Russian Federation and its territorial bodies on transboundary movement of waste.

These restrictions mainly apply to the movement of hazardous waste. Nevertheless, this decree covers such types of waste as used tires, aluminum slag, used batteries, etc. However, it is worth considering that the export of waste indicated in these lists is practically devoid of commercial sense due to the lack of demand. Licensing of transboundary movement of hazardous waste practically does not apply to types of secondary raw materials, the export of which would increase the volume of their use or procurement, although in some rare cases, this can become a significant obstacle to the export of, say, scrap lead batteries.

Despite possible obstacles, licensing of transboundary movement of hazardous waste is consistent with international agreements, and work with such hazardous waste in any case requires obtaining a hazardous waste license.

Another regulator of foreign economic activity is customs duties. The procedure for establishing customs duties is determined by the Law of the Russian Federation of May 21, 1993 No. 5003-I “On Customs Tariffs”. Article 3 of this law determines that import and export customs duties are established by the Government of the Russian Federation. On January 1, 2002, the Customs Tariff of the Russian Federation, approved by Decree of the Government of the Russian Federation of November 30, 2001 No. 830, came into force.

The table below shows the rates of export customs duties on the main types of waste.

*) Apply to goods exported from the customs territory of Russia outside the member states of the agreements on the Customs Union. Members of the Customs Union are Russian Federation, Belarus, Kazakhstan, Republic of Kyrgyzstan and Tajikistan.

Customs duties are widely used as the main instrument for regulating foreign economic activity. Export duties are a tool for limiting the export of products outside of Russia by reducing the profitability of export operations with such goods. Increased rates of export duties apply to goods whose export is undesirable for some reason. At the moment, scrap and waste of non-ferrous metals are subject to the greatest pressure from export duties: copper, aluminum, nickel, etc. Non-ferrous metals are widely used in high-tech industries: defense, aerospace, electrical engineering, radio-electronic, automotive. At the same time, the price of non-ferrous metals on the international market is quite high, which causes a natural outflow of some raw materials abroad. A similar situation arises with waste and scrap ferrous metals.

For procurement enterprises, this, first of all, means a decrease in the profitability of their core activities. At the same time, it should be taken into account that waste for which high export duties are established is used in the best possible way. This is explained by the fact that recently the depth of processing of waste ferrous and non-ferrous metals has increased significantly. Many producers and processors of secondary metals produce products with high added value and, as a rule, these products no longer belong to the group of waste. An example of this is the situation with the processing of aluminum scrap and waste. Many procurement enterprises have production facilities and produce aluminum alloys, both for domestic consumers and for export. If previously alloys were mainly produced secondary groups AB, used mainly as a deoxidizer in ferrous metallurgy, is now producing high-quality aluminum alloys for various branches of mechanical engineering, both for casting and for forming. Low-quality scrap and waste aluminum is now used as a deoxidizer ( aluminum cans, laminated foil, etc.), and a number of enterprises use high-tech equipment for their processing, which makes it possible to achieve the required quality and shape of the product.

It can be noted that high export duties contribute to technical re-equipment enterprises, because force entrepreneurs to carry out deeper processing of waste in order to increase the profitability of the entire production by increasing the cost of the final product. In addition, the processed product may be subject to a much lower export duty (for example, for secondary aluminum alloys the export duty is 5%, versus 50% for waste), which further stimulates the deep processing of waste.

With regard to waste and scrap ferrous metals, the situation is somewhat different. Processing ferrous scrap into products with higher consumer properties requires significantly more expensive equipment than in the case of non-ferrous metals. As a rule, these are electric arc furnaces of high power and volume with a continuous casting system. Although there are mini-productions in the world that meet local needs for long products, in Russia this practice is just beginning to appear. The bulk of producers of scrap and ferrous metal waste actually only prepare raw materials for smelting, i.e. for delivery to metallurgical plants. It is almost impossible to organize production for the deep processing of ferrous scrap without significant capital costs, and often has all sorts of restrictions from energy supply and environmental standards. In addition, in the domestic market the supply of metal products currently exceeds demand, which also reduces the investment attractiveness of such projects.

Medical waste, according to Federal Law No. 323 “Fundamentals of protecting the health of citizens of the Russian Federation,” is waste that appears as a result of the interaction of medical consumables with human biological fluids.

(ADV38)

They also include pathological and operational waste, waste resulting from the development and production of vaccines and vaccinations, as well as food waste from infectious diseases departments.

Class B waste poses an epidemiological hazard.

