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For over a decade metal recyclers have been fighting to declassify metal as waste and now they are closer than ever to achieve their goal. In April and agreement was reached with the European Commission and yesterday (October 27) the Environment Agency published the regulatory guidance for scrap metal to cease to be waste.
Despite achieving their objective metal recyclers are concerned about the requirements and declassification system determined by the “Regulatory Guidance 333/2011”. Some say that instead of creating a straight forward system to declassify scrap metal as waste, the Agency is bringing in a potentially burdensome classification system.
According EA’s regulations scrap iron, steel and aluminium cease to be waste when they have undergone treatment and meet the requirements laid down in the regulations:
1. The waste inputs to the metals recovery process must comply with technical criteria in the regulations
2. The waste input must be treated in accordance with the criteria in the regulations.
3. The output must comply with the criteria set out in the regulations.
4. The producer of the output must issue a statement of conformity for each consignment of material which has met the relevant criteria. This must be passed on to the next holder of the material with the producer keeping a copy for a minimum of one year.
5. The producer must implement a quality management system (QMS) which complies with the regulations. If any part of the treatment process has been carried out by a prior holder of the metal, that prior holder must also implement a QMS.
6. The QMS must be verified every three years by an independent outside body that has been accredited by the UK Accreditation Service (UKAS).
7. The QMS and statement of conformity must be available for inspection by the Environment Agency on request.
Accreditation
Right now there is no accreditation scheme in place and according to the EA’s guidance UKAS and business sectors will need to work together to develop an accreditation scheme and rules for the operation of the verification process.
The Environment Agency commits itself to facilitate this process and stated that none of the numerous accreditation bodies in the UK is yet accredited to assess the QMS of waste processes.
The British Metals Recycling Association has not commented in detail on the new Regulatory Guidance but a spokesman speaking to letsrecycle.com earlier this week said: “At the moment it’s taken a bit longer than hoped for the Environment Agency guidance to come but they’re in the process of refining it at the moment and it’ll come.”
Further Information:
A summary of the Regulatory Guidance can download at http://publications.environment-agency.gov.uk/PDF/GEHO1011BUIW-E-E.pdf.
The full text of the regulations can be found at http://www.environment-agency.gov.uk/business/regulation/129311.aspx and you should consult them.
British Metals Recycling Association - http://www.recyclemetals.org/
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