We are walking down a laboratory corridor when Kirk Bridgewood stops and shows me a bag of waste material submitted for testing. “You can see just by looking at it that this isn’t going to pass the LOI test”, he says. “When you get above the 10% mark you can actually see the plastics and lumps of wood in there.”
As technical director of Derwentside Environmental Testing Services (DETS), Mr Bridgewood knows a thing or two about loss on ignition (LOI). Based in Consett, County Durham, the North East laboratory was established in 1999 and became one of the first in the UK to offer services for waste processors looking to meet the Landfill Directive. Now, some 20 years after the legislation came in, those same services are game-changing for hundreds of waste businesses striving to keep disposal costs down.
Tax
Last year, the government announced that it would make LOI tests mandatory for any waste company aiming to send their waste to landfill at the lower (then £2.60 – now £2.65 per tonne) rate of tax. Under lab conditions, the sample submitted by the companies is weighed, heated, and weighed again to determine how much inert material is lost. Operators were required to achieve a result of 15% – now dropped to 10% – or pay the standard rate of £84.40 per tonne on the load.
More than 12 months later, Mr Bridgewood says the system has been largely successful. DETS unsurprisingly has seen a 120% increase in LOI tests – mainly within its pre-existing waste customer base – and in a presentation given to a conference in Liverpool last month revealed that out of 1,567 samples taken in the last 6 months, the mean result had been 6.98% LOI (see letsrecycle.com story).
But questions remain. How for instance can HMRC be sure the tests are being conducted on a level playing field? And will a lack of accreditation and inconsistency among different laboratories lead to loopholes in the system?
Out of all the tests DETS conducts, from contaminated land and groundwater discharge to speciated mercury, LOI is in fact one of the simplest. The tests cost £20 each, with companies required to submit samples for every 1,000 tonnes of waste sent to landfill at the lower rate of tax. If the operator fails the test, they are required to submit for every 500 tonnes, and where consistent failures occur, every single load.
Test
Once received by DETS, the fines are weighed as received, recorded, and then dried at <40°C. Once dry, the sample is coned, quartered, and a 200g sub-sample taken for analysis. From there, the lab workers grind the sub-sample down to <2mm using cutting machinery to create an analysis sample.
The fine sample is then heated at 180°C for at least 45 minutes, taken out and weighed. A sample is then heated in a crucible and heated in a furnace at 440°C for five hours, which is taken out, weighed, and placed back in until it achieves a “constant weight”.
“Then what we do is then measure the distance between 180°C weight and the weight at 440°C and that gives you the percentage of loss on ignition which is what’s reported to HMRC,” Mr Bridgewood explains. “The majority of our tests that come through do qualify for the 10%, but it’s a cliff edge because above that the cost difference is huge. It would make sense to have a stringent approach.”
Issues arise when laboratories adopt different tolerances in the time and temperature at which waste fines are tested. DETS also ensures a duplicate analysis, an analysis quality control sample, and blank sample are run with every test batch.
Transparency
For Mr Bridgewood, ensuring laboratories are accredited to run LOI tests – and operate at the same standard – would leave less room for error when the margin is already so tight. In his presentation last month, he even noted that the HMRC-approved guidelines are more likely to underestimate the amount of organic in a waste load compared to the standard method that was used previously.
“We have seven or eight individual labs set up to do that dedicated waste testing in the UK,” he explains. “But there would be nothing to stop a waste company or any other operator setting up their own laboratory to test material and submit their own results. Getting the Environment Agency to accredit labs to do this as is the case with other landfill work would offer more transparency.”
It is this lack of regulation that could easily undermine the new rules, although Mr Bridgewood adds that the investment necessary for a waste company to purchase the equipment to conduct their own LOI tests would be far greater than the £20 price offered by external labs.
Trust
Once completed, DETS return a report to the waste processor declaring whether they have passed the LOI test – which in turn they are expected to pass on to HMRC. Mr Bridgewood admits that “very few” landfill companies ask DETS to run the tests on loads they have received from their customers, and I ask whether there is an element of trust involved in the whole process.
“It is up to the customer what they do with those reports.”
Kirk Bridgewood, technical director
DETS
“We’re not allowed to relay information to other companies about test results, and it is up to the customer what they do with those reports,” he considers.
Tourism
On the need to legislate LOI, DETS prefers to stay neutral. Last month skip hire association URoc withdrew its support for the April implementation of the 10% threshold – partly on grounds that Scotland does not intend to tighten up its own tax regime until October 2016.
As one of the labs operating closest to the Scottish border, could DETS’ customers send their waste north of the border to meet the lower tax rate? Mr Bridgewood is unconvinced by the waste tourism argument. “Revenue Scotland has set its test to exactly the same standard, and I don’t think six months between the two dates is going to make a huge amount of difference”, he says.
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