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

Standards—a note by M B Recycling Ltd 11 September 2001

  At the recent round table meeting held at the Conference Centre at the DTI on 21 August 2001 to discuss the implications of the New Regulation 2037/2000 with regard to the disposal of domestic refrigeration waste after 31 December 2001, it was confirmed that in order to comply with Section 16/2 a new method of disposing of this waste stream will have to be developed, after it was recognised by DEFRA, the DTI and the EA that this country had at the present time no technologies established for the removal of all ozone depleting substances from either the refrigerants or the foam blowing agents trapped within the insulation of domestic refrigeration waste.

  Being aware that new technologies would need to be developed, much consideration was given to the standards which would need to be set to achieve Best Practice before industry would have sufficient information to be able to make decisions on which technology to deploy.

  The discussions then gave rise to a representation from the RAL Quality Assurance Body (a German organisation that had set a minimum standard for recovery of ODS, in the absence of legislative standards within Germany). Close examination shows that the RAL Standard set a very low minimum recovery rate of 283 grams of ODS per unit, and by RAL's own concession, as given to the Stena Gorhard Workshop on CFC Recovery from Refrigerators held in Oslo on 23-24 September 1999, they themselves admitted it was artificially compiled. Nonetheless, examination shows that there are a variety of standards, all measuring different aspects, which are mentioned in regard to ODS. In reality there are a wide variety of standards of which RAL and TA Luft are but two. Collectively these chart a pattern of measurement and behaviour which is always dominated by the two words "where practicable" in compliance with the Environmental Protection Act.

  If this was compared with the UK's interpretation of "where practicable" under the Environmental Protection Act which stated it was not practicable to reclaim any ODS blowing agents, the RAL standards or any of the other standards were much better than the UK position of a 0 per cent of reclamation.

  The new Regulation 2037/2000, Section 16(2) did not include this "where practicable" clause and has made mandatory the requirement to reclaim ODS trapped within the foam insulation as from 31 December 2001. As such, neither the RAL Standard nor any of the other simple standards any longer carry any bearing to the requirements of the Regulation.

  The alternatives, one strongly advanced by Mr Gary Taylor of Clwyd Refrigeration and another advanced by Mr Peter Jones of Biffa, relate to details of the overall problem and all of them carry great input, but at the end we have to recognise that the full standard which it covers will have to measure the losses and reclamation of all ODS substances from the moment the refrigerator enters the gate to the time when it is fully destroyed and therefore the measurements must cover wastage to atmosphere, the amount residual in the foam, the amount that is in the processing unit itself and the amount that is vented to atmosphere in other ways. Additionally, the measurement must also measure any quantity of risk involved in the operation through the process.

  With this in mind, the benchmark would very much resemble that contained in the German document E DIN 8975-12 . . . 2000/11. This document, which I am sure had been read by many of the attendees at the meeting contains the draft proposed by the Germans. The categorisations in it are all capable of being met and it would seem probable that the Germans have given very mature thought in arriving at these standards. It may well be that within the framework of the DIN it is possible to improve, for example on the amount of residual ODS left in the foam or in the means by which measurements are taken with regard to discharge to atmosphere via the chimneys, but these are details against a mature backdrop prepared by people who have had considerable experience in operating the standards that have been laid before us, such as TA Luft Regulations and RAL Standards . It is perhaps a pointer to the future that in preparing the DIN document which is by far the highest standard, they have effectively moved away from the piecemeal approach to a fully integrated approach and it would appear realistic that we should also pursue the same realistic approach. There is surely no loss of face in adopting a standard prepared by people with far more practical experience of the use and destruction of ODS than ourselves.

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