guideline_handling_final

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Annex D: Guideline on hazardous goods handling, storage and treatment including warehouse

management

Summary 1. Aim and application field:..................................................................................................................... 3

2. References ........................................................................................................................................... 3

3. Preface: ............................................................................................................................................... 3

4. Management of waste produced after the shredding process .............................................................. 3

a. Responsibility of waste management ............................................................................................... 4

5. Arrangement of warehouse: ................................................................................................................ 5

a. Arrangement of non-hazardous goods area ...................................................................................... 7

b. Arrangement of untreatable goods area ........................................................................................... 8

c. Arrangement of hazardous goods area ............................................................................................. 8

2. The identification of hazardous goods. ................................................................................................. 8

a. Physical hazards ..............................................................................................................................10

Explosives ...........................................................................................................................................10

Flammable ..........................................................................................................................................11

Oxidizing gases ....................................................................................................................................12

Gases under pressure (Compressed gas, liquefied gas, refrigerated liquefied gas, dissolved gas) .........13

b. Health hazards ................................................................................................................................14

Toxicity: ..............................................................................................................................................14

Skin corrosion/irritation – Serious eye damage/irritation ....................................................................15

Respiratory or skin sensitisation ..........................................................................................................16

Germ cell mutagenicity .......................................................................................................................17

Carcinogenicity ...................................................................................................................................17

Reproductive toxicity plus additional category for effects on or via lactation.......................................17

Specific target organ toxicity (STOT) – single and repeated exposure ..................................................17

a. Environmental hazards ....................................................................................................................18

Risk for aquatic environment ..............................................................................................................18

Hazardous to the ozone layer ..............................................................................................................19

6. Risks assessment for hazardous goods handling and treatment ...........................................................19

a. Introduction ....................................................................................................................................19

b. Risk assessment related to handling and treatment of hazardous goods: exposure scenarios ..........20

c. Risks assessment for handling and sorting phases ...........................................................................20

d. Risks assessment for storage phase .................................................................................................20

e. Risk assessment for the shredding phase.........................................................................................21

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7. Proposal for the destruction of untreatable goods ..............................................................................21

a. Food ................................................................................................................................................21

b. Liquors and Beverage ......................................................................................................................22

c. Metal ..............................................................................................................................................22

d. Bulky electric and electronic equipment ..........................................................................................22

e. Chemical .........................................................................................................................................23

f. Batteries and accumulators .............................................................................................................23

g. Under pressure containers ..............................................................................................................23

6. Conclusion and Recommendation .......................................................................................................23

Annex 1 - Decisional tree – Warehouse arrangement ..................................................................................26

Annex 2 - Decisional tree – Risk assessment of goods .................................................................................27

Annex 3: Examples of risk assessment .........................................................................................................28

Example 1: Batteries ...............................................................................................................................28

Example 2: Dishwasher tabs ....................................................................................................................28

Example 3: Liquors and spirits .................................................................................................................29

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1. Aim and application field: The aim of the guideline is to describe how to handle the counterfeited goods with a specific focus on

hazardous goods and how to arrange the warehouse in order to avoid the risk for the health of workers

involved during the handling and destruction phase and, at the same time. On the basis of information

obtained and the results of on-site visits we can estimate that the largest part of goods stored can be

considered as non hazardous goods ( about 85%). The residual part presents some hazardous properties or

not well known composition and have to be handled and stored as hazardous.

2. References EU Directive 2004/48/EC on the enforcement of intellectual property rights

EU Directive 2008/98/CE on waste

EU Regulation 1272/2008 on Classification, Labelling and Packaging of hazardous goods

Guidance on the Application of the CLP Criteria Version 4.1 – June 2015

Guideline on handling hazardous goods – INAIL (Italian Institute for safety on workplaces)

Relevant Serbian Laws into the scope of this guideline:

Law on Trade (OGRS 53/2010 )

Law on special power of effective IPR Protection (OGRS 46/2006 and amendments)

3. Preface: The destruction of confiscated goods represents a fundamental step in the market enforcement process

because only through the physical process it is possible to avoid the risk that these goods can be resold on

the illegal market. Therefore, the use of shredder have to be intended as a part of the enforcement of IPR

directive to ensure the destruction of the infringing goods.

