In response to the Welsh Governments consultation that closed on the 4th of October, which asked for clarification on the use of End of Waste (EoW) criteria to define products, materials and substances, EEESafe gave a response about its Preparation for Reuse Criteria with regards to White Goods Appliances.
Below is a part transcript of the response which the Welsh Government may make public.
“The Environment Agency defines this as a Quality protocol set out for the production and use of a product from a specific waste type. The Waste Type we wish to highlight that we believe requires further consideration and possibly legislation is in regards to the product range under White Goods that fall under WEEE, UEEE and EEE categories.
In your Draft Guidance Documentation 130823 section 3.2.2 you refer to the three permitted Preparation for Reuse (PFR) recovery operations which apart from Checking and Cleaning also includes Repair. Therefore we offer our concerns relating to Repair in White Goods.
PAS 141 according to the FAQ’s on WRAPs Website states:
The PAS 141 re-use of used and waste electrical and electronic equipment (UEEE and WEEE) process management specification has been developed to improve the standards for the re-use and refurbishment of discarded electrical and electronic equipment in the UK. Developed by industry experts working with the Department for Business, Innovation and Skills (BIS), the PAS 141 specification aims to address a general demand (from consumers, retailers and others) for reassurance that used apparatus is both electrically safe to use and functionally fit for purpose.
The protocols are basically flawed because they do not carry sufficient warnings about Electrical Repairs, the dangers in doing it and nor does it recommend that it is done by a competent person, who in themselves of course must be proven.
We think this is fine for IT equipment but in White Goods Appliances you embrace Mechanical, Plumbing and Electrical products that we feel needs a Registered Competent Person to repair. Whilst it may be fine for an individual to undertake their own risks in reparation, we feel that where a charge is made for a repair or reuse service there needs to be accountability and assurance for a member of the public that a Registered Competent Person has conducted a repair on these products.
The use of PAS141 in this process has no such requirement in the Protocol. The Companies, who accredit organisations using the PAS, have no recognised qualifications in the Appliance Repair sector and neither do WRAP who have written the Protocols. It would seem from reading the Protocols that there is an assumption that some sort of testing procedures and/or qualified personnel are available to carry out tests, but assumption is clearly a poor element of this protocol. How can the public trust this protocol when there is no Registered Body with this repair knowledge to certify that operators in the process are competent? PAT Testing a product does not make it safe to use and additionally there are no requirements to electrically test components that are fitted properly and that are backed by employers experienced in the White Goods repair sector.
We feel that a Repair to an Electrical item, and in particular, White Goods Appliances, (many of which are left running on timers without attendance and in the vicinity of children), should be repaired by a recognised competent person. If a Business, A Local Authority or subsidiary, including a Mutual or a Reuse organisation does not have a Registered Competent Person conducting a repair, then there is a high risk of a serious accident or a fatality. See Appendix for links to research, highlighting the potential outcomes of unqualified repairers such as those working under PAS 141.
As a Government, you have informed us that you support PAS141 which is a British Standard, but that you do not actively promote it to businesses and what is not clear at the closing stage of this consultation is whether you promote it to Local Authorities under your remit. We feel that if you do not promote it to businesses, then you should not promote it to Local Authorities for the reasons we have outlined. (NOTE: Subsequent Communications confirmed that they would not “promote” PAS141 to Local Authorities)
At EEESafe we operate to a common term used by the HSE. This term is “Competent” and we see failure in your criteria to define Products, when you utilise the Preparation for Reuse process, particularly against PAS 141.
Whilst you may not be responsible for Safety on its own, in Waste Prevention terms and according to your Guidance document, where we reiterate you include Repair as part of your PFR, you have a duty of care in Safety terms to ensure that your policies and procedures used or supported are in the highest safety interests of the citizens of Wales.
Therefore in your final Guidance document, we recommend you alter your wording to reflect the ethos and message of Safety. We also recommend you seriously consider the detail of your PFR and any support of PAS141 when it comes to White Goods Repairs.
Finally EEESafe is a Council Member of the Domestic Appliance Services Association (DASA) and the response here represents their views as well as that of EEESafe.
According to government figures, over the last two years (2010/11) almost 6,000 appliances or their electrical leads caught fire because of faults.