In June, the government announced it is to carry out a full review of waste policies. We wholeheartedly welcome its commitment to undertake this review and want to ensure future waste management regulatory frameworks are fit for purpose and not rooted in the past.
Ian Hetherington is director-general of the British Metals Recycling Association The current framework appears to be based on an assumption that all ‘wastes' are a problem which simply isn't the case for recycled metals. Certain metal ‘waste' should in fact be reclassified as a secondary raw material because of its high intrinsic value – meaning it will be recycled, not discarded, and thus a value-added secondary resource.
With its ‘one-size-fits-all' approach, it causes confusion amongst both Environment Agency staff and regulated businesses. It leads to unintentional non-compliance by the operator, or over-zealous or misdirected inspection efforts causing an unnecessary burden without demonstrating environmental benefits.
Under previous waste management licensing regulations, the metals recycling sector had its own legal and technical guidance. It recognised that the metals recovery and recycling sector differs from the wider waste industry whilst acknowledging that specific risks are posed by metals recycling activities.
We see the government's review as a great opportunity to redefine the core purpose of environmental regulation and so would welcome the introduction of a sector-based approach. It is crucial that those making decisions understand the metals recycling industry and can apply regulation in a considered and appropriate manner.
We question the value of the existing inspection-based regime and so urge government to consider greater use of self-assessment models, quality management standards and Board level self certification as an alternative.
It would ensure environmental performance is widely recognised as a board-level issue whilst at the same time, administrative and economic burdens on regulated businesses would be reduced, enabling substantial savings to be made on the cost of waste regulation.
Furthermore, with our industry plagued by unlicensed and illegal operators, we are calling for the funding rules that prevent the Environment Agency from focusing on those that trade illegally to form part of the review. The balance needs to be redressed so that most of the effort is directed towards non-compliant or illegal operators and not on the majority of well-managed and compliant businesses.
ELV recovery target
Another issue that needs swift action is meeting 2015's challenging 95% end-of-life vehicle (ELV) recovery target. BMRA members are leading the way in developing technologies and processes to recover high-value materials from ELV shredder residue. However, it is likely the last fraction of the shredder process will be recovered only as energy, requiring the establishment of dedicated energy-from-waste capacity.
At this time, investment decisions are on hold as confirmation is required from government that energy generated by the thermal processing of shredder residue will be classed as “recovery” rather than “disposal”.
The government's waste policies review is a much needed and welcome step towards achieving “zero waste” and we are embracing this opportunity to reshape the future of environmental regulation. Our proposals will further improve the already high environmental performance of the sector whilst taking into consideration other issues the industry currently faces.
Subscribe for free