Call for urgent clarity on commingling in Scotland

The Plan, published for consultation in October 2012 (see letsrecycle.com story), sets out a number of actions to improve the quality of recyclables collected and managed in Scotland.

And, while the Local Authority Recycling Advisory Committee (LARAC) which represents recycling officers across the UK – welcomed the general thrust of the plan, it raised concerns over what the document says about commingled versus separate collections, particularly with regards to glass.

The draft Plan explains that under the Waste (Scotland) Regulations 2012, councils must introduce separate recycling collections from 2015 but that commingling is acceptable provided a number of conditions are met. These include ensuring that the quality and quantity of recyclables collected is not significantly less than a fully segregated collection and that it can meet relevant quality standards.

However, in order to meet these requirements, the document suggests that fully commingled collections, which include both paper and glass, are unlikely to remain acceptable because glass collected commingled contaminates paper and many paper mills are unprepared to take it.

The document states: Fully commingled systems which include both paper and glass together should therefore be avoided and the paper and glass is likely to be of significantly lower quality than that collected separately.

Concerns

The comments have big implications for those local authorities in Scotland which collect glass commingled and as a result, LARAC raised concerns in its consultation response.

It said: LARAC members do have concerns regarding, again, the co-mingled collections versus separate collections debate, particularly with regard to glass. Whereas the Waste (Scotland) Regulations 2012 clearly allow co-mingled collections (including glass), Section 5 (20), 5 (21), 5 (23) and Table 1 of the consultation document would suggest that this is not actually the case and that glass should be collected separately.

With many Scottish councils collecting glass co-mingled, we would welcome urgent definitive clarification on this issue in order to ensure money, time and effort is not invested in establishing collection systems that will not meet Waste (Scotland) Regulations 2012 requirements.

Quality

The draft action plan outlines proposals which would require MRFs handling municipal waste to measure the quality of their inputs and outputs as well as introducing regulation which require compliance with a MRF Code of Practice as a condition of holding a waste management licence.

Commenting on this, LARAC said recyclates quality standards are largely still dictated by reprocessors and operators of materials recovery facilities (MRFs) in the absence of a specific piece of legislation or guidance which means there is a large variation in standards and the shifting of goal posts on quality.

As a result, LARAC agreed with the Scottish Governments proposals to make the MRF Code of Practice mandatory.

It said: As stated in Section 6 (32) of the document, less than 30% of MRF operators have robust quality monitoring processes in place, and there is currently a lack of robust and consistent information on the both the methods of quality sampling used and the quality of outputs. This would suggest that the voluntary approach has not altogether worked and we feel that a statutory basis is now required in order to create a level playing field for investment.

In addition, LARAC said it supported the need for quality materials and welcomed a grading system that align to End of Waste Criteria. However, it acknowledged that as the material input at Scottish MRFs varies greatly, any proposed system would need to be undertaken in full consultation with local authorities and key stakeholders.