Guidance

Manage waste upholstered domestic seating containing POPs

Identify, describe, classify and manage waste upholstered domestic seating containing persistent organic pollutants (POPs).

Applies to England

Identify waste upholstered domestic seating that contains聽POPs

Waste domestic seating is any item of seating of a household type from households or businesses that is waste. Upholstered domestic seating may contain聽POPs. For example:

  • sofas
  • sofa beds
  • armchairs
  • recliner chairs (electrical or mechanical)
  • kitchen and dining room chairs
  • garden furniture
  • stools and foot stools
  • office chairs that are fire resistant to domestic standards
  • futons
  • bean bags, floor and sofa cushions
  • any other upholstered items that can reasonably be described as a form of seating used by households, and to which relevant fire regulations apply this might include child car seats, highchairs, and benches

This includes any part made of or containing leather, synthetic leather, other fabric, or foam.

The following items of domestic seating are unlikely to contain聽POPs:

  • items that are not upholstered, for example, a wooden chair without a cushioned or textile back, seat, or arms
  • deckchairs
  • wastes from manufacturing new domestic seating that the manufacturer can show do not to contain聽POPs

Mattresses, curtains, blinds, beds, and commercial seating of a type not used in the home are not domestic seating and are not covered by this guidance.

Items that are not domestic seating may still contain POPs. Where they do contain POPs you should identify and manage them appropriately, see:

Commercial seating is at particular risk of containing POPs and you should consider this as part of your duty of care.

Describe and classify waste domestic seating containing聽POPs

In your waste transfer note you must:

  • describe the waste as 鈥榙omestic seating waste containing聽POPs
  • classify it with the list of waste code 20 03 07

You must add this description for waste domestic seating containing聽POPs聽where it has been mixed with other waste (not containing聽POPs). For example, in a skip or bay of bulky household waste.

Although it may contain POPs, waste under a 20 03 07 code is classified as absolute non-hazardous. 聽

You must list the relevant chemicals in the waste transfer note, or provide this information separately, so the recipient is aware of their presence.

POPs聽and other chemicals that waste domestic seating may contain

Waste upholstered domestic seating often contains one of the following聽POPs聽on the back of the covers and in the foam:

  • decabromodiphenyl ether (DecaBDE) 鈥 the most common
  • hexabromocyclododecane (HBCDD)
  • pentabromodiphenyl ether (PentaBDE)
  • tetrabromodiphenyl ether (TetraBDE)

These chemicals may also contaminate lining and wadding in contact with foam or covers.

The following hazardous chemicals are also likely to be present:

  • antimony trioxide 鈥 a carcinogenic synergist often used with DecaBDE
  • medium chain chlorinated paraffins 鈥 often used in synthetic leather to make it flexible

Other flame retardants, and hazardous components of PVC, may also be present. Electrical recliner chairs may contain POPs in plastic components, internal and external cables, and printed circuit boards.

Sort and store waste upholstered domestic seating containing聽POPs

You must sort and store waste upholstered domestic seating containing聽POPs聽in a way that prevents:

  • damaging it
  • release of聽POPs
  • contamination with other waste

You must avoid mixing waste upholstered domestic seating containing聽POPs聽with other waste during waste:

  • production
  • storage
  • collection
  • treatment

This includes in a:

  • skip or container
  • bay at a household waste recycling centre (HWRC), transfer station, or treatment site

In exceptional circumstances, you can justify not segregating further where both of these apply:

  • you have already taken all reasonable steps
  • there are no other alternatives

You must provide evidence to the Environment Agency. However, they may not accept this.

If you do mix聽POPs听飞补蝉迟别 with non-POPs听飞补蝉迟别, you must manage the whole load as聽POPs听飞补蝉迟别 until you can separate the upholstered domestic seating. You must destroy the聽POPs聽even if the mixing has diluted the聽POPs聽to below the POPs concentration limit.

You can read guidance on fire prevention plans and managing fire water.

