Earlier this month, the Environment Agency (EA) announced that it would review all 13 of the current quality protocols (QP) for compost, anaerobic digestate and poultry litter ash over the next 12-18 months.
The specifications direct when the waste streams cease to be a waste and therefore no longer subject to waste regulation. The protocols allow different materials, such as aggregates, biodiesel, glass and biomethane to be used or sold as products. Subsequently, the processing of these products is often cheaper, more straightforward, whilst still being safe to use without harm to the environment.
Some of the quality protocols were developed in 2004, therefore the EA is concerned that they may be out of date and no longer meet the current legislative or technical standards of today. Additionally, QPs associated with land spreading have recently come under intense scrutiny with concerns about increased levels of physical contamination.
Following each review, one of the following decisions shall be made:
- the EA supports the QP with its current wording or where only minor amendments are required. The QP would then be a Resources Framework and would be published on the GOV.UK website;
- the EA no longer supports the QP, but industry confirm they would wish for it to be revised and updated. This would involve a complete overhaul of the QP and paid for by industry to bring it up to date so that it would meet the latest standards; or
- The EA no longer supports the QP and industry does not wish or is unwilling to meet the EA’s costs for its revision. ‘Any material produced and used in compliance with the affected QP would no longer be regarded by [the EA] as a non-waste product and the relevant waste regulation controls would apply.’
The outcome of each consultation could vary quite significantly and could even prompt the withdrawal of the protocol and consequently disincentivise producers to maintain standards. This would be a huge backward step within the UK organics industry, where the PAS 100 and PAS 110 protocols have encouraged the production of quality products that would have otherwise been treated as a waste.
Taking action to review and improve technical standards is a positive step towards addressing environmental issues. However, the outcomes have the potential to cause substantial effects to the industry in a relatively short time frame.
This highlights the need for industry wide engagement to ensure that the best outcome for the waste industry is achieved. We urge all operators who may produce products in line with the quality protocols, such as the PAS 100 and PAS 110 standards to forward any comments to us or the REA. The EA will also liaise directly with each QP producer.
WRM is keen to be involved with consultations and will keep you updated throughout the review of each QP.
