Nicky Cunningham, deputy director for waste regulation at the Environment Agency, looks at wood waste and its correct treatment, and the role of waste producers, in an article that was first published in the July issue of the CIWM Journal
My job at the Environment Agency is to ensure the right waste goes to the right place. At the moment, we are seeing treated waste wood ending up in the wrong place. This can lead to negative health and environmental consequences.
The problem? Wood is often treated with chemicals, which can include inorganic substances, such as arsenic, or organics, such as cresols. Our evidence shows treated waste wood is being used for unsuitable purposes, including unabated fuel burners and composting.
The unregulated presence of chemical treatments in wood waste can also add costs to the recycling process and potentially undermine recycled product quality. We are also seeing large stockpiles of waste wood, which increases the risk of fires.
The solution? My team works really hard to ensure waste wood is managed properly. We are working with Defra, the Department for Business, Energy and Industrial Strategy (BEIS), Ofgem, Natural Resources Wales and important trade associations, like the Wood Recycling Association (WRA) to make this happen.
The solution lies in ensuring that all those handling waste wood know what it is and are confident they can describe it accurately, so it goes to the right end user. The whole waste chain has duty of care responsibilities and we know that the better the practice at the beginning of the chain, the lesser the burden for others further down it. With the UK producing around 5m tonnes of waste wood per annum , it’s crucial everyone gets it right.
We want to make sure all waste producers, carriers and operators of sites managing waste wood are aware of the need to accurately describe the wood and can tell subsequent holders about any contamination, especially chemical or organic treatments applied. Our particular focus is mixed waste sources, such as at civic amenity sites and waste from demolition activities.
If reliable waste descriptions and segregation is undertaken by producers, and the right checks are made throughout the waste chain, then waste wood will end up in the right place.
We are also keen on ensuring waste contractors understand what is happening so they don’t inadvertently allow waste wood to be handled, processed or used without appropriate waste management controls, particularly in the Renewable Heat Incentive (RHI) scheme.
Firstly, waste contractors should always make sure they are given an accurate description of any waste wood – either on a Waste Transfer Note or Consignment Note, from the person they accept the waste from.
Secondly, waste contractors should always check they are delivering waste wood to an authorised site.
The WRA is developing a Code of Practice, with our help, to assist those who manage waste wood. We are also working with BEIS and Ofgem to improve the guidance for those involved in the RHI scheme.
By law, all waste needs to be accurately described; our WM3 guidance explains how to do this. The law requires the presence of any treated waste wood, in any quantity, in any mixed load or a processed output/fuel, to be identified clearly:
- items of treated waste wood have different legal disposal and recovery requirements that continue to apply even if they have been mixed with other waste wood
- hazardous waste wood must be reliably identified and segregated at source, and kept separate in the waste chain during transport and storage
- the segregation of untreated wood and non-hazardous treated waste wood is an important consideration. The presence of treated waste wood has a huge impact on the legal recovery options.
The end use of waste wood is restricted:
- only untreated, clean waste wood can be used for animal bedding, as a mulch, in composting, as a fuel in wood burning stoves or other sensitive uses.
- hazardous waste wood can only be burnt in permitted Chapter IV compliant incinerators or used in panel board manufacturing, subject to gatehouse checks at those sites
- non-hazardous treated wood can be recovered as per hazardous wood, and can also go to a non-hazardous landfill if it can’t be recovered.
Most activities involved with recovering and disposing of waste wood require a permit under the Environmental Permitting Regulations (EPR), either as an installation activity or a waste operation, depending on the type of activity and throughput. Burning of waste wood is regulated by us, or the local authority. Small-scale burning of untreated waste can be done under the terms of registered exemption from permitting.
Making all this happen so the right waste goes to the right place is a challenging job, but I also find it rewarding working with such a wide range of partners, knowing we are making a real difference.
The rules on waste management are explained on the www.gov.uk website. You can also get excellent advice at our customer contact centre: 03708 506 506