18 November 2020 by James Langley

Agency outlines when Covid-19 waste can be incinerated

The Environment Agency has issued a regulatory position statement (RPS) outlining when operators of permitted municipal waste incinerators can accept Covid-19 waste.

In a document published today (17 November), the Agency says the RPS applies for those wishing to incinerate coronavirus waste without varying their permit.

The RPS when operators of permitted municipal waste incinerators can accept Covid-19 waste

The RPS reads: “Your environmental permit states the waste types and quantities you can accept. Normally you will breach your permit conditions if you accept waste types or quantities beyond those stated in your permit.

“If you follow the conditions in this COVID-19 regulatory position statement (RPS) you can accept and incinerate coronavirus (COVID-19) waste at a municipal waste incinerator without varying your environmental permit.”

Companies must get written agreement from the Agency before they use the COVID-19 RPS.

The RPS will be withdrawn on 31 January 2021.


There are 12 conditions operators must comply with to use the RPS, alongside their permit requirements.

These include limiting the RPS to wastes carrying the following European Waste Catalogue (EWC) classifications: 18 01 03*, 18 01 07, 18 01 09 and 18 01 07 and 18 01 09. This covers orange and yellow bagged and containerised infectious waste from human healthcare activities, absorbents, filter materials, wiping cloths and protective clothing contaminated by hazardous substances.

Operators must be able to identify all the healthcare waste they accept at their site by the date of its arrival, original producer details and the type of waste, including the EWC code.

Other conditions include limiting operators to storing healthcare waste at their facility for a maximum of 24 hours before incineration except in exceptional circumstances, such as unplanned outages.

EfW operators must also test their incinerator bottom ash (IBA) and compare it with tests from before they incinerated the healthcare waste to confirm there is no change to the IBA composition.

Where reasonably practicable, this  must be done two weeks “from the date you first incinerated the healthcare waste in the plant, and no later than 4 weeks after”.


The Agency issued a similar RPS outlining when Covid-19 infectious waste could be incinerated at a municipal facility without the need to vary a permit on 15 April (see letsrecycle.com story). This guidance has since been withdrawn.

The only differences between the guidance published yesterday and the one from April is that the waste codes 18 01 04 and 20 01 99 have been removed. These cover “offensive hygiene wastes (human)” such as plaster casts and linen, as well as “other fractions not otherwise specified”.


In July Veolia claimed energy from waste (EfW) was the best disposal option for orange bagged healthcare waste (see letsrecycle.com story).

And, earlier this month the operator of the Lakeside EfW plant near Slough applied to alter the permit for the 450,000 tonnes per year capacity plant to allow it to process some hazardous waste (see letsrecycle.com story).

Related links

Incinerating specified healthcare wastes at a municipal waste incinerator: RPS C23


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