The products of the destruction process are waste. Starting from this point it is necessary to consider also

the relevant legislation on waste management. In particular it is possible to identify the Market

Inspectorate as the waste producer. The management (meaning transport and treatment) of waste have to

be carried out by a specialized company as a Public Waste Management Company that collects urban

waste.

4. Management of waste produced after the shredding process

Although the aim of this guideline is the handling of hazardous goods, it is necessary to dedicate to this

issue a specific paragraph. As described before, the result of shredding operation is the production of waste

therefore it is necessary to consider the effects of this legal status change on the management and

storage.

The EU directive 2008/98/CE on waste (hereafter WFD) provide these definitions (Art.3):

Waste as substance or object which the holder discards or intends or is required to discard.

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Waste producer: means anyone whose activities produce waste (original waste producer) or

anyone who carries out pre-processing, mixing or other operations resulting in a change in the

nature or composition of this waste

Based on these definition we can identify the Market Inspector body as waste producer. The management

of waste have to be done by a specialized company that will be the responsible for the final treatment that

can be a recovery operation or a disposal operation. The definition of “recovery” and “disposal” are

provided by the WFD.

a. Responsibility of waste management Art. 15 of the WFD describes the responsibility of the different actors involved in waste management. The

waste producer have to deliver the waste to a dealer or company or an undertaking which carries out

waste treatment operations or arranged by a private or public waste collector.

The paragraph 2 of the same article explain that the responsibility for waste management.

When the waste is transferred from the original producer or holder to one of the natural or legal

persons referred to in paragraph 1 for preliminary treatment, the responsibility for carrying out a

complete recovery or disposal operation shall not be discharged as a general rule.

Without prejudice to Regulation (EC) No 1013/2006, Member States may specify the conditions of

responsibility and decide in which cases the original producer is to retain responsibility for the

whole treatment chain or in which cases the responsibility of the producer and the holder can be

shared or delegated among the actors of the treatment chain.

The best practices in Europe, related to this paragraph, describe that the responsibility for waste producer

ends when he receives the documents from the waste management company that proves that his waste

has been accepted by the waste management installation.

The waste producer have to verify that the waste management company is an authorized company.

The treatment of waste produced after the shredding process, in terms of costs and responsibility can be

defined in a specific agreement between the Market Inspectorate and the waste management company.

The Market Inspectorate have to store in temporary storage area the waste produced before the collection.

This step is not considered as a waste management operation and it isn’t necessary to obtain a permit. (see

also. EU Directive 2008/98/CE Recital 15).(Pic. 1)

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Pic.1 End of good status and waste status

5. Arrangement of warehouse: Based on our experiences and on-field controls at Vilijne Vode warehouse and Irig warehouse, we suggest

to adopt a spatial criteria to arrange and sort the different kind of goods stored in.

These basic criterions are based on the assumption that part of goods stored are evidences in a trial and

should be kept without any modification before the verdict of the Court. For this reason, we suggest to

identify two dedicated areas:

One dedicated to the storage of evidences (Live Evidences Area)

One dedicated to the storage of goods that have to be destroyed.(Goods Area)

The evidence storage area, in order to ease the management should be subdivided using a time based

criterion; as example if there are some racks or shelves in the warehouse, it could be possible to subdivide

the evidence based on the date when they were confiscated. (Pic. 2)

Pic. 2 Warehouse

At the end of the trial if the evidences have to be destroyed, the warehouse manager can break the seals

and place these good in the dedicated area of the warehouse.

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This part, in turn, will be divided in three main area:

Non hazardous goods

Hazardous goods

Untreatable good

Each part, in turn, will be divided in sub-areas on the basis of the composition of the goods.

In order to guarantee a safe work environment and in order to avoid any risk, for health and environment ,

we suggest to sort the goods with care on the basis of criterions herein described.( Pic. 3)

Also in this case, if there are some shelves or racks, the physical separation of different kind of material

could be easier.

In addition to this, the diplaying of signs to identify the area and the shelves is strongly recommend.

At the end of the process, it will be possible to create a scheme or map (Pic. 4) that should be used in the

aftermath.

Pic. 3 – Warehouse arrangement criterions

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Pic. 4 Example of warehouse map

a. Arrangement of non-hazardous goods area The non-hazardous goods represent the largest part of confiscated goods and the material obtained after

the shredding process could be recycled. The shredding of non hazardous goods will produce non

hazardous waste.

