Waste industry calls for urgent action to strengthen draft MRF regs
Defra's proposals for implementing the long-awaited MRF code of practice are not strong enough to effectively deliver the high standards that are needed across the materials recovery facility sector.
Responding to the Government department's consultation on the MRF code of practice on Friday (26 April), the Environmental Services Association has called on Defra to tighten the final regulations in three important areas to ensure that it is fit for purpose.
The ESA wants to see tougher enforcement of the regime and has called for the Environment Agency to take the lead role in regulating MRFs rather than Defra's proposal to allow operators to arrange their own annual audits.
The trade association also wants the enforcement regime to be risk-based and has argued that any additional permit/audit costs should be no more than the costs of being part of the ESA RRS scheme.
To strengthen the proposals further, the ESA also argues that a tighter sampling regime is required to help drive up material quality. Sampling needs to be robust enough to be representative of the material streams without adding unnecessary cost, it argues.
The ESA has recommended that the sample sizes for the input and paper output streams should be increased and it would also like to see an increase in the minimum time-based sampling frequency.
As a third important measure to ensure the code is fit for purpose, the ESA is calling on Defra to ensure that plans to publish detailed sampling data should be extended to all reprocessors so that the industry can gain a full picture of comparable data across the entire recycling chain.
"MRFs have a key role to play in delivering a recycling revolution but only if they have good quality management systems and are able to meet their customers' needs," said the ESA's director of policy Matthew Farrow.
"Not every MRF today can match this description so we must get the code of practice right so that weaker MRFs are brought up to scratch. That's why we're calling for a strengthening of the code's provisions."
In a further move, the ESA has called for the scope of the regulations to be extended to bring in MRFs below 1,000 tonne throughput and to cover facilities that sort single stream materials.
UK recycler ECO Plastics echoed the ESA's calls for a robust testing regime in its own submission to the two-month consultation, launched by Defra in February.
Managing director Jonathan Short said that this was the best way to ensure that high standards would be met.
"MRFs must be required to carry out frequent analysis of their materials and they must be subject to regular, unscheduled tests of their facilities by the Environment Agency," he insisted.
"Full transparency is essential, with the information summarised and made publicly available. The industry has nothing to hide and everything to gain by working to best practice - we will produce material which is attractive to any market in the world, at premium value."
Adding to the call for the draft regulations to be strengthened, the Resource Association went further on the issue of enforcement.
Chief executive Ray Georgeson said that the Environment Agency needed to have a clear mandate for enforcement, which must include twice yearly unannounced permitting enforcement visits.
"Unannounced must mean just that - unannounced, and must include the ability to take physical samples and have the right to interview operatives as well as site management," he said in the trade association's response.
The Resource Association has also echoed the call for greater intensity in the proposed sampling regime. It said that the absence of guidance on sampling technology was a major issue and called on Defra to address it urgently.