Management of Hazardous Waste – using the waste hierarchy to encourage recycling and recovery, and reducing reliance on landfill.

While many contributors to AWE International are scientists and laboratory professionals, this edition we’ve consulted Defra’s input with regard to the management of hazardous waste.

The Department for Environment, Food and Rural Affairs published a fulsome policy document in March 2010, all of which you can refer to here:

Given the industrial emphasis that’s of interest to our readers, however, we’re focusing on government strategies for hazardous waste management within this context, specifically.

What is hazardous waste?

Hazardous waste is waste that may cause particular harm to human health or the environment. Such wastes contain one or more hazardous properties. The European Commission defines hazardous wastes, currently asterisked in the European Waste List (Commission Decision 2000/532/EC). The list is subject to periodic review by the European Commission.

Some everyday items such as computer monitors, TVs, refrigeration equipment and some batteries may be hazardous waste as well as more obvious materials such as asbestos and oil. Hazardous waste, therefore, comes from a wide range of sources, including households, businesses of all types, and public services, such as the health service, schools and universities.

Why do we need a strategy?

Some 6.2 million tonnes of hazardous waste arose in England in 2008 – see Annex One for more details, while capacity needs for treatment and disposal are outlined in Annex Two.

Discussion with the Environment Agency and the waste sector in 2008 and 2009 showed a clear need to steer waste producers and waste managers on the appropriate treatment for certain hazardous waste streams – especially those traditionally landfilled before the Landfill Directive (1999/31/EC) provisions came into force, such as oil and solvent contaminated waste residues, contaminated soils, air pollution control residues, acids and sludges.

It is recognised that investments in new treatment technologies require some certainty that the facilities will be used, and although in recent years there has been investment in above ground treatment systems, more may be possible with greater certainty of use. Furthermore, waste producers and waste managers have not always sought to push waste up the hierarchy – even where ultimately this can lead to cost savings such as in the prevention of hazardous waste, or in gaining value from recovered material. This is particularly important in the current economic situation.

The Strategy for hazardous waste management in England complements Defra’s approach to commercial and industrial waste more generally. It does not, however, cover waste classified as radioactive waste under the Radioactive Substances Act 1993, as this is dealt with separately by the RSA and Managing Radioactive Waste Safely MRWS programme.

The strategy is broken down into six important areas.

1. The Waste Hierarchy

A hierarchy in line with the Waste Framework Directive (2008/98/EC) has been devised and includes:

a. Prevention b. Preparing for re-use c. Recycling d. Other recovery, e.g. energy recovery and e. Disposal

Where the production of hazardous waste cannot be prevented, opportunities for recycling and recovery should be fully investigated with disposal being the last option for consideration.

Landfill is the disposal option of last resort, and is at the bottom of the hierarchy. Deep underground storage of hazardous waste which is also a disposal operation, and is permitted in the UK as a landfill operation, is an option for certain difficult-to-manage hazardous waste streams such as metallic mercury4 (where permitted), or air pollution control residues.

High temperature incineration without energy recovery is also a disposal operation, but may be a better treatment option than landfill for certain intractable waste streams. Energy recovery as either a waste recovery operation or a waste disposal operation should be of a higher priority order than either disposal by incineration without energy recovery or landfill.

Where prevention refers to the reduction of harmful substances, it is only applicable to materials and products other than waste.

2. Infrastructure Provision

Defra has looked to the market for the development of its hazardous waste infrastructure, which implements the hierarchy for the management of hazardous waste and meets the needs of the UK to ensure that the country as a whole is self sufficient in hazardous waste disposal, facilities are put in place for hazardous waste recovery in England, and the proximity principle is met.

3. Reduce our reliance on landfill

We must continue to reduce our reliance on landfill for hazardous waste, which should only be used where, overall, there is no better recovery or disposal option.

