Waste management... Over regulated and under-enforced?


J


ohn Galvin MBE FCIWM is an Independent Waste Regulation Specialist, previously having been Defra’s policy lead on waste regulation and crime


as well as chairman of the National Fly-tipping Prevention Group (NFTPG). He was winner of the CIWM’s Sustainability and Resource Waste Regulation Award for 2015/6. John was a regulator with the Environment Agency and its predecessors, responsible for licensing, compliance and enforcement in East London.


I read the fi rst edition of ‘ROJ’ with considerable interest and am very pleased to have been asked by Jenny Watts to contribute to this edition. It is important that Small and Medium-sized Enterprises (“SMEs”) have a voice as they oſt en don’t have the resources to keep up-to-date on issues of the day. So I hope ROJ is a success and helps UROC members and others to be fully informed and engaged.


Jenny’s inaugural article on ‘Regulatory Creep’ focussed on burdens and red tape and the confusion that can arise if the rules are unclear. T at can be the case, but from my experience, operators will put up with most regulatory rules providing they are fairly and consistently enforced so as to create a level playing fi eld for them to compete. Being taken to task for a minor breach is galling if a cowboy down the road gets away operating illegally or on the cheap.


At the macro level, government, the regulators and the waste industry share common aims, to drive high standards of segregation and recycling and have fi rm but fair regulation to protect local communities and the environment and support investment and innovation. Yet we continue to disagree about how to achieve these shared aims or cannot understand it when there are fl agrant breaches of the rules that go unpunished. How for instance did the Waste4Fuel site in Bromley get away with storing and then abandoning over 20,000 tonnes of combustible waste that cost the public purse millions of pounds to clear!


We see examples that seemingly fl y in the face of those shared aims. For example, if we espouse support for small businesses, why do we shy away from providing comprehensive guidance that will help business comply? We seem slow in responding with regulatory approaches in a timely manner to address changes in technology and waste markets; and why, as I have


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estimated, do we allow perhaps 1,000 sites to operate without any technically competent management?


We live in a time where waste management is changing more rapidly than it ever has before. We talk in terms of the waste hierarchy, extended producer responsibility, the circular economy and minimising carbon emissions, and as the title of this journal refl ects, increasingly see waste as a resource. T ese along with landfi ll tax are driving waste away from landfi lling towards new treatments and markets. Yet the economics still mean that costs of alternative treatments and recycling are high and we are far from guaranteeing a sustainable future.


But we also live in a time of limited public resources to enable the legislative and other changes to deliver these outcomes or to monitor whether changes that are made work alongside other rules or whether there are unforeseen consequences or loopholes. We’re oſt en playing catch-up.


T is can leave waste operators confused, frustrated or variously worried about regulatory creep or conversely a lack of action. Equally though if industry wants to excel it can help by taking the initiative to promote technical standards, share intelligence on prices and markets and illegal activity and adopt professional standards of operation to keep out the cowboy. Of course there are many examples of this happening now but it doesn’t always end up being accepted by all parties and there is plenty of room for improvement!


Change will continue unabated and the more we


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