Category Archives: Regulations

Albion’s ABC of Waste Management – P – Persistent Organic Pollutants (POP’s)

  • What are persistent organic pollutants (POP’s)?
  • How do the recent changes to the hazardous waste regulations impact you?
  • What are the implications of POP’s in waste electrical and electronic equipment (WEEE)?
  • What does this mean for the re-use and recycling industry?

Persistent Organic Pollutants (POP’s) are potentially hazardous organic substances which can impact the environment and human health if they escape. Chemical have historically been used in plastic for electrical items due to their flame-retardant properties.

Legal aspect

Many items of WEEE meet the criteria for hazardous waste under the Hazardous Waste Regulations 2005, most common are fluorescent light tubes and cathode ray tubes. Hazardous WEEE should be segregated from general WEEE for specialised collection and treatment.

The Hazardous Waste Regulations were amended 2019 to take into account the revised EU Regulation on Persistent Organic Pollutants (POPs).  The new legislation sets tougher controls on chemicals historically used as flame retardants as well as other potentially hazardous substances. 

Research carried out by the Industry Council for Electronic Equipment Recycling (ICER) suggested that levels of POPs present in common WEEE plastics are actually higher than previously thought. High bromine levels that could exceed the POPs Directive threshold can be present in the following electronic plastics:

  • Plastic from cathode ray tube (CRT) display units
  • Flat panel displays
  • Small mixed WEEE
  • Fridge compressors

Further to those, tests have been taking place to determine the presence of POPs in cabling.

Issue for the WEEE reuse and recycling industry

The new legislation sets maximum concentration levels for POPs in waste materials to levels that are below what have been commonly used in products in the past.  Many items, in particular Small Mixed WEEE, Cathode Ray Tube TVs and Flat Screen TVs, could contain levels of POPs that effectively render them hazardous.  Most of these items which previously could be reused or recycled must now be incinerated. 

Implications to the WEEE reuse and recycling industry

We are waiting for guidance from SEPA around this.

The legislation will result in a need for greater sorting and separation of what is now deemed potentially hazardous plastic derived from WEEE.

In practice, the new legislation means that some plastics from WEEE which would previously have been recycled, will now be destroyed by incineration (or potentially other high temperature processes like a cement kiln). Bromine separation technologies may be used to separate these POP containing plastics from other plastics and wastes. The latter may then be suitable for recycling.

It is anticipated that this could add significant cost to the treatment of waste electrical and electronic equipment, as hazardous waste materials are subject to greater regulatory controls than non-hazardous waste and due to more limited treatment options.

Recycling industry

Recyclers of WEEE have highlighted that plastics recycled from the WEEE stream such as computer cases had been in high demand, and they believe that concern about POPs is overstated and would prevent recycling.

Does it make sense to burn plastics which could have an alternative route?

The idea of plastic from the backs of television being seen as hazardous is also worrying exporters of refuse derived fuel. The RDF Industry Group concerns are that this would potentially mean that RDF containing these plastics should be classed as hazardous if the plastics were not covered by the exemption for household WEEE.

An additional concern pointed out by the industry was about the impact on recycling rates with the potential that some target rates may now not be achievable.

Reuse industry

There is still uncertainty on the impact of the POPs Legislation on the reuse industry.

The EA has stated that waste display devices and Small Mixed WEEE cannot cease to be a waste, or be reused, unless it is demonstrated that POPs are not present in a particular device or item of equipment. The reuse industry is expressing their concern as this could bring the reuse market for display and small items of WEEE to a close. 

In addition, it is not clear how this would impact on WEEE reuse at civic amenity sites and charity shops. Although the reuse industry did point out that the risk of spreading POPs is low as it is ‘encapsulated in the plastic’, and can only be released upon waste treatment. This means that reuse of items that may contain POPs would not create any risk of harm as the integrity of the plastic is not compromised during testing and repair.

How can Albion help?

This will impact businesses including;

  • Metal recyclers,
  • Recyclers of IT equipment and others accepting WEEE with POPs
  • Local authorities which handle WEEE at recycling centres

Albion can help to assess the implications of this legislation through;

  • Review your activities on the handling of WEEE, licences and/ or permits and cross check against the POPs legislation
  • Identify areas of non-compliance
  • Review your data and estimate potential impact on recycling rates (in case of LAs)
  • Estimate potential impact on costs based on required method of disposal to meet regulations
  • Identify options for management and classification of materials.

