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Market need certainty

Because hazardous waste has the potential to cause particular harm to human health and the environment, it is vital it is handled and treated in an appropriate way to maintain public confidence. Hazardous waste must be properly regulated so that all of it can be accounted for.

Hazardous wastes arise because many of the goods and services that society demands result in some limited quantities of hazardous waste as a by-product. Many everyday items such as computer monitors, mobile phones, TVs, fridges and some types of batteries can contain hazardous materials and so can become hazardous waste, as well as more obvious materials such as asbestos and waste oils. Hazardous waste comes from a wide variety of sources including businesses of all kinds, households, and public bodies such as the health service, schools and universities. If society wants the benefit of these goods and services, then we need hazardous waste infrastructure to deal with the waste.

Specialist waste treatment companies deal with these hazardous materials using the latest technologies, protecting the public and the environment and providing jobs and growth for the UK economy. The technologies used to treat hazardous waste include high temperature incineration (HTI), and thermal desorption, amongst other special facilities that have been developed for the treatment of cathode ray tubes, ozone depleting substances, air pollution control residues, contaminated soils, waste oils and other hazardous waste materials. The provision and development of these technologies requires substantial investment, which companies are prepared to make provided there is certainty of markets, delivered through the proper enforcement of high standards of treatment.

About 3.7 million tonnes of hazardous waste were managed in England and Wales in 2010, according to figures from the Environment Agency. About 18% of this was landfilled, 11% was incinerated, a further 28% was subject to biological or physico-chemical treatment, while 40% was recovered, recycled or reused. In 2009, the latest year for which data is available, 243,500 tonnes of hazardous waste were exported, virtually all of it for recovery. Over three quarters of this went to Germany, Belgium and France.

UK waste companies are investing huge sums in new technologies to deal with hazardous waste responsibly. But many are concerned that some hazardous waste is going to low cost or sham treatment or recovery options, with potentially adverse consequences for the environment and for investment. To address this issue, the ESA’s Hazardous Waste Strategy Group, which is chaired by Alex Gazulla of Tradebe and includes the main ESA member companies active in hazardous waste treatment, has recently commissioned research from consultants MJCA to determine the extent of the problem.

ESA Hazardous Waste Strategy Group ChairAlex Gazulla says: “Our sector provides a strategic service for our manufacturing industry. Without it, the UK industry could not operate. Our challenge is to keep investing in developing infrastructure in the UK that meets the highest environmental and safety standards, improve the service to our customers, and creates quality jobs in the UK.

“As a highly regulated sector, the need for a level playing field in the UK and the EU is crucial to create the right conditions to improve the quality and capacity of our treatment infrastructure in the UK. If we fail to do so, we will contribute to develop such infrastructure and jobs outside the UK.”

The Government’s Hazardous Waste Strategy for England, published in March 2010, set out a number of key principles, including applying the waste hierarchy to hazardous waste, facilitating the provision of infrastructure for management of hazardous waste, reducing reliance on landfill for hazardous waste, ensuring hazardous wastes are not mixed or diluted, ensuring best available techniques are applied to hazardous organic waste, and ending the use of derogations from the Landfill Directive.

Matthew Farrow, Director of Policy at the Environmental Services Association, which represents the major waste and resource management companies, said:

“The ESA and its members fully support the Hazardous Waste Strategy and the principles on which it is based. But it is imperative that the Strategy is fully implemented by Defra and the Environment Agency. The Strategy has been in place for two years now and there is emerging evidence that its aims are not being realised on the ground. There seems to be an economic incentive for hazardous waste producers to send their waste to low cost landfill or in some cases “sham” recovery facilities, either in the UK or elsewhere in the EU, to avoid the higher cost of having the waste dealt with responsibly by the UK’s specialist hazardous waste facilities”.

In the industry’s view, these developments are potentially damaging to human health and the environment, here or elsewhere in the EU, and risk undermining the investment in high quality hazardous waste treatment, recovery and recycling infrastructure made by ESA members. The research recently commissioned by ESA will confirm whether this abuse is taking place and the extent of it in terms of volumes of waste diverted from optimum treatment. The project is expected to be completed by April 2012 and should provide an overall picture of what is going on in the hazardous waste sector in England & Wales. The outcomes of the project will provide evidence on which ESA and its members can make representations to Government and the Environment Agency in the summer of 2012.

Roy Hathaway, ESA hazardous waste policy coordinator

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