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UK Landfill Practise and the Landfill Directive’s Ban on Co-disposal of Hazardous Waste

Looking back at the effect the Directive’s ban on Co-Disposal has had on Hazardous Waste Disposal in the years since it was introduced in 2005.

The implementation of the Landfill Directive meant that landfill would never again be available in the UK as readily or as cheaply as it had always been. The UK government knew that in order to comply with the EU Landfill Directive the waste management industry would have to divert up to 5.4million tonnes of waste from landfill by 2010 to comply with its statutory obligations under the Landfill Directive. So, it had to bring about changes, and that was the start of the huge annual price rises through the “Landfill Tax Price Escalator policy” which has now brought taxation in the current year (2011) to £57/tonne for all industrial and commercial waste, including Municipal Solid Waste (MSW) being sent to landfill.

Another part of the big change, which brought a sea-change to the use of landfill in the UK, was the outlawing of all hazardous waste disposal to the same landfills as industrial and commercial/ MSW, barring of course the small quantities mixed in with MSW, such as battery waste and electronic waste which were to be reduced by other measures, at source.

Until then, all wastes other than a few of the most toxic of all wastes which landfill operators refused to accept had been co-disposed to general landfills. That means that the toxic waste, liquids and solids (although all liquids were prohibited to landfill before this date) had been spread into the general waste, and quite successfully allowed to react and stabilise within the body of the waste. If the percentage of toxic waste was kept to below about 20% of the waste landfilled by weight, and mixed into the waste well away from leachate drainage wells in lined and capped landfills this gave no problems of any significance. In fact the move away from co-disposal was a political one, and acceeded to by UK politicians of the day as a compromise for adoption of other UK measures throughout Europe, and not scientifically or environmentally considered by the UK waste industry to be any better than co-disposal. In other words, the UK had to do it in order to comply with long-standing EU practise which their waste industry was not about to change just because the UK and other nations had joined the common market.

It was again, the Landfill Regulations which were implemented to make the necesary UK changes to comply with the requirements of the Landfill Directive to ban the co-disposal of hazardous and non-hazardous waste from 16 July 2004. Hazardous and non-hazardous wastes have since then be dispatched to mostly separate and appropriately designated sites, possibly with the exception of asbestos waste, which is often disposal to separate haz waste cells at the same landfill site location.

Mono-disposal has ever since been creating hazardous waste time-bombs throughout the UK. However, nobody has shown any concern either at the time or subsequently, which is quite remarkable.

The Regulations also imposed a set of “waste acceptance criteria” (WAC) detailing the types of waste that can be accepted at landfill sites. Most waste, with the exception of municipal waste, now has to meet the WAC.

The Regulations also required hazardous wastes, as identified in the European Waste Catalogue (EWC) to be pre-treated to reduce their quantity and hazardous nature before landfiliing.

The Hazardous Waste Regulations 2004 govern the movement and consignment of hazardous waste from the producer to its final disposal. They replaced the Special Waste Regulations 1996 and introduced new and simpler procedures for hazardous waste, and the Regulations come into force to coincide with the implementation of the waste acceptance criteria.

To complete the picture for you, the producers of waste are subject to a Duty of Care under the Environmental Protection Act 1990 (EPA) to ensure waste does not escape from their control, is only passed to persons authorised to take it, and is accompanied by written descriptions and correctly completed waste transfer notes.

Together with pre-existing legislation relating to fridges, vehicles and batteries, the Regulations effectively made almost every business a hazardous waste producer.

At that time there was a lot of concern that businesses would simply not be able to find enough hazardous waste landfill capacity to dispose of their waste, and people actually suggested that queues would form at the few remaining Hazardous Waste Landfills left holding a licence immediately after implementation of the rules banning co-disposal. If that happened it never hit the press, and since then UK manufacturing factory closures (which were no doubt partly due to the higher cost of hazardous waste disposal to landfill), has resulted in incineration options and recycling by closed-loop waste reprocessing becoming far more common. In combination with the REACH Regulations which make using hazardous materials in products much more difficult to sustain, these measures have and greatly reduced the quantities of hazardous waste generated by UK industry.

In fact, the operators of hazardous waste landfills and hazardous waste incinerators who were investing in these facilities a few years after the co-disposal ban, in the hope of high demand for their void space, and high profits, have been largely disappointed.

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