Temporary storage of hazardous waste

Temporary storage of hazardous waste is an intermediate phase in the waste management chain that allows such waste to be accumulated in a controlled and safe way before its treatment, recovery or final disposal.

Given the potential risk of these wastes (due to their toxicity, flammability, corrosivity or reactivity), their storage requires dedicated facilities, qualified personnel and strict compliance with environmental and safety regulations. In Spain, this stage is governed by the Waste and Contaminated Soil Law 7/2022 and Royal Decree 553/2020 on the movement of waste, in line with the EU directives.

Definition

Temporary storage of hazardous waste is the controlled, provisional deposit of such waste before its collection, transport or treatment, for a legally established maximum period. Its purpose is to guarantee the safety and traceability of the waste while it awaits final treatment, avoiding risks of contamination or accidents.

Purpose of temporary storage

1. Optimise waste management logistics.
2. Group sufficient quantities for efficient transport or treatment.
3. Avoid uncontrolled accumulation at producing facilities.
4. Guarantee environmental and occupational safety.
5. Facilitate the traceability and documentation required by law.

Types of storage

1. At the place of production

Producers may temporarily store their hazardous waste within their own facility, provided they meet the safety conditions and time limits.

• Maximum period: 6 months.
• Labelling, containment and record-keeping obligations.

2. At authorised managers' facilities

Waste is moved to an authorised intermediate store, where it remains until its recovery or final disposal.

• Maximum period: 1 year (for recovery) or 2 years (for disposal).
• Requires the corresponding environmental authorisation.

Types of hazardous waste accepted

• Industrial chemical waste: solvents, paints, acids, used oils.
• Infectious healthcare waste.
• Contaminated sludge.
• Oil and fuel filters.
• Batteries and accumulators.
• Waste containing heavy metals or PCBs.

Each waste must be identified by its LER/EWC code (European List of Waste) and stored according to its hazard category.

Technical storage requirements

Temporary storage areas must meet the conditions set out in the Industrial Emissions Directive 2010/75/EU and Law 7/2022, among others:

• Impermeable surfaces with leachate collection systems.
• Retention bunds with a capacity above 110% of the volume of the largest container.
• Separation of incompatible wastes (acids and bases, oxidisers and flammables).
• Adequate ventilation and temperature control.
• Hazard signage in accordance with the CLP Regulation (EC) No 1272/2008.
• Fire detection and extinguishing systems.
• Spill and emergency containment equipment.

Applicable regulations

European Union

• Directive 2008/98/EC (Waste Framework Directive).
• Industrial Emissions Directive 2010/75/EU.
• Regulation (EU) No 1357/2014: classification of hazardous waste properties.
• ADR Agreement: carriage of dangerous goods by road.

Spain

• Waste and Contaminated Soil Law 7/2022.
• Royal Decree 553/2020 on the movement of waste.
• Royal Decree 815/2013 on industrial emissions.
• Chemical product storage regulation (Royal Decree 656/2017, APQ).
• Regional hazardous waste management plans.

Mandatory documentation

Every producer or manager must maintain documentary traceability of stored waste, including:

• Waste identification (LER/EWC code and properties).
• Safety data sheet.
• Quantity and date of entry.
• Intended destination (recovery or disposal).
• Movement documents (identification document and prior notification).
• Annual hazardous waste report.

Environmental and safety control

Temporary stores are subject to periodic inspections by environmental and labour authorities. They must have:

• Internal and external emergency plans.
• Preventive maintenance of facilities.
• Fire and explosion prevention measures.
• Specific training for staff.
• Environmental and occupational risk assessment.

Associated risks

1. Accidental leaks or spills.
2. Uncontrolled chemical reactions.
3. Fires or explosions.
4. Soil or groundwater contamination.
5. Occupational exposure to toxic agents.

Good management practices

• Clearly label all waste with its LER/EWC code and hazard pictograms.
• Keep containers closed and in good condition.
• Record waste inflows and outflows in real time.
• Avoid accumulation beyond the legal time limits.
• Separate incompatible wastes and maintain adequate ventilation.
• Ensure that onward transport is carried out by authorised managers.

Relationship with the circular economy

Although temporary storage is not directly part of recovery or recycling, it is a key element of the circular economy because it guarantees the safety and traceability needed for hazardous waste to be treated correctly. It helps to:

• Prevent illegal dumping and contamination.
• Support the recovery of valuable hazardous materials (mercury, solvents, oils).
• Ensure regulatory compliance across the whole management chain.

Innovation and digitalisation

Current trends in hazardous waste storage include digital management systems integrated with regional platforms, IoT sensors for leak or temperature detection, RFID labelling and blockchain traceability, and artificial intelligence for predictive risk control. For example, Spain's e-SIR system enables mandatory digital communication between producers, managers and authorities for tracking hazardous waste.

Conclusion

Temporary storage of hazardous waste is a fundamental stage for ensuring environmental safety and efficient waste management. Responsible management requires adequate infrastructure, rigorous control, trained staff and digital traceability, so that this waste is handled without risk to people or the environment. Within the framework of the circular economy and the ecological transition, temporary storage should be seen as a safe bridge between waste generation and its recovery or final disposal.

At Manglai we help companies measure their carbon footprint and the environmental impact of their waste streams as part of their sustainability reporting. Discover how Manglai can help you.