OPINION: Describing waste correctly at the point of production is the most critical step in the waste management chain and is fundamental in protecting the environment and human health.
It also ensures that when waste is sent for recovery or disposal that the journey is problem-free and the waste is accepted at the receiving site.
Unfortunately, this vital step can get overlooked because describing waste correctly requires an understanding of waste classification technical guidance WM3 and the need to apply the correct List of Waste code to the waste.
To do things properly takes effort and we know operating conditions are difficult for the waste management industry at the moment. The pandemic, the cost-of-living crisis and the resulting economic turbulence have all meant businesses are struggling and when things get tight environmental compliance may not be at the forefront of people minds. Nevertheless, it is vital to expect all operators to act responsibly to get the basics right to drive a culture of environmental compliance. This protect legitimate operators but also helps the country take the waste hierarchy seriously and use our natural resources more sustainably, which is critical.
Our officers aim to help legitimate operators comply with the rules and give advice and guidance to companies who inadvertently make mistakes. We know that, like other sectors, the construction and demolition (C&D) sector doesn’t always get things right, but if our officers can influence and persuade companies to classify their wastes properly at the outset, then this should improve the environmental performance in other sectors too.
For example, excavation waste is often sent off-site with insufficient assessment, resulting in environmental harm. On ‘brownfield sites’ our advice is to segregate hotspots to reduce the volume of hazardous waste generated and prevent illegal mixing and dilution. Typically, our officers find that waste producers have made the mistake of using Waste Acceptance Criteria limits to classify their waste. Often, waste producers don’t have a waste assessment to indicate if their waste is hazardous or not.
Our officers don’t aim to make life even more difficult for the C&D sector and it is not our aim to take enforcement action unless operators have no intention of doing things right. Our officers will signpost the WM3 guidance and pages on gov.uk in order to help operators comply and they will offer a deadline to work towards.
Collaboration
Indeed, collaboration will be even more important in the future. Importantly, expectations will increase when waste tracking is in place, the Government’s approach to which you can read more about here. We are also likely to see more wastes having to be reclassified as we start to understand more about some of the chemicals they may contain, for example chemicals in insulation foam, as well as some sealants. These could require special measures to protect the environment.
Environment Agency guidance as well as various industry bodies should help companies navigate through emerging challenges, but implementing good practice early will help companies to be in a strong position into the future.
We know waste criminals choose to put people and communities at risk when they mismanage waste to make money. Our latest figures from our waste crime survey are that 18% of waste may be being managed illegally at some point in the waste supply chain – around 34 million tonnes of waste every year.
We have teams in place to act against waste criminals who have no intention of complying with the rules and we work more closely than ever with partners such as HMRC and the Joint Unit for Waste Crime to close illegal sites and recover proceeds of crime. By taking the required action to describe waste correctly all producers of waste are helping to ensure that their wastes are handled safely and correctly through the supply chain and that they themselves are compliant and taking an important step helping to ensure that the waste industry is protected from the threat of waste crime.
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