In particular, it is warning that a company recycling oil into biodiesel under the Protocol could not use the resulting fuel on its own site.
Under the quality protocol, the EA sets out criteria for when waste vegetable oil ceases to be a “waste” in the eyes of the law, and becomes the product biodiesel (see letsrecycle.com story).
The protocol is based on the recovered oil conforming to the British standard BS:EN 14214 or the alternative, BS: EN 14078.
Accordingly, biodiesel derived from waste vegetable oil would have to be produced via a “chemical process” and used for combustion in “automotive engines”.
The EIC – whose members include oil recycling companies such as D1 oils and Eco-oil Ltd – claimed in its response to the 12-week consultation to the protocol, which closed on Monday, that the protocol as it stands could restrict the use of biodiesel as a product to off-site use.
EIC director Merlin Hyman said: “The Protocol states that waste vegetable oil (WVO) derived biodiesel ceases to be a waste 'when it has been dispatched to the customer.' This on one hand is a positive step, but its use offsite as a diesel fuel is not its only use. It can be used as fuel in the boilers or power generators onsite.
“We do not believe that its use should be restricted to offsite use. Also it would seem rather odd to store it onsite as waste. WVO biodiesel should cease to be a waste once it has met the requirements of BS: EN 14214,” he added.
Mr Hyman claimed that another problem with the protocol was that it did not allow for flexibility in the way in which recycled biodiesel was produced. At present, the protocol suggests that the production process and quality controls must be those it specifies and that recyclers cannot achieve non-waste status unless they follow it.
He said: “The problem here is that there are many slightly different ways to make biodiesel that meets BS:EN 14214 and obviously manufacturers would not be willing for these to be displayed in this protocol. If the final product can meet the British Standards, then the processing route is immaterial.”
Testing
Under the Quality Protocol, testing must be done at least annually, to make sure producers achieve the standards set out for them.
Mr Hyman suggested that in order to make sure the system was not open to abuse from unscrupulous operators, this could also be ramped up.
He said: “To be effective, testing probably should be done on each batch or weekly, but it is appreciated that this is quite costly. It is therefore recommended that testing has to take place monthly.”
Other recommendations by the EIC include including waste vegetable oil glycerol in the protocol.
These suggestions will now be fed alongside others into the final draft of the protocol, which will be published in due course by the Environment Agency.
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