A farewell to arms and THAT document

Written by: RWW | Published:

In his final article for Recycling & Waste World on behalf of the Wood Recycling Association, Peter Butt, outgoing executive director of the Wood Recycling Association, explains the association's concerns over the lack of industry involvement in the generic guidance document published by the Environment Services Association regarding proposed stockpile limits for material reprocessors.

This will be the last article that I write for RWW. I have decided that, at 67 years of age, it is high time that I got in with the serious matter of “ski holidays”; yes, you’ve got it, spending the kids’ inheritance. So, soon after this article is published, I shall be handing over the chain of office to Simon Dowson, and it is from him that you will be hearing in the future.

Simon comes with an outstanding pedigree earned, first, in the Army, and then in the commercial world. He has run his own companies and also been the bursar at four different independent schools. So he knows his way around business, and is now soaking up the intricacies of wood recycling like the proverbial sponge. He will take the WRA on to bigger and better things.

My only wish is that I could hand him a blank sheet of paper showing that the serious issues facing our industry amount to zero. But I can’t. There is much on the go at present, relating (among other things) to export operations, EU policy in the form of the Industrial Emissions Directive, fines disposal and waste fires. In these and other areas, the WRA will continue its work to ensure that its members can conduct their businesses in a sensible and operationally achievable regulatory climate. As an essential ingredient of this process, we shall continue to drive standards within our young and growing industry. Ultimately, the best way to relax the regulator is by showing him consistently high standards in all fields of activity. There have been remarkable improvements in recent years, but there is always scope to do better.

An on-rushing train

Of all the issues on the table, none affects our industry as much as that of fire storage. I wrote about this in RWW last year, and there has been a great deal of activity since then. 

At the time of writing, I see a glint of light at the end of the tunnel, but I wouldn’t bet against it being an on-rushing train. 

Here is where we are with it.

The draft WRA guidance on fire storage was almost complete and close to endorsement by the EA and fire service when, as readers may recall, an outbreak of waste fires caused it to be “parked” last summer. And parked it remained until very recently.

In June, the WRA held useful discussions at senior level with the EA and Chief Fire Officers’ Association (CFOA). We are agreed that, in principle, industry-specific guidance is more pertinent than a generic document that covers all material streams. To this end, we have also agreed that the WRA document will be reviewed in the light of developments since last year, and changes made where necessary, with the aim to publishing it with full regulatory endorsement as soon as possible.

The main point at issue is the size of stockpiles and the distance between them. 

We are looking for a sensible compromise that satisfies the regulators and allows re-processors to operate their sites profitably. 

It also needs to satisfy the insurance industry who holds the power of veto in areas such as this.  

Wood, we should remember, is a low-value, high volume material. So it takes up a lot of space, and only through processing a great deal of it will the recycler make a decent living. It is, at the risk of stating the blindingly obvious, inflammable. 

But it is also considered a low-risk material and one which offers much better value chipped up for productive use than it ever can stuffed into landfill.

An unwelcome complication appeared late last month when a generic guidance document, published by the Environmental Services Association (ESA) with the backing of the regulators and the waste safety forum WISH, was circulated for consultation. I have just responded to ESA on the WRA’s behalf, and my comments are not positive. 

Furthermore, a very large proportion of WRA members have added their own independent reactions to the ESA/WISH document. This is unusual as normally members are happy to leave the writing to me, and the fact that so many have chosen to respond is testament to the strength of their opposition to this guidance.  

A backward step?

What we so dislike about the ESA/WISH document is firstly the lack of industry involvement in it. In my five years in this job, I think we have made good progress in terms of working together with the regulators, but this ESA/WISH document represents a backward step.  

Frankly, I find it astonishing that a document of this importance, which affects a number of sectors so critically, can see the light of day without industry being allowed to contribute to it in any way.

It is perhaps not surprising, therefore, that the stockpile limits in the document are not to our liking. Indeed, they would seriously impede the operations of the majority of wood recyclers. Nor do we agree with the thinking that underpins the figures. 

And at the risk of repeating myself, a great deal of nugatory work would have been avoided if we had been asked to contribute to the work in the first place.

The wood recycling industry is not alone in its opposition to the ESA/WISH work. 

We have held discussions with a number of other sectors that feel as strongly as we do about it. Our hope and expectation, therefore, is that the combined force of our comments will send it back to the drawing board, and that we can then continue to work with the regulators in completing and publishing our own sector-specific guidance at an early stage.

Make no mistake

This issue is probably the most important one that the wood recycling industry has faced in the past 20 years. Unless we can find a mutually acceptable outcome, the consequences will be dire for my sector and probably for others, too. And there will be serious unintended consequences for the environment. So there is much to play for, and if ever there was a good time for open minds and listening skills, this is it. 

Perhaps I can close with a few words of thanks to those who own and work in the 90-odd WRA member companies, for their patience, forbearance and support to me over the past five years or so. It is not easy to make progress in their industry but I have been so impressed by their spirit of cheerful optimism, their indomitable good humour and their good companionship. Together they make a very considerable contribution to the economy and the environment. 

I wish them every good fortune in the years and the challenges ahead. 

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