The European directive on waste imposes to maximize the matter recovery adopting, all along the

production process, criteria and method to ease the management after the use of a goods. The waste

hierarchy (Art. 4 of EU Dir. 2008/98/CE) indicate only as worst option the landfilling of unsorted

materials.(Pic. 5)

Pic. 5 Waste Hierarchy

To be in compliance with the EU directive on Waste we suggest to identify a waste operator able to

recovery the different kinds of materials and, in order to ease the recovery process, also the warehouse

should be organized bearing in mind this target.

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On the basis of this requirement, the non-hazardous goods area could be divided in sub-areas based on the

nature of goods (e.g. Textiles and shoes, plastic, rubber, paper and cardboard…).The different product

groups can be decided in agreement with the waste management company that will collect the waste after

the shredding process. (see Scheme 1)

If the final destination of the waste will be a energy recovery plant (incinerators or cement kilns) or a

landfill the separation in different product group could be omitted.

b. Arrangement of untreatable goods area As untreatable goods are identified goods that, due to his size or composition cannot be treated with the

equipment. Some goods, as furniture, have to be dismantled before the shredding process. Other goods, as

truck spare parts, should not be introduced in the cutting chamber of the equipment to avoid damages to

the hooks. As general rule, goods made of metals with high thickness (8 mm) cannot be treated.

These goods can be recycled and, as described in the previous paragraph, to ease the recovery process they

should be stored in separated piles on the basis of their nature and composition.

c. Arrangement of hazardous goods area The hazardous goods represent a small part of the counterfeited goods. The handling and storage of goods

that contain hazardous substances have to be done using adequate PPE and storage systems. As main

criterion, also the hazardous goods area should be arranged on the basis of the nature of goods (e.g.

batteries, mineral oils, drugs…)

In case of hazardous liquid (e.g. detergents, limescale remover) they should be stored in closed plastic

boxes in order to avoid the risks of leakage.

As for non-hazardous goods, also hazardous goods can be recycled, with an additional positive effective on

the environment. In order to achieve this target it is important to segregate the different kinds of

hazardous goods on the basis of their nature.

Hazardous goods cannot be treated in the shredder. If the hazardous goods will be mixed with non

hazardous goods and shredded together it is mandatory to manage as hazardous waste all the materials

collected in the same container.

2. The identification of hazardous goods. The identification of hazardous goods is based on the evaluation of the composition of the goods. The

European Regulation n. 1272/2008 on Classification, Labelling and Packaging of hazardous substances

(hereafter CLP) is the most important tool to recognize the potential hazards.

However, in many cases the composition of the goods are not well known. In these cases, the visual

evaluation of the goods and a precautionary approach represent the most effective solution to reduce the

risk related to the handling of hazardous goods.

The CLP has identified three different main typologies of hazards:

Physical hazards

Health hazards

Environment hazards

Each group, in turn, is dived in other sub-groups

Physical hazards

o Explosives

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o Flammable gases

o Flammable aerosols

o Oxidising gases

o Gases under pressure (Compressed gas, liquefied gas, refrigerated liquefied gas, dissolved

gas)

o Flammable Liquids

o Flammable solids

o Self-reactive substances and mixtures

o Pyrophoric liquids

o Pyrophoric solids

o Self-heating substances and mixtures

o Substances and mixtures which in contact with water emit flammable gases

o Oxidising liquids

o Oxidising solids

o Organic peroxides,

o Corrosive to metals

Health Hazards

o Acute toxicity,

o Skin corrosion/irritation

o Serious eye damage/eye irritation

o Respiratory or skin sensitisation

o Germ cell mutagenicity,

o Carcinogenicity,

o Reproductive toxicity plus additional category for effects on or via lactation

o Specific target organ toxicity (STOT) –

o Specific target organ toxicity (STOT) – repeated exposure

o Aspiration hazard

Environment Hazards

o Hazardous to the aquatic environment

o Hazardous to the ozone layer

The Regulation CLP has adopted a system of images (pictograms) that the producer have to apply on the

packaging if the good is classified as hazardous. Each pictogram is related to a specific hazard. This

regulation will enter in force completely starting from the June 1st, 2015.

