In brief
The temporary waste storage area is where chemical residues from different parts of the business come together, and it is often the least inspected corner of the site. The Waste Management Regulation requires waste to be stored labelled, in a way that prevents reactions between wastes, and within time limits; spontaneous combustion of oily rags, solvent vapour and the mixing of incompatible wastes are the main OHS risks of this area. Training and suitable PPE for waste staff are an explicit obligation under the regulation.
Why is hazardous waste storage an OHS issue?
On the production line, every chemical has a safety data sheet, a label and instructions for use. The residues of those same chemicals, however, are emptied into a drum at the end of the shift, dirty rags are stuffed into a sack and everything is carried to an area behind the building. The hazardous waste storage area is therefore where all of the business's chemical risks come together, with less information.
Waste legislation falls under the Ministry of Environment, Urbanisation and Climate Change; however, it also refers directly to worker safety. Under Art. 9 of the Waste Management Regulation, the waste producer is obliged to provide training for its workers responsible for collecting, transporting and temporarily storing waste and to take all measures relating to health and safety. On the OHS side, the waste area should be treated as a separate work area in the risk assessment.
Temporary waste storage area: the basic rules in the legislation
Most of the rules the Waste Management Regulation sets for the temporary waste storage area are also OHS measures:
| Rule | Basis | What it means for OHS |
|---|---|---|
| Waste is stored separately by type and kept so that wastes cannot react with each other | Art. 13/1, 13/3 | Heat, gas or fire from mixing incompatible wastes is prevented |
| Waste may not be mixed with other substances or wastes, or diluted | Art. 5 | The practice of "empty it all into the same drum" is prohibited |
| The container is marked hazardous or non-hazardous waste, with the waste code, quantity and storage date | Art. 13/2 | Everyone entering the area knows what they are dealing with |
| Hazardous waste is stored temporarily for at most 6 months, non-hazardous waste for at most 1 year | Art. 13/3 | The amount of waste accumulated and the fire load are limited |
| Those producing 1,000 kg or more of hazardous waste per month obtain a permit from the provincial directorate for the temporary storage area | Art. 13/5 | The layout of the area is also subject to administrative inspection |
| Hazardous waste is sent via licensed carriers and permitted facilities | Art. 9 | The external company's workers also enter the area during handover |
Medical waste falls outside these rules and is subject to its own regulation; for details, see our article on medical waste and worker safety.
Oily rag fires and solvent waste
The risk of an oily rag fire is the most underestimated hazard in waste areas. Some vegetable oils, wood oils, varnishes and oil-based paints oxidise on contact with air, and this reaction produces heat. When rags soaked in such products are piled up in a sack or an open box, the heat cannot escape and the rags can ignite spontaneously, without any source of flame. This often happens after the shift has ended and the area is empty.
Measures:
- Oily and solvent-soaked rags are collected in metal waste bins with self-closing lids; plastic bins or cardboard boxes are not used.
- The bin is emptied at the end of every shift and its contents kept in a closed metal drum, away from sunlight and heat sources.
- Rags contaminated with wood oil or varnish can, where the manufacturer recommends it, be soaked in water and stored in a closed container.
- Solvent waste containers are kept closed, the container and funnel are earthed, the area is ventilated and there are no ignition sources nearby. For static electricity, see our article on static electricity and earthing; for explosive atmosphere assessment, see our article on the ATEX document.
- Drums and containers that have been emptied but still hold chemical residue also contain vapour. This packaging is not cut, welded or sold for scrap; it is managed as hazardous waste.
For general rules on storing flammable liquids, see our article on storing flammable liquids.
Leaks and mixing: separating incompatible wastes
In a waste area, the "unknown mixture" is the most dangerous waste. The following pairs must not be put in the same container or share the same spill tray:
| Waste group | Group to keep separate | Possible result |
|---|---|---|
| Acid waste | Basic (alkaline) waste | Violent release of heat, splashing |
| Acid waste | Cleaning waste containing hypochlorite | Release of chlorine gas |
| Oxidising waste | Oily rags, solvents, organic waste | Fire |
| Waste containing hypochlorite | Waste containing ammonia | Release of toxic gas |
| Water-reactive waste | Aqueous waste, open-air areas | Gas release, heating |
The source for determining compatibility is the safety data sheet of the chemical the waste came from; in particular, the stability and reactivity section and the disposal section should be read. For how to read it, see our article on how to read a safety data sheet, and for the logic of segregation, see chemical storage compatibility.
