MARCO MUIA BSc (Hons) MSc MCIWM, Managing Director
Business Clinic
ENVIRONMENTAL
at Oaktree Environmental Limited. Marco specialises in all aspects of waste planning and regulation consultancy. He also holds the level 4 COTCs for Hazardous Waste Treatment and Transfer.
01606 558833 |
marco@oaktree-environmental.co.uk Twitter @wastechat.
Moving low risk positions
SINCE the demise of the Environment Agency website (and many others) in favour of
gov.uk I have to say that I do like some of the content but do wish they would reduce the number of links to other pages as it is sometimes impossible to fully research a subject unless you have significant time on your hands.
One example of this is the change affecting one of my favourite documents: “Low risk waste: activities that do not need a permit”, which took place in November 2019. Previously, when typing “Low Risk Waste” into a search engine, I would easily be able to download a single 29-page PDF containing all of the current low risk positions that sit outside exemptions and permits but are arguably of equal importance. Now, I am faced with a main page which leads to 16 web pages that contain repetitive standard content - which does not provide a nice, easy list to read through - all of which then go into other web pages again.
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To read the full list that was that single document now involves navigating and downloading often repetitive detail from over 70 web pages. Whoever was responsible for this nonsense, please stop; you’re helping no-one.
The cynic in me says that doing the list in this way makes it easier to remove position statements.
The document had not been reviewed since October 2018 but whenever it was previously reviewed it was easy to check what changes had been made. Now, it could take hours to do the same checks. I would urge anyone that benefits from a low risk position to check the web pages as the numbering system for the positions has changed, the conditions that apply to each position have been varied and the list has new additions and some removals. If you put the number on your transfer notes it will need to be changed.
The example below is used by many plastic processing sites:
Storing and treating waste plastic by cleaning, washing, spraying or coating. The position was introduced because many permits do not allow washing and the T1 waste exemption does not include the 19 12 04 EWC code for plastics arising from mechanical treatment. LRW 520 was introduced in September 2012 but is now LRWP 50. There is no change to the limit for processing, which mirrors the T1 exemption for waste plastics from other sources. It did take time to find it under the miscellaneous page rather than the “tyres, rubber and plastics” page. What was previously less than 1/3 page is now three A4 pages long if printed.
I am in the process of condensing all of the limits of the low risk positions into a single document for our own use so if any readers wish to obtain a copy by email please contact me and I’ll send it as soon as possible.
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