When Sending Your Waste to Disposal/Recycling Facilities:
PAY ATTENTION TO THE FOLLOWING!
1. Waste Identification/Waste Analysis
The IDENTIFICATION and disposal/recycling of the waste generated in your facility as a result of your activities is one of the essential issues both for you as Waste Producers and for Authorized Facilities.
- The assignment of the waste code is the first step to determine the method of disposal/recycling for your waste.
"WASTE CODE ASSIGNMENT HIERARCHY AND WASTE CODE DESCRIPTIONS".
See Page 1 titled .
- Once the waste code is assigned, it will be easier for you to select an Authorized Facility when you are informed about the method through which your waste will be included in disposal/recycling processes. Therefore, make sure to request the “ANALYSES OF YOUR WASTE” from the Authorized Facility to which you will send your waste.
See page 2 and 3 titled "WASTE CODE ASSIGNMENT HIERARCHY AND WASTE CODE DESCRIPTIONS"
for disposal/recycling processes.
2. Environmental Permit and License
After the identification and analysis of your waste, make sure to ask for the license of the Authorized Facility with which you will work.
Environmental Permit and License is granted to companies by the Ministry of Environment and Urbanization for a limited period of time. In the event that Authorized Facilities fail to fulfill their responsibilities, their licenses are suspended or revoked. The Environmental Permit and License inquiry page will help you in this context.
3. Site Visit
In order to ensure a much healthier process, you should DEFINITELY visit the Authorized Facility to which you plan to send your waste, and obtain information on the following important matters before signing a contract.
Make sure to obtain information from the Facility Official on the following topics:
• Environmental Permit and License;
• Laboratory/Waste Analysis Methods;
• Waste Storage Conditions;
• Disposal/Recycling Processes;
• Floor Impermeability, Rainwater Harvesting Channels and Soil Pollution;
• Fire Protection/Extinguishing Systems;
• Ventilation System;
• Facility Cleaning;
• Camera System;
• Waste Reporting System; and
• Occupational Health and Safety Policies.
4. Joint Responsibility
Unfortunately, this issue is not widely known in our country and constitutes the riskiest step in the waste management process.
Subparagraph 5(ü) of the Waste Management Regulation is given below.
ü) Those engaged in the collection, transportation, temporary and interim storage, recycling, reuse, and disposal of hazardous waste shall be jointly liable for any damage caused by environmental pollution and degradation due to hazardous waste. The compensation liability of those responsible for damages caused by these activities shall be reserved based on general provisions. Expenses incurred and/or required to be incurred by public institutions and organizations due to the failure of those responsible for waste management to take the necessary measures to prevent, eliminate, or limit environmental harm, or due to the measures taken directly by authorities shall be borne by those responsible for waste management pursuant to the Law No. 6183 on the Procedure for the Collection of Public Receivables dated July 21, 1953.
Your responsibility does not end when you load your waste to the vehicle to send it to the Authorized Facility.
The following examples are provided to explain this article:
Scenario 1:
The vehicle of the Authorized Facility or the Waste Transportation Company left your facility with your waste. The same vehicle was involved in an accident 100 m from your facility, causing environmental pollution.
Result: As the Waste Generator, you shall be jointly liable with the Waste Transportation Company and the Authorized Facility for any environmental pollution and the resulting environmental penalty (Article 20).
Scenario 2:
Your waste was delivered to the disposal/recycling facility and accepted. The relevant Integrated Environmental Information System records were approved.
This does not mean that your responsibility ended.
Your waste was managed by the Authorized Facility in violation of the procedures, principles, bans, or limitations stipulated in the Environmental Law and environmental regulations. As the Waste Generator, you shall also be liable for any environmental pollution and the resulting environmental penalty (Article 20).
Scenario 3:
As the Waste Producer, you shall also be liable for any environmental penalty (Article 20) due to any air pollution caused by any fire that may occur in the Authorized Facility to which you send your waste; any water pollution caused by the mixing of your waste with rainwater; or any soil pollution caused by storage in areas where floor impermeability is not adequate.
5. Insurance Policy
Due to the aforementioned liability, the Authorized Facility shall issue Insurance Policies in order to protect you from any damage resulting from the problems that are not caused by you as the Waste Generator, but for which you are jointly responsible.
Unfortunately, this matter is only considered in the context of waste transportation vehicles in our country. Furthermore, these policies do not offer sufficient coverage for any environmental pollution or environmental penalty (Article 20).
Therefore, do not hesitate to request at least 4 different insurance policies and check the coverage and expiration dates of these policies.
- Waste Transportation Insurance
- Product Financial Liability Insurance
- Authorized Facility Financial Liability Insurance
- Insurance Policy for Any Damage to Third Parties
6. Logistics and Collection Capacity
• In the event that your waste will be transported not by your company but by the Authorized Facility, it must be ensured that the vehicles are owned by the Authorized Facility or the contract between the Authorized Facility and the Waste Transportation Company commissioned by the Authorized Facility is reliable.
• Check the license of the vehicle sent to you, the documents of the driver, and whether the vehicle was designed in accordance with the ADR regulations.
• Check the waste collection dates specified in the contract. Please note that the failure to deliver the waste on the specified dates will affect your production.
7.Waste Acceptance and Reporting
Make sure that the contracted Authorized Facility accepted all the waste you sent, that the amount of waste is accurate, and that your waste reached the Authorized Facility in full.
Do not hesitate to request a waste acceptance report from the Authorized Facility for this purpose. When possible, request the relevant camera footage to keep regular records for a potential Environment and Quality inspection.
8.Sales Support
After-sales service is one of the most important issues today. Prefer Authorized Facilities that offer quick contract, delivery, analysis, billing or reporting services.
Please note that you shall also be liable for every piece of waste you send until its disposal or recycling.
9.Waste Disposal Footage
Even though you obtain a document from the Authorized Facility indicating that your waste has been disposed of/recycled, this document shall not be sufficient on its own in the event that you are accused of any illegal activity.
Therefore, the camera footage showing the disposal/recycling processes of your waste will provide you with protection.
10. Waste Disposal Fee
Even though the waste disposal/recycling fee appears as a cost, no cost is higher than the cost of environmental pollution or environmental penalty.
As a Waste Producer, you can ensure continuity by considering the quality/price ratio instead of only focusing on the price when evaluating the offers you receive during the selection of the Authorized Facility.
