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


Memorandum submitted by British Metals Recycling Association (BRMA)

  In response to the Select Committee's announcement of an inquiry into Hazardous Waste Disposal, this memorandum is submitted by the British Metals Recycling Association (BMRA).

  The BMRA is the trade association for the metal recycling industry in the UK, which has an annual turnover of some £4 billion. The sector plays an important role in the UK economy, employing over 10,000 people and generating significant export revenue, in excess of £2 billion. The BMRA represents some 320 members who, collectively, recycle around ten million tonnes per annum of ferrous and non-ferrous scrap metal into secondary raw materials. The BMRA thanks the Environment, Food and Rural Affairs Committee for the opportunity to submit evidence.

  We recognise the need for waste which is genuinely hazardous to be controlled and disposed of in a proper manner. Our main concern with hazardous waste disposal is to ensure that regulation, when applied, does not become so onerous that established recycling routes for materials which might be nominally classed as hazardous, eg lead, become non-viable. There is a great danger that the classification of materials and products as hazardous, for example by means of their being "starred items" in the European Waste Catalogue (EWC), invokes a whole set of controls and restrictions which had hitherto been considered unnecessary as they were being recycled effectively.

  A classic example is that of End of Life Vehicles (ELVs). From January 2002, undrained ELVs are classified in the EWC as hazardous waste, which means that, in theory, additional controls and documentation will be needed for their collection, transportation and treatment. These will add to the cost of an already expensive process for the depollution of vehicles in accordance with the End of Life Vehicles Directive-also due to be introduced this year. In fact, most ELVs are no more hazardous than a vehicle in current use, and the point at which it suddenly becomes hazardous when somebody decides to dispose of it is hard to comprehend. It is equally confusing that an ELV that is "rescued" from the waste stream by somebody taking remedial action with the vehicle, not its hazardous elements, miraculously becomes non-hazardous again.

  The Committee has indicated its intention, inter alia, to examine the steps taken by the Government to prepare for the implementation of the ELV Directive. In our view, this has been woefully inadequate, partly as a consequence of a desire to exercise a light touch, which meant that it did not want to impose more rigorous measures than other Member States, but predominantly because of a failure to recognise the need for infrastructure developments to be funded, both for investments in facilities and ongoing treatment costs. Even now, we still have no visibility on this, as a result of which there will be serious inadequacies in the infrastructure for some time to come.

  Another example is Electrical and Electronic Waste (WEEE) and white goods in particular. These, too, are being classified as hazardous, and this will impose additional controls and costs on the operators, particularly those in the retail sector, who will find it increasingly difficult to justify continuing their existing collection rounds. Refrigerators which, until December 2001, had been routinely recycled by the metal recycling sector, suddenly became a liability with the imposition of the Ozone Depleting Substances Regulation in January 2002, and huge stockpiles of scrap fridges was the result. Admittedly, this was not because they were hazardous, but it is a clear illustration of what happens when heavy-handed regulation is imposed on an established and effective market.

  We would like to stress that for both Metallic Waste and End of Life Vehicles and, to a lesser extent Waste Electrical Equipment, sophisticated and well-developed infrastructures are already in place, employing a great many people and achieving very high levels of recycling. They exist because their processes are economically viable and the companies involved, many of whom are our members, can make a reasonable return on their efforts and investments. If those returns, which are not by any means great, are diminished by the imposition of excessive controls and compliance costs, businesses may well decide that continuing with their recycling is not a worthwhile option.

  In conclusion, we would urge the Committee to consider the potential negative consequences of gold-plating any legislation on Hazardous Waste Disposal to the extent that established routes for recycling these materials or products are destroyed, because it is easier and cheaper to consign them to landfill.

  If Committee members require any further information, representatives of the BMRA would very much welcome the opportunity to explain and expand upon these views in more detail at the Committee's convenience.

British Metals Recycling Association

27 May 2002

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