The British Metals Recycling Association (BMRA) provided an update regarding the Metal Shredder Residue (MSR) project they have developed and will be running.
In 2005, the Environment Agency (EA) and Scottish Environmental Protection Agency (SEPA) stated that metal shredder residues (MSR) produced during the processing of non-hazardous waste, including fully de-polluted end-of-life vehicles (ELV), could be classified as ‘non-hazardous’. Since then, based on this regulatory position statement (RPS), operators have not routinely characterised their MSR.
However, this position is set to change. In 2015, the EA announced its intention to review the RPS, citing three reasons:
- The composition of shredder feedstock has changed significantly since 2005;
- The RPS only covers depolluted ELVs and other non-hazardous metal wastes. However, it has been misapplied by some operators to include residues from WEEE shredders;
- MSR is increasingly being diverted from landfill as new disposal and recovery techniques are developed.
Additionally, new waste classification guidance (WM3) was published in June 2015. This increased the number of compounds to be considered and uses the assumed ‘worst case’ compounds in the waste classification. At the same time, the European Union legislation governing waste classification also made amendments to the List of Wastes and hazardous waste criteria, lowering thresholds for ecotoxic metals and adding the requirement to assess for persistent organic pollutants (POPs).
After a delay to its review, in mid-2016 the EA informed the BMRA it would be gathering evidence on the issues that could arise if the RPS was repealed and if some or all MSR became classified as ‘hazardous waste’ under WM3.
Pilot study
Pre-empting this call for evidence, in 2017, the BMRA together with shredder operator representatives and waste expert consultancy, WRc, developed a sampling strategy and methodology to characterise MSR at a national level.
A pilot study was commissioned to test the methodology’s robustness, and a representative sample of mixed MSR was collected from a nominated facility. The study used techniques such as hazardous property (HP) assessments (via sequential extraction, analysis by X-ray fluorescence (XRF) and compositional sorting) and bioavailability testing on algae and water fleas. The overall results of the study classified the sample as ‘non-hazardous’ waste, with a List of Wastes code 19 10 04.
Proposal to run a national MSR study
Having completed the pilot study, meetings with EA colleagues were convened throughout 2018 in order to:
- obtain their endorsement of the sampling strategy and characterisation methodology to enable a national HP assessment of MSR;
- agree the number of samples and/or shredder installations required for testing;
- agree a timeline to complete this work, ahead of any changes to the RPS (or its withdrawal).
Having refined the methodology and analytical testing process, in August 2019 the EA endorsed the project. (SEPA offered its broad agreement of the project’s aims and objectives in January 2020.)
The ambitious project will test the MSR arising from 12 representative installations, over a six-month sampling and testing period. The aim is to provide a national HP assessment to hopefully demonstrate that MSR is ‘non-hazardous’ for the purposes of waste classification across the United Kingdom and the Republic of Ireland.
If this can be demonstrated, the BMRA will lobby the EA, SEPA, Natural Resources Wales, Northern Ireland Environment Agency and the Irish EPA to either:
- update and amend the current RPS to enable the continued disposal of MSR at non-hazardous landfills or facilitate the movement of MSR destined for other disposal and/or recovery operations, or
- produce a new position statement (or comparable agreement) that recognises the non-hazardous status of MSR for the purposes outlined above.
Given the expected variability in the composition of MSR, it is extremely unlikely that the current RPS will be extended (option a). However, a new position statement (or comparable agreement) may be feasible (option b), in which case the BMRA would endeavour to ensure that any testing requirements of this material are risk-based and proportionate.
However, if the study indicates some residues are to be classified as ‘hazardous waste’, the BMRA will work with those agencies to achieve workable transitional arrangements to minimise any impact on operations.
Funding of a national study
The BMRA, the EA and SEPA believe a collaborative approach to characterising MSR at the national level is preferable to individual companies making their own assessments.
All actors in the metals recycling and ELV sectors stand to benefit from a ‘non-hazardous’ designation for a number of reasons. Firstly, they won’t need to obtain hazardous waste authorisations thereby avoiding potential planning issues. Instead, they will be able to maintain existing permits.
Secondly, it could, potentially, reduce the frequency of waste classification assessments for MSR (depending on infeed materials) and remove certain parameters from testing. While BAT-AEL emissions monitoring under the Industrial Emissions Directive would still be required, the results from the proposed study could also be used to lobby for reduced IED monitoring frequencies or parameters tested.
Finally, not only will it ensure appropriate disposal/recovery options remain unrestricted but it could also lead to significant cost savings for operators.
The BMRA contributed £45,000 to meet the costs of the pilot study. It also funded an additional £25,000-study to demonstrate that depolluted ELVs, a significant shredder infeed material, are unlikely to contain elevated levels of antinomy trioxide in flame retardant plastics, which could affect future depollution criteria or waste classification.
Despite the difficult trading environment of the past six months, recognising the potential impact of a hazardous designation, the BMRA’s members raised over £370,000 to fund the costs of completing a national MSR HP assessment.
Next steps
While the BMRA has appointed WRc to carry-out the project and the test sites agreed, the move to roll out training across these sites and start testing has been put on hold due to the coronavirus pandemic. Once business has returned to normal, we will progress with the study. In the meantime, if you want to know more about any aspect of this critically important project, please contact Howard for more information.
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