| (a) | This delay [ in determining the Waste Acceptance Criteria] should not have occurred (paragraph 18).
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| (b) | We are concerned that landfill operators are required to make crucial decisions about the future designations of their sites without the Waste Acceptance Criteria having been agreed. We can only reiterate our previous recommendation, made in relation to the disposal of refrigerators, that in cases such as this, which require radical changes in the practices of an important industry, any new item of European legislation should not be agreed until all the practical implications of implementation are well-understood (paragraph 21).
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| (c) | We recommend that the Minister takes this discussion forward and instigates a thorough review of the process by which environmental legislation is arrived at in the European Commission (paragraph 22).
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| (d) | When fundamental aspects of legislation are left to be developed after a Directive is signed, as in this case, we urge the Government to lobby vigorously for the implementation date of the Directive to be tied to the date when all the criteria are finalised and not to the date on which the Directive was agreed (paragraph 23).
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| (e) | The Environment agency and DEFRA must work with the waste management industry to provide timely high-quality data on the amount of hazardous waste produced each year and to develop management methods to assist in planning for future capacity (paragraph 24).
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| (f) | the lessons learned from the fridge crisis also apply here and, as the Government suggested then, it remains up to the Government "to create a policy framework that stimulates innovative and market-led solutions". (Paragraph 29).
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| (g) | This needs to be provided well before implementation dates and part of this policy framework must include ensuring sufficient regulatory certainty to encourage waste management companies to invest at an appropriate time (paragraph 29).
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| (h) | We recommend that the Performance and Innovation Unit consider the issues surrounding the provision of new hazardous waste management facilities in the light of the Government's aim to move waste up the waste hierarchy and adhere to the principles of proximity of disposal and self-sufficiency in waste management (paragraph 33).
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| (i) | The Government should clarify its position on the specific role of incineration in the disposal of hazardous waste (paragraph 34).
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| (j) | we recommend that the Government takes the utmost care to ensure that such consultations occur as early as possible, are of the right kind and are at the right level (paragraph 41).
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| (k) | It is vital that stakeholders are adequately consulted while the Directive is being developed and negotiated as well as when it is implemented into United Kingdom law. The consultations should be tailored to the role of those being consulted. For example, the basic implications for waste producers and local government should not be lost in a mass of technical data. Finally it seems clear to us that if private industries are to provide the solutions to waste management problems, they should be involved in the development of any strategy to achieve such solutions (paragraph 42).
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| (l) | We therefore recommend that, as a matter of urgency, the Government re-examines the funding available to the Environment Agency and ensures that it can adequately enforce legislation and prevent and respond to illegal disposal (paragraph 46).
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| (m) | We recommend as a matter of urgency that the Government formally assesses the risks posed by the landfill of hazardous waste between the date that the ban on co-disposal comes into force and the introduction of the Waste Acceptance Criteria. If, as the Environmental Services Association believes, these risks are unacceptable, contingency plans should be made for that period (paragraph 55).
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| (n) | It is the Committee's view that there should be a diversity of management options for hazardous waste and that high temperature incineration is part of this. The continued existence of such a diversity is called into question by the lack of demand for high temperature incineration for high calorific value wastes. We recommend that if the Government wishes to sustain diversity in this sector, it must recognise the problems faced by high temperature incinerators and should look again at the equivalency of use of high calorific values wastes as fuel in high temperature incineration and cement kilns (paragraph 60).
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| (o) | The Committee believes that the primary consideration in allowing waste to be incinerated should be the overall environmental impact of doing so. It remains for the Environment Agency to decide how best to ensure that the environmental impact of waste management is minimised within the current regulatory regime (paragraph 63).
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| (p) | We urge the Government and the PIU to address ways of better informing the public about hazardous waste management issues and addressing their concerns (paragraph 72).
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| (q) | We recommend that the Government consider how waste streams occurring at a domestic level should be handled, particularly in the context of the Waste from Electrical and Electronic Equipment (WEEE) Directive and the End of Life Vehicles Directive where new streams of waste are emerging (paragraph 79).
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| (r) | The Government must make clear what specific targets, if any, it has set for hazardous waste reduction and what positive steps it has taken to achieve those targets (paragraph 81).
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| (s) | While we do not believe there is a need for a formal strategic plan, we recommend that the Government should produce a framework paper that draws together, in a single document, the issues that must be addressed for hazardous waste management. This should outline:
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the demands on industry;
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targets for hazardous waste reduction and recovery;
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how the uncertainties discussed in this report can be resolved; and
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how the Government is looking ahead (paragraph 83.(d)).
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| (t) |
to the implementation of forthcoming EC Directives to guard against the delays and confusion that have so far attended the implementation of the Landfill Directive (paragraph 83.(d)).
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| (u) |
The Government should encourage the development of a national hazardous waste forum to address the issues outlined in the framework document. The forum must involve waste producers, the waste management industry, the regulators and local government and should take care to have regard for the public's view of waste management.
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| (Paragraph 84). |
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| (v) |
What is clear is that the Government and industry must form a partnership for the management of hazardous waste to ensure that, in 2004 and beyond, we have an adequate and environmentally appropriate hazardous waste management infrastructure (paragraph 85).
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