The previous European Directives on dangerous substances (Dir. 67/548/EEC) and Directive on dangerous

preparation (Dir. 1999/45/EEC) had adopted another group of pictogram

A substance can have more than one hazardous property.(e.g. Mineral oil can be considered flammable and

Hazardous to the aquatic environment).

The assignment of the specific hazardous properties is not the aim of this guideline and we can adopt a

streamlined approach using this list as support during the goods evaluation process.

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a. Physical hazards

Explosives Definition:

An explosive substance or mixture is a solid or liquid substance or mixture of substances which is in itself

capable by chemical reaction of producing gas at such a temperature and pressure and at such a speed as

to cause damage to the surroundings. Pyrotechnic substances are included even when they do not evolve

gases.

The class of explosives comprises:

(a) explosive substances and mixtures;

(b) explosive articles, except devices containing explosive substances or mixtures in such quantity or of such

a character that their inadvertent or accidental ignition or initiation shall not cause any effect external to

the device either by projection, fire, smoke, heat or loud noise; and

(c) substances, mixtures and articles not mentioned in points (a) and (b) which are manufactured with a

view to producing a practical, explosive or pyrotechnic effect.

Pictograms

Reg. CE n.1272/2008 CLP Dir. 67/548/CEE

Examples: Fireworks, Propane gas bottles

Pictures:

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Flammable

Definition:

The definition “flammable” can be applied to several substances with different physical states. The CLP

regulation identifies:

1. Flammable gases

2. Flammable aerosols

3. Flammable liquids

4. Flammable solids

“Flammable property are applied to substances with a low flash point at standard conditions (20 C –

1013mb) and that are readily combustible.

The pictogram “flammable” is also applied to pyrophoric substances indeed pyrophoricity means the ability

to spontaneously ignite in air, is the result of a reaction of a substance or mixture with the oxygen in the

air. The reaction is exothermic and has the particularity that it starts spontaneously.

The pictogram “Flammable” is applied also to self-heating substances and mixture and to substances and

mixtures which in contact with water emit flammable gases.

Pictogram


Examples of where we can find it: Lamp oil, petrol, nail polish remover, alcohol

Pictures:

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Oxidizing gases

Definition:

Oxidising gases means any gas or gas mixture which may, generally by providing oxygen, cause or

contribute to the combustion of other material more than air does.

The same pictogram is applied to organic peroxides. The CLP definition of this specific category of organic

substances is: liquid or solid organic substances which contain the bivalent -O-O structure and may be considered

derivatives of hydrogen peroxide, where one or both of the hydrogen atoms have been replaced by organic radicals.

The term organic peroxide includes organic peroxide mixtures (formulations) containing at least one organic peroxide.

Organic peroxides are thermally unstable substances or mixtures, which can undergo exothermic self accelerating

decomposition. In addition, they can have one or more of the following properties:

be liable to explosive decomposition;

burn rapidly;

be sensitive to impact or friction;

react dangerously with other substances.

In some cases organic peroxides can present also the “Explosive” hazardous property.

Pictogram


Examples of where we can find it: Bleach, oxygen for medical purposes, hydrogen peroxide.

Pictures:

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Gases under pressure (Compressed gas, liquefied gas, refrigerated liquefied gas, dissolved gas)

Gases under pressure, also non hazardous gases (e.g. nitrogen) could be considered hazardous because

they can explode if heated. Often the content can presents also other hazardous properties.


There is no existing

symbol for this hazard pictogram.

Examples of where we can find it: Spray bottles

Pictures:

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b. Health hazards o Skin corrosion/irritation

o Serious eye damage/eye irritation

o Respiratory or skin sensitisation

o Germ cell mutagenicity

o Carcinogenicity

o Reproductive toxicity plus additional category for effects on or via lactation

o Specific target organ toxicity (STOT) – repeated exposure

Toxicity:

Definition:

Acute toxicity means those adverse effects occurring following oral or dermal administration of a single

dose of a substance or a mixture, or multiple doses given within 24 hours, or an inhalation exposure of 4

hours. There are two hazard classes for acute toxicity – ‘Acute toxicity’ and ‘STOT-SE (Specific Target Organ

Toxicity – Single Exposure)’.


