Delegates to the Tyre Recovery Association's annual conference in Solihull yesterday questioned whether the protocol would simply encourage less monitoring of the sector of the tyre recycling market which operates beyond the law. And, there was concern that a change in legislation could cause confusion and extra paperwork.
If there is one form of regulation now, then we will have to go through the work involved in other rules and regulations.
Tim Stott, president, Tyre Recovery Association
The concerns came after a presentation by Environment Agency official Suzanne Laidlaw who had spoken of the advantages of having a protocol for the “production and use of tyre-derived rubber materials”. She said this would represent a certification scheme which would look “at how the tyre is recycled or recovered responsibly”.
Fly-tipping
But, a key issue at the conference earlier in the day had been the extent to which the Environment Agency is tackling the fly-tipping of tyres – on public land and on tyre association member company yards. Many delegates felt that more should be done by the Agency, the police and local authorities.
Ms Laidlaw was asked by association president Tim Stott, general manager of Sapphire Energy Recovery, whether “if there is one form of regulation now, then we will have to go through the work involved in other rules and regulations.”
Patrick O'Connell of Bandvulc Tyres said: “I believe that this protocol is almost generating a loophole”.
Ian Bryan, who is involved with the association's Responsible Recycler Scheme and is a director of Waste Per Se, said: “Clearly if this works, there will be less regulatory effort – it is a flag of convenience.” He explained in terms of a flag of convenience, he was asking whether there was a trade off to be made “between the cost of regulation and compliance and that industry's concerns were that the protocol could potentially be abused as a flag of convenience for rogue traders.”
Ms Laidlaw, who is on secondment from the Scottish Environment Protection Agency, said: “I will have to get back to you on this.”
The conference also heard from Paul Hallett from the sustainable development and regulation unit at BERR, who said that there were some difficulties in getting data from the sector. 2006 figures were late but showed that the market was in parity with uses found for used tyres.
Parity
Mr Hallett said: “In broad terms there is a parity between arisings and recovery with about 500,000 tonnes generated each year.”
The BERR official's figures showed that materials recovery handles about 160,000 tonnes of tyres and both energy recovery and landfill engineering using about 100,000 tonnes each, with the retread sector taking about 60,000 tonnes.
Difficulties
Steve Waite from WRAP spoke of the difficulties that his section had encountered in recent months and confirmed that WRAP's tyre programme comes to an end in March 2008.
WRAP found there was little interest in the tyre market for it getting involved in an infrastructure fund and instead it is looking at the potential to give out money towards helping maintain plant and equipment. WRAP has, however, given support to three tyre reprocessing projects to expand capacity.
And, Mr Waite said that “after many months' work” a trial of rubberised asphalt with one local authority had collapsed and then a second project with another authority had also failed to proceed becaused of design problems with the bitumen.
Next week, a WRAP tyre conference will learn from a consultant's report – which Mr Waite refused to outline to the tyre recovery audience – the likely outlook for tyres over the next 10 years. However, Mr Waite cautioned: “Forecasting can be a real pie in the sky affair but we hope it will be a boon to people like yourselves.”
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