NEWS
ENVIROMAN
Happy 11th birthday to me – even though I was studying
regulatory websites!
Gov.uk has steadily taken over from the old Environment Agency website, and it is always worth a recap of what’s available. Knowing your stuff when the regulator calls is always a good thing, while improving your knowledge helps with technical competence assessments, and the continuing competence test.
With European Waste Catalogue (EWC) queries, most questions I have to deal with relate to 19 codes, or more specifically 19 12 ** codes arising from waste management operations. I was pleased to see a specific area of
the site set aside to “Classify different types of waste.” My elation was short lived. Not only
was there nothing on 19 codes, the section entitled: “What to include in your description,” failed to mention a written description is required in addition to the EWC code. There is a link to duty of care which is
reasonably well written, but it’s all too disjointed. Unless you click on all the links, content can easily be missed. But that’s the way guidance has gone in these days of austerity. Another pet subject involves
regulatory position statements (RPS), which specify circumstances that may not fall within an exemption, or permit, but are allowed as long as the specified rules are followed. Useful examples are listed below, and
apply to all waste sectors: RPS063: Storage of up to 3m³ waste
aerosol containers, not on the site of production for up to 3 months RPS060: Secure storage of fly tipped
waste prior to final recovery, or disposal for landowners, or those responsible for clearing the waste: i.e. at another site controlled by that person, with a limit of
20m³ for non-hazardous waste and 5m³ for hazardous waste. RPS060: Dewatering of street
sweepings by a local authority, or their contractor (carried out on a site with a sealed drainage system). RPS075: Using treated asphalt waste
that contains coal tar (AWCCT) in bound material for sub-base, base and binder layers, and not surface applications. RPS112: Small-scale heat treatment
of waste plastics for recovery. This statement was issued to cover the exclusion of heat treatment from the new T4 exemption, when the permitting regulations came in on 6th April 2010 (and will be withdrawn when the activity is added to standard rules permits). RPS124: Crushing of fluorescent
tubes at WEEE collection points. This is similar to the T17 exemption, which allows the activity at the place of production, and permits it to take place at collection points which are not the site of production. RPS182: Regulating trials of waste
management operations. Innovative technologies can be tested under controlled conditions, to establish that a technology works. This is very useful, and we have used it to test novel procedures before applying for a permit. The trial will limit throughput of the operation, but allows significant research and development to take place, usually over a 6 month period.
RPS190: The use of manufactured
topsoil for recovery operations. The statement allows up to 1,000 tonnes to be used for recovery – with strict guidelines, including meeting the requirements of BS3882:2015 which soil must meet: i.e. classification and composition. This is an important RPS, as there is currently protocol for the production of soils (as there is for the production of aggregates). RPS200: Storing catalytic converters
at metal recycling sites (EWC 16 01 21*): subject to applying to vary a permit before 31st August 2017, and having 16 01 22 in an existing permit. RPS205: Temporary storage of up to 5
ELVs at a motor manufacturer’s dealership for no more than 7 days, subject to specified storage and record keeping requirements. Low Risk Regulation is still around as
version 63 (May 2016), and specifies similar allowances for activities considered of sufficiently low impact as not to require a permit. As with the RPS list, it is worth keeping
up to date because RPS documents and low risk positions are withdrawn when the list of exemptions are updated in the secondary legislation (regulations), or added to standard rules permits. Send me your questions or ideas for
articles in 2017, and have a great New Year. Thanks for reading my column for the past 11 years.
By Marco Muia aka “Enviroman”
Marco Muia BSc (Hons) MSc MCIWM is the Director of Oaktree Environmental Limited. He specialises in all aspects of waste planning and regulation consultancy. He also holds the level 4 COTCs for Hazardous Waste Treatment and Transfer. You can contact Marco on 01606 558833 if you have any questions about this article or e-mail him at
marco@oaktree-environmental.co.uk and follow him on Twitter @wastechat.
12 SHM December 2016 Issue 132 Register your email for news and updates at
www.skiphiremagazine.co.uk
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