To guard against leaks, the floor of the area must be impermeable and must not drain into a rainwater or sewer grate. Liquid waste containers are kept in a spill tray or bunded area able to hold the contents of the largest container. Absorbent material, a spill kit and suitable PPE are kept ready at the entrance to the area. For what to do when a spill occurs, see our article on responding to chemical spills.
Waste labelling and records
Waste labelling should not be limited to the four pieces of information the regulation requires (hazardous or non-hazardous waste marking, waste code, quantity and storage date). From an OHS point of view, a good label also shows:
- The source of the waste: which department, which process?
- The main component and hazard pictograms: flammable, corrosive, acutely toxic, etc. For the meanings of the pictograms, see chemical labels and pictograms.
- The name of the person who wrote the label.
Waste codes are the six-digit codes in the waste list; codes marked with an asterisk denote hazardous waste. For example, absorbents, wiping cloths and protective clothing contaminated with hazardous substances are tracked under code 15 02 02*, and packaging containing residues of hazardous substances under code 15 01 10*. If an unlabelled container or one with unknown contents is found, it is not opened or emptied into another container; it is set aside, marked and its contents traced back to the source.
Waste yard safety: protecting staff
For waste yard safety, everyone who comes into contact with waste must be considered: the worker carrying waste from the department, the cleaning staff who keep the area tidy, the forklift operator and the driver of the company collecting the waste. Measures:
- PPE: chemical gloves suited to the type of waste, goggles or a face shield and, where necessary, chemical protective coveralls. For choosing coveralls, see types of chemical protective coveralls.
- Manual handling: use a drum trolley or lifting attachment instead of tipping and rolling full drums by hand.
- Hygiene: no eating or drinking in the area; hands are washed at the end of work. An eyewash is provided according to the risk assessment.
- Training: as part of the training required by the regulation, waste staff are taught, with hands-on practice, about incompatible wastes, reading labels, and responding to spills and fires.
- Handover: the person responsible for the area is present when the waste company's vehicle and staff enter; no other work is done during loading.
Checklist
- Is the waste area included as a separate section in the risk assessment?
- Are incompatible wastes kept in separate containers and separate spill trays?
- Does every container have a label, waste code and storage date; is any container past the 6-month limit?
- Are the oily rag bins metal with self-closing lids, and are they emptied every shift?
- Are the spill kit, extinguisher and PPE ready at the entrance?
- Is the training of waste staff recorded?
As part of our risk assessment work, Bursa Sistemer OSGB inspects the waste areas of businesses in Bursa and the surrounding provinces on site, scores incompatibility and fire risks and plans training for waste staff. For risks specific to chemical and plastics businesses, see our chemicals and plastics page.
Frequently Asked Questions
How long can hazardous waste be kept at the workplace?
Under Art. 13 of the Waste Management Regulation, excluding medical waste, hazardous waste may be kept in the temporary storage area for at most 6 months and non-hazardous waste for at most 1 year.
Why do oily rags catch fire by themselves?
Some oils and varnishes oxidise on contact with air and produce heat. When rags are piled up, this heat cannot escape and can reach ignition temperature. Metal bins with self-closing lids and regular emptying prevent this risk.
What should a waste label show?
Under the regulation: the hazardous or non-hazardous waste marking, waste code, quantity stored and storage date. From an OHS point of view, it is also recommended to add the source of the waste, its main component and hazard pictograms.
Can we sell empty chemical drums for scrap?
Packaging containing residues of hazardous substances is hazardous waste and is sent through licensed routes. These drums must not be cut or welded; flammable vapour may remain inside.
A risk assessment that identifies and scores hazards on site, links each measure to an owner and a date, and has a clear renewal schedule.
Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.