4. No mixing or dilution

Where hazardous waste cannot be prevented, waste producers and waste managers:

a. Shall not mix different categories of hazardous waste, or mix hazardous waste with other waste, substances or materials, unless under the terms of an environmental permit, and the mixing operation conforms to Best Available Techniques, (as identified in Article 2 of the Integrated Pollution Prevention and Control Directive) b. Shall not treat hazardous waste by the dilution of hazardous substances c. Must keep organic hazardous waste fractions separate from other streams to assist with their subsequent management in line with the hierarchy 5. Treatment of hazardous organic wastes

Hazardous organic wastes that cannot be reused, recycled or recovered shall be subject to destruction using best available techniques, with energy recovery for all appropriate treatments. No hazardous organic waste shall be landfilled unless the requirements of the Landfill Directive are met.

6. End reliance on the use of Landfill Directive waste acceptance criteria derogations

The practice of relying on higher Landfill Directive waste acceptance criteria (derogation for 3x WAC) to enable hazardous waste to continue to be landfilled must end.

The legal bases, policy drivers and practical applications for all of these provisions are outlined in detail on Defra’s website.

Outline Decision Trees for the Treatment of Hazardous Waste

Decision trees have been developed to support the Strategy for Hazardous Waste Management in England. They support the strategy objective of raising the bar of hazardous waste management through using the waste hierarchy to encourage recycling and recovery, and reducing reliance on landfill. The Defra website carries a superb document where these are illustrated fully, and cover:

• All hazardous wastes • Hazardous articles • Organic waste streams • Inorganic waste stream

Implementation of the Strategy for Hazardous Waste

EU Member States are required to transpose the revised Waste Framework Directive (WFD) by December 12, 2010. Defra has conducted a separate first stage consultation on how that transposition should proceed in England for significant and key aspects of the revised Directive. This includes information on how the revised waste hierarchy should be applied to waste producers, to permit applications for the treatment of waste and also to existing waste permits and authorisations. Responses to that consultation will also inform how this proposed strategy is realised. There is no doubt, however, that the waste hierarchy is required to apply in those circumstances.

It is recognised that it will take time for this strategy to be fully realised. Planning, development and implementation of infrastructure takes time. Investment funding needs to be secured, sites, identified, plans drawn up and the necessary permissions – development consents and environment permits – obtained. The development of a National Policy Statement on hazardous waste will assist the provision of infrastructure.

It is proposed that the impact of this new strategic approach be assessed after five years, in 2015, to see if further action or refinements are needed to ensure the continued provision of infrastructure and the successful management of hazardous waste. This is not envisaged to be a fundamental review or lead to a reduction in the requirements, but a ‘temperature check’ to ensure that the strategy is working.

Annex One – Hazardous waste trends, England and Wales 2008 to 2010

Trends in the fate of hazardous waste from 2000-2008 are illustrated on Defra’s website, showing that 6.6 million tonnes of hazardous wastes were sent for disposal and recovery in England and Wales in 2008. This showed an increase in 3% compared to 2007. The amount of hazardous waste sent to landfill increased by 26% to over 1 million tonnes, with recycling and reuse showing a decrease of 6% in 2008.

Trends in hazardous waste management

• There are 24 hazardous waste only landfills in England and Wales; 17 merchant and 7 restricted user. However there are also around 50 non hazardous landfills that have a mono cell for the disposal of stable non-reactive hazardous wastes such as asbestos • The increase in hazardous waste to landfill in 2008 was mainly due to the disposal of waste from the Olympics site • Although recycling and reuse of hazardous waste appear to have decreased by 6% in 2008, the movement through transfer stations for recovery purposes increased by 40% • Waste from waste water treatment plants, construction waste with asbestos and oil/ oil and water m0ixtures were the three waste streams with the largest tonnage increases in 2008 (26%, 22% and 21% respectively) • London and the South East were the largest exporters of hazardous wastes in 2008 with the East Midlands and the North East importing the largest quantities

Annex Two – Updated Summary of Facility Needs for Hazardous Waste Management in England

The priority needs by waste stream are as follows:

Oily sludges

Some 60,000 tonnes of oily sludges and oily filter cakes arise each year. Over the past two years thermal desorption has emerged as the most sustainable treatment option and four plant have been constructed. Additional thermal desorption plant for the treatment of oily sludges and oily filter cakes may be needed. These plant enable the recovery of oils from the wastes and in some cases the solids, so are higher up the waste hierarchy than incineration or landfill, and reduce the need for such treatment.