Places where medical waste is generated

To places of education medical waste Class B includes:

• Pathology departments
• Operating
• Dressing and treatment stations
• Department of Dermatovenerology and Infection
• Laboratory organizations (3-4 group of pathogenicity of bacteria)

Collection, movement and temporary storage of class “B” waste

SanPiN clause 3.6. 2.1.7.2790-10 regulates methods of movement and storage of medical waste in organizations that are places of generation of such waste.

It is important that all personnel who come into contact with Class B waste in any way are vaccinated against hepatitis B.

The head of the enterprise must draw up and approve instructions that contain instructions for handling waste at all stages of contact with it. This instruction must also indicate those responsible for the collection, storage and transportation of hazardous waste.

Waste is collected in specially marked yellow bags, which indicate the name of the organization, its department and which are signed by the employee responsible for disposal. Sharps waste such as medical instruments, syringes, etc. collected in disposable puncture-resistant containers. They are also marked. Organic waste must be placed in a sealed container with a lid.

When collecting Class B waste, it is important to consider the following:

• It is prohibited to produce on waste physical impact before neutralization
• It is forbidden to cover used syringes with caps.
• It is unacceptable to move waste by pouring it from one container to another
• Compacting waste is also prohibited
• Before any interaction with waste, it is necessary to use protective equipment (special suits, respirators, gloves)
• It is unacceptable to store waste in close proximity to heating devices.

During one work shift, it is necessary to collect all waste and send it for further disposal procedures. Disposable containers can be filled within 3 days, unlike bags. The bags must be changed every shift, taking into account that the maximum filling level should not exceed three quarters of their volume.

After the containers and bags are filled, the waste collection officer closes the lids of the containers tightly and ties the bags using special ties.

The prepared containers and packages are marked with the date, name of the organization and the initials of the person responsible for the specific shift. It is also necessary to indicate that this is class B waste.

Moving waste to a place of storage or further handling is done by placing it in special containers. Then they are transported either to the place of further circulation or to places of temporary storage before export by specialized vehicles.

It is important to consider the material, heat and heat resistance of containers for moving. They must be stable and not open spontaneously.

There should be no unauthorized people in temporary storage premises. Access must be limited to persons responsible for disposal.

Removed structural medical organizations have grounds to temporarily store Class B waste on their territory. They can be placed in utility rooms, but in the future they must be sent to the medical facility. organization for the purpose of disinfection.

If storage is necessary for more than a day, prepared waste of class “B” must be placed in refrigerators, which cannot be used for any other purpose.

Disposal methods

Organic waste (from operating rooms and pathology departments) classified as class “B” is cremated or buried. There are special cemeteries for this purpose. This category of waste does not require preliminary disinfection.

What about other medical waste? They must be subjected to a disinfection procedure and only after that they are burned.

Some medical institutions have specially installed equipment designed for waste disposal. Smaller institutions use the services of third-party companies specializing in waste disposal.

Based on the above, we can distinguish two methods for neutralizing class “B” waste. These are decentralized and centralized methods.

The decentralized method is called disinfection on the territory of medical institutions. Accordingly, the centralized method involves disinfection in an area that is located outside the medical territory. institutions and involves transporting waste to the disposal site.

Transportation of waste to the disinfection site

Transportation of waste to disinfection sites is carried out specialized organizations. Vehicles used to transport Class B waste are used exclusively for this purpose. It is prohibited to transport waste of other classes or any other cargo in them.

It is noteworthy that class “B” waste that has undergone the disinfection procedure (marking about completion of the disinfection procedure is required) can be transported to the disposal site along with class “A” waste.

Containers for transporting waste are reusable. They are washed and disinfected for further use.

Waste accounting in the journal

SapPiN requires keeping logs for all types of waste to be disposed of. Each hazard class has its own form of this log.

Documents required to maintain such a journal:

• The organization's technological logbook, which indicates all filled waste containers and their quantity.
• Technological log of the amount of waste that is removed from the organization for further treatment and disposal. It also indicates the details of contracts with organizations transporting this waste.
• Certificate indicating completion of the disinfection procedure. Also information about the organization conducting this procedure and the agreement with it.
• A technological journal of a specific department of an organization in which a report on waste management is kept.

Disinfection of Class B waste

To neutralize waste, chemical or hardware methods are used. In the first case, the waste is exposed to powerful disinfectants; in the second, the waste is treated with high-temperature steam, and it is also exposed to radiation and electromagnetic radiation.

After waste has been decontaminated, tests are carried out to ensure its safety.

Also, solid waste materials remaining after the disinfection procedure are allowed to be placed in landfills for solid waste.

It is impossible to produce secondary raw materials, even already disinfected waste.