External waste specialist

Who needs a waste manager?

The following companies require a waste representative: (§ 59 KrWG)

 1. The operators of the following facilities:

• Landfills until final closure
• Hospitals and clinics, if more than 2 tons of hazardous waste are generated per year.
• Wastewater treatment plants of size class 5 (= greater than 6,000 kg/d BOD5) according to Annex 1 of the Wastewater Ordinance, insofar as waste is recovered or disposed of.
• Plants requiring a permit according to the 4th BImSchV, which are listed in the following numbers of Annex 1:Plants according to numbers 1 to 7 as well as numbers 9 and 10, insofar as more than 100 tons of hazardous waste or 2,000 tons of non-hazardous waste are generated per calendar year, (These are in particular the so-called heavy industry – coal, metal production + processing…, energy, mining, quarrying, chemical products, wood processing, food, luxury food and feed products, storage of highly flammable liquids and gases, including liquid manure), as well as installations referred to in point 8, for which process type G is provided for in column c. (These are in particular recovery and disposal of waste).

2. Producers and distributors who take back waste voluntarily or on the basis of a legal ordinance pursuant to § 25 KrWG. In other words, producers and distributors who

• take back more than 100 tons of transport packaging per calendar year pursuant to Section 15 (1) Sentence 1 Number 1 of the Packaging Act. (The law defines here only transport packaging = packaging that does not accrue to the end consumer).
• take back sales packaging filled with goods. Unless the third parties appointed by them have already appointed a waste representative.
• ensure the take-back of more than 100 tons of sales packaging that does not accrue at the private end consumer. (voluntary or non-voluntary)
• take back more than 2 tons of sales packaging containing harmful substances per calendar year. (voluntary or non-voluntary)
• voluntarily take back more than 2 tons of dangerous waste or more than 100 tons of non-dangerous waste per calendar year.
• Offer to take back waste electrical and electronic equipment. Unless their contracted third parties employ a waste manager.
• Produce automotive and industrial batteries and take back automotive and industrial waste batteries in accordance with the Battery Act. This does not include producers who are members of a voluntary system for the take-back of waste automotive and industrial batteries.

3. Betreiber von Rücknahmesystemen, die

• Verkaufsverpackungen zurücknehmen, die beim privaten Endverbraucher anfallen.
• Elektro- und Elektroaltgeräte zurücknehmen.
• Gerätealtbatterien zurücknehmen (Gemeinsame und herstellereigene Rücknahmesysteme).
• Fahrzeug- und Industriealtbatterien freiwillig zurücknehmen.

Violation of the obligation to appoint a waste management officer pursuant to Section 69 (2) No. 14 KrWG may be punished by a fine of up to €10,000.

Who can become a waste manager?

It is possible to become a waste manager if you have the following qualifications:

• § Section 8 of the Waste Management Officer Ordinance stipulates reliability.
• In addition, the waste representative must have a professional qualification, which is explained in § 9 of the Waste Representative Ordinance.
• Either a university degree or at least one year of practical experience is required for this qualification
• Study or activity must be in connection with one of the areas from the KrWG (circular economy system).
• Another possibility is the participation in an approved course. Regular further training is obligatory

What are the tasks of waste managers?

According to § 60 KrWG, waste officers have the following tasks:

• Advising the management and employees of the company on matters that may be significant for waste prevention and waste management.
• Monitoring and control as well as proposals for the organization of the company’s waste management,
• Monitoring the path of waste from its generation or delivery to its recovery or disposal
• Monitoring of compliance with the laws and legal ordinances applicable to waste as well as the fulfillment of conditions and requirements issued, in particular by inspecting the premises and the type and quality of the waste managed at regular intervals, notifying the company of any deficiencies found and proposing measures to eliminate these deficiencies
• Informing the employees of the public welfare hazards that may be caused by the waste or waste management activities and of the facilities and measures to prevent them, taking into account the legal provisions applicable to the prevention, recovery and disposal of waste
• Informing the employees about the possibilities of waste reduction or avoidance and waste collection
• Inspection and monitoring of the internal waste collection points
• Participation in the selection and control of the waste disposal companies working for the company
• Working towards the development and introduction of environmentally friendly and low-waste processes, including processes for the avoidance, proper and harmless recycling or environmentally compatible disposal of waste; environmentally friendly and low-waste products, including processes for reuse, recycling or environmentally compatible disposal after discontinuation of use
• To assist in the development and implementation of the above-mentioned processes, in particular by assessing the processes and products from the point of view of waste management
• To work towards the improvement of the process at facilities where waste is generated, recovered or disposed of.
• Establishment of an annual report that complies with the requirements of § 60 Para. 2 KrWG and submission to the company management
• Giving an opinion on investment decisions
• Maintaining expertise and participating in appropriate continuing education activities related to these tasks in accordance with the respective legally prescribed deadlines
• Not required by law: Maintenance of the waste disposal register

With regard to the fulfillment of the tasks as waste management officer, he is not subject to any instructions from a technical point of view. In the event of problems arising in the course of the performance of duties which cannot be clarified with the heads of the responsible organizational units, he is entitled to raise the matter personally with the responsible member of the Board of Management.

Who does the waste manager work with?

• For specialized waste management companies, it is necessary to appoint a responsible person.
• In addition, specially appointed persons who have been trained within the framework of TRGS 520 are required for pollutant collection points.
• Each collection point must be staffed by at least 2 persons.
• Both tasks are not to be confused with the waste representative.

Where are the duties of the waste manager regulated?

The basis for the appointment and their tasks are, among others, the Closed Substance Cycle Waste Management Act (KrWG) and the Waste Management Officer Ordinance (AbfBeauftrV).

What is the advantage of having an external waste manager?

The topic of waste does not stand alone, the waste officer is also often the contact person for other topics, such as dangerous goods, dangerous substances or work safety. Here, too, they should be confident in the subject. In addition, they should be able to carry out their tasks safely in accordance with legal regulations and, for example, to represent and monitor material flows.
External knowledge and experience help here, so that you can be helped quickly and comprehensively – and at low cost.