MRF Code of Practice Must be Mandatory - Unanimous Verdict?

The UK's recycling industry has welcomed the Defra's consultation on a Code of Practice for MRFs, and has called for it to be mandatory.

The UK's waste and recycling industry has welcomed the government's Department for Environment Food & Rural Affairs' (Defra) consultation on a Code of Practice for Material Recycling Facilities (MRFs), and has called for it to be mandatory.

Defra's aim is to introduce a Code of Practice for England and Wales for MRFs over a given size to measure the quality of materials coming into and going out of the facility – making the market more transparent.
Responding to the consultation the Chartered Institution of Wastes Management (CIWM) said that it is strongly in favour of the Code being mandatory, and called for the greatest possible degree of transparency of information while still protecting operators’ commercial confidentiality needs.

However, Steve Lee, chief executive of the CIWM also called for more robust sampling and analysis requirements, as well as audit and enforcement frameworks to be put forward.

“In the case of sampling and analysis, we want consistently good MRF operation to be recognised through regulatory relief for the operator, including a reduced future sample frequency or a link to the regulator’s compliance assessment scheme," he explained.

According to Lee, for audits, unannounced visits by the regulators, possibly linked to permit compliance inspections, would be the minimum requirement. As for enforcement, the CIWM called for a robust scheme, ideally with quality of recyclates checked more at the MRF than at the dockside.  
“While CIWM acknowledges that minimum output standards or quality thresholds may not be appropriate or workable, it is essential that the sampling, analysis and reporting regime is robust and representative to ensure that this Code helps to deliver both improved quality and confidence,” urged Lee.

Common ground

Echoing this sentiment, in the response it submitted to the consultation the Resource Association - a trade association for the reprocessing and recycling industries - welcomed the proposals and commend the desire to make the Code mandatory and also called for more robust auditing and enforcement.

According to the association greater intensity in the proposed sampling regime is needed, both in terms of sample size and frequency, with the proposed sample sizes for input and paper are particularly low and need to be increased fourfold.

The organisation also noted the absence of guidance on sampling methodology, which it said needs to be addressed urgently by Defra.

Full transparency of MRF data to aid market intelligence as indicated by Defra was also welcomed by the association, which sees this as essential if Defra’s desired aim of improved market intelligence to aid reprocessors in understanding the outputs of MRFs is to be achieved.

“In principle, we will be happy to respond to any reasonable requirement to publish data such as yield rates, if this is seen to assist in full understanding of the supply chain," commented Ray Georgeson, chief executive of the Resource Association.

"In the same spirit, I look forward to the waste industry operators that have called for this responding by completing the necessary supply chain transparency and supporting our calls for full transparency of the end destination of recycling,” he added.

Wider supply chain

In addition to welcoming the proposals, and urging for tougher enforcement, tighter sampling and for the Code to be mandatory, the Environmental Services Association (ESA) also noted that MRFs are but one part of the supply chain and that all stakeholders need to take responsibility for ensuring a high quality of recyclates.

According to the organisation plans to publish sampling data must be extended to reprocessors: If detailed sampling data is to be published at MRF level, then to get a full picture of the recycling chain comparable data should also be published by reprocessors.

The ESA response also called for:

• The scope of the regulations to be extended, so that MRFs below 1000 tonne throughput and facilities sorting single stream materials are also covered

• The enforcement regime to be risk-based, and for any additional permit / audit costs to be no more than the costs of being part of the ESA RRS scheme

• The requirement for compulsory sampling of the residual stream to be dropped, as this is not necessary for the objectives of the scheme.

“ESA wants to see high standards across the MRF sector, and for all MRFs to play their part in a recycling chain which in the coming years must both collect more recyclable material and ensure recyclate is fit for purpose," commented Matthew Farrow, director of policy at the ESA.

"That is why we developed the concept of a MRF Code of Practice and campaigned for it to be made a mandatory requirement for all MRFs," he added.

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