Metal Shredders – appropriate measures for permitted facilities

Results updated 14 Feb 2022

Introduction

We wanted to hear your views on our draft technical guidance for facilities mechanically treating metal wastes in shredders.

We drafted the guidance to help deliver improvements in the design and operation of permitted facilities mechanically treating metal wastes in shredders. Our aim is to ensure appropriate measures are applied consistently at permitted facilities. The guidance also incorporates the relevant requirements of the waste treatment Best Available Techniques (BAT) conclusions document, made under the European Industrial Emission Directive (2010/75/EU).

How we ran the consultation

We shared an early pre-consultation draft version of the guidance with key stakeholders during August 2020. We reviewed the initial comments raised and used them to produce the draft guidance.

We formally consulted you from Monday 30 November 2020 until Monday 8 February 2021, using our online consultation tool, Citizen Space.

In total we asked 26 questions. Questions relating to specific aspects of the draft guidance were set out in questions 5 to 25 of the consultation and we also asked for any additional comments on the guidance.

We received 2 responses to the consultation from the following organisations:

• East Sussex Fire and Rescue Service (ESFRS)
• Chartered Institute of Waste Management (CIWM)

Both respondents were supportive of the guidance and the need for sector specific guidance for mechanically treating metal wastes in shredders. One respondent stated that metal shredding is by its nature a higher risk process and therefore the process precautions are key to reducing risk. Detailed sector specific guidance would assist operators in demonstrating compliance.

The respondents both agreed that the guidance should be applied to both installations and waste operations that are carrying out this activity. They also agreed that the measures set out in the management system section were appropriate to all facilities that are mechanically treating metal wastes in shredders.

Accident management plan

The requirement for an accident management plan and the measures that we have prescribed were supported. The responses suggested this requirement could potentially reduce insurance premiums, make obtaining insurance easier and reduce interruption to the businesses.  

Following the consultation we have altered the wording in Section 2.3 - Accident Management Plan to emphasise pre-acceptance and acceptance checks and cross referenced to section 3.

We cannot include health and safety requirements in this section of the guidance as was suggested by one respondent. This is because health and safety requirements are regulated by the Health and Safety Executive. We may however, review Health and Safety procedures and records if a worker safety incident has resulted in an environmental impact which we are investigating.

Deflagration management plan

There was support for the approach in Section 2.1 for not requiring deflagration management plans at all sites. We will however, require them at sites with a history or ongoing issues with deflagrations.

One comment suggested that there should be a reference to fire precautions in this section. We have required the risks of fire to be identified and assessed as part of the accident management plan required under section 2.3. In addition, in section 2.4 we require each site to have a fire prevention plan which meets our fire prevention plan guidance and its 3 objectives. We will review section 2.1 with respect to these comments and consider if fire prevention and risks should also be referenced this section as well.

Fire prevention plans

We require fire prevention plans (FPP) to be developed and implemented at all sites shredding metal wastes. Both respondents agreed with this requirement. We asked whether further sector specific guidance relating to metal recycling and metal shredding sites is required. Both respondents supported this. We will work with the sector and other interested parties in developing metal sector specific FPP guidance.

Waste pre-acceptance and characterisation

We asked about the requirement for waste pre-acceptance procedures to ensure the waste is technically and legally suitable for the facility, and also to reduce the deflagration risks. Both respondents agreed with this requirement and the measures that we have prescribed in this section.

Quarantined wastes

We have required that operators establish quarantine areas and set out time limits on quarantine storage. Both respondents agreed with this requirement and the measures that we have prescribed.

Waste treatment - appropriate measures

In the guidance, we require that operators must implement appropriate measures as set out for the waste treatment activity. We asked if there were any measures that should be included but have not been. One respondent suggested that measures such as the design and operation of process precautions and emergency procedures should be included. We consider that this has been covered on page 27 under the subheading “Metal shredding plant and downstream processes”.

Both respondents suggested meeting the waste treatment appropriate measures will lead to enhanced business continuity and protection and although there would likely be additional costs there are associated benefits relating to the protection of the environment and potential business opportunities.

Next steps

The responses we received were supportive of the guidance and the proposed measures set out within the draft guidance. We will now review the draft and the comments and produce a final version for publication on GOV.UK. Our aim is to publish this guidance late summer 2021.

Should you wish to follow up on your responses, or have questions relating to this consultation response then please contact us at wastetreatment@environment-agency.gov.uk including “Metal shredders appropriate measures guidance” in the subject of your email.

Please see our consultation response document for a full summary of your responses on GOV.UK.

Thank you for participating in our consultation.