Environcom has written to the Department for Environment, Food and Rural Affairs (Defra) over concerns it has following the awarding of the Waste Electrical and Electronic Equipment (WEEE) Protocols Study to Mayer Environmental.
In a letter from its technical executive Jeff Weeks to Defra, Environcom argue that Mayer Environmentals commercial links with European Metal Recycling- one of the largest shredder operators in the UK- means that an independent study may not be possible.
Also, with clear de-manufacturing process requirements neither set nor agreed, the company feels that the study has no benchmark from which to measure a clear mass balance and to assess Best Available Treatment, Recovery and Recycling Techniques (BATRRT).
This is due to the fact that Defras treatment guidance is yet to be finalised or published and is unlikely to appear before the regulations. With this being the case, organisations bidding to carry out the study were unable to determine a reasonable estimate for the costs of the work involved.
In his letter, Jeff Weeks suggests the study should not only address WEEE, but also BATRRT and questions the use of conventional shredders in the process.
He writes: There is significant doubt in respect of the ability of the conventional shredding process to deliver the recycling targets in the directive, avoid contamination and meet the requirements of Annex II [of the directive] despite heavy lobbying by the shredding industry.
If conventional shredding methods are applied, WEEE will no doubt be mixed with other light iron, plastics, etc. from other waste streams assuming that market forces (and lack of regulatory control) will allow shredder operators to mix WEEE with other similar waste streams.
He argues that if the Government allows current practices to continue, it will be left with a regulation without substance or meaning. Defra, he writes, must therefore address the treatment process itself with a study carried out by a company completely independent of any commercial organisation.
Allowing these [shredder] operators to continue as is would place a huge burden on current Environment Agency enforcement officers who would surely struggle to police such operators and enforce the directive during such time when a mountain of WEEE and other waste appears.
A blanket ban on conventional shredders processing WEEE must therefore be put in place.