Solving waste disposal problems-A Comparative
The regulatory regime in the UK prohibits the
cement industry responding rapidly as new wastes, possibly ones
that are a problem for the country to dispose of, become available.
An anecdote best illustrates this point:
In 1999, a proportion of Belgium's
livestock population was contaminated with PCBs. To protect the
health of the consumers, the government ordered the destruction
of all contaminated meat and derived products. As there was insufficient
incineration capacity to achieve this, the government ruled that
three cement works should use the material as fuel. In the four
months at the end of that year, 7,500 tonnes of powders and 10,000
tonnes of fats were used at the factories.
In 2001 at the time of the Foot and
Mouth outbreak carcasses were being incinerated at low temperatures
in open pits with no environmental controls and high levels of
dioxins being emitted. The UK cement industry offered to incinerate
the carcasses in cement kilns and recover energy from them. The
industry was told it could only burn the carcasses if it did not
make cement at the same time. To use the carcasses as a fuel would
require the full application of the SFP. Carcasses continued to
be incinerated in the open at huge environmental expense.
LCUK embraces the need for full engagement with
the stakeholders in its business in order to maintain and preserve
its licence to operate. This is particularly important during
the introduction of new processes, materials or fuels. The systematic
approach the company takes to this in general and specifically
when introducing new fuels is summarised in Annex 1.
LCUK's vision for the UK cement industry is
based on the sustainable provision of an essential product to
develop and enhance the built environment at minimum impact to
the physical and social environment.
LCUK urges the Committee to consider initiating
a full review of the regulatory framework governing the use of
waste derived material in cement manufacturing; the cement industry's
potential to contribute to not only the solutions to hazardous
waste disposal but also a wide range of other wastes; and to ensure
that best environmental options are adopted in the use of hazardous
and non-hazardous wastes.
LCUK requests the Committee to consider that
any new regulatory system governing the use of waste derived materials
in the cement manufacturing process should reflect:
European best practice in terms of
permitting processes, without loss of environmental rigour;
The extensive knowledge and experience
gained in the UK and the rest of Europe in the use of waste derived
material since the Committee last looked at this issue; and
The UK cement industry's public commitment
to earning and retaining its 'licence to operate' through its
environmental performance and its stakeholder engagement activities.
The competitive position of the UK
cement industry that can work to maximise environmental additionality.
Lafarge invites the Committee to visit one or
more of its mainland European plants to see and hear more about
the use of hazardous and non-hazardous waste in the cement manufacturing
Lafarge would be happy to present oral evidence
to the Committee in terms of UK and European comparisons.
Lafarge Cement UK
17 May 2002