Transporting whole and shredded items of waste upholstered domestic seating

You can collect waste upholstered domestic seating on the same vehicle as other waste items (for example, doorstep bulky waste collection) as long as they are:

  • not mixed with other waste
  • collected in a way that does not contaminate the other waste (for example compaction)
  • separated from the other waste when unloaded from the vehicle

If you use a roadside collection vehicle (RCV) you must:

  • collect only waste upholstered domestic seating
  • contain any particulates and debris generated during the compaction within the body of the vehicle
  • use a vehicle dedicated to the collection of waste upholstered domestic seating only or, where this is not possible, make sure it is cleaned before it is used to collect loads of non-POPs waste

You must unload the RCV in a dedicated bay within a building that is allocated for the waste upholstered domestic seating. A dust suppression system must be in place to contain and control any particulates created when the waste upholstered domestic seating is removed from the RCV and then handled.

If you are transporting waste prepared for destruction you must:

  • make sure that the waste is baled, in a sealed container, or within the body of fully enclosed vehicle to contain the waste and prevent release of particulates and debris
  • unload the waste within the incinerator building, with a dust suppression system in place to contain and control any particulates created
  • use a vehicle dedicated to the collection of this waste only or, where this is not possible, make sure it is cleaned before it is used to collect loads of non-POPs waste

When you clean any vehicle you should use a dry-cleaning method to avoid producing contaminated water. For example using a dedicated vacuum cleaner to remove foam, textiles and particulates from within the vehicle body. The material collected should be sent for destruction using one of the methods for waste upholstered domestic seating containing POPs described in this guide.

Mixed waste and separating whole items of upholstered domestic seating from mixed waste

You must avoid mixing waste upholstered domestic seating containing POPs waste with other waste. 聽聽

Where the waste was mixed you must destroy the聽POPs聽even if the mixing has diluted the聽POPs聽to below the POPs concentration limit. 聽

You can only separate whole items of upholstered domestic seating from mixed waste, for example fly-tipped waste or waste in a skip, if you can show that it has not contaminated the other waste.

Contamination can happen when pieces of foam, cover, lining, or wadding material are released from the item.

If contamination has taken place, you must manage the whole load as聽POPs听飞补蝉迟别.

Identify whole items that do and do not contain聽POPs

You can identify items of waste upholstered domestic seating that do not contain聽POPs聽and store them separately.

You can use x-ray fluorescence (XRF) to scan for bromine, the presence of bromine indicates that聽POPs聽are likely to be present. However, you must:

  • have the right training for using聽XRF聽and use a suitable device
  • contact the Environment Agency to check if you need to make any changes to your permit and management system
  • be able to show that your process works and is accurate 鈥 the Environment Agency may ask you for this evidence

If no bromine is present in the rear of the cover, foam, other fabrics, or any electrical components then brominated POPs will not be present.

You should contact the Environment Agency for advice if you are considering using an XRF scanner.

Dispose of waste domestic seating containing聽POPs

You must incinerate waste domestic seating containing聽POPs聽or mixed waste containing it.

The municipal or hazardous waste incinerator (or cement kiln) must be authorised to accept聽POPs听飞补蝉迟别.

You must not use any other type of incinerator, for example a small waste incineration plant (with a capacity below that set out in Section 5.2 of Annex I IED) unless:

  • the operator has implemented bi-annual polybrominated dibenzo-dioxins and furans monitoring to air
  • the Environment Agency has approved evidence of destruction efficiency of brominated POPs submitted by the operator

You must not use any other waste treatment, recycling or disposal methods, for example landfill.

Contingency plan for incinerator shutdown

Where the incinerator cannot accept the waste, you can:

  • store the waste until the incinerator is able accept it
  • send it to another incinerator or cement kiln authorised to accept and destroy it

You must not send it for any other type of disposal or recovery operation, for example landfill.

Incinerator operators need to put contingency plans in place to manage accepting waste from customers with waste upholstered domestic seating containing聽POPs聽for destruction. They cannot send this waste to landfill in the event of a planned or unplanned shutdown.

Prepare the waste for destruction

If the incinerator operator requires the聽POPs聽containing waste to be shredded, because they cannot handle whole items of waste upholstered domestic seating, you must:

  • use the shredding plant inside a building
  • not allow unabated point source or fugitive emissions of particulates from the plant or building

You must control fugitive emissions of particulates with one of the following:

  • containment and abatement of the shredding plant
  • local extraction to abatement
  • full building extraction under negative pressure to abatement

You must use bag filters on the abatement plant designed to release particulates below 5mg/m3. They must be fitted with continuous and alarmed pressure monitoring to make sure the filters are working correctly.