Albion’s ABC of Waste Management – N – Non-Hazardous Soil Waste

Albion Environmental provide training and advice to ensure your business is compliant and reduce your waste disposal costs.  Do you produce, manage or handle waste soils? Are you aware of your legal obligations? Find out more and sign up for one of our courses now.

Scotland produces approximately 11.6 million tonnes of controlled waste per annum and approximately 4.3 million tonnes of this is waste soil.

If you produce waste soil, to comply with the Waste (Scotland) Regulations 2011 and the Waste Management Licensing (Scotland) Regulations you must:

  • Apply the waste hierarchy to the management of your soil waste
  • Ensure your waste is transferred to someone authorised to receive it
  • Complete a waste transfer note
  • Describe the waste accurately
  • Take measures to ensure that your waste does not cause pollution or harm to human health

While most businesses will have their waste transfer note paperwork, in our experience, many do not fully complete all of the above steps.

Why should you take time to consider this?

  1. Financial Benefits – By ensuring the waste hierarchy has been applied and soils classified correctly you could reduce the volume of waste soil you generate and its associated cost for disposal.
  • Environmental Benefits – You could reduce the volume of material going to landfill, help identify greater opportunities to reuse soils and lower your carbon footprint.
  • Legal Compliance – It is a legal requirement

What Can Albion Do?

Albion can provide those who produce, handle and manage waste soils with a range of services to comply with your Duty of Care Requirements, including:

  • Bespoke training to help your staff understand their Duty of Care Obligations
  • Sampling and assessment of soil waste
  • Soil waste classification in accordance with WM3 Guidance
  • Soil reuse assessments
  • Development of soil management plans

The results of the above will help your business demonstrate it is complaint and can generate significant cost savings.

To find out more or to have an informal chat please contact Andrew Howlett.

REHIS 2 Day Course – Working with Waste Management Legislation

Do you need to comply with current Waste Management Legislation or are you working towards gaining a WAMITAB COTC award? If the answer is ‘yes’ then our 2 Day Working with Waste Management Legislation course is not to be missed.

Next Course 30th & 31st March 2020. Book Here or contact us directly on 01292 610428 to speak to our Training Manager Kirstie MacDougall

This two-day course is designed to provide an understanding of the legislation relating to the Waste Management industry and provides background knowledge and understanding for WAMITAB candidates. The course is suitable for those new to the Industry, anyone starting or completing WAMITAB COTC awards or experienced managers who require to be kept abreast of recent changes.

Candidates who successfully complete the course will receive a joint certificate from Albion Environmental Ltd and The Royal Environmental Health Institution of Scotland (REHIS) which can be used to demonstrate Advanced Prior Learning (APL) for WAMITAB awards.

To provide evidence of the knowledge & understanding aspects required for the technical units of WAMITAB’s Certificate of Technical Competence (COTC’s) and to provide a basic understanding of the main elements of the Environmental Protection Act 1990

To understand and apply the practical aspects of:

  • The Definition of Waste
  • The Duty of Care
  • Registration of Carriers
  • Special Waste Regulations
  • Transport of Wastes (Including Dangerous Goods)

Course Content

  • The Definition of Waste
  • Registration of Carriers
  • Duty of Care
  • EWC Codes Special Waste Regulations & Consigning Special Waste
  • Carriage of Dangerous Goods (By Road)
  • Storage of Hazardous/Special Wastes
  • Environmental Monitoring
  • Health & Safety Management

Training Methods
Participative with a mix of lecturing, case studies and exercises.

Course Materials include:
Course Manual

Confirmation of Learning
Confirmation of learning is achieved by completion of course exercises.

Albions ABC of Waste Management – M Materials Recovery Facility

Are you aware of your obligations under the Waste (Recyclate Quality) (Scotland) Regulations 2015?  Albion’s Waste Compositional Analysis team have been providing bespoke training support and ad-hoc expert advice on the requirements for waste sampling and data provision.

A Material Recovery Facility (MRF) is a facility where collected commercial and or household recyclable waste is sorted into different material types. The so called ‘Dirty’ MRFs are those which only accept and sort residual waste.

