Treatment of non – hazardous wastes prior to landfill

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Under Landfill Regulations implemented across the United Kingdom (details and timings of Regulations differ in England & Wales, Scotland and Northern Ireland), landfill sites will no longer be able to accept waste unless it has been pre-treated. This took effect in England, Wales and Northern Ireland from 30 October 2007 and in Scotland from 31 March 2007.

The Environment Agency have issued Guidance, which can be accessed on their website at:

The Environment Agency

To date Scottish Environment Agency (SEPA) and the Northern Ireland Environment Agency (NIEA) have not issued any guidance.

The objective of pre – treatment is to reduce the amount of waste going to landfill and/or reduce the impact of waste when it is landfilled. This can include sorting and segregation of waste, provided that some of the sorted or segregated is disposed of by methods other than landfill.

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From the point of view of waste collected by Citron, this affects offensive waste which we collect from your premises in ‘tiger bags’ and which is subsequently landfilled. Other similar wastes which are germicide treated (e.g. feminine hygiene units, offensive waste in Citron units) are currently viewed as treated for the purposes of The Regulations.

This requires that some portion of your other waste has to be disposed of other than by landfill. This could include:

    clinical wastes which are segregated and collected for treatment/incineration (either by
    ourselves or other Companies)
    wastes segregated for some form of recycling
    other wastes segregated for disposal by methods other than landfill

In order for Citron to continue collecting the offensive ‘tiger bag’ wastes for landfill, we have to determine if they have been treated, and therefore attach a Non Hazardous Waste Treatment Declaration Form for you to provide us with this information.

What this means is that we need information on wastes that we do not collect, but are segregated by you from the waste we do collect.

It may be that you have also been contacted by other Contractors taking away other waste for landfill, and having already addressed these issues in relation to your waste, so are easily able to provide similar information to ourselves.

If you already have a separate collection of other parts of your waste and some is already segregated for treatment or disposal by methods other than landfill then your waste satisfies the treatment requirements. This could include clinical waste for treatment/incineration, wastes for recycling, or other waste for some form of treatment. However, if you are not

currently segregating any part of your waste for disposal by methods other than landfill or do not return this Form to confirm that, we may be unable to continue to offer you a service in the same way, and will have to review the service provision.

If no waste is currently being segregated for recycling or disposal by methods other than landfill then the easiest way to ensure that the waste Citron collect (and other waste you may have collected for landfill, about which you may be or have been contacted in a similar way by other Waste Contractors) is treated by segregation of recyclables from your waste; this also has other environmental benefits. In that case you should strongly consider implementing recycling of some or all of your wastes with that potential (e.g. paper, card, plastic, metal etc). 

Signing the declaration form: Landfill Regulations – Pre-treatment Requirements Declaration Form.

Treatment under the Landfill Regulations is defined by using the ‘three point test’, with all three criteria having to be met for waste to have been pre-treated:

   1. It must be a physical, thermal, chemical, or biological process including sorting
   2. It must change the characteristics of the waste
   3. It must do so in order to
      (a) reduce its volume; (b) reduce its hazardous nature, (c) facilitate its handling or
      (d) enhance recovery.

In general you can comply by segregating one or more types of waste from your waste segregated from the ‘tiger bag waste’, for some form of recycling or treatment and hence diversion from landfill. This could include clinical waste segregated for treatment/incineration (e.g. yellow bag or sharps waste, very likely with the type of premises producing ‘tiger bag waste), waste which is segregated and recycled or some other waste which is segregated for some other form of treatment.

Please follow the procedure to sign electronically.

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