Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Memorandum submitted by Shanks Group plc


  There is a clear need for a new national framework for the management of hazardous waste. The framework should focus more on the producer of waste (including households) and should prohibit environmentally unacceptable treatment methods. Increased costs should be managed through producer responsibility which will discourage the production of hazardous waste.

  The period 2004-08 represents an environmentally unsustainable period for the landfill of hazardous waste due to poorly defined acceptance criteria. The acceptance criteria for this period must be reassessed and published in sufficient time.

  The Committee should not listen to "prophecies of doom" regarding the availability of, and capacity for, alternative treatment technologies. Hazardous waste treatment capacity has seriously declined in recent years as the regulatory framework has not generated demand. Shanks, in common with other industry participants, successfully operates alternative treatment technologies on the continent. The technologies and the readiness to invest are here. It is not too late (although very nearly) to ensure the legislative and regulatory framework provides the climate for action on our sustainable future.


  Shanks Group plc is one of the UK's largest waste management companies and, with its operations in Belgium and The Netherlands, is also a leading independent player in the European market. Beyond Europe, Shanks is also active through its environmental remediation services. As a Group, Shanks employs over 4,500 people, based at more than 120 sites and involved in 200 operations.

  The Group provides an extensive range of waste management services and handles a wide variety of wastes, including domestic refuse, commercial waste, contaminated spoils and hazardous waste. Operations range from collections, domestic and commercial waste recycling, thermal treatment systems, industrial cleaning and special waste treatment, to high temperature incineration and modern landfill. Shanks is one of the largest generators of electricity from landfill gas and produces a range of fuel-from-waste products.

  Within the UK, a wide range of activities processing an annual total of approximately 150,000 tonnes of hazardous waste is carried out by the Shanks Chemical Services division.

  The inquiry is welcome and it is timely as the UK waste management industry is at the threshold of the largest single legislative and regulatory upheaval in its history.


  The hazardous waste processing industry has little natural demand. History has proven that whilst hazardous waste is allowed to be managed indiscriminately, no environmentally sustainable treatment capacity can survive economically. All significant demand, therefore, accrues from informed legislation and its effective enforcement.

  In 1989 the then HoC Environment Committee observed in their report on Toxic Waste: (Footnote1) "Never in any of our enquiries into environmental problems have we experienced such consistent and universal criticism of existing legislation and of central and local government as we have during the course of this inquiry."

  Since 1989 there have been some improvements in the regulatory system, most notably the establishment in 1996 of the Environment Agency. Significant weaknesses still remain, especially:

  The focus of regulatory action is on the waste processor not the waste producer.

  ie The system has been good at ensuring hazardous waste processing facilities are to the requisite standard but lamentable at ensuring their use. Processing plants have received significant and ultimately fruitless investment whilst too much hazardous waste has been allowed to landfill. (See Appendix 2: Case Study—Pontypool High Temperature Incinerator.)


    —  There must be a national hazardous waste plan which prohibits inappropriate treatment for hazardous wastes.

  This action plan should not prescribe particular treatments but proscribe unacceptable options. In this way sustainability is achieved without stifling innovation and competition.


  Current landfill practice relies upon the co-disposal technique to reduce waste (both hazardous and non-hazardous) to an inert state over time, say within a generation. From 2008 the expected regime for hazardous waste will require its treatment to Final Storage Quality (FSQ) prior to the landfill. Using this regime unmanageable environmentally damaging processes will not occur in the landfill post the deposit of waste. However, a significant problem will arise in the 2004-08 period. From 2004 co-disposal is outlawed but until 2008 hazardous waste will not be required to be treated to FSQ.

  There is a significant risk therefore that hazardous waste landfills used in 2004-08 will never be environmentally benign.

  Consequently, it is unlikely that the private sector will be prepared to operate in this regime for fear of future liabilities.

  Fiscal measures could be utilised to accelerate the provision of facilities to treat hazardous waste to FSQ. During the period prior to 2008, a higher rate of Landfill Tax, for example, could be introduced specifically for hazardous waste which does not meet the acceptance criteria as agreed by the Technical Adaptation Committee (TAC).


    —  The deadline to pretreat hazardous waste to FSQ should be brought forward to 2004 (preferable) or the end of co-disposal delayed until 2008.

    —  A new fiscal measure to encourage the earlier provision and use of new treatment facilities for hazardous waste should be announced prior to 2004.


  The Landfill Directive has significant impacts for the future management of all categories of waste. Currently, the co-disposal technique is often relied upon to reduce household hazardous waste to an environmentally benign state. Post 2004 co-disposal is outlawed, therefore household hazardous waste should be separately collected.


    —  Systems for the separate collection of household hazardous waste should be put in place.

Shanks Group plc

17 May 2002

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