Waste experts have lamented a lack of understanding of the requirements of the amended waste regulations that will come into force next year and said the debate has been too focussed on the so called ‘TEEP test’ for councils.
In a panel session at RWM, Andrew Bird, chair of the Local Authority Recycling Advisory Committee noted the revised EU framework directive, which will be implemented from 2015, applies to all waste collectors, therefore also on private companies and individuals.
“It is not a local authority issue,” he said. “It is an issue across the board.”
He said he was worried about the level of awareness among commercial operators of the requirements of the new rules.
“I have massive concerns on the commercial sector on how they can even begin to comply with the regulations,” he said. “I feel there is a complete lack of understanding.”
He added he was looking forward to seeing how the Environment Agency will manage the enforcement regime.
Esther Kiddle, a lawyer with experience in the waste sector, noted another important element has received little attention, the so-called necessity test.
Under the the Waste (England and Wales) Regulations 2012, waste collectors should collect recyclable materials separately where necessary to ensure that waste is treated in accordance with the waste hierarchy and to protect human health and the environment, and where it is technically, environmentally and economically practicable (TEEP) to do so.
Kiddle said that councils had rushed to conduct TEEP assessments due to “sheer panic”, while there had been little consideration for the necessity argument.
“I have not seen any evidence on the necessity test that convinces me that we even have to go to the TEEP point… We got it the wrong way round.”
Kiddle added that more information and peer review, such as data on contamination levels and quantity of materials, was needed to assess whether separate collections were necessary to achieve the objective of the waste framework directive.