It’s been a long time in the making, but from October 2014 MRF operators processing more than 1,000 tonnes of dry mixed recyclables a year will have to comply with the MRF Code of Practice for England and Wales. The Code is being incorporated into newly amended Environmental Permitting (England and Wales) Regulations.
Today DEFRA has published its sampling guidelines, which can be found here.
The sampling guidelines are unlikely to result in any serious changes at Casepak. Our testing, analysis and reporting of both inputs and outputs has always been robust and transparent. Feedback from our partners regularly states that our reports are more comprehensive than any others they have received to date, enabling them to initiate improvements where needed.
As one of the UK’s newest and most advanced MRFs, Casepak has always sought to deliver the highest quality materials. Since starting operation in 2011 this has required us to work closely with our material suppliers, to iron out communication issues and instigate collection and storage improvements. It has also required a continuous and ongoing internal improvement programme.
This means that we are well positioned to meet the Code’s requirements. We will just need to amend them slightly. For us, the Code of Practice will simply add an EA stamp of authority to processes that have been long established.
The guidelines are more about setting an industry-wide benchmark from which to drive sectoral improvements. We welcome the twice yearly inspections and are please that one of these will be in the form of an unannounced spot check; if enforced these will ensure that responsible MRF operators adhere. However, it may not be sufficient to change the practices of all operators.
If the EA does not follow through with these external audits or surprise spot checks, the Code is likely to deliver little.
Because the MRF Code of Practice has fallen short of setting minimum material standards, it is unlikely that this alone will change the resource recovery landscape significantly. As a supplier or buyer, the power to really influence change remains with you. If you know that the dry mixed recyclables you supply to a MRF make the reprocessor grade, it is likely that your MRF is doing the right thing.