Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Letter from Biffa Waste Services Ltd to the Environment Agency 19 March 2001


  EC Regulation 2037/2000 on ozone depleting substances places significant restrictions on point sources of ozone depleting chemicals with effect from 1 January 2002 in relation to consumer products. The regulations have applied since the 1 January 2001 for industrial and commercial arisings but from our perspective they appear not to have been enforced.

  This assumption is applied in relation to refrigeration equipment. The majority of this material (amounting around 250,000 domestic units monthly weighing 40,000 tonnes) have tended to be routed to car fragmentation plants where the quality of record keeping in relation to collection of liquid CFCs is highly variable and the CFCs contained in the insulating foams are released by fragmentation and crushing to atmosphere. Our understanding is that if the regulation as currently framed is applied this latter practice will become illegal.

  The consequence is that retailers will probably not take an old for new fridge from householders and that 40,000 tonnes of fridges will thus inundate civic amenity sites from January next year.

  Biffa and Michael Baker Group of Companies are examining the feasibility of investing around £2 million in a reprocessing plant for fridges but we are reluctant to commit such investment until we have a clearer understanding from DTI and DETR as to how the regulations will be enforced. Clearly such investment will be wasted in the absence of any absolute ban on the disposal of fridges through car fragmentisation plants. Even if such a ban is introduced there will be an immediate requirement for large scale stockpiling of scrap fridges from the 1 January since we are unlikely to be able to install our plant and equipment in time.

  We are seeking clarification from DTI and DETR but in the meantime it is now an urgent priority to involve the Agency in this debate. As a result we are enclosing a copy of our recommended Code of Practice for the plant and equipment we have in mind and we would welcome the opportunity to sit down with your appropriate staff and evaluate how the necessary licensing procedures can be accelerated to anticipate what we see as a substantial pollution risk area which has the added potential for significant public relations damage if not managed within a sensible framework.

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