Examples of where we can find it:

Pesticide, biocide, methanol

Pictures:

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Skin corrosion/irritation – Serious eye damage/irritation

Definition:

Skin corrosion: means the production of irreversible damage to the skin; namely, visible necrosis

through the epidermis and into the dermis

Skin irritation: means the production of reversible damage to the skin\

Serious eye damage: means the production of tissue damage in the eye, or serious physical decay

of vision, which is not fully reversible within 21 days of application.

Eye irritation: means the production of changes in the eye, which are fully reversible within 21 days

of application.

Pictogram



Drain cleaners, hydrochloric acid, ammoniac, detergents

Pictures:

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Respiratory or skin sensitisation

Definition: Respiratory sensitizer means a substance that will lead to hypersensitivity of the airways

following inhalation of the substance. Skin sensitizer means a substance that will lead to an allergic

response following skin contact.

Pictogram for respiratory sensitization


Pictogram for skin sensitization



Glass wool, polyisocyanates compounds (external coatings, paints, foams for automobile seats, footwear,

bedding, adhesives and sealants.)

Nickel plated jewellery and watches (skin sensitizer)

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Germ cell mutagenicity

Carcinogenicity

Reproductive toxicity plus additional category for effects on or via lactation

Specific target organ toxicity (STOT) – single and repeated exposure

These hazards properties have the same pictogram and the specific hazard can be identify using a

laboratory test or by specific knowledge of the composition of good. In order to ease the use of the

guideline it is possible to gather together these specific issues. In some cases the substance classified as

Carcinogenic can be also classified with other hazards properties of this group.

Definitions

Germ cell mutagenicity: This hazard class is primarily concerned with substances that may cause mutations

in the germ cells of humans that can be transmitted to the progeny. The more general terms ‘genotoxic’

apply to agents or processes which alter the structure, information content, or segregation of DNA,

including those which cause DNA damage by interfering with normal replication processes, or which in a

non-physiological manner (temporarily) alter its replication.

Carcinogen means a substance or a mixture of substances which induce cancer or increase its incidence.

Reproductive toxicity includes adverse effects on sexual function and fertility in adult males and females,

as well as developmental toxicity in the offspring. In this classification is included also the substances may

cause harm due to its effects on or via lactation. This can be due to the substance being absorbed by

women and adversely affecting milk production or quality, or due to the substance (or its metabolites)

being present in breast milk in amounts sufficient to cause concern for the health of a breastfed child.

Specific target organ toxicity (single and repeated exposure) is defined as specific, non lethal target organ

toxicity arising from a single exposure to a substance or mixture. All significant health effects that can

impair function, both reversible and irreversible, immediate and/or delayed and not specifically addressed

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Pictogram



Pesticides, biocides, Asbestos, Solvent based varnish

Pictures:

a. Environmental hazards

Risk for aquatic environment

Definition:

Substances can present risk for the environment and ecosystems. The Global Harmonized System for the

classification and labelling of chemicals developed some guidelines in order to define this hazard. The

aquatic environment is considered in terms of the aquatic organisms that live in the water, and the aquatic

ecosystem of which they are part. The basis, therefore, of the identification of acute (short-term) and long-

term hazards is the aquatic toxicity of the substance or mixture, although this shall be modified by taking

account of further information on the degradation and bioaccumulation behaviour, if appropriate.

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Pictograms



Pesticides, biocides, mineral oil, detergents,

Pictures

Hazardous to the ozone layer

Definition: Goods containing substances can present risk of depleting the atmospheric ozone layer . The EU

Reg. 1005/2009 provide a list of these substances e.g. carbon tetrachloride, hydro chlorofluorocarbons

Pictograms: None


Refrigerants (as gas contained in old freezers or air conditioning machines), spray gases, polyurethane

foams.

6. Risks assessment for hazardous goods handling and treatment a. Introduction

“The hazard of a substance or mixture (as goods) is the potential for that substance or mixture to cause

harm. It depends on the properties of the substance or mixture. In this connection hazard evaluation is the

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process by which information about the intrinsic properties of a substance or mixture is assessed to

determine their potential to cause harm.” (from “Basic guidance to Regulation (EC) No 1272/2008 on

Classification, Labelling and Packaging of substances and mixtures”)

The evaluation of hazardous property of the substances or mixture contained in a good represent the first

step for the evaluation of the risks related to the exposition scenarios where the good will be used.

