SEPA plans to make Scotland’s metal sector go circular

The Scottish Environment Protection Agency (SEPA) has devised a new sector plan to make Scotland’s metal sector part of the nation’s emerging circular economy and improve environmental compliance and prevent illegal activity within the industry.

SEPA launched The Metals Sector Plan on 10 November, and is one of SEPA’s 16 detailed plans for individual sectors, such as the landfill sector plan, produced in accordance with SEPA’s overarching strategy, One Planet Prosperity, which seeks to lay out a path for Scotland to achieve greater resource efficiency. This is in line with the Scottish government’s circular economy strategy, ‘Making Things Last’.SEPA plans to make Scotland’s metal sector go circular

The Metals Sector Plan covers all regulated activities that involve the production of metal from raw materials, the manufacture of metal products and the reprocessing, recycling and recovery of metallic wastes. It aims to reduce the amount of materials, energy and water used across the metals sector through a range of ambitious goals. These include:

  • Displacing virgin raw materials with recycled or recovered metals within the industry;
  • Ensuring operators can better collect individual metal types and alloys;
  • Changing vehicle technology on end-of-life vehicle depollution and dismantling operators;
  • Saving energy by promoting industry best practice in energy efficiency and low carbon energy projects for the Scottish metal manufacturing processes; and
  • Regulating baseline water use at metals production sites and improving water efficiency.

“Full compliance with environmental regulations will not, by itself, deliver the transformational change required to secure our One Planet Prosperity objectives,” said Terry A’Hearn, Chief Executive of SEPA. “The Metals Sector Plan needs to unlock the potential for businesses to gain strength in resource efficiency and environmental innovation that will help them to succeed in their markets.”

The sector plan also identifies particular areas of inefficiency. For example, it cites a University of Cambridge report which states that the current quality of recycled steel within the UK is low due to poor control of its composition. It also points out that materials separated from metals at reprocessing facilities, such as plastic, are often unnecessarily disposed of as waste.

The need to increase resource efficiency in the metals sector is clear as key materials, such as copper, lead, tin and lithium, which is fundamental to electric vehicle and renewable energy manufacturing, are all in short supply.

A’Hearn added: “As the world faces shortages in metals and environmental constraints on their use, we will encourage the development of new technologies and business models that reduce resource use and environmental impact in ways that meet market needs.”

A ‘highly varied environmental performance’

Within its plan, SEPA states that metal recycling and reprocessing sites had an environmental compliance rate of 88 per cent in 2017, compared to the national average of 90.9 per cent. As SEPA states: ‘This means that the sector is currently underperforming and that there are a number of operators that consistently perform poorly.’

A range of issues can contribute to non-compliance, such as storage of polluted waste on permeable ground, the non-provision of an impermeable surface, waste duty of care failing, issues with waste data reporting and administration, and the failure to depollute end-of-life vehicles.

Illegal activity can range from the small-scale breaking of vehicles to resell their separate parts, to industrial estates where unlicensed end-of-life vehicle (ELVs) operations take place. Initial assessment suggests that some are involved in wider criminality and a few have links to serious and organised crime groups and are a known violence and aggression risk.

The export of waste electrical and electronic equipment (WEEE), ELVs and vehicle parts are also susceptible to illegal activity and there is concern that some operators are still paying cash for metal, which has been banned since 2016, or do not have a Scrap Metal Dealers licence from their local authority.

A’Hearn adds: “Metals is a sector with a highly varied environmental performance. At one end, there are responsible operators who have a good track record of compliance and are seeking new business opportunities based on solving environmental challenges. At the other end, there are those who undertake activities illegally, ‘outside the system’, creating environmental risks and undermining legitimate operators.

“In the plan, we set out the ways we will try to get these illegal operators into the system or out of the market. This is tough work. We will use a combination of approaches and work with other organisations to try to achieve this aim. We will also drive those legitimate operators with outstanding compliance issues to solve them.”

SEPA’s plan to improve compliance and tackle illegal activity includes proposals to develop effective intervention strategies to tackle and deter illegal practices with Police Scotland, local authorities, the DVLA, industry trade bodies and other UK environment agencies, as well as making it easier for operators to understand their obligations through permit simplification and improved guidance on environmental compliance, and increasing scrutiny of duty of care compliance.

To read the Metals Sector Plan in full, take a look at SEPA’s website.

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