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MARCO MUIA BSc (Hons) MSc MCIWM, Managing Director


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.


ENVIRONMENTAL


Protocol update


WELL, the waste returns have been submitted and the world hasn’t ended, although some Technically Competent Managers (TCMs) we know have been contacted regarding the number of sites they cover and the time they are required to spend on site. We’ll update you as news comes in.


Now for something completely different.


There are currently 13 end of waste quality protocol’s (QPs) used by our industry to enable processed waste to be classed as a non-waste product, removing the need for further compliance with waste regulation legislation. Some of the protocols have been around for more than a decade so a comprehensive review is being carried out over the next 12-18 months.


The review appears to have a balanced approach in that it will look for evidence of abuse, unintended risk of pollution and whether the terms of the QP are excessively onerous. There will also be the opportunity to include additional waste inputs or processes. For a full review read the document on gov.uk.


There will be three possible outcomes following the review of each protocol: 1. Support the existing/slightly amended document;


2. No longer support the QP but completely overhaul the document if industry wants it to continue. (No surprise that this work is chargeable!);


3. No longer support the QP, which could include industry not wanting to still be subject to waste regulatory controls.


This review does not include assessments of new protocols, which is disappointing, given that charging will be imposed for any review. As the industry evolves why are we not considering new protocols?


I am also puzzled at the lack of mention that the protocols are not the sole route to proving that waste has been recovered and is a valid product. The courts are able to determine end of waste cases and, whilst it is costly, case law is the last word on the matter unless further determinations are made which supersede the original decision. Surely assessing new protocols would be a better option?


The timetable for the review is shown below but if you have any questions you can email the review team at resourcesframeworks@environment- agency.gov.uk


Planned order of review of the quality protocol (correct at time of printing, timings subject to change depending on complexity of reviews)


1 2 3 4 5 6 7 8 9


10 11 12 13


Quality Protocol: Compost (Review to start August 2019)


Quality Protocol: Anaerobic digestate (Review to start August 2019) Quality Protocol: Poultry Litter Ash (Review to start August 2019) Quality Protocol: Aggregate from inert waste (Planned late 2019) Quality Protocol: Processed Fuel Oil (PFO) (Planned late 2019)


Quality Protocol: Pulverised Fuel Ash (PFA) and Furnace Bottom Ash (FBA) (Planned late 2019) Quality Protocol: Tyre-derived rubber materials (Planned early 2020) Quality Protocol: Biodiesel (Planned early 2020)


Quality Protocol: Biomethane from Waste (Planned early 2020)


Quality Protocol: Recycled gypsum from waste plasterboard (Planned late 2020) Quality Protocol: Non-packaging plastics (Planned late 2020) Quality Protocol: Aggregate from steel slag (Planned late 2020) Quality Protocol: Flat Glass (Planned late 2020)


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