You may be able to use regulatory position statement Shredding waste upholstered domestic seating containing聽POPs:听搁笔厂听264 while you change your processes.

You may be able to use regulatory position statement Monitoring fugitive emissions from shredding waste upholstered domestic seating: RPS 297 to support changes to your process.

You must:

  • not remove materials for recycling unless you can show that they do not contain residual dust, fabric or foam containing聽POPs
  • send any outputs or residues from treatment that contain the聽POPs聽containing material, fabric or foam, for destruction
  • send plastics, printed circuit boards, and cables from electrical recliner chairs for destruction.
  • send any fines, dust or particulates produced by the process for destruction, and describe the waste for transfer as 鈥榗ontaining聽POPs
  • store shredded waste upholstered domestic seating containing聽POPs聽on an impermeable surface
  • store the waste either within a building, in a sealed container, or baled and securely wrapped

You must make sure POPs are not released to sewer, surface water or the wider environment. You should, where possible, locate shredders and waste storage away from drains. Your misting and spray systems should use the minimum water possible to prevent or reduce the production of contaminated water. Drain mats and blockers could be used to prevent runoff from entering drains.

You may send metal fractions to a suitably authorised smelter operating under recovery code R4. Where the waste contains fabric and foam, you must classify and describe the waste as 鈥榤ixed waste containing聽POPs鈥. If you carry out any intermediary treatment you must:

  • have appropriate abatement and emissions controls
  • send any outputs or residues containing the fabric and foam for destruction
  • have an environmental permit that authorises this activity

If you send the waste to an intermediary site for storage, before transporting to a smelter, you must make sure that the waste containing POPs is kept separate to avoid contaminating other waste.

Where the incinerator is not able to accept and process segregated waste, the operator may require you to blend the segregated waste upholstered domestic seating with other waste to:聽

  • make loading easier
  • control calorific value
  • optimise combustion

The operator should explain what blending is required, why it is technically necessary, and provide you with a specification to address that.

When you blend the segregated waste, you must do it in a controlled way that uses the least amount of non-POPs听飞补蝉迟别 necessary to avoid:聽

  • release of particulates containing聽POPs
  • contaminating more waste than necessary

You should only blend immediately before shredding or incineration.

You must have an environmental permit that authorises this blending activity.

You should check your management system and permit if you want to install plant to prepare聽POPs听飞补蝉迟别 at your site.

If the waste you prepare for destruction creates a refuse derived fuel you should classify the waste as 19 12 10, a non-hazardous waste. Fines from the shredding process should be assessed for hazardous properties and classified as 19 12 11* or 19 12 12 as appropriate.

How landfill operators must manage waste upholstered domestic seating

Landfill operators must not accept any waste upholstered domestic seating containing聽POPs. This includes:

  • segregated items of waste upholstered domestic seating
  • mixed waste containing items of waste upholstered domestic seating
  • shredded or broken up waste from treating waste containing waste upholstered domestic seating, including refuse derived fuel and solid recovered fuel
  • trommel fines from treating waste containing waste upholstered domestic seating, including the dust from air filtration systems

Your waste acceptance procedures must screen out waste upholstered domestic seating. You must quarantine this waste type and send it to an appropriately authorised incinerator for destruction.

You can only landfill items of waste upholstered domestic seating where you have confirmation that it does not contain聽POPs. This confirmation must come from a site that has documented procedures in place for correctly identifying and separating items of seating containing聽POPs. See the section on 鈥業dentifying whole items that do and do not contain聽POPs鈥.

If you accept items or material from the manufacture of waste upholstered domestic seating, you must also follow the guidance in the section 鈥榃aste from manufacturing upholstered domestic seating鈥.

Treatment of waste upholstered domestic seating

Separating materials containing聽POPs聽from other materials

You can separate the foam and fabric containing聽POPs聽from other materials in an item of domestic seating. Your environmental permit must authorise this activity.

