The impact of COVID-19 on the waste industry

This is in order to get a clearer understanding of the issues experienced in local areas and the extent to which they are impacting household waste and recycling services, bulky waste collection services, commercial services and household waste recycling centres.

There has also been some recognition that waste transfer stations are likely to be handling an increase in specific waste types generated by community COVID-19 mass-testing, including Lateral Flow Devices (LFD) and Personal Protective Equipment (PPE). In response to this, the Environment Agency (EA) has issued new guidance for operators receiving waste from dedicated mass-testing sites.

Resumption of waste services survey

ADEPT’s decision to resume the survey comes after reports of increased disruption to waste services. The survey, which ran from March to September 2020, resumed on 1st February in an attempt to gain a better understanding of the issues resulting from the upheaval. Local authorities across the UK have reported increasing numbers of staff going into self-isolation because of COVID-19, which has resulted in delays and suspensions to waste and recycling services. Chair of ADEPT’s waste group, Steve Palfrey, suggested that the landscape has changed since the survey ended in September, when most local waste services were operating with minimal disruption. He indicated that this is no longer the case.

Role of waste transfer stations in handling mass-testing waste

The EA has issued guidance for waste transfer stations explaining how to collect and transfer waste originating from mass-testing sites. The guidance has been drafted in the form of a ‘frequently asked questions’ document and seeks to help operators understand what action they will need to take in order to accept waste, including LFD’s and PPE, where acceptance of these waste types would ordinarily be in breach of their permit. The document explains that large quantities of this type of waste is being generated. The EA’s preferred method of disposing of such waste is via municipal waste incinerators (MWIs). It has advised that MWIs can make use of RPS C23 to incinerate these waste types.

However, the EA has acknowledged that most MWIs expect larger loads for health and safety reasons and that waste would subsequently need to be bulked up before being transferred to the MWI. Waste transfer stations where waste would normally be bulked up may not have the relevant waste codes on their permit allowing them to accept this waste. Ordinarily, operators seeking to vary their permit would have to apply to the EA for a permit variation. The EA has conceded that under the current circumstances, this process would take too long. Subsequently, the EA has agreed that it will not take enforcement action against operators accepting this waste stream provided that certain conditions are complied with.

COVID-19 Temporary Local Enforcement Position (C-LEP)

The EA has stated it will consider applications to accept testing-site waste on a case by case basis. Requests must be made by email to the EA regulatory officer for the site in question. Where the EA agrees that a site may accept this waste stream, it will issue a temporary C-LEP setting out the conditions which must be satisfied in order for an operator to accept specified testing waste outside of its permit conditions and not be subject to enforcement action. The C-LEP will have an expiry date. After this date the C-LEP will cease to apply and operators must comply with the conditions of their permit. Compliance with the C-LEP should be demonstrated through records kept by the operator.

What should a request for a C-LEP include?

The guidance states that requests must include an Activity Plan which sets out the nature of the activities the operator is proposing to undertake. Activity Plans must, as a minimum, provide the following information:

Proposed Activities

• Location – including permit number and site plan if appropriate
• What will be done – specify the methodology including if the activities will be managed in accordance with your existing EMS or operating techniques document(s) or an additional procedure that has been written for the activity, which should be attached
• How staff will be made aware and provided with any training that is required
• Equipment (e.g. containers) and parameters for use
• Appropriate or mitigation measures designed to minimise risk of pollution and harm to human health
• Timescales

Risk Assessment

• How the risk level for the proposed activities compares with your normal activities
• Why appropriate/mitigation measures you have identified will control risk effectively

Handling test-site waste

The EA’s document sets out a number of measures which should be in place at sites handling testing site waste. The main objectives are that the waste is handled safely and in a way which means that it cannot escape. Waste should be clearly segregated upon generation and collection, transport and storage of the waste should be undertaken in a way that maintains the integrity of the waste packaging. PPE and LFD Kit wastes can be co-collected if they are being taken directly to a MWI or waste transfer facility with a C-LEP. The waste description, however, must make it clear that the waste is co-collected and the whole load must be handled as healthcare waste for incineration. The waste must be presented at an MWI as discrete loads in order for it to be managed properly.

The EA has confirmed that PPE and LFD Kit wastes can be collected with municipal wastes as long as safe collection, transport and storage can be done in a way that maintains the integrity of the packaging and it can be presented at an MWI as discrete loads. The Agency has advised that where bagged wastes are collected separately and loose, the risks are lower than where front or rear end loading refuse collection vehicles are utilised. The latter method of collection, it states, requires more assessment to meet the objectives set out above. In terms of storage, the EA states that under its Appropriate Measures guidance, offensive waste at a transfer station operating in accordance with a C-LEP can be stored for up to seven days outside, or fourteen days if stored in a building. It further advises that as testing site waste is not odorous, longer storage times may be acceptable in a building or sealed container, if this is required to consolidate a full load prior to transfer to an MWI. If such an arrangement is needed, this will need to appear as a condition of the C-LEP.

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