For the purpose of this guideline, it is possible to foresee three exposure scenarios: the handling, the

storage and the destruction of confiscated goods.

In order to apply in the right way the mentioned Regulation it is necessary to know the composition of the

goods, however the composition of confiscated goods, without dedicated analysis, could not be exactly

known by the operators and, on the other hand, due to the origin of confiscated goods, also the labels

cannot be considered as reliable.

Bearing in mind these information a precautionary approach is strongly recommend. Hereafter are

described the three exposure scenarios and how to assign the hazardous properties to goods.

b. Risk assessment related to handling and treatment of hazardous goods:

exposure scenarios Based on our experiences it is possible to identify three different stages that are distinguished by different

kind of risks:

1. Handling and sorting of goods

2. Storage

3. Shredding phase

c. Risks assessment for handling and sorting phases During the handling and the sorting phase to move the goods from the “ Live Evidence Area” to the “goods

area” it is possible to identify two kinds of risks related to the composition of goods and their packaging

conditions (entirely, presences of leaking).

As example, in case of dusty materials (e.g. washing powder, cement…), there is a risk of inhalation and eye

or skin irritations. To avoid these risks it is mandatory the use of adequate Personal Protective Equipment

(PPE) as masks, protective glasses and gloves.

It is necessary also to pay specific attention during the unloading of goods from the lorry:

Heavy and bulky goods have to be handled using the forklift and metal boxes

Avoid shaking and bumping

Visual control of packaging condition before handling

d. Risks assessment for storage phase The main risk during the storage of confiscated goods are:

1. Presence of animals as mice and rats attracted by the food.

2. Leaking of the contents due to failures on the packaging

To reduce the risk related to the presence of animals (health risk), the first step is the reduction of the

storage time to the minimum as possible and, at the same the use of closure systems as sealed plastic

boxes.

The use of sealed boxes can also avoid the risks related to the leakage of contents.

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The spatial arrangement of the storage area have to take into the account also the risk related to physical

or chemical reaction among different substances (e.g. flammable substances). This specific kind of risk have

to be evaluated during the sorting phase in order to identify the right place to storage potentially

hazardous goods.

The identification of a dedicated area for hazardous goods and the use of separated boxes represent only a

partial solution. As described before, the reduction of the storage time and reduction of quantity of

hazardous goods stored represent the suggests solution to minimize the risks.

It is important to underline that some hazardous goods can’t be shredded due to the potential risks for

health of workers or risks of environment pollution. (see after). For these kind of materials it is necessary to

make an agreement with a specialized operator (e.g. hazardous waste treatment plant) which is able to

destroy the goods without risks. The use of an external operator, for specific kind of products, represents a

standard procedure in other MS and it can be considered as a best practice.

e. Risk assessment for the shredding phase The risk related the shredding phase are:

Risks of fire or explosion due to the presence of flammable/explosive substance

Risk of environment pollution

Risk of inhalation of dusts

Risk of being hit by flying particles

All these risks can be minimized through the enforcement of a strict sorting procedure. In particular to

eliminate the risk of fire or explosions the better solution is a precautionary approach based on the visual

evaluation of goods. If the composition or nature of the goods are not well identified we suggest to classify

it as hazardous and do not shred it.

Regarding the risk for the environment, some goods (such as batteries or liquid detergent) can be shredded

but the waste produced should be considered as hazardous for the environment. Due to this reason, we

suggest to divide the goods presenting this feature and store in the dedicated sub-area. These good have to

be destroyed in specialized plant (as hazardous waste treatment plant) which is able to minimize the risk

for the environment.

Regarding the risk of inhalation of dust produced during the shredding phase (and during the cleaning of

the machines) can be reduced through the use of protective masks.

As described before, the shredding of powdery materials as cement or cleaning powder is not allowed due

to environmental risks related to these materials.

Regarding the risk of being hit by flying particles the only way to reduce the risk is to stand away from the

machine during the shredding and the use of PPE.

7. Proposal for the destruction of untreatable goods Some kind of goods confiscated cannot be shredded due to their physical state, composition or dimensions.

However it is possible to propose some different treatment process able to guarantee a safe destruction of

these materials.

a. Food Example: Chocolate, biscuits, sugar,

Proposal: these kind of goods can be used as animal feed or destroyed in a composting or biogas

production plant (a biogas plant is located in Vrbas).

