Classifications and Recommendations

The purpose of this Code is to advise how the different types of photo-processing businesses should dispose of their trade effluent to enable them to comply with their legal obligations and to protect the environment.

It is important to classify photo-processing operations into different categories since they will possess different environmental risks.

The following is a list of the types of photographic laboratories using processing chemicals.  These include trade premises that produce “trade effluent” as described in the Water Industry Act 1991 and non-trade premises.

Effluent from non-trade premises is not covered by this Act. It is recommended that these laboratories will still comply with this Code.

Type of Operation/Company

Photographic "Trade" premises

• Photofinisher Develop and Print
• Professional Laboratories
• Laboratories specialising in Schools/Portrait Photography
• Microfilm laboratories
• Graphic Arts and Pre-Press Operators
• Printers
• Miniprint (Estate Agent photos) Laboratories
• E6 Processing Houses
• High Street Minilab Shops
• In-Store Minilabs
• Company In-house Photographic Units
• Professional Photographer: processing any quantity of films and papers

Non "Trade" premises

• Hospital Medical Photo Units
• Hospital X-ray Units
• Dental Surgeries
• Veterinary Practices
• Other Medical Premises
• Police Forces Photo Units
• MOD/Military Establishments
• Colleges/Schools
• Passport Booths: not usually connected to drainage and have all effluent removed for treatment.
• Amateur/Home Processing: outside the scope of the regulations. Check with your local water services company to see if small quantities can be poured down the foul drain in your local area.

Laboratory Classification

• The photographic laboratories have been divided into various categories based on their annual volume of trade effluent produced.

Minilabs

Summary

• A photographic laboratory offering, or capable of offering, a one hour develop and print service using only "waterless wash” (also called “washless”) Minilab equipment, i.e. the machine is not plumbed in to the water supply.
• The laboratory may operate as a stand-alone retail unit, or be within a larger operation, or in trade premises. 
• Effluent volumes typically less than 12.5 cubic metres (12,500 litres) per annum
• Recommended method for handling the photo effluent is to use a recognised haulaway contractor to remove it. 
• The local Water Services Company will make charges based on a domestic tariff.

Recommendation

All photographic effluent, silver bearing and non-silver bearing should be collected in storage tanks (on board the processor and/or external) for subsequent haulaway to an off-site waste treatment centre.

Normally it is not practicable for small labs to do silver recovery. This is because of the need for careful control of the process to ensure silver purity is high and silver levels in the waste are low enough to meet the stringent controls that are now in place. In addition, an application for consent to discharge would be required. Consequently, this Code of Practice recommends that silver recovery is not undertaken at a Minilab site.

A ‘Consent to Discharge Trade Effluent’ will not normally be required due to the low volumes involved. To qualify the Minilab must:

1. Use less than 12.5 cubic metres (12,500 litres) of water per annum.
2. Provide proof of haulaway of all chemical effluent.
3. Have a spillage policy and site plan indicating chemical storage areas.
4. Laboratories should be prepared to demonstrate their compliance to their Water Services Companies.
5. If a ‘Consent’ is not required, the Water Services Companies will levy charges for the water supply and domestic sewage. It may be possible to claim for an allowance for the trade effluent removed from the site by haulaway. 
6. The local Water Services Companies retains the right to issue and charge for a ‘Consent’ if it sees fit to do so, or if any of the above requirements are not met in full.
7. In certain circumstances, a Minilab may need to discharge small volumes of effluent to the sewer. This can occur when processor racks are washed as part of a maintenance programme. The discharge of these small volumes may be acceptable for sewer discharge in some areas and subject to local Water Services Companies approval.

General Photographic Laboratories

Summary

• Any trade or premises where the primary business is the developing and printing of photographic film and paper; utilising photographic chemicals.
• It can be for amateur, professional or in-house photographers.
• Effluent volumes typically between 12.5 and 10,000 cubic metres (12,500 to 10 million litres) per annum, including wash-water (roughly equates to the annual water consumption).
• Recommended method for handling the photo effluent is to use a recognised haulaway contractor to remove it. 
• The efficient use of in-house silver-recovery technology may be an option.
• It is proposed that such premises be on a fixed-charge trade effluent tariff. Typical values would be in the area of COD of 350 ppm and a suspended solids content of 35 ppm for photo-processing effluent.

Recommendation

These laboratories must obtain a ‘Consent to Discharge Trade Effluent’, even if they use haulaway for all their used photo-chemicals, since the wash water will be discharged to sewer.

