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Under starter’s orders for TEEP

Waste collectors in England and Wales must ensure separate collections of waste if technically, environmentally and economically practicable (TEEP) from 1 January 2015. MRW asks three waste management companies for their views and how ready they are

Peter Allan 182

Peter Allen, director, ISM Waste

Despite an announcement to cut red tape, it appears that prime minister David Cameron forgot to inform his Government to hit the ‘stop’ button, with our sector now facing a requirement to comply with TEEP in January 2015.

While the regulations have a default position that waste must be collected separately unless it is technically, environmentally and economically practicable, this piece of legislation conspires against the well-established alternatives that many companies have invested in.

Many SMEs across the UK, like ISM, have invested millions of pounds in equipment and infrastructure to process and treat mixed commercial and industrial waste that contains recyclate. We achieve high landfill diversion and can process both source-segregated and mixed collections at our MRF, which allows us to control the quality from start to finish. Many waste producers prefer this business model, not least because some still have difficulty in ensuring that source-segregated materials are not contaminated.

We have a healthy list of reprosessors/end users keen to purchase our commodities, so we do not need mandatory source segregation or MRF monitoring to ensure we get it right.

In the real world, failure to supply compliant recyclate to end users is often met with downgrading, non-payment and even sometimes rejection, followed by a costly return bill – which is enough to focus most business minds.

The absence of guidance sums up a willingness to adopt EU policies with little thought for how it is actually going to work.   

James Capel 182

James Capel, managing director, Simply Waste Solutions

Simply Waste has been investing heavily in collection vehicles and reporting infrastructure in order to provide our customers with viable and economical solutions to manage the varied waste streams that now need to be collected separately as a requirement of TEEP.

Contrary to traditional collection methods – large trucks collecting large volumes on a relatively infrequent basis – Simply Waste has also been developing collections systems to match the smaller and more varied volumes of waste that now prevail. This will increasingly become more important as the legislation begins to take effect and businesses assess the impact of TEEP on their bottom line and their corporate social responsibility.

These smaller, more flexible vehicles can carry varied types of material on a more frequent basis, which will allow the customer to store less and recycle more. These vehicles, rather than act as replacements, work alongside the more traditional collection fleet made up of large goods vehicles.

This ‘layered’ approach to collections is almost always bespoke to the needs of the customer and, as well as a range of solutions for individual clients, we have been busy developing industry-specific collection solutions so that customers can take advantage of our extensive knowledge.

We believe that the days of a one-size-fitsall collection method are now numbered.

Although the lack of guidance from the regulatory bodies on TEEP is not at all helpful, as an entrepreneurial business, we believe it is our responsibility to second guess how the legislation will affect businesses and then devise a range of innovative services that our existing, new and potential customers need.  

Dr Alan Kirk, environmental specialist, and Anthony Egbokhan, strategic environmental manager, both at Bywaters

It is worth noting that article 11 of the revised Waste Framework Directive states that the separate collection of target material streams is to “promote high quality recycling”, but ‘high quality’ is not defined.

Bywaters collects the target materials commingled, and all possible steps are taken to ensure this material arrives at our MRF as uncontaminated as possible. Incoming waste is sampled by our Quality Control (QC) team before acceptance for processing, and recyclates produced by the MRF are also sampled to ensure quality.

We are confident that our recyclates are of such a good quality that they would easily pass any set standard for ‘high quality recycling’, and that our commingled collections of dry recyclables are capable of producing this high quality.

We have increased the level of sampling on MRF inputs and outputs, and recruited additional QC team members to help with this increased sampling. No increased cost to customers has been passed on for the first two months of increased sampling while we bedded in the systems.

The business is completely ready for the new regulations. Sampling is something we have done for several years; we have simply made changes to ensure we are 100% compliant with the new sampling requirements of the MRF code of practice.

We all know that some MRFs will just do the bare minimum until the Environment Agency catches up with them. Guidance would have ensured we all implemented exactly the same sampling regime so that there would have been no excuses.

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