Appropriate measures are the standards operators need to meet to comply with their environmental permit requirements. Where a measure is not suitable, an operator can propose alternatives that achieve the same level of environmental protection.
The Agency is looking to update and expand on the guidance for the best available treatment recovery and recycling techniques (BATRRT) and treatment of WEEE published by Defra in 2006.
Relevant requirements on waste treatment made under the European Industrial Emission Directive (2010/75/EU) are also included within the consultation.
Topics covered include waste pre-acceptance, tracking, indoor storage, gas discharge lamps, fires, persistent organic pollutants (POPs) and cathode ray tubes, among others.
There is an additional focus on waste cooling equipment including fridges, in part due to the fact they contain refrigerants, blowing agents and oil which must be removed during treatment.
In a statement, the Agency said it produced the proposed guidance to “make relevant standards clear, consistent and enforceable”.
The appropriate measures will apply to all permitted waste facilities, new and existing, that accept WEEE for transfer or treatment.
The consultation takes the form of an online survey and runs until 5 September.
“The AATF Forum is having a meeting to discuss the consultation next week, but in principle we welcome it”
The Environment Agency says it will review and revise the guidance using the responses it receives. The enforcement body aims to publish its updated guidance “during the winter of 2021/22”.
Phil Conran is chair of the AATF forum, an informal body representing the interests of the UK WEEE treatment sector. Mr Conran said the consultation represented more than a “tidying up exercise” and was part of a much wider process of the Agency updating the permit BATRRT requirements.
He said the Agency started on the programme after recognising the need for an updated standard and amid general agreement that ‘off the shelf’ standards like WEEElabex were too “onerous” for widespread application. The Agency carried out a pre-consultation with approved authorised treatment facilities (AATFs) last October, Mr Conran said.
He told letsrecycle.com: “The AATF Forum is having a meeting to discuss the consultation next week, but in principle we welcome it, although there are concerns over some of the more prescriptive requirements that will add extensively to the level of administration required to run an AATF.”
Gas discharge lamps
Nigel Harvey is CEO of lighting industry compliance scheme Recolight and chair of the WEEE Scheme Forum trade association. He welcomed the launch of the consultation.
Mr Harvey told letsrecycle.com: “The original guidance on BATRRT has been unchanged since 2006. That means an update that takes account of changes to both recycling techniques and to products is long overdue.”
Mr Harvey said the appropriate measures regime would add a lot more detail to the most appropriate ways to store and treat WEEE. As an example, he cited the section on gas discharge lamps, which has been updated to require linear fluorescent lamps to collected and stacked separately from non-linear lamps.
Mr Harvey said: “That is very sensible as a way of reducing the risk of breakage in transit. Many of the new requirements are similar – capturing learning from the experience since the original BATRRT was published.”
Online electricals retailer AO set up its WEEE recycling division in 2017. Anthony Sant, MD of AO Business, welcomed the launch of the Environment Agency’s consultation.
He told letsrecycle.com: “When AO entered the WEEE recycling sector, we were committed to reaching the standards required for WEEE treatment and invested in both the people and the equipment needed to achieve this.
“We have repeatedly called for consistency of clear standards that are enforced across the sector and we welcome the Environment Agency’s intention to make this a reality. We look forward to seeing the results of this consultation.”