Last year saw the waste wood industry face two of the biggest regulatory issues in more than a decade: revised fire prevention plan (FPP) guidance and proposed changes to how waste wood is classified. The outcome of both issues still remains to be seen. But for the Wood Recyclers’ Association (WRA), working with regulators to try to ensure a positive end result remains a priority.
Andy Hill, WRA chair, said the association has been working more closely with the Environment Agency (EA) in the past two-and-a-half years than ever before. The focus of this work began in 2015 when proposed changes to the EA’s FPP guidance was published. For wood recyclers, the changes caused concerns about unworkable stack sizes and storage durations.
“The issue was not that we do not think safety measures needed to be in place,” said Hill. “Rather it was about the fact that one size cannot fit all when it comes to running a recycling site – and that the guidance had been created with no consideration to operational reality nor underpinned with any science.
“Many of our members and other operators outside the wood sector need non-standard FPPs in order to operate their business, and the proposals just did not give them the flexibility they needed.”
The WRA began a campaign to highlight its concerns to the EA, and later had meetings with key personnel who promised to work with the WRA and other trade bodies to develop industry-specific templates that would build in the flexibility required. That work is still ongoing, but the WRA said it has learnt of lot of lessons through the process.
Hill said: “We needed to engage sooner with the EA, our members and other trade bodies, and we needed to understand the real scale of the problem.”
The WRA has drawn up a draft template to help wood recyclers that require standard or non-standard FPPs to gain them more quickly. The draft is currently with the EA awaiting input on what it will class as acceptable alternative measures for operators needing to move outside the standard guidance. The WRA hopes the template will be published this spring.
When proposed changes to how waste wood is classified were announced by the EA last year, the WRA knew it was facing another major challenge to its industry and had to act quickly. “This time we have engaged with the EA and other affected stakeholders straight away,” said Hill. “As a result we have been asked by the regulator to lead a waste wood industry group to come up with a solution.”
As well as a range of WRA members, the group includes waste management companies, representatives from the waste wood industry’s major customers, other trade associations, local authority representatives and representation from the EA’s technical team, who are charged with finding a process to ensure that waste wood is properly classified at the front end; the people who process the wood further check and maintain that classification; and those taking the processed wood ensure they use suitable wood for particular end uses.
“We have led a number of industry-wide workshops focusing on the testing required to reach an evidence-based, practical and risk-based solution, but this again is ongoing work,” said Hill. “During the next 10 months, we will be carrying out further waste analysis and assessment to help shape what happens next.”
The need for a reclassification of waste wood follows concerns about whether treated waste wood was being misdescribed as untreated, clean grade A material and ending up in boilers that were not Industrial Emissions Directive (IED) Chapter IV-compliant.
While this work is carried out, an interim regulatory position statement (RPS) has been published by the EA which states that clearly identifiable clean untreated waste wood is only suitable for animal bedding or non-Waste Incineration Directive boilers, and mixed waste wood must only go to Chapter IV IED-compliant boilers or panelboard manufacturing.
A precautionary hazardous waste classification and associated consignment requirement will be applied to mixed waste wood loads in any other situation. Waste wood currently recognised as hazardous, such as railway sleepers, telegraph poles and wood treated with creosote, must continue to be segregated as hazardous waste and consigned as hazardous to appropriate facilities.
The RPS will remain in place until November 2018, after which time the WRA hopes for scientific evidence to support the different uses of waste wood for varying end markets.
It is not just the WRA that fears the consequences of the waste wood classification project if it does not have the right outcome. Concerns are also being raised by waste management companies and local authorities, who are worried that incorrect guidelines for classification could lead to a reduction of 2-6% in national recycling rates, a significant rise in costs for councils and an increase in landfill of a recyclable material.
The National Association of Waste Disposal Officers (Nawdo) is working with the WRA and others on the industry group. It fears classing all wood from household waste recycling centres as treated could move a lot of waste wood down the hierarchy from recycling to recovery.
Claire Brailsford, Nawdo chair, said: “This would have dramatic effects on the wood recycling industry and hence significant impacts on the UK recycling rate and targets. Any potential increased costs incurred by local authorities would have to be met by taxpayers.
“In addition, if this is not thought through properly, another unintended consequence is likely to be that some waste wood could be diverted to hazardous landfill which has very limited capacity, is expensive and, again, moves waste down the waste hierarchy.”
For the WRA, the prime focus for 2018 remains working with regulators to ensure the right outcomes and raising general standards across the waste wood sector. It has been working on a code of practice for the past few months and is planning to launch the first phase by the end of this year. The code will focus on a number of topics including the FPP and waste wood classification in detail, as well as dust issues and site health and safety.
“It will be a requirement of WRA membership that companies sign up to the code,” said Hill. “How we audit that is part of the scope of the work we will be completing this year. But signing up to the code and agreeing to operate to a certain standard or above will bring many benefits to operators. Not least of these will be recognition by industry regulators, who will be able to see [that the association] and our members have committed to maintaining the highest standards.
“Both FPP and waste wood classification are hugely important issues for our industry, and the outcome of the work we are currently doing will have enormous and long-lasting effects. It is therefore crucial we get it right.”
Why waste wood is important to the UK
Waste wood has been recycled traditionally for use in a variety of end products including animal bedding and panelboard. These account for around 1.4 million tonnes of waste wood in the UK every year.
But during the past five years, there has been huge growth in waste wood being recovered for use as biomass fuel (pictured). The UK’s renewables policy has played a big part in this, with wood recyclers supplying around 1.6 million tonnes of processed post-consumer waste wood to biomass facilities in 2017.
That figure is set to double in the next 18 months, with an additional 1.6 million tonnes of waste wood biomass facilities due to begin operations. These facilities contribute significantly to the UK’s overall energy security, reducing reliance on fossil fuels and further reducing the amount of materials sent to landfill.
The 3.2 million tonnes of waste wood biomass represents around 2.9TWh of annual domestic power production, enough to supply more than 700,000 households.
It signifies the success of the UK’s renewables policy, with all forms of renewable energy now accounting for around 25% of energy production and coal just 10%. This compares with 1990 when coal represented 70%, nuclear 20% and oil 10%.
The introduction of biomass as an energy source has begun to move the UK away from the historic model of centralised energy generation and towards the development of localised distributed networks. Biomass power stations are increasingly fuelling local industrial operations as well as the national network. They are also helping to reduce emissions and enabling the UK to retain its waste wood and use it as a valuable resource.
Billions has been invested to ensure full recovery capacity away from landfill. WRA members have invested in the past few years in both processing equipment and additional measures to ensure they are compliant with regulations, and will continue to do so.
All these end markets play an important role in ensuring that waste wood continues to be recycled and/or reprocessed and not sent to landfill. With an estimated five million tonnes of waste wood being generated in the UK each year, it is essential we do all we can to ensure they can continue to operate effectively.