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Needs: In order to guarantee the safety and health of animals, if the foods are used as animal feed it is

mandatory for a prearranged control carried out by local Veterinary services. If used in biogas production

there aren’t mandatory specific controls but it is necessary to define a contract with the Biogas plant. At

the moment there is only a biogas plant operating in Serbia managed by a private company (Mirotin Energo

d.o.o.).

In both cases the packaging have to be removed before the use. The packaging can be shredded as non-

hazardous goods.

b. Liquors and Beverage Example: fruit juices, liquors

Proposal: these kind of goods can be destroyed in a Wastewater Treatment plant that collect sewage or in

a biogas production plant

Needs: Public utility companies are usually the managing authorities of wastewater treatment plants. In

this case, as if by the waste management company, it is necessary to define an agreement between the

bodies.

In both cases, bottles or other liquid containers, have to be emptied in a plastic tank (provided by the

wastewater treatment plant or biogas plant). The residual packaging can be shredded as non-hazardous

goods.

Example of plastic tank

c. Metal Example: truck and automotive spare parts, pipes.

Proposal: this kind of good cannot be shredded if the thickness of the metal is higher than 5-7 mm,

however they can recovered through a smelting process in furnace. These goods have also a substantial

market value and could represent an income for the Market Inspectorate and Customs.

Needs: A Waste management company can manage this kind of goods. The management of metals goods

should be included in the general agreement.

d. Bulky electric and electronic equipment Example: freezer, washing machines, television.

Proposal: this kind of good cannot be shredded due to the contents of potential hazardous materials. (e.g.

ozone depleting substance contained in freezer). The management of Electric and Electronic Equipment

and Waste from Electric and Electronic Equipment have to be done in specific treatment plant.



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e. Chemical Example: detergents, washing tabs, acids, mineral oil

Proposal: this kind of good cannot be shredded due to the contents of potential hazardous materials. Their

destruction have to be done in specific treatment plant. (e.g. Chemical treatment plant or Incinerator plant)

Needs: A Waste management company can manage this kind of goods. The mineral oil can be burned in

power plants as source of energy.

f. Batteries and accumulators Example: car accumulator, nickel cadmium batteries, alkaline batteries.

Proposal: this kind of good cannot be shredded due to the contents of potential hazardous materials. Their

destruction have to be done in specific treatment plant. (e.g. Chemical treatment plant or Incinerator plant)

Needs: A Waste management company can manage this kind of goods. Metals such as lead contained in car

accumulators could be recovered after the removal of acid. All these operations have to carried out in

dedicated plants.

g. Under pressure containers Example: spray bottles, lighters.

Proposal: this kind of good cannot be shredded due to the risk of explosion. Their destruction have to be

done in specific treatment plant. (e.g. Chemical treatment plant or Incinerator plant)



6. Conclusion and Recommendation

The conclusion will be subdivided on the basis of the different phases:

Handling phase:

There are some aspects that we can consider as mandatory during the handling of goods

Use a precautionary approach: if the composition is unknown the goods have to be considered as

potentially hazardous

Visual controls of packaging condition and contents represent the first fundamental step for the

recognition of potential hazards

The use of PPE is mandatory

Storage phase:

During the storage the goods have to be arranged in racks, following the scheme showed in picture 1. The

hazardous goods have to be stored in sealed boxes with a clear indication of the content using signs.

The different areas (live evidence area, hazardous goods area, untreatable area…) have to be clearly

identified using signs and drawing a perimeter on the floor.

A plan of the warehouse that show the different locations of areas have to be displayed by the entrance of

the warehouse. A paper or digital index of the different goods stored and their position have to be

prepared (below an example)

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Rack Level

(top to

bottom)

Date of

confiscation

Kind of goods Evidence n. Moved to destruction

area

Date of

movement to

another area

1 1 01/01/2015 Chocolate

“milka” 100

pieces

100/2014 Area: Untreatable

Rack 2 Level 2Box 3

1 2 02/01/2015 Nike socks 200

pieces

2/2015 Area: non hazardous

Rack 3 Level 2 textile

3/3/2015

Example of index for Evidence Area

The movement of goods from the “ live evidence area” to another area have to be done avoiding bumping

and after a visual inspection of the packaging condition.

