Category Archives: Zero Waste Scotland

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.

Scottish Resource Conference 2019 Sponsorship

Albion Environmental host table and provide sponsorship for the  “Best Food Waste Initiative” award at Scottish Resources Awards Dinner 2019 (now in its 18th year) at Perth Concert hall. This prestigious event is to recognise companies and individuals for their creative input within the circular economy and resource management sector. It is held in partnership with the Chartered Institution of Wastes Management (CIWM), Zero Waste Scotland (ZWS) and the Scottish Environment Protection Agency (SEPA) . We look forward to welcoming our guests and would like to wish all the finalists the best of luck for the awards.

SWITCH Workplan

Please find below an important message about SWITCH.

Dear Colleague,

As a Forum we have worked hard this year to review our work for the past 4 years, which has highlighted many of our successes and achievements even though it is entirely based on us collectively giving our time on a voluntary basis. It has also given us a chance to review our governance system, structure and documents to consider how best to put it on a more sustainable path – more detail on this will follow. At our last meeting the following work plans for each of the working groups were identified and outlined and I would ask you to all please review these workplans and let me know what suggestions you have for SWITCH to take these pieces of work forward by Tuesday 27 November by emailing Fiona Craig back directly.

Executive Working Group

  1. To establish new governance system for SWITCH based on becoming a Scottish Charitable Incorporated Organisation (SCIO) with accountability to the Office of the charity regulator in Scotland (OSCR).
  2. To review the Constitution to ensure fit with the criteria of becoming a SCIO.
  3. To review and develop an overall communication and engagement plan for SWITCH including an improved website.
  4. To oversee the development of a sustainability plan for SWITCH.

 Health & Safety Working Group

  1. WISH 4 (Safe Collection Practices) has just been reviewed and republished. SWITCH is to review and agree how and what to promote this WISH Guidance in Scotland using the website, SWITCH Network and annual event.
  2. The HSE Waste & Recycling Sector Working Plan has been published and section 5.2 notes areas for concern. SWITCH to review and promote this, particularly site traffic management plans and segregation of pedestrians and vehicles.
  3. WISH has drafted a guidance document on vehicle specification. SWITCH to review this and consider how we can influence standards and what’s available.
  4. Health & Wellbeing is a theme that SWITCH wishes to develop and introduce a few case studies (Binn Group can demonstrate real progress in this regard for example).
  5. Possible Annual Theme – with the aim of prioritising it  

Education, Training and Competence Working Group

  1. To continue to develop the SWITCH SHEA Passport Scheme for the waste and resources sector.
  2. To participate fully in the National Occupational Standards (NOS) Review for the sector which will take place September 2018 to March 2019 led by Energy and Utility Skills.  Once completed the NOS can be reconciled with the existing SWITCH Competence Framework and to ensure it is reviewed and up to date and fit for purpose.
  3. To review the CF once NOS review is complete to see how it can be built on (it is currently based on only 6 key roles within the industry)
  4. To start to promote how the CF relates to a range of common qualifications and accredited courses e.g. SHEA Passport Scheme, Manual handling, H&S, and particularly the FLES Award. A series of supporting documents to be produced for this.
  5. To establish a mentor and mentee program to support managers/ team leaders through the process of and to also provide support for those being assessed.

With thanks for your continued support


Alasdair Meldrum is one of the SWITCH ambassadors and is a member of the Education, Training and Competence Working Group.

If you have any queries regarding this message or SWITCH in general please do not hesitate to contact Alasdair directly or call 01292 610428.

Waste Compositional Analysis Works

Albion Environmental is an experienced provider of Waste Compositional Analysis services to local authorities, waste management companies and producers of commercial and industrial waste.

Over the past 10 years we have sorted in excess of 280,000 kg of waste by completing Waste Compositional Analysis for our clients.

In recent weeks we have sent teams to Perth, Scottish Borders, and Carlisle, and we are due in Dundee in November, this is in addition to a weekly analysis carried out for a major waste operator in the area.

We can carry out a comparative Waste Compositional Analysis over longer periods, often 2 per year in spring / autumn or 4 over an 18 month period. 

Many clients will engage us to carry out a Waste Compositional Analysis before a new collection system is put in place and can complete similar Waste Compositional Analysis once implemented to allow a detailed report on the effect of the new collection systems

Our reports include detailed review of our work and information relevant to client requirements for example;

  • Weight (kg) and volume (litres) of each sort category within the sample
  • Waste is sorted down to 17 primary and 70 secondary categories
  • Percentage of each waste type found within the sample by weight and volume
  • What materials could be diverted to recyclate or considered to be contamination

For further information, contact 01292 610428 or

Albion’s ABC’s of Waste Management – C

C – Circular Economy

The circular economy is an alternative to the traditional economic model whereby we produce goods, use them and then dispose of them. Currently, we tend to regularly update our technologies such as smartphones, tablets and computers. However, in the linear economy these are thrown away and are not designed to be re used.

On the other hand, the circular economy would extract maximum value from these products and materials. For example, a smartphone would be designed so it would be easily repairable and upgradable thus prolonging the device’s usefulness. Also, at the end of its useful life we would be able reuse the phone’s components and raw materials. These could be used in a new device or made into a new product.

Vector illustration of circular economy showing product and material flow. Product life cycle. Sky meadow nature blurry background. Natural resources are taken to manufacturing. After usage product is recycled or dumped. Waste recycling management concept.

A circular economy also offers several economic benefits, for example the creation of new jobs and demand for new skills. Expansion of the circular economy has potential to address unemployment and skill gaps and create up to 200,000 jobs. For more details please follow the link to Zero Waste Scotland Website