You can also separate the printed circuit boards, cable and plastic components containing POPs in electrical recliner chairs. These items are waste electrical devices but are outside the scope of the Waste Electrical and Electronic and Equipment (WEEE) Regulations 2013 (as amended). You can manage them alongside other waste upholstered domestic seating.

If you manually separate, you must make sure:

  • all foam and textiles are completely removed, and you manage any part of the item with foam and textile attached to it as聽POPs听飞补蝉迟别
  • printed circuit boards, cable and plastics from electrical recliner chairs are managed as POPs waste.
  • you prevent or contain any dust, or fragments of foam and textile released from the material and you must manage the dust and fragments as聽POPs听飞补蝉迟别
  • you store separated material containing聽POPs聽inside a building, under cover, or in a sealed container
  • that no聽POPs聽are released to the sewer or surface water

If you use mechanical treatment processes, you must also follow the guidance in the section 鈥楶repare the waste for destruction鈥.

Compacting waste domestic seating containing聽POPs

Compacting waste domestic seating containing聽POPs聽is allowed. However, you must take reasonable steps to prevent, contain and collect any releases of聽POPs聽contaminated material or dust that the compaction produces.

You can do this by squashing the waste slowly to confine all materials within the space you are working. For example you can use:

  • a grab or bucket to compact the waste steadily
  • the roller packer system in the container
  • ram-based compaction into a container

You must regularly check for particulates to make sure they are not released during compaction. You can control release by:

  • misting and using sprays over the container
  • using suitably placed mobile dust suppression cannons
  • spraying the surface of the waste before compaction using a backpack sprayer

You must send this compacted waste and any contaminated material or dust for destruction. You must not send it to landfill.

Exporting waste domestic seating containing聽POPs聽for incineration

You must only export waste upholstered domestic seating to European Union or European Free Trade Association countries for incineration with energy recovery (R1).

If the incinerator you are sending the waste to requires you to prepare the waste for destruction, you can do this as long as your site, or the site you use, is suitably authorised.聽Contact the Environment Agency聽to check how to make sure your management system and permit covers this treatment.

If you export聽refuse derived fuel or solid recovered fuel聽which is made from waste upholstered domestic seating or is partly made from of waste domestic seating containing聽POPs, the聽POPs聽must be destroyed.

You must make sure that the presence of聽POPs聽is made clear in block 12 鈥榙esignation and composition鈥 of your notification.聽

Waste from manufacturing upholstered domestic seating

When you manufacture upholstered domestic seating you must know what chemicals are in the:

  • covers
  • foam
  • lining
  • wadding

Suppliers from some countries that have not fully implemented the Stockholm Convention may supply materials containing chemicals, for example flame retardants, that are聽POPs. You should ask the manufacturer for evidence of which flame retardant is present. If the manufacturer cannot provide evidence of what chemicals it contains and in what quantities (either via a supplier鈥檚 specification or analytical testing) you must assume that it contains POPs.

You must make sure that any waste you produce from manufacturing upholstered domestic seating is described and classified correctly. This is so that your waste contractor can manage it appropriately.

You should clearly label your new products with the chemicals that are present in their components. This will make sure that they are managed appropriately in the future, including when they are:

  • reused
  • recycled
  • disposed of

Updates to this page

Published 19 December 2022
Last updated 2 December 2024 show all updates
  1. Removed the reference to regulatory position statement 'Temporary storage of waste upholstered domestic seating containing POPs: RPS 265', as it has expired and been withdrawn.

  2. Removed the reference to the regulatory position statement (RPS) 'Segregating waste upholstered domestic seating that may contain聽POPs聽at HWRCs:聽RPS聽266', as it has expired and been withdrawn.

  3. Updated to clarify guidance on: how to identify waste upholstered domestic seating containing POPs; separating waste containing POPs from other materials; transporting whole and shredded items of waste upholstered domestic seating; preparing waste containing POPs for destruction.

  4. Added text under 'Sort and store waste upholstered domestic seating containing POPs' - In exceptional circumstances, you can justify not segregating further where both of these apply, you have already taken all reasonable steps and there are no other alternatives. You must provide evidence to the Environment Agency. However, they may not accept this.

  5. First published.

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