Waste policing – red tape or a real necessity?
In what was sadly the very last issue of renowned industry journal LAWR Magazine, UNTHA UK’s managing director Chris Oldfield shared some thoughts about the extent to which the waste industry needs greater ‘policing’. He also explored whether developments in this respect would tie the industry up in red tape or drive health and safety standards in the sector. If you missed the article, you can read it in full here…
“At the turn of the new year, when Defra published the results of its call for evidence on Refuse Derived Fuel, there were mixed feelings within the alternative fuel production sector. The consensus seemed to be that finally, the Government was sitting up and paying attention to the valuable contribution that RDF makes to the UK’s resource agenda. Talks of a quality standard were largely well received too, as this would surely heighten the ethicality and professionalism of the sector, so that further progress could be made.
But Defra’s pledge to work with the Environment Agency, in order to better police these standards, caused some concern. This was undoubtedly because often with newfound protocol, comes increased procedural control. Many worried that the move would tie responsible companies up in red tape, making it harder for them to do business.
However, efforts to drive standards, especially when it comes to health and safety, should not be seen as ‘nannying’. First and foremost, the industry is an inherently hazardous place to work, so an unswerving duty of care to protect the wellbeing of employees, stakeholders and the wider public is paramount.
A minimum quality standard
A minimum quality standard steering overall operator practice would therefore be ideal, rather than a benchmark which purely assesses the characteristics of the resulting fuel. This would help to ensure best-practice compliance is outlined, monitored and upheld. There are some stand-out companies who strive for excellence – in fact it is part of their market differential. They prepare method statements and carry out very worthwhile risk assessments – not just tick box exercises – to keep their people and the surrounding environment safe.
But unfortunately there are other firms who are so money driven, sometimes just in order to survive, that they do what they need to do to get by, and don’t or can’t aspire beyond that. That’s why we have the Health & Safety at Work Act – it sets the baseline. But perhaps in our sector we need more.
The Transfrontier Shipment of Waste Regulations 2007 go some way to regulating the non-compliant storage and export of MSW, for instance. But given the frequency of fires that we see being reported on in the press, could more health and safety-led criteria be introduced to the sector’s operations?
Dust levels could be better regulated for example, to protect personnel wellbeing and reduce the risk of fire or explosion. A few things could be learned from the chemical industry in this respect. Operators could wear monitors to continually assess their occupational exposure limits and plant wash downs could also become compulsory, to overcome the build-up of dust. All it takes is a small spark, and that dust may as well be gunpowder.
The careful procurement of alternative fuel production technology has a role to play here too. Due to machinery innovation, it is no longer necessary to invest in high speed equipment to achieve desired throughputs. Modern, slower speed, high torque technologies can attain equivalent capacities with much less dust generation. Given they have a lower tip speed, the potential for a spark is also reduced.
Say no to noise
Then there’s the matter of noise, rumoured to be the ‘next big thing’ for the UK’s ‘no win, no fee’ legal specialists to get their teeth into. And because continued exposure to noise can have a debilitating and incurable effect on operatives’ hearing, it’s no surprise.
The number of decibels a plant operates at should therefore be capped and policed. Yes hearing protection can be worn, but why not strive to design plants that operate below the first dB(A) action point? If average exposure levels are 85 decibels, hearing protection is mandatory; at 80 decibels it must be made available; but below that it isn’t required. Not only would this move preserve the hearing quality of on-site operatives, it would save money on hearing plugs too!
A commercial incentive to better protect employees shouldn’t be required, of course, but looking at the bigger picture does help to encourage some businesses in the right direction.
How will the RDF sector be policed in practice though? The apparent lack of manpower within the agency could, in truth, make it tough. Investment in resources will no doubt be required, so that the job doesn’t become impossible to manage, and some thought should also be given to the penalty of quality breaches. Will a warning, or even a fine, automatically cleanse the WtE industry of less responsible operators, keen to make a quick buck? It is doubtful. To truly deter non-compliant behaviour, perhaps regulation, with clear routes of personal prosecution, is required.
Being safe and successful
Hopefully the newly-formed RDF Export Industry Group will carefully consider the close-aligned link between standards, policing and safety. When business is carried out properly in the Waste to Energy arena, it is done so with great control and real precision across all parts of operations. When corners are cut, whether due to complete disregard for safety or unfortunately being too financially squeezed, we tread into very dangerous territory indeed.
Of course RDF production is not the only facet of the environmental sector to fall under greater scrutiny. For instance, Resources and Waste UK (R&WUK) – the newly created partnership between CIWM and ESA – has outlined that a key policy area for the new government should be to clamp down on general waste crime while reducing burdens on legitimate businesses. We only have to look at the health and environmental dangers associated with illegal WEEE trade to understand why tougher surveillance and enforcement is so important.
However, as R&WUK rightly points out, the ‘system’ needs to ensure the cost of regulation is aimed at poor performers, meaning, equally, that good practice among responsible operators is rewarded too.”