The Environment Agency (EA) has launched a new consultation involving a new standard permit for small scale ELV recycling and a new standard rule for small scale metal recycling. In this consultation, the EA has taken a new approach with these rules sets by including a Fire Prevention Plan (FPP) within the standard rules.
This consultation concerns two new standard rules permits that will allow operators to store and treat up to 5,000 tonnes of ferrous and non-ferrous metals each year, and operate a vehicle storage, depollution and dismantling facility for up to 10 end-of-life vehicles per week.
The new standard rules permits are for small scale operators and include an FPP to ensure operators comply with the EA’s fire prevention plan guidance.
In 2018, the Department for Environment, Food and Rural Affairs (Defra) and the Welsh Government carried out a public consultation ‘Reducing crime at sites handling waste, and introducing fixed penalties for waste duty of care’. They proposed making substantial changes to the waste exemptions regime, including changes to exemptions T9 (recovering scrap metal) and U16 (using depolluted end-of-life vehicles for parts).
Although the outcome of the consultation has not yet been published, the aim of introducing these new standard rules is to help operators if they are required to transition from these exemptions into environmental permitting.
The new standard rules permits are supported by generic risk assessments produced to ensure that risks to the environment and human health are kept to a minimum.
The EA want your views on whether the proposed two new standard rules permits, fire prevention plans, and generic risk assessments are appropriate to manage the risks of the permitted activities.
The fire prevention plan is included with each rule set. The objectives set out in their FPP guidance are to minimise the likelihood of a fire, aim for a fire to be extinguished within 4 hours, and minimise fire spread within the site and to neighbouring sites.
The standard rules require the activities to be carried out in accordance with the fire prevention plan. Failing to comply with the requirements of the fire prevention plan will breach the permit conditions.
If an operator cannot fully comply with the fire prevention plan or the activities or waste types change, they must vary their permit. They will need to submit a site-specific fire prevention plan as part of their application to vary their permit.
Below is a summary of the proposed rules being consulted on, and they do not replace any other standard rules currently in place.
Small end-of-life vehicle depollution and dismantling facility (less than 750 tonnes) with associated fire prevention plan (SR 2021 No.12) will allow the operator to:
- operate a vehicle storage, depollution and dismantling facility that stores no more than 10 end-of-life vehicles at any one time and accepts less than 750 tonnes of end-of-life vehicles a year
- depollute end-of-life vehicles and sort, separate, grade or cut waste into different components for recovery
- operate a vehicle storage, depollution and dismantling facility in accordance with the fire prevention plan in schedule 3
Small metal recycling facility (less than 5,000 tonnes) with associated fire prevention plan (SR 2021 No.11) will allow the operator to:
- operate a metal recycling facility that accepts no more than 5,000 tonnes of specified ferrous and non-ferrous wastes per year – the combined storage limit of wastes stored on the site at any one time is limited to 100 tonnes
- sort, separate, grade, manual feed, cut (using hand-held equipment only), shear, bale and compact
- operate a metal recycling facility in line with the fire prevention plan in schedule 3
The consultation is open from 28th June 2021 to 20th September 2021.
Click here to submit your views on the proposed two new standard rules permits and their associated fire prevention plans and generic risk assessments in an online survey.