
However, the company’s chief executive has said its position remains the same, that a trip to a CA site can’t be deemed essential as long as core residual and food waste collection services continue.
The document, which can be seen here claims that it would only be lawful to open a site under the current restrictions in very limited circumstances.
“Waste services do not constitute obtaining basic necessities, they are a service and not an object,” the report states.
It adds: “Attending a CA site could be considered the ‘accessing of critical public services’ and therefore a reasonable excuse, but only if the service was a compulsory service if the service was not being provided in another form.”
This interpretation, according to Suez, means that only if residual or food waste did not have a collection regime (of whatever infrequency) would it be lawful to open an HWRC under the current restrictions.
The report comes as Defra has encouraged councils this week to open HWRCs (see letsrecycle.com story). Around 90% are thought to be completely closed in England, with none operating completely as usual .
Social distancing
Any site reopening would also have to make drastic changes in order to ensure everyone remains two metres apart.

This includes reducing the number of parking bays by 50-66% depending on site layout, reducing the number of containers available.
Other steps include not allowing staff to assist the public with heavy or bulky items, as well as reviewing staffing levels as many have been drafted to help with other front-line services.
As such, the report says that most sites would only be able to support the deposit of two types of waste or would need to further significantly reduce public activity to prevent breaking social distancing rules.
‘Valuable contribution’
In a statement given to letsrecycle.com, John Scanlon, chief executive officer for SUEZ, said the report looks to make a valuable contribution to the debate, but its position remains the same.
“With the closure of household waste recycling centres moving up both the local and national political agenda in the wake of media reports of increases in fly tipping, we identified we could make a valuable contribution to the debate by carefully considering when it might be necessary to re-open a recycling centre under the current lockdown restrictions,” he said.
“Our position remains that as long as core residual and food waste collection services continue, no trip to an HWRC can be considered essential”
Mr Scanlon added: “After a significant amount of consideration and reflection, our position remains that as long as core residual and food waste collection services continue, no trip to an HWRC can be considered essential and these facilities should remain closed. However, when the current lockdown restrictions begin to be relaxed, we recognise that some local authorities may need to assess strategic sites to determine their suitability for re-opening, considering how they can operate safely and efficiently.”
Useful links
The document, What does COVID-19 mean forhousehold waste recycling centre
(HWRC) operations?, can be seen here.
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