Waste oils

There are some 350,000 tonnes of waste oils arising annually in the UK which require treatment. There is currently approximately 70,000 tonnes per annum capacity of waste oil regeneration/recycling/laundering. There is a demand for at least one further modern high quality oil regeneration plant (re-refinery) with a capacity of 80,000 tonnes per annum, which would enable the UK to broaden its management options for used oil and help the UK to meet the demand for base lubricating oil; waste oil regeneration is classed as recycling and is higher up the waste hierarchy than processing waste oil for energy recovery.

In time, once the first plant has a settled operation, the market would likely sustain the development of a further re-refinery plant of similar size. Such plant do require substantial capital investment.

Plant exist for the treatment of waste oils for use as fuel. An end of waste protocol is being developed for the production and use of processed fuel oil from waste lubricating oils. If this protocol is agreed and accepted then plant currently producing recovered fuel oil, which is classified as a waste, could upgrade their facilities to produce Processed Fuel Oil (PFO) in line with the agreed protocol.

Air Pollution Control Residues

APC residues arise from the treatment of flue gases from municipal waste incinerators and energy from waste plant. Such residues are classified as hazardous waste due to their elevated alkalinity. They also contain dangerous substances from the pollution abatement process. Arisings of APC residues are predicted to rise as the number of EfW plant also rises. EAs hazardous waste data shows annual arisings of APC in the last three years were: 2006 – 111,000 tonnes; 2007- 118,000 tonnes; 2008 – 122,000 tonnes, so the trend is upwards.

Analysis of the EfW plant under construction show a further 77,000 tonnes per annum of APC residues are expected to arise in England, needing treatment. A further set of EfW plant have planning approval which indicates that arisings of APC residues would increase by at least a further 95,000 tonnes per annum (total further arisings 172,000 tonnes) if all the plant come on stream. There is the possibility for a significant number of additional EfW plant to be developed, which would lead to even greater demand for APC residue treatment.

A number of different treatment options exist for APC residues. Treatments that are able to make use of the resources in the waste through recycling and recovery are higher up the hierarchy than waste disposal operations. There is a need therefore for at least five facilities that can recycle APC residues to other materials that can be re-used, each with a capacity of 33,000 tonnes per annum, and a significant number of additional facilities may be needed if further EfW plant are developed. Other treatments for APC residues, which simply enable the waste stream to meet Landfill Directive requirements are lower down the hierarchy.

Contaminated soil

The market for the treatment of contaminated soil is relatively volatile, and is heavily influenced by the economic climate, which affects rates of development and the siting and introduction of major projects such as the Olympics.

Considerable capacity for the treatment of contaminated soils already exists or is planned, including facilities for bioremediation, soil washing and soil stabilisation. However, the latest hazardous waste data shows that a considerable proportion of hazardous waste from the construction and demolition sector, comprising a substantial proportion of contaminated soil, continues to be landfilled despite the application of the landfill tax.

A need is considered to exist for at least one further facility to treat contaminated soils using bioremediation or soil washing to further meet the treatment needs of contaminated soil diverted from landfill. Such a plant would be likely to have a capacity well in excess of 30,000 tonnes per annum.

Building insulation foams

The increased separation of building insulation foams containing ozone depleting substances (ODS) from construction and demolition wastes is likely to increase demand for plant that are able to remove and treat ODS, and enable more C&D waste to be prepared for re-use or be recycled. Research conducted for Defra and soon to be published indicates that the maximum annual tonnage of ODS-containing foam waste is predicted to peak in 2034, with annual arisings of almost 24,000 tonnes. On average the annual arisings will be in the region of 8,000 tonnes between 2010 and 2064.

Hazardous waste electrical and electronic equipment

The key waste streams here are discarded televisions and computer monitors, including both cathode ray tubes (CRTs), flat panel displays (FPDs) and refrigeration equipment.

An extensive network of plant for the treatment of discarded refrigeration equipment containing CFCs already exists. Facilities also exist for the treatment of CRTs, but no plant exists for FPDs.

