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What is Green List waste? A regulator’s perspective

What is Green List waste? A regulator’s perspective. Allison Townley Senior Scientific Officer, Northern Ireland Environment Agency. What is Green List waste?. Policy priorities What the law says Green List is Green List from co-mingled collections Regulatory approach.

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What is Green List waste? A regulator’s perspective

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  1. What is Green List waste?A regulator’s perspective Allison Townley Senior Scientific Officer, Northern Ireland Environment Agency

  2. What is Green List waste? • Policy priorities • What the law says Green List is • Green List from co-mingled collections • Regulatory approach

  3. Getting to compliant waste exports • The right type of waste • At the right quality • To the right country • For the right type of ESM recovery • In compliance with the applicable control system

  4. What is Green List waste? • The legal answer: • Annex III to WSR • List of wastes subject to the general information requirements laid down in article 18 • Origin? • OECD decision Appendix 3 – “GX123” codes • Annex IX Basel Convention – “B1234” codes

  5. What isn’t Green List waste? • Any waste that isn’t listed in the Green List • Any waste listed in any other Annex to the WSR • Y46 waste collected from households - unless appropriately classified under a single entry in Annex III • Mixtures of waste – even if all Green List components • “Contaminated” Annex III waste • If it isn’t Green List export it is either: • Prohibited, or • Subject to notification controls

  6. Mixtures of Green List waste • WSR – does not follow OECD • Notification unless listed in WSR Annex IIIA • Annex IIIA – currently empty • Annex IIIA to non-OECD? Notification pending further “write round” and revised Green List regulation

  7. Contaminated with other material to the extent: • Increases the risks associated with the wastes sufficiently to render them appropriate for submission to the procedure of prior written notification and consent, when taking into account the hazardous characteristics listed in Annex III to Directive 91/689/EEC Or • Prevents the recovery of the wastes in an environmentally sound manner

  8. Material outputs from MRFs destined for export • Co-mingled household waste input must be: • “properly sorted” • And therefore is not: • Y46 waste collected from households - unless appropriately classified under a single entry in Annex III, or • A mixture of wastes; or • Excessively contaminated

  9. Key Annex III entries • B3010 - Solid plastic waste: • The following: • Plastic or mixed plastic materials, provided they are not mixed with other wastes and are prepared to a specification. B3020 - Paper, paperboard and paper product wastes The following materials, provided they are not mixed with hazardous wastes: • Waste and scrap of paper or paperboard.

  10. Key Annex III entries • B2020 - Glass waste in non-dispersible • form: • Cullet and other waste and scrap of glass except for glass from cathode-ray tubes and other activated glasses

  11. Properly sorted?

  12. The regulatory challenge • Rapidly increasing trade • 5000 exports per annum • Port inspections • Must get it right at the MRF • Upstream regulation is key

  13. MRF audits • 12+ MRF audited • Approx 2/3 good or OK • Approx 1/3 cause for concern • Marginal or poor quality output • Poor record keeping • Don’t know where output goes

  14. MRF as quality material manufacturer • Can operators demonstrate: • Outputs are consistent? • They know what the contaminants are? • The waste has been “properly sorted”? • A documented audit trail to demonstrate consistent outputs of known parameters? • Where the material goes and how it’s used?

  15. If we don’t get it right? No public confidence No end user confidence Miss recycling recovery diversion targets Infraction Additional legislation

  16. More information? • http://www.ni-environment.gov.uk/waste/regulation-and-legislation/transfrontier_shipment_of_waste.htm

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