LAWR

June 2015 Local Authority Waste & Recycling 21 SKILLS & TRAINING ack in 2008, the amended EU Waste Framework Directive introduced the requirement for the provision of the separate collection of paper, plastic, metal and glass. In January just gone, this was implemented through the amended Waste (England & Wales) Regulations 2011; in Scotland and Northern Ireland there were similar amendments published. As ever with new waste regulations, the devil is very much in the detail. In England and Wales, the requirement to provide for separate collection is required where it "is necessary to ensure that waste undergoes recovery operations in accordance with Articles 4 and 13 of the Waste Framework Directive and to facilitate or improve recovery" and also where it "is technically, environmentally and economically practicable". Wrap has, of course, produced guidance to help guide us all through the process of deciding whether separate collection is Teep. This is an important process for local authorities because the additional costs of providing for separate collection can be considerable. It's also further complicated by the fact that once collected 'separately' it is now illegal to then mix these wastes; that is unless it can be demonstrated that the mixing will not impact the potential to facilitate or improve waste recovery – an argument that will be difficult to make under most circumstances. For local authorities, therefore, it is more important than ever to understand the requirements of the duty of care elements relating to separate collection and to the Teep process. Also looming large on the horizon B Amendments to waste collection requirements and the classification of hazardous wastes could prove to be a headache for local authorities. Ken Westlake and Keith Roberts explain what we know so far. Training for regulatory change in 2015 " The Environment Agency is particularly hot on the misclassification of wastes " this month are significant changes to the way that hazardous wastes are classified. This is thanks to the implementation of a 'Globally Harmonised System' for chemicals classification, which replaces controls that have been implemented through the Chemicals (Hazard Information and Packaging for Supply) Regulations. What we know so far is that changes to 'hazardous' threshold levels mean that some non-hazardous wastes will have to be reclassified as hazardous once the new controls are in place. What we don't know is which ones – the government has had other things on its mind recently and is yet to publish any guidance. However, producers of waste – including local authorities – will have to review their assessments and ensure Ken Westlake (left) and Keith Roberts are directors at Waste Training Services. New regulations to collect materials separately are not easy to follow. they are managing their wastes in a legally-compliant manner. This is easier said than done. Both GSH and Teep come with extensive guidance, but it can be difficult to follow and in such cases competency can become a significant issue. Training will be essential. Legal controls under the Duty of Care for wastes require that all waste holders act in a way that is "reasonable in the circumstances" in order to manage their wastes in a legally-compliant manner: for many, this will require evidence – through training, for example – of what they have done to ensure they are law-abiding. At a time when the Environment Agency is particularly hot on the misclassification of wastes (deliberate or otherwise) the need to prove competency has never been greater. Throw in these regulatory changes and it's clear that without proper training, problems could arise.

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