Trade effluent charges will be calculated using a “Mogden”-type Formula based on fixed strengths using water in, less an allowance for domestic waste plus haulaway volumes. If laboratory effluent strength differs from the typical values above, the charge will be based on the actual COD and suspended solids discharged.

Silver-bearing waste effluent i.e. bleach, fixer, bleach-fix and super rinse stabilisers, must either be removed off site for recovery/disposal or treated in-house. This should be done in an efficient manner that will ensure a maximum effluent discharge for silver as stated in the ‘Consent to Discharge Trade Effluent’ (unlikely to exceed 5 ppm).

Some non silver-bearing waste may be discharged to sewer together with wash water as trade effluent, subject to all Consent limits being met.

1. To qualify for this category, the laboratory must satisfy the following:
2. Have a water usage less than 10,000 cubic metres per annum.
3. Have a current ‘Consent to Discharge Trade Effluent’.
4. Have proof of haulaway or an outline of their silver recovery system and data on the recovery efficiency.
5. Have an emergency spillage response procedure and a chemical storage plan.
6. Have a water supply and drainage plan.
7. Have an environmental policy approved by the laboratory management.
8. Laboratories should be prepared to demonstrate their compliance to their Water Services Companies.

Photofinishing Laboratories

Summary

• Effluent volumes greater than 10,000 cubic metres (10 million litres) per annum, including wash-water.
• Recommended that efficient in-house silver-recovery technology and/or haulaway be used, as appropriate. 
• Charges for such operations will not be fixed but will be calculated by the local Water Services Company using a “Mogden”-type formula.

Recommendation

These laboratories must have a ‘Consent to Discharge Trade Effluent’ and meet all its terms and conditions. However, the charging system will not be fixed and will use the standard Mogden Formula using the actual COD, etc., figures from the premises obtained by the Water Services Companies. Hence, each laboratory will be treated separately by the Water Service Companies even if they are in the same region.

To comply with this code of practice, the laboratory must satisfy the same requirements as the General Photographic Laboratory, but the water usage will be greater than 10,000 cubic metres (10 million litres) per annum. This would equate with a consented effluent volume of 40 m3/day.

X-Ray Film Processing Facilities

Radiographs are produced when X-ray film is processed. Most X-ray films have relatively thick silver halide emulsions coated on both sides of the base. They are designed for processing with short cycle times in roller transport machines, although manual processing is also possible.
The processing chemicals are more concentrated than other photographic types and consist of a water-based monochrome (black and white) developer and fixer.

Radiographs are predominantly used for medical diagnosis in hospitals, chiropractic clinics, dental surgeries and veterinary practices. They are also important for checking electronic components, aircraft structures and metal welding and casting quality.

On trade premises, it will be necessary for operators to apply for, and comply with, a ‘Consent to Discharge’.

Graphics Film Processing Facilities

Within the scope of the Coppice remit, Graphic Arts photo-processing operations are the pre-press activities involving the processing of film prior to use in the preparation of printing plates. This can be carried out by printing establishments themselves or on their behalf by third parties commonly referred to as 'Trade Houses'.

On trade premises, it will be necessary for operators to apply for, and comply with, a ‘Consent to Discharge’. This will contain the discharge from both graphics and photo processes if appropriate.

Microfilm Processing Facilities

On trade premises, it will be necessary for operators to apply for, and comply with, a ‘Consent to Discharge’.

Other Small Users of Photographic Chemicals

General

• Users in this category will typically produce effluent volumes below 10 litres a week, excluding wash-water.
• Any user with premises that discharge into a septic tank or cesspit should not dispose of photographic chemicals into such a system or any surface water system.

Professional

• Small quantities from professional users will be covered by the waste regulations.
• Professional users should discuss their situation with the local Water Services Companies and provide them with details of the typical volume and waste content (generally available on request from the manufacturer of the chemicals).

Amateur

Photographic waste from amateur users is not covered by the waste regulations. It is considered domestic waste.

Check with your local Water Services Company to see if small quantities of waste can be disposed of down the drain in your local area.

Notes to the Code

Water consumption is as measured by the premises' incoming water meter or sub-meter to the process. If water recycling is used, the original volume used prior to recycling should be utilised to establish into which category the laboratory falls.

Exclusions from the Code

This code of practice is not intended to apply to businesses engaged in the use of reprographic photolitho, fast print shops, or printing.

It is not applicable where photographic and other imaging products are manufactured.

Any company whose business also uses non-photographic processes should apply the Code of Practice only to their photo-processing effluent.