There has been a lot of talk recently about the withdrawal of RPS250, concerning hazardous waste wood, and the restrictions concerning wastes that potentially contain Persistent Organic Pollutants (POPs) including domestic seating and cables. I have certainly put time into reading the guidance published on .gov.uk and by the Wood Recyclers Association. However, talking to operators of waste transfer stations there seems to be a good amount of confusion as to what they should be doing about this, how to document it, record and train staff to ensure they remain compliant.

My approach to providing advice in such cases is to break it down and keep it as simple as possible. Permitted waste transfer stations are required to have a written Environmental Management System so that, in my opinion, is where to start. Including relevant information into a number of procedures within your EMS is key to implementing the required changes. I have included a short list below to explain what I mean:

• Pre-acceptance Procedure - Include information in this procedure to ensure that you are seeking the correct information from your customers about waste wood, domestic seating and cables before the waste is sent to you.

• Waste Acceptance Procedure - Include information in this procedure concerning the identification of waste items that may not be acceptable on the site. Be sure to include a list of acceptable waste codes in this procedure for reference.

• Waste Rejection Procedure - Include information in this procedure so that staff know what to do if, for example, waste arrives on the site that is suspected of having been described / classified incorrectly.
• Waste Classification Procedure - Include information in this procedure on the lab test suites that should be used if waste sampling, testing and classification is required to evidence if a waste is hazardous or non hazardous.
• Waste Storage Procedure - Include information in this procedure to inform staff on the particular storage requirements for these waste types.

• Waste Treatment Procedure - Include information in this procedure to describe how this waste is to be treated including additional emission abatement systems required. For example, extraction hood over shredders for POPs waste.
• Waste Removal from Site - Include information in this procedure to ensure that particular wastes are sent to appropriate disposal facilities. With the aforementioned wastes it is likely that this would be an IED chapter 4 permitted incinerator.

The above is only a suggestion but I feel that this approach has many advantages over creating separate procedures for the requirements of the different waste types, for example – having a waste wood procedure and a POPs waste procedure.

And then the most important thing will be to train your staff on the changes that have been made to the EMS Procedures.

Change is the only thing in life that we can be certain of, and that doubly applies to the regulation of waste. I feel that having a consistent approach to dealing with changes can greatly reduce the stress and problems that change can cause. Including information on the new requirements into your EMS, in a well-organized and thoughtful way, will help ensure compliance in an effective and efficient way.