This position on sorting links to treatment requirements for municipal waste which will affect local authorities. It has just been released in draft guidance from the Environment Agency, entitled Requirements for waste destined for disposal in Landfill.
While this is not being seen as new guidance as such for local authorities, the wording of the Agency document is important to both the waste management industry and local authorities as they adapt to the introduction of Landfill Directive regulations.
In effect, it means that councils who have municipal waste strategies in place to achieve the diversion of waste from landfill will meet landfill treatment requirements through the sorting and recovery of material.
Treatment definition
The definition of treatment is important because of the impacts of the Landfill Directive, as implemented by regulations in 2002. A key point of the regulations is that most wastes must be “treated” before they can be landfilled.
The Agency identifies five core requirements to the Landfill Directive regulations:
- Certain kinds of waste can no longer be sent to landfill for disposal.
Biodegradable municipal waste will be progressively diverted away from landfill - Landfills will be classified as to whether they can accept hazardous, non-hazardous or inert wastes and can only be accepted if they meet the waste acceptance criteria for that landfill
- Most wastes must be treated before they can be landfilled
- The waste producer is responsible for ensuring that basic characterisation of the waste has taken place to establish its key characteristics as specified in the regulations.
The agency document pays particular attention to the question of treatment. It says that waste destined for landfill must be subject to “prior treatment”, in line with the “three point test”. Any potential treatment must fulfil the three criteria in the test, but need only meet one of the four objectives of the third point listed below.
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| 1. It must be a physical/thermal/chemical or biological process including sorting. |
| 2. It must change the characteristics of the waste. |
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3. It must do so in order to: a. reduce its volume, or b. reduce its hazardous nature, or c. facilitate its handling, or d. enhance its recovery. |
Sorting
The draft document also makes further observations about treatment, and in particular sorting. It emphasises that the common treatment of sorting or segregation “will not in itself enhance recovery – there needs to be an intent subsequently to recover part or all of the waste. It is not acceptable to sort wastes and then landfill all the sorted wastes.”
On the characteristics of the waste, these are described as the properties that “affect its potential impact on human health or the environment when it has been landfilled.” So, these characteristics must be changed to meet the third criterion. And, the Agency adds: “Processes such as compacting household waste in a refuse collection vehicle (or elsewhere) do not change those inherent properties of the waste and thus does not constitute treatment.”
The final guidance document is expected to be issued by the end of the year or early in 2005 with the Agency closing consultation on October 25.
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