For each area a paper or digital index can be adopted. The use of cross reference, in order to ease the

controls is strongly recommend

Rack Level

(top to

bottom)

Date of

movement

Kind of goods Evidence n. Date of destruction

1 1 01/01/2015 T-shirt Adidas

10 pieces

50/2014

2 3 03/03/2015 Nike socks 200

pieces

02/2015 5/3/2015

Shredding phase

The goods can be destroyed only after a visual inspection. The boxes should be opened before the

destruction and the packaging removed and treated separately (if the waste will be recovered e.g.

cardboard boxes or paper ).

The goods destroyed have to be recorded in a separated index with cross reference with the index

proposed before.

Shredding

operation

Date of

destruction

Kind of

goods

Evidence n. Notes

1 05/03/2015 T-shirt

Adidas 10

pieces

Process n. 01/2015

2 03/03/2015 Nike socks

200 pieces

Process n. 02/2015

During all these phases the use of PPE is mandatory.

Handling and storage of hazardous goods.

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The handling and storage of hazardous goods have to be done using a precautionary approach.

The goods have to be handled only after a visual control of the goods, the packaging condition and absence

of leakages. The use of PPE is mandatory. The goods have to be stored in sealed boxes labelled with the

signal that clearly represent the contents and relevant risks.

The destruction of these goods have to be done by a specialized company as a waste management

company.

Recommendations about waste management:

The management of waste produced after the shredding process have to be carried out by a specialized

waste management company. Based on the on our observations the largest part of goods are non-

hazardous and the waste produced by their destruction can be managed by the company that collects

urban waste.

Regarding the residual part of hazardous and untreatable goods, the same company will be able to propose

a treatment process because the composition of these hazardous goods are similar to the hazardous waste

produced by the citizens (detergents, batteries, Electronic equipment).

For some specific kind of untreatable goods (food, liquid) it is possible to arrange a dedicated contract with

a biogas production plant or wastewater treatment plants. As an alternative, it is possible to delegate their

management to the supplier that will provide for the other waste treatment process. In this case, the

contract will have to indicate this aspect in a dedicated paragraph.

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Annex 1 - Decisional tree – Warehouse arrangement

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Annex 2 - Decisional tree – Risk assessment of goods

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Annex 3: Examples of risk assessment

Example 1: Batteries

STEP 1 Visual evaluation of counterfeited goods Alkaline batteries

STEP 2 Are hazardous substances contained in the goods?

YES

STEP 3 Which substances Heavy metals

STEP 4 Which relevant hazardous properties Dangerous for the environment, Explosive

STEP 5 Is the good hazardous? YES

STEP 6 Risk assessment for handling The goods have to be handled using adequate PPE (gloves)

STEP 7 Risk assessment for storage The goods have to be stored in the dedicated area “Hazardous good” in the dedicated rack/boxes

STEP 8 Risk assessment for treating The goods cannot be destroyed using the shredder. The goods have do be destroyed in a dedicated plant

Example 2: Dishwasher tabs

STEP 1 Visual evaluation of counterfeited goods Dishwasher tabs


YES

STEP 3 Which substances Detergent substances, alkanine

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substances

STEP 4 Which relevant hazardous properties Dangerous for the environment, Irritant


STEP 6 Risk assessment for handling The goods have to be handled using adequate PPE (gloves, masks and glasses)

STEP 7 Risk assessment for storage The goods have to be stored in the dedicated area “Hazardous good” in the dedicated rack/boxes. If possible remove the packaging.

STEP 8 Risk assessment for treating The goods cannot be destroyed using the shredder. The goods have do be destroyed in a dedicated plant. The packaging can be destroyed and recycled.

Example 3: Liquors and spirits

STEP 1 Visual evaluation of counterfeited goods Liquor


STEP 3 Which substances Detergent substances, alkanine substances

STEP 4 Which relevant hazardous properties Dangerous for the environment, Irritant


STEP 6 Risk assessment for handling The goods have to be handled using adequate PPE (gloves, masks and glasses)

STEP 7 Risk assessment for storage The goods have to be stored in the dedicated area “Hazardous good” in the dedicated rack/boxes. If possible remove the packaging.

STEP 8 Risk assessment for treating The goods cannot be destroyed using the shredder. The goods have do be destroyed in a dedicated plant. The packaging can be destroyed and recycled.

guideline_handling_final

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