Evaluating if a site requires single collections – applying the TEEP test.

Introduction – OCS WasteLine Part of OCS Group UK Ltd; Provision of cleaning, security, horticulture, catering and facilities management; OCS WasteLine provide waste management services to the OCS business – internal & external clients; OCS WasteLine is a waste brokerage service.

Overview of Presentation Summary of legislation; What does this mean?; External guidance; Act now – the plan; Waste Decision Worksheet; Suggestions to prepare; The unknowns.

Summary of the legislation The Waste (England & Wales) Regulations 2011 came into force on the 28 th March 2011; Regulation 13 stated: ‘An establishment or undertaking which collects waste paper, metal, plastic or glass must, from 1st January 2015, take all such measures to ensure separate collection of that waste as are available to the establishment or undertaking…’

Summary of the legislation Any one arranging the collection or carrying out the collection of waste material that will contain paper/cardboard, metal, plastic or glass must do so as separate collections from the 1 st January 2015; The 2011 regulations stated that comingled was a form of single collection.

Summary of the legislation The Regulations were then amended in 2012 to better reflect the revised Waste Framework Directive; The statement that comingled was a form of single collection was removed and replaced by:

Summary of the legislation ‘…every waste collection authority must, when making arrangements for the collection of waste paper, metal, plastic or glass, ensure that those arrangements are by way of separate collection. The duties in this regulation apply where separate collection – 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 is technically, environmentally and economically practicable.’

Summary of the legislation Article 4 – is the application of the Waste Hierarchy; Article 13 – requires necessary measures to ensure the protection of human health & the environment, from waste management practices.

What does this mean? Anyone who generates the four key materials must have them separately collected from the 1 st January 2015……..unless; It is proven that single collections are not necessary to aid the recovery, quality & quantity of recyclable material, and/or; Single collections are not Technically, Environmentally & Economically Practicable.

What does this mean? As OCS WasteLine arranges the collection of waste – we are responsible for making sure our clients are compliant; Each client and their sites need to be assessed to understand if single or comingled should be implemented; Evidence is key to demonstrating our choice.

External Guidance Defra have not yet produced any guidance on how Regulation 13 should be applied; WRAP stepped in to help the Public Sector and produced the ‘Waste Regulations Route Map’; The Route Map is an in-depth guidance on how to apply the Necessity and the TEEP Test; Act now or wait for further guidance?

Act Now – The Plan OCS WasteLine have decided to act now but adapt to any further guidance or regulations; A worksheet has been designed to capture the evidence to support why single or comingled has been applied; The worksheet was influenced by the techniques used in the Waste Regulations Route Map.

Act Now – The Plan The worksheet is currently being trialled by our Account Managers (AM); AM’s will select a couple of their clients and their associated sites; The worksheets will be completed and feedback obtained; Trial will run from the 25 th August – 26 th September.

Waste Decision Worksheet AM, client and site details; Summarise current service against the WH; Current cost of services to the client; The Necessity Test will always pass – based on the information required to disprove if the Necessity Test fails.

Waste Decision Worksheet Next step is to ascertain if single collections are Technically, Environmentally & Economically Practicable; Or what is known as applying the TEEP test; The Waste Regulations Route Map state that if either one of those tests fail, then single collections are not practical.

Waste Decision Worksheet Technically Practicable? -Can suppliers be sourced to collect separate waste streams? -Has the client got space to store separate bins internally and externally; -Is there a resource to extract the four key materials into separate external bins at the client site?

Waste Decision Worksheet Environmentally Practicable? Calculating the total carbon footprint for the treatment method for comingled and for the single waste streams; Calculating the total carbon footprint for the total distance travelled for comingled and single waste streams over a 12 month period; Total both footprints and evaluate which has the higher value.

Waste Decision Worksheet Economically Practicable? Ascertain the cost to the client for a comingled service and setting up single waste collections; Include any additional costs such as the implementation of new bins; Evaluate the cost difference between comingled and single waste collections.

Waste Decision Worksheet All of the data and calculations will be recorded on the worksheet; If any of the three tests fail, the client will continue to receive comingled collections. The client will receive a copy of the worksheet for evidence.

Waste Decision Worksheet Evaluate feedback from the AM’s and the information captured; Make any necessary amendments to the worksheets before the end of September. All worksheets to be completed for every site serviced by OCS WasteLine before the 31 st December 2014.

Suggestions to Prepare Ascertain if you generate any of those four key materials; Are they separately collected or captured as part of a comingled service; Request that your waste management contractor provides you with evidence to support comingled collections; Make sure that this is in place before the 1 st January 2015.

The Unknowns Will there be an exact requirement of how TEEP should be applied? Who will be inspected – the waste producer and/or the waste collection establishment? How will these inspections take place and what exactly will be required for as evidence? Will there be any further guidance from the Government?

Thank you Any questions?