Following extensive discussions with the Environment Agency, the Wood Recyclers’ Association (WRA) has welcomed the launch of a new regulatory position statement for waste wood which it says will make it more practical to meet regulatory requirements while still ensuring compliance.
RPS 291 allows, in the short term, for potentially hazardous ‘amber’ waste wood items* removed from domestic premises, demolition sites or other buildings to be stored and processed as non-hazardous provided the material is tested at least quarterly and the results are shared with the WRA.
This means that producers still need to test amber material, but will no longer have to test every item or consign them as hazardous in order to achieve compliance.
Importantly, those who do not share their test results with the WRA and receive a submission report will NOT be compliant under the RPS. Furthermore, the RPS is short term and if testing does not happen, it could be removed at any time.
Other conditions of the RPS include that material must be destined for Chapter IV biomass plants or panel board manufacture and must be moved under a waste transfer note.
The RPS will expire on 1st October 2024 and could be withdrawn before then if sampling and testing is not forthcoming.
Whilst the other UK environmental regulators have not published new positions, they support all of the WRA guidance, so the same principles will apply in Scotland, Wales and Northern Ireland.
The development of the RPS, driven by the WRA, follows concerns raised over the last few weeks by the WRA of ongoing confusion over the removal of RPS 250 and what it means for those handling waste wood from household refurbishments.
In particular, some housing associations, roofers and window installers have not been able to access wood skips due to the requirement to test or consign as hazardous every amber item.
“We welcome the launch of RPS 291 which is the result of us raising concerns about those collecting waste wood from households and some very long discussions with the Environment Agency on behalf of industry”, comments Vicki Hughes, Technical Lead on the WRA Board.
“Testing still needs to happen but this short-term RPS will mean it is less onerous and ensure that waste wood can continue to be processed with minimal disruption and cost.”
“We would like to thank the Environment Agency for listening to us and for building the requirement for testing into the regulatory framework. However, we need to stress that this has only been agreed for a short period on the basis that testing continues and that the results are shared with us.”
“We also need the other trade bodies impacted to engage with their members and encourage testing to ensure that everyone is ready for when the RPS is withdrawn next year.”
To help industry understand the new RPS, the WRA has produced a new video and updated its Frequently Asked Questions document to explain the changes.
These will be available on the WRA website as part of its updated Toolkit on the withdrawal of RPS 250, which contains a number of resources to help operators ensure they are compliant. This includes detailed guidance on how to take samples of amber wood items and send them for testing.