  • Are you aware of your obligations under the Waste (Recyclate Quality) (Scotland) Regulations 2015?
  • Do you know what data should be reported?
  • Are you aware of the sampling protocol that should be followed?

Since 2015, the sampling and testing at MRFs are covered by two main statutory documents:

  • the Code of Practice on Sampling and Reporting at Materials Recovery Facilities – it aims to improve the quality of output materials by developing standardised testing processes and reporting mechanisms for all input and output materials
  • the Collection and Reporting of Material Recovery Facilities (MRF) Data guidance – it aims to assist operators in complying with the Code of Practice data form. The data reporting is a requirement as set out in the Waste (Recyclate Quality) (Scotland) Regulations 2015 and the associated statutory Code of Practice on Sampling and Reporting at Materials Recovery Facilities.


Both statutory documents above apply to those facilities who hold a licence or permit and that receive/ are likely to receive 1,000 tonnes or more of mixed dry recyclable materials (comprising of two or more materials) or separately collected dry recyclable waste for sorting, over a 12-month period.

Examples of facilities excluded from the Code:

  • Household Waste Recycling Centres (Civic Amenity Sites)
  • MRFs receiving and sorting residual waste only (‘Dirty’ MRFs)
  • Waste Transfer Stations acting only as bulking point (with no sorting activities)
  • WEEE management facilities
  • RDF production facilities
  • MBTs – unless mixed dry recyclable waste is accepted for any MRF operations that form part of the process

Brief on Requirements

The Code of Practice sets out the requirements for sampling, including weight, frequency, reporting periods, measurement and materials to be sampled, and the information to be recorded and reported to SEPA. It requires that MRFs identify materials in relation to what is defined as:

  • Target Material – A material that is specifically targeted by the MRF licence or permit holder as destined to be separated out from other material to facilitate its recycling.
  • Non-target Material – A material that is capable of being recycled but is not a target material for the MRF.
  • Non-Recyclable Material – Waste material that is not capable of being recycled.

Target material that is found in a sample must, as a minimum, be separately identified in the following types:

  • Glass
  • Paper
  • Cardboard
  • Metal
  • Plastic

How we can help

Albion is an experienced training organisation and delivers a wide range of training for organisations across the UK.

Albion’s Waste Compositional Analysis team have been providing training support and ad-hoc expert advice on the requirements based on the MRF statutory documents.

We delivered MRF sampling training programme on behalf of Zero Waste Scotland (ZWS) across all MRF operations in Scotland. We have received approval, from ZWS to use this training material (which is still current and relevant).

Training support can be tailored for each facility’s needs and activities. In general, the approach we have used with clients include the following:

  • Session 1 (Half Day Theory) – This session will work through the Code of Practice and is relevant for Directors, Managers, Supervisors and also the staff that carry out the quality sampling.
  • Session 2 (Full Day Practical) – Deliver one day practical sampling and sorting session for a minimum of 3 staff (max. to be agreed) at your facility, using your equipment.
  • Site Specific MRF Sampling Plan – Using information provided for the training we will provide a Site Specific MRF Sampling Plan for your facility, which can then be integrated into your company procedures.
  • We can also assist with undertaking waste compositional analysis surveys in accordance with relevant guidance.

To find out more or to have an informal chat please contact Jane Bond

The movement and use of treated asphalt waste containing coal tar.

Asphalt waste is created when material is removed from roads, car park, pavements etc. When the binder used within the asphalt is bitumen, then the asphalt waste produced can be regarded as a non-hazardous waste. However, when the binder contains coal tar and exceeds the relevant hazardous threshold, then the asphalt waste produced will be classed as hazardous. The normal route for dealing with this type of hazardous waste in Scotland is to remove the material and transport it to a suitable third-party facility for disposal. This can be very expensive with disposal costs, landfill tax costs and haulage. 

Albion Environmental have had approval from SEPA, on a site by site by basis, that if the waste produced is treated in an agreed manner and is backed up with suitable procedures and records, then this waste can comply with current Waste Legislation.  This material can be re-used in sub-layers of the new road, car park or footpath engineering works at the site it was produced. This approach also very much improves the sustainability criteria that we are all striving to achieve. 

If this is of interest to you please contact Gerry McCabe or Andrew Howlett or for further information or call us on 01292 610428.