It is estimated that some 89,000 tonnes of ‘display equipment’ arise in the UK per annum. While levels of FPDs in the waste stream are currently relatively low, the levels are expected to increase substantially, and a dedicated treatment plant to enable parts and materials to be recycled and recovered will be needed, and this is likely to have a capacity above 30,000 tonnes per annum. Sufficient plant already exist for the treatment of refrigeration equipment and fluorescent tubes.


Implementation of the Batteries Directive will increase the collection and recycling of end of life batteries. Disposal of waste industrial or automotive batteries by landfilling or incineration is now prohibited, and challenging targets for the recycling of portable batteries have been set.

A priority need exists for further treatment capacity in existing or new battery recycling plant. Development of a specialist facility for processing portable batteries including NiCds, lithium ion and NiMH batteries would obviate the need for export, and at least one plant is likely to be needed, with a capacity up to 30,000 tonnes per annum. Sufficient plant already exist for the recycling of lead acid car batteries in the UK.


Metallic mercury is now controlled under a new European Regulation (EC 1102/2008). This Regulation requires all metallic mercury specified in Article 2 to be considered a waste and its export from the EU is prohibited both from 15 March 2011. From this date, all arisings of metallic mercury will require treatment and disposal and re-use and recycling will be prohibited. Export of mercury within the EU will be possible, but the UK should also look to treat and dispose of its own arisings in the interests of national self sufficiency.

Options for treatment of metallic mercury include deep underground storage. The EC Regulation provides for certain derogations from the requirements of the Landfill Directive for the storage of metallic mercury that is considered a waste. Annual arisings are not estimated to be excessive. It is estimated that the European chlor-alkali industry will require the disposal of 8,000 – 9,000 tonnes in total of elemental mercury between now and 2020. The quantities from other sources that will require disposal such as redundant electrical components, thermometers and the cleaning of natural gas are not well understood.

Household Hazardous Waste

Some household waste recycling centres (HWRCs) are permitted to receive household hazardous waste and as more hazardous waste is segregated from the municipal waste stream, then HWRCs will need to have sufficient capacity and be designed to handle it, in particular to keep such hazardous waste separate from the general municipal waste as is required by existing legislation. Types of household hazardous waste collected at such sites includes asbestos panels, hazardous WEEE, motoring products including waste oil and car batteries, some paints and related materials, and certain household and garden chemicals.

The additional need for the following types of facility are not clear cut:

• High temperature incineration (HTI) for waste diverted from landfill. Current capacity in the two existing dedicated commercial HTI plant in England appears to be sufficient for current need. It is recognised that if the market were to encourage the provision of an additional plant, it would require considerable investment and planning, and should be designed and fitted with energy recovery

• Some municipal waste incinerators are allowed by their Waste Incineration Directive (WID) permit to take specified hazardous wastes such as contaminated packaging, and further capacity could be needed for this waste stream and others such as treated wood waste. In many cases the planning permission and waste permit for the plant would require modification

• Plant for the treatment of hazardous healthcare waste are considered sufficient for current need. There is scope for further segregation of hazardous and non hazardous healthcare waste at source and a consequent reduction in arisings of the hazardous fraction

• The transposition of the Mining Waste Directive (2006/21/EC) may result in demand and need for facilities to recover and dispose of the hazardous waste streams from mines and quarries

• Stabilisation/Solidification plant or other acceptable treatment to enable certain hazardous waste to meet the requirements for deposit in hazardous waste landfill or in separate cells for stable non reactive hazardous waste at non-hazardous waste landfill sites; evidence indicates that the country has adequate capacity

• Hazardous waste landfill appears to be sufficient for current need with some seven dedicated hazardous waste landfills in England providing a disposal option for a wide range of hazardous wastes. There are also a number of separate cells in non hazardous landfill for stable non-reactive hazardous waste and for asbestos. Current void capacity in dedicated hazardous waste landfills is estimated to be 19million cubic metres.


It seems that at the very time AWE International goes to press, the time sensitivity of Defra’s Strategy for the management of Hazardous Waste is significant, since December 12, 2010 marks the day EU Member States are required to transpose the revised Waste Framework Directive (WFD). This is most certainly a development worth watching, and one which we hope to report back on in future editions of AWE.



Published: 10th Dec 2010 in AWE International