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

Annex 1


  Have problems of dealing with hazardous (special) wastes properly been taken into account in the development of waste disposal policies?

  The focus in recent years has been predominantly on municipal solid waste (MSW) as this is perceived to pose the greatest challenge for the UK in the short to medium term. In formulating the waste strategy some key differences in the management of hazardous waste seem to have been lost. There is insufficient priority given to managing the hazards to human health and the environment over the need to minimise/recycle/recover.

  These problems are often seen as being a matter for the waste management industry resulting in "end of pipe" mentality. Producer responsibility and duty of care appears to be a low priority and consequently there has been insufficient interfacing of chemical policy, product stewardship and waste policy.


  Historically DoE, DETR, DEFRA and the EA have struggled with determining the BPEO for hazardous waste, particularly for landfill. By way of example; in 1996 the EA published Technical Guidance on BPEO for prescribed processes. (Footnote 2). At S 9.1.2 it states in relation to hazard assessment of wastes generated ...

    "It is recognised that the hazard assessment approach adopted for the purposes of BPEO assessment does not take into account differences in the releases which may occur from different forms of waste treatment or disposal, for example solvent recovery or incineration. It is proposed that further research will be undertaken by the agency to develop an approach which can take these differences into consideration, however this is a complex issue and is unlikely to be easily resolved."

  Little progress has been made. The ability to provide clear indication of which waste management technique is preferable for a particular type of waste is essential to ensure that the UK has the right blend of waste management options and an industry sufficiently confident in the regulation of waste to invest. For hazardous wastes it is the differences in environmental releases between waste management options that the EA needs to focus on to ensure an acceptable level of environmental protection.

  Incineration of Hazardous Waste Directive (Council Directive 94/67/EC) and Integrated Pollution Prevention and Control.

  The Hazardous Waste Incineration Directive (HWID) has been implemented rigorously on a "cause celebre" basis. The merchant High Temperature Incineration (HTI) industry fully meets the requirement of the directive in a transparent manner, and continues to be highly regulated. However the HTI industry continues to compete with lower environmental standards applicable to co-incineration and merchant HTI capacity has fallen dramatically in the last few years to its lowest point in over a decade. The closure of one other plant would result in a monopoly situation in the UK and would be a potential disaster for the UK chemical and pharmaceutical industries.

  Whilst we recognise that co-incineration is an important option a level playing field needs to be established. Recovery of energy during the destruction of waste by HTI is of equal value to the recovery of energy during cement manufacture.

  We also see opportunities in applying PPC as a means of managing the risks associated with hazardous waste and encouraging elimination, recovery and recycling where this can be done safely. PPC should be used as the tool for regulating BPEO for wastes that display particular hazardous characteristics or are of particular public concern.


  We fully support supply chain methods for promoting improvements in waste management.

  The Waste Management Industry is eager to play a part in providing solutions/expertise at the start of, or ideally prior to, formal consultation. Shanks operates a range of recycling operations in Europe including recycling of electronic goods. These are effective and profitable as a result of a clear statutory waste management plan being in place.

  We warn of the risks of sustainability without consideration of the precautionary principle. It is particularly important to prevent additional hazards from entering the supply chain undetected where recovery/recycling is chosen.


  It is important to ensure that the principles of prevention of dilution of hazard in the Waste Framework Directive, the Hazardous Waste Directive and the Landfill Directive are regulated and enforceable. The regulations must require and define assessment criteria to be used when designating a waste as being hazardous with a clear statutory power. In addition they should require and define assessment criteria to be used when designating a waste treatment that renders a waste non-hazardous. The PPC regulations could be used to effect these.

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