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Scottish MRF sampling to start on 1 October

Operators of materials recovery facilities (MRFs) in Scotland will need to begin sampling incoming and outgoing material from 1 October 2015, the new ‘Code of Practice on Sampling and Reporting at Materials Recovery Facilities’ has revealed.

Launched last week (2 March), the code of practice (CoP) applies to anyone holding a waste management licence or pollution prevention control (PPC) permit for the operation of a MRF receiving (or likely to receive) more than 1,000 tonnes of mixed dry recyclable waste (or separately collected dry recyclable waste) in any reporting year (running 1 April to 31 March the following year).

It will also apply to anyone being issued a waste management licence (or varying an existing licence) on or after 1 April 2015, as required by the new Waste (Recyclate Quality) (Scotland) Regulations 2015. Any MRF licence or permit holders that do not comply with the CoP will be deemed to be non-compliant with their licence or permit conditions.

The CoP, which is very similar to one already in place in England and Wales, has been brought in by the Scottish Government to ‘promote and deliver high quality recycling’, as required by the European Commission’s Waste Framework Directive, and the Waste (Scotland) Regulations 2012, the former of which, according to the CoP, requires all waste holders to take ‘reasonable steps to promote high quality recycling’.

It compels operators of qualifying MRFs to weigh and sample materials received at the facility and leaving the facility, and identify the composition of the samples with regard to the type of material contained within.

It is hoped that by requiring MRF operators to do this, there will be:

  • improved transparency on material quality in the supply chain, through the provision of accurate information on contamination levels, and variances in these levels;
  • demonstrable compliance with the requirements of the Waste Framework Directive to deliver high-quality recycling;
  • an improved contracting environment for MRF licence or permit holders and for all businesses involved in the material supply chain;
  • a boost of innovation in the operation of MRFs and supply chain dynamics; and
  • certainty in the consistency of approach and practice in MRF material sampling and quality control, irrespective of the technology available to the MRF licence or permit holder.

The Scottish Government has stated that, as sampling data will be reported quarterly, it will help assess whether material arising from co-mingled collections and sorted at MRFs is compliant with the provisions of the Waste (Scotland) Regulations 2012. This law states that where recycling is not collected separately, it should be ‘managed in such a manner as will ensure that the amount of material recycled from the waste is not significantly less, and the quality of the material recycled is not significantly lower’ than would be the case in separate collections.

Sampling requirements

Scottish MRF sampling to start on 1 October

Input material sampling

According to the CoP, between 1 October 2015 and 1 October 2016, one sample must be taken for every 160 tonnes of mixed dry recyclable waste or separately collected dry recyclable waste received at a MRF from each of its suppliers. This will change to every 125 tonnes from 1st October 2016.

The average weight per sample must be 60 kilogrammes (kg) or more. However, a sample may be collected in several parts, contemporaneously, none of which may weigh less than 20 kg.

Operators must then identify the types of target material (glass; paper; cardboard; metal; and plastic), non-target material and non-recyclable material (including material fragments) that are contained in the sample, and specify the weight of each material identified.

MRF licence or permit holders must also record and inputt:

  • the total weight in tonnes of input material received at the facility, from each named supplier, during each reporting period;
  • for rejected loads and materials transferred onwards for sorting at another facility, the total weight in tonnes, the identity of the supplier and, where appropriate, the buyer, date material is rejected/transferred, reason for rejection/transfer and where the rejected/transferred material is sent;
  • the weight and composition of each input material sample taken at the MRF from each named supplier during a reporting period, and the total number of samples taken and the total weight in kilogrammes of all samples taken;
  • the mean percentage composition levels of target glass, metal, paper, cardboard and plastic in input material received, based on all applicable sample results;
  • the mean percentage composition levels of target material, non-target material and non-recyclable material received, based on all applicable sample results; and
  • the standard deviation of the mean percentage composition level of target material, based on all applicable sample results.

Output material sampling

MRF operators must also take samples of the output material separated at that facility in a reporting period, and measure the composition of those samples, by identifying the materials comprising that sample (as above) and measuring their weight.

The total weight in tonnes of target, non-target and non-recyclable that leaves the facility in each reporting period must also be recorded.

The samples must be taken at a minimum frequency of once per the amount in tonnes of target material, as shown below: 

  • a minimum sample of 10 kg of glass per every 50 tonnes;
  • a minimum sample of 50 kg of paper for every 80 tonnes prior to 1 October 2016 (falling to 60 tonnes on or after 1 October 2016);
  • a minimum sample of 50 kg of cardboard for every 80 tonnes prior to 1 October 2016 (falling to 60 tonnes on or after 1 October 2016);
  • a minimum sample of 10 kg of metal for every 20 tonnes; and
  • a minimum sample of 20 kg of plastic for every 20 tonnes prior to 1 October 2016 (falling to 15 tonnes on or after 1 October 2016).

For paper and cardboard, the total sample can be obtained in smaller parts of not less than 20 kg, collected contemporaneously.

If the sample taken through these processes contains material fragments, they are deemed to comprise the proportions of target materials, non-target materials and non-recyclable materials already identified as making up the other contents of that sample.

MRF licence or permit holders must also record and input:

  • the weight and composition of each output material sample taken at the MRF, by reference to the type of target, non-target and non-recyclable material that is contained in the sample, and the total number of samples taken for each output material, and the total weight in kilogrammes of all samples taken for each output material;
  • the mean percentage composition levels of all of the samples taken for output material by reference to the grades of glass, metal, paper, cardboard and plastic identified within those samples;
  • the mean percentage composition levels of target materials, non-target materials and non-recyclable materials in the output materials, based on all of the applicable sample results;
  • the standard deviation of the target materials for each output material sample tested;
  • the total weight in tonnes of output material by reference to the type of target, non-target and non-recyclable material that leaves the MRF in each reporting period;
  • the total weight in tonnes of mixed dry recyclable waste that leaves the MRF for sorting at another MRF during a reporting period and where it is sent;
  • the end destination or, where this is not available, the next destination for the materials leaving the facility;
  • the use to which the material will be put and/or the treatment to which the material will be subjected at the end destination or, where this is not available, the next destination; and
  • the location (country, region, city) to which the materials are to be sent.

Reporting periods

MRF operators must then report the results of material sampling to SEPA every three months, within one month of the end of the reporting period.

The reporting periods are:

  • 1 October (testing should commence on 1 October 2015) to 31 December (with reports to SEPA due by 31 January);
  • 1 January to 31 March (with reports to SEPA due by 30 April);
  • 1 April to 30 June (with reports to SEPA due by 31 July); and
  • 1 July to 30 September (with reports to SEPA due by 31 October.

All information obtained and recorded must be kept for a minimum of four years from the date it was recorded and made available to SEPA upon request.

Unannounced inspections

Like in England and Wales, the regulatory body (in this case, SEPA) will undertake unannounced inspections of MRFs in order to assess the quality and accuracy of testing and reporting procedures. These may include mapping and understanding MRF processing capabilities relative to inputs and outputs from the MRF, sampling of baled outputs to independently assess bale quality against MRF licence or permit holder reports, and assessment of whether staff are adequately trained and whether appropriate equipment and facilities are available on site to enable testing to be undertaken in line with the CoP.

It is not yet known whether operators will have to pay for these inspections, though operators in England and Wales may have to pay more than £2,000 for similar visitations from the Environment Agency/Natural Resources Wales.

SEPA has said it may also undertake additional inspections of MRFs based upon intelligence, outcomes of previous inspections or quarterly data returns. The targeting of site inspections will change once the sampling and reporting regime has become established to focus more on ‘poor performing’ sites.

The information collected by SEPA will reportedly help support future policy consideration of measures to further improve recyclate quality. It is hoped that clarity and certainty around the quality of recycled materials placed on the market will help create the confidence needed to invest in the expansion of Scotland's reprocessing sector, which is expected to become increasingly important as the drive toward a more efficient use of resources and more sustainable product use and design continues.

Detailed advice on designing and carrying out material testing and reporting procedures will be made available in ‘Materials Recovery Facilities – Testing and Reporting Guidance’, which will be available from Zero Waste Scotland (ZWS) shortly. In addition, ZWS will offer training and advice, as well as support via the MRF Quality Testing Infrastructure Capital Fund to help MRF operators to understand their obligations under the CoP.

Read the full ‘Code of Practice on Sampling and Reporting at